Starting a virtual clinic in Tennessee: 2026 telehealth requirements

Yes. Tennessee's rule is written three times over. Tenn. Code Ann. 63-6-209(b) requires a physician to hold a license under chapter 6 or 9 of title 63 to practice telemedicine. Tenn. Code Ann. 63-1-155 requires a telehealth provider to be licensed in Tennessee, with exceptions for supervised graduates and students and for out-of-state volunteers working through a free clinic under title 63, chapter 6, part 7. Board of Medical Examiners rule 0880-02-.16 prohibits the practice of medicine, in person or remotely, without a Tennessee license. CCHP's at-a-glance entry marks a telehealth license or registration process as available, but the detail shows what that means today.

The telemedicine license is closed. Rule 0880-02-.16, as summarized by CCHP, says the Board no longer issues telemedicine licenses. Former holders may convert to a full license, with no new application fee if they convert within two years of the rule's effective date. Any telemedicine license that is retained must be renewed every two years, requires current ABMS specialty certification, is limited to medical interpretation within that specialty and carries no prescriptive authority. The osteopathic board's rule 1050-02-.17(2) still describes a telemedicine license restricted to the applicant's certified specialty, but neither instrument supports a prescribing telehealth practice.

Tennessee is a member of the Interstate Medical Licensure Compact, along with the Nurse Licensure Compact, the Physician Assistant Compact and a long list of allied health compacts. For physicians whose principal license is in a compact state and who meet the IMLCC's eligibility standards, the compact is the fastest route to a full Tennessee license, and that full license is what a telehealth roster needs.

For a brand, every clinician who sees Tennessee patients must hold a full Tennessee license. The retained telemedicine licenses and the free-clinic volunteer exception are not pathways for a commercial program. MyOrbitHealth's 2,400+ provider network covers all 50 states, so Tennessee coverage typically comes from providers who already hold the license rather than from new applications.

Tennessee is classified as a moderate corporate practice of medicine state in our dataset. The core prohibition is statutory: Permit Health's guide cites Tenn. Code Ann. 63-6-204 and describes the ban as strong and unambiguous, grounded in the Tennessee Prohibition Against the Corporate Practice of Medicine Act and the Tennessee Practice of Medicine Act, supported by court decisions and Attorney General opinions. The moderate classification reflects how broad the statutory exceptions are. Permit Health lists employers covering their own staff and relatives, hospitals, physician groups, nursing homes, federally qualified health centers and community mental health centers; the MedPath guide likewise lists the professional corporation as the entity with nonprofit and hospital exceptions and non-physician ownership limited.

Two details matter for telehealth brands. First, Permit Health reports that fee-splitting among physicians is prohibited in Tennessee apart from patient referrals, and that violating the practice of medicine statute is a Class B misdemeanor. Second, a professional corporation may practice only one profession unless an exception applies, and professional LLCs are permitted. Permit Health also notes that supervising physicians must have regular in-person visits with the nurse practitioners they supervise, which ties the ownership question to staffing.

The workable structure is the standard one. The brand owns a management services organization that provides the platform, intake, marketing, billing and administrative staff under a management agreement. A professional corporation or professional LLC owned by a Tennessee-licensed physician employs or contracts the clinicians and makes every clinical decision. Set management fees at fair market value for the services delivered, avoid percentage-of-collections compensation that could be characterized as fee-splitting, and keep hiring, supervision and treatment decisions with the physician owner.

MyOrbitHealth operates under an MSO and friendly professional corporation model with a flat platform fee and no revenue share, which is the form Tennessee's doctrine expects. Have Tennessee counsel review the management agreement and the professional entity before launch.

AANP classifies Tennessee as a restricted practice state (map data dated May 2026). In AANP's definition, a restricted state requires career-long supervision, delegation or team management by another health provider for at least one element of NP practice. In Tennessee that takes the form of a supervising physician relationship that covers prescribing, and Permit Health's CPOM summary adds that supervising physicians must make regular in-person visits with the nurse practitioners they oversee.

For a telehealth program, each Tennessee NP on the roster needs a supervising Tennessee-licensed physician, documented protocols and a plan for the required in-person contact, so physician time is a real staffing cost rather than a formality. Asynchronous workflows remain possible because the physician does not join each encounter, but the Board's prescribing rule 0880-02-.14 requires a history and physical, a diagnosis, a documented plan and arranged follow-up before any drug is prescribed, and a facilitator for telemedicine encounters with patients under 18 unless otherwise authorized. Our sources do not state a transition-to-practice hour requirement, so confirm current supervision rules with the Tennessee Board of Nursing.