Provider resources

How to start a telehealth practice with no office

By Vye Health editorial team

Published . Updated .

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To start a telehealth practice, choose the patients and states you will serve, then confirm your authority to treat patients located in each state. Settle prescribing, payment, malpractice, privacy, and referral arrangements before opening appointments. A practice without a patient-facing office still needs a plan for in-person assessment, urgent concerns, and follow-up. Test that plan with a fictional patient before accepting the first real booking.

This guide covers practices that deliver their visits remotely. Federal and licensing sources were checked October 12, 2026. State rules and the service you provide determine the specific requirements; use the linked agencies and qualified advisers to review your plan.

How do you start a telehealth practice?

Start with the service and geography. Decide what can be handled remotely, what needs an in-person referral, and which states you can support. Then build the legal, financial, and clinical workflow around those decisions. A video platform is one part of the setup, alongside records, coverage, results, and payment.

  1. Review your employment agreement, outside-work rules, notice, and patient communications.
  2. Define the patient population, visit types, and limits of remote care.
  3. Confirm licensure or other lawful authority in each intended patient state and where you work.
  4. Resolve prescribing and registration requirements for the actual medications and states.
  5. Complete entity, identifiers, malpractice, and payment setup using the private-practice guide.
  6. Review vendors, privacy, consent, accessibility, and the connection-failure process.
  7. Rehearse booking through follow-up, including an in-person referral.

Do you need a license in every state where patients are?

You need legal authority to practice where the patient is physically located during the appointment. Depending on the state and profession, that may mean a full license, telehealth registration, or a specific exception. A patient's mailing address does not settle the question. Confirm their location before every visit and review the rules where you work, too.

HHS's cross-state licensing guide describes full licenses, temporary practice laws, reciprocity, compacts, and telehealth registration. Each route has conditions; do not treat an exception in one state as permission in another.

For example, a patient who lives in your licensed state may join from a vacation rental elsewhere. The booking and check-in process should catch that change before the visit begins.

Keep one readiness record for each state:

Item Evidence to keep before accepting visits
Practice authority License, registration, or confirmed exception, with renewal date
Professional scope Applicable scope, prescribing, and collaboration requirements
Prescribing State and federal registrations or applicable exceptions
Insurance Written confirmation of malpractice coverage for the services and locations
Payment Payer effective dates and telehealth billing rules, or reviewed direct-pay terms
Patient operations Consent, location check, local referral routes, and coverage during absences

How much does the Interstate Medical Licensure Compact cost?

As of October 12, 2026, the Interstate Medical Licensure Compact charges a $700 application fee plus each selected state's initial license fee. The fees are nonrefundable, and renewal fees are separate. The Compact helps eligible physicians obtain individual state licenses; it does not issue one national license or remove each state's practice rules.

Check eligibility before paying, then use the Commission's fee table for your actual state list. The physician pathway explains the qualifying license and application process. Track renewal dates as well as initial costs in the startup budget.

Can nurse practitioners practice telehealth across state lines?

Nurse practitioners need the applicable advanced-practice authority in each patient state. An RN multistate license does not itself grant NP practice authority. Review each state's scope, prescribing, and collaboration rules separately, even if you already hold licenses in several states. The agreement or supervision required in one state may differ from another.

The Nurse Licensure Compact FAQ, checked October 12, 2026, says the compact covers RN and LPN/VN licenses and that advanced practice registered nurses need an individual APRN license in each state of practice. Use the NP private-practice guide and each nursing board's rules to plan the next steps.

Can you prescribe controlled substances by telehealth in 2026?

Federal law permits qualifying telemedicine prescribing without a prior in-person evaluation through December 31, 2026, under the temporary rule. That permission has conditions and does not override state law. Confirm the medication, encounter format, registration, and patient location before using it. A clinic's plan for 2027 should include a review of the rules then in effect.

DEA's December 31, 2025 announcement describes Schedule II through V prescribing by audio-video visits, with specified audio-only prescribing for opioid use disorder treatment. It also identifies separate authorities for buprenorphine treatment and Veterans Affairs patients. Each has its own requirements; the general extension is 21 CFR 1307.41.

Licensure and DEA registration are separate questions. DEA's cross-state registration guidance describes a general state-by-state requirement and exceptions. Because that guidance dates to 2020, confirm which exception, if any, applies to your 2026 arrangement with DEA or counsel. Also review the physical-location requirements in 21 CFR 1301.12; a plan to register in a state is not proof that your address qualifies.

Set a review date before year-end and arrange a workable in-person route where required. Do not promise patients that the temporary rules will continue unchanged.

Does Medicare pay for telehealth from home after 2027?

Many Medicare home-telehealth flexibilities extend through December 31, 2027. Under the rules checked October 12, 2026, general rural-area and medical-facility restrictions return January 1, 2028 for most non-behavioral services. Behavioral health and other specific exceptions have separate rules. Build the payment plan around the services you offer and their applicable requirements.

HHS's policy update distinguishes temporary non-behavioral flexibilities from permanent home access for behavioral health. The mental-health in-person visit requirement is deferred through December 31, 2027; permanent home access does not mean every other condition disappears.

CMS's FAQ, updated October 8, 2026, adds these practical details:

Issue What to plan
Home-based clinician A virtual-only practitioner whose only practice location is home must enroll that address. Mark it “Home office for administrative/telehealth use only” to suppress the street address on Care Compare.
Claim location CMS uses POS 10 for telehealth in the patient's home and POS 02 for telehealth elsewhere.
January 1, 2027 modifiers BB applies to specified virtual-platform contracting or payment arrangements; BC applies to telehealth furnished incident to a professional service. CMS says these modifiers do not change payment.
January 1, 2028 Review the service-specific location and in-person requirements before scheduling care under the post-extension rules.

Ask your Medicare Administrative Contractor to confirm enrollment and claims setup. For commercial plans, obtain each payer's written telehealth policy and effective date. For direct payment, review the Medicare and estimate questions in the cash-pay guide.

What does a HIPAA-compliant telehealth setup need?

For a practice subject to HIPAA, review how each vendor handles protected health information, complete the required risk analysis, and put appropriate safeguards and business associate agreements in place. Also plan identity verification, private visits, consent, and access for patients who need assistance. A vendor's marketing label cannot replace the practice's own compliance work.

A business associate agreement (BAA) sets out the HIPAA duties of a vendor acting as a business associate. HHS's audio-only guidance explains that a telephone carrier acting only as a conduit may not need one, while an app storing recordings or transcripts on your behalf does. Review the actual service and data flow.

HHS confirms that the pandemic telehealth enforcement-discretion transition ended August 9, 2023. Use a setup that meets the applicable rules, with a documented process for consent and a failed connection. HHS's workflow guide is a useful starting point for the operational design.

What should you rehearse before your first visit?

Test a fictional patient's whole journey, including the work after the call. Confirm malpractice coverage for your services and patient locations in writing. Then check that staff can explain the next step when a patient travels, the connection fails, a result arrives during an absence, or the clinician needs an in-person assessment.

Rehearsal What the team should be able to explain
Patient joins from a different state How location is confirmed and authority checked before care
Video stops working How the patient reconnects and when to reschedule or use another permitted format
Concern needs in-person care Who arranges the next step and how local urgent or emergency help is reached
Result arrives after the visit Who reviews it, contacts the patient, and covers absences
Patient receives a bill What the fee includes and who answers a payment question

Resolve unclear ownership before opening more slots. For claims-made malpractice and departure coverage, read the tail coverage guide.

Where can Vye Health help?

Vye Health helps providers launch, run, and grow private practices. Vye manages licensing, credentialing, malpractice insurance, and your website, and payer contracts if you want them.

Bring your state list, prescribing plans, and proposed patient workflow. Apply to Vye Health.

Sources

  1. Licensing across state lines. Telehealth.HHS.gov.
  2. A faster pathway to physician licensure. Interstate Medical Licensure Compact Commission.
  3. What does it cost?. Interstate Medical Licensure Compact Commission.
  4. NLC FAQs. National Council of State Boards of Nursing.
  5. 21 CFR 1307.41, Temporary extension of certain COVID-19 telemedicine flexibilities for prescription of controlled medications. Electronic Code of Federal Regulations.
  6. DEA Extends Telemedicine Flexibilities to Ensure Continued Access to Care. Drug Enforcement Administration, December 31, 2025.
  7. Telemedicine: separate DEA registration in the state where patients are located. Drug Enforcement Administration, Diversion Control Division, July 28, 2020.
  8. 21 CFR 1301.12, Separate registrations for separate locations. Electronic Code of Federal Regulations.
  9. Telehealth policy updates. Telehealth.HHS.gov, February 5, 2026.
  10. Telehealth FAQ, updated October 8, 2026. Centers for Medicare and Medicaid Services, October 8, 2026.
  11. Guidance on How the HIPAA Rules Permit Covered Health Care Providers and Health Plans to Use Remote Communication Technologies for Audio-Only Telehealth. HHS Office for Civil Rights.
  12. HIPAA and Telehealth. HHS Office for Civil Rights.
  13. Planning your telehealth workflow. Telehealth.HHS.gov.

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