Florida telehealth MSO-PC: registration, prescribing, and ownership

Direct answer

For the full Florida statute list, read Florida CPOM. For the multi-state picture, start at the telehealth MSO-PC hub and the CPOM 50-state guide. General information only, not legal advice. Foundry is not a law firm.

License or registration

Florida gives telehealth teams two lanes. A clinician with a Florida license practices under it. A clinician licensed elsewhere can register with the Florida board under § 456.47(4) if they meet every condition:

• An active, unencumbered license from another state, D.C., or a U.S. territory that is substantially similar to the Florida license.
• No disciplinary action on that license in the 5 years before applying, and no pending investigation.
• A registered agent for service of process in Florida.
• Liability coverage or financial responsibility that covers telehealth patients outside the home state, at Florida's required amounts.

Registrants may not open an office in Florida or treat Florida patients in person, so a hybrid model needs Florida-licensed clinicians for the in-person visits. Registrants must report any new restriction or discipline to the Florida board within 5 business days. The Florida Department of Health telehealth page has the forms, and Foundry's Florida out-of-state telehealth registration guide walks through the application.

What the statute says about each visit

Who owns the Florida practice

Florida has no single California-style ownership ban, and commentators still argue about whether Florida "has CPOM." The questions that matter are practical. A clinic that is not wholly owned by licensed practitioners generally needs a license under the Health Care Clinic Act. The Board of Medicine can discipline a physician for paying or receiving a kickback, rebate, or split fee for patient referrals under § 458.331(1)(i). A professional corporation owned by a Florida-licensed physician, paid nothing tied to referrals, answers both questions in one structure. The founder owns the MSO that runs the software, brand, and marketing under a fixed or cost-plus fee set at fair market value.

Florida APRNs work under a written protocol with a supervising physician under § 464.012, unless they register for autonomous practice in primary care under § 464.0123. The physician who supervises APRNs and the physician who owns the PC can be the same person, but they are separate jobs with separate paperwork.

Setup steps for a Florida telehealth company

1. List each clinician's license states and decide who needs a Florida license and who can register under § 456.47(4).
2. Mark any visit type that could involve a Schedule II drug and set prescribing rules to match § 456.47(2)(c).
3. Match a Florida-licensed physician to own the PC ($3,000/mo).
4. Form the professional corporation and the MSO, and sign an FMV management services agreement. See MSO-PC formation ($15,000).
5. Sign APRN protocols where needed, and add the Department of Health registrant link to the site if any clinician registers.
6. Enroll the PC with payers under its own tax ID and route all clinical payments to the PC's bank account.

Pricing

Florida telehealth MSO-PC FAQ

Can an out-of-state physician treat Florida patients by telehealth?

Yes, if the physician holds a Florida license or registers as an out-of-state telehealth provider under Florida Statutes § 456.47(4). Registration requires an active, unencumbered license in another state, no discipline in the prior 5 years, a Florida registered agent, and liability coverage that includes telehealth patients outside the home state. Registered providers may not open a Florida office or see Florida patients in person.

Can I prescribe controlled substances by telehealth in Florida?

Florida bars using telehealth to prescribe Schedule II controlled substances except for a psychiatric disorder, inpatient hospital treatment, hospice patients, and nursing home residents under § 456.47(2)(c). Schedule III to V prescribing follows the general standard of care plus federal DEA rules.

Does Florida have corporate practice of medicine rules?

Florida is Moderate. It has no single California-style ownership ban, but the Health Care Clinic Act, unlicensed-practice rules, and the fee-splitting rule in § 458.331(1)(i) still shape who owns the clinical entity and how the MSO is paid. Most telehealth companies use a physician-owned professional corporation plus an FMV management services agreement.

Does my telehealth website need anything for Florida registrants?

Yes. Under § 456.47(4)(c), the website of a registered out-of-state telehealth provider must prominently link to the Department of Health page that lists registrant information. Put that link where Florida patients will see it, such as the clinician profile or the footer of the booking flow.

How much does Foundry charge for a Florida telehealth MSO-PC?

MSO-PC formation is $15,000 one-time. A Florida-licensed friendly PC owner is $3,000/mo. Formation typically takes 1 to 3 days after the states, the clinical model, and the physician match are scoped.

Related reading

Written and last reviewed 2026-10-26 by Matthew Milford, Founder. Sources: Fla. Stat. § 456.47 (telehealth), ch. 621 (professional service corporations), § 400.990 (Health Care Clinic Act), § 458.331(1)(i), §§ 464.012 and 464.0123; Florida Department of Health telehealth page. Foundry PC is not a law firm. General information only, not legal advice.