Washington telehealth MSO-PC: licensing, parity, and who owns the practice
Washington requires a Washington or compact license for most telehealth, pays telemedicine at in-person rates with a carve-out for larger groups, and limits audio-only billing to established patients. See where the PC fits.
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A Washington telehealth company needs clinicians licensed in Washington, directly or through the Interstate Medical Licensure Compact, because RCW 18.134.050 limits out-of-state clinicians to consultations, specialty assessments, and short continuity follow-ups. Washington is a Moderate corporate practice of medicine state, so the clinical side usually sits in a professional service corporation owned by Washington-licensed physicians under chapter 18.100 RCW, and the founder owns an MSO paid a fixed fair-market-value fee. RCW 48.43.735 requires telemedicine to be paid at the in-person rate, but telemedicine companies and groups of 11 or more providers may negotiate a different rate. Foundry forms that MSO-PC for $15,000 one-time and matches a Washington-licensed friendly PC owner for $3,000/mo.
The statute list for the entity rules sits on Washington CPOM, and the CPOM 50-state guide compares Washington with other states. For the multi-state view, start at the telehealth MSO-PC hub. General information only, not legal advice. Foundry is not a law firm.
Licensing: who may treat Washington patients online
| Path | Who it fits | Limits |
|---|---|---|
| Washington license | Any clinician treating Washington patients | Physicians licensed by the Washington Medical Commission |
| Interstate Medical Licensure Compact | Physicians with a clean license in another compact state | Washington joined in 2017; still a full Washington license |
| Out-of-state license only | RCW 18.134.050 exceptions | Consultation with the treating Washington clinician, a specialty assessment with no treatment, or follow-up with an established patient temporarily in Washington |
The Medical Commission's telemedicine policy holds practitioners to the same standard of care as in person and allows the relationship to start by telemedicine when the standard of care does not call for an in-person visit. Under RCW 43.70.495, licensed clinicians other than MDs and DOs, such as NPs, PAs, and therapists, complete a telemedicine training and keep a signed attestation.
Payment parity and audio-only rules
| Rule | What it says | What it means for the PC |
|---|---|---|
| RCW 48.43.735 | Telemedicine paid at the same rate as the in-person service | Bill under the PC's contracts |
| RCW 48.43.735 | Hospitals, telemedicine companies, and provider groups of 11 or more may negotiate a different rate | A larger PC may see a lower telehealth rate in its contracts |
| RCW 48.43.735 | Audio-only requires an established relationship: an in-person or audio-video visit in the past three years, or a referral | Book the first visit by video |
| RCW 48.43.735 | Patient consent before billing an audio-only visit | Capture consent in intake |
The patient's home counts as an originating site, and carriers may apply the same utilization review and cost sharing as in person. Claims belong to the physician-owned PC under its own tax ID and group NPI.
Controlled substances and the PMP
Under WAC 246-919-985, physicians who prescribe Schedule II to V drugs in Washington register for access to the Prescription Monitoring Program, query it at set points in opioid prescribing, and query it for every opioid prescription when their EHR integrates the PMP. The DEA telemedicine flexibilities under 21 CFR 1307.41 run through December 31, 2026, and each prescriber needs a DEA registration for the state where the patient sits.
Who owns the Washington practice
| Role | Where it sits | Washington note |
|---|---|---|
| Physician owner | Owns the Washington professional service corporation or PLLC | Washington-licensed MD or DO |
| Treating clinicians | Employed or contracted by the PC | Washington or compact license |
| Founder and investors | Own the MSO | Brand, software, marketing, billing support |
| MSO fee | Written management services agreement | Fixed or cost-plus at fair market value; review against chapter 19.68 RCW on rebates |
Run the MSA red-flag audit on CPOM compliance before you sign. Opening a physical studio instead? Read the Washington med spa MSO-PC guide.
Setup steps for a Washington telehealth company
- List each visit type, the payers you plan to bill, and any controlled substances.
- License each clinician in Washington directly or through the compact, and collect telemedicine training attestations.
- Match a Washington-licensed physician to own the PC through friendly PC owner matching ($3,000/mo).
- Form the Washington PC and the MSO, and sign a fair-market-value MSA. See MSO-PC formation ($15,000).
- Set first visits to video so later audio-only visits can be billed, and record consent.
- Credential the PC with payers and route all clinical payments to the PC's bank account.
Pricing
MSO-PC formation
$15,000One-time. The MSO and the Washington physician-owned PC, scoped to your visit model.
Friendly PC owner
$3,000/moA Washington-licensed physician who owns your PC.
Washington telehealth MSO-PC FAQ
Do I need a Washington license to treat Washington patients by telehealth?
In most cases, yes. RCW 18.134.050 allows a Washington license or a compact license, with narrow exceptions for consultations, specialty assessments without treatment, and continuity follow-up for established patients temporarily in Washington.
Does Washington require telehealth payment parity?
Yes. RCW 48.43.735 requires carriers to pay telemedicine at the in-person rate, but hospitals, telemedicine companies, and provider groups of 11 or more may negotiate a different rate.
Can Washington telehealth visits be audio-only?
Yes, for established patients. Audio-only billing requires an in-person or audio-video visit within the past three years or a referral, plus patient consent before billing.
Can a lay founder own a Washington telehealth practice?
Not the clinical entity. Washington is a Moderate CPOM state, and the common structure is a Washington physician-owned professional service corporation or PLLC plus a founder-owned MSO under a fair-market-value MSA.
How much does Foundry charge for a Washington telehealth MSO-PC?
MSO-PC formation is $15,000 one-time. A Washington-licensed friendly PC owner is $3,000/mo.
Related reading
Ready to treat Washington patients online?
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