Ohio Telehealth Compliance for Cash-Pay Clinics: Licensure, the 2023 Rules, OARRS and Pharmacy Enforcement
Ohio's rules are fairly specific: an in-person standard of care for telehealth, documented consent, an in-person exam only for new-patient Schedule II prescribing, and OARRS review rules. The Board of Pharmacy has also been an active enforcer.
Key Highlights
- Ohio requires an Ohio license to treat patients located in Ohio, with no separate telemedicine license.
- An administrative rule effective February 28, 2023 sets an in-person standard of care for telehealth, allows asynchronous technology if that standard is met and requires consent to be documented.
- An in-person exam is required only for new-patient Schedule II prescribing, so Schedule III drugs such as testosterone and ketamine have no state in-person mandate under that rule.
- The Board of Pharmacy has summarily suspended dozens of clinics and med spas since early 2025.
Licensure
The State Medical Board's guidance says an Ohio license is required to treat patients located in Ohio, with no separate telemedicine license. The exceptions are limited to the physician-consult and one-year follow-up cases in the statute. An Ohio-licensed provider may treat Ohio patients from another state. Ohio enacted the Interstate Medical Licensure Compact in 2021, though we could not confirm its current operational details from a primary source.
The Standard of Care and Consent
Ohio's administrative rule 4731-37-01, effective February 28, 2023, sets the standard of care for telehealth at the in-person standard, requires patient interaction, allows asynchronous or store-and-forward technology only if that standard is met, and requires patient consent to telehealth to be documented. It does not specifically address questionnaires. A separate statute allows synchronous or asynchronous technology for an initial visit if the standard of care is met.
Prescribing and OARRS
- Schedule II: an in-person exam is required only for new-patient Schedule II prescribing, with exceptions for hospice and palliative care, medication-assisted treatment, mental-health conditions and emergencies. Schedule III drugs have no in-person mandate under that rule, though older Board FAQs used a broader approach, so check current text.
- OARRS review: review of Ohio's prescription monitoring system is required before prescribing any opioid or benzodiazepine, and for other reported drugs once treatment passes 90 days and at least annually after that.
- Weight-loss drugs: Ohio's controlled-anorexiant rules cover controlled drugs, not GLP-1s.
- Compounded GLP-1s: Board of Pharmacy FAQs from July 2025, as reported by a law firm, reach nonresident pharmacies shipping into Ohio.
NPs and PAs
Certified nurse practitioners need a standard care arrangement, and secondary sources report a physician may collaborate with at most five advanced practice nurses at a time on prescribing. The Medical Board's prescribing rules apply to physician assistants.
Corporate Practice
Ohio's position is unusually unclear. The State Medical Board stated in 2012, as reported by a law firm, that the corporate practice of medicine doctrine no longer exists in Ohio, citing a statute that requires physicians to exercise independent judgment, with exceptions such as physician-owned pain clinics. Other sources and our own state guide still treat Ohio as a corporate-practice state. We found no telehealth-specific authority. Because the position is unsettled, a physician-owned PC with a flat-fee management agreement is the conservative structure.
Enforcement to Know About
The Ohio Board of Pharmacy has summarily suspended more than 30 clinics and med spas since early 2025, according to secondary reporting, and our earlier post covers the May 2025 license revocations over compounded GLP-1s. Pharmacy sourcing and handling are as much a risk in Ohio as medical-board rules.
Disclaimer
This article is general educational information, not legal advice. Telehealth rules change often and differ by state, and parts of this summary rest on secondary sources, so confirm specifics with health care regulatory counsel in the state before you rely on them.
MedGrid MSO provides management services to independently owned practices; it does not practise medicine and does not direct clinical decisions. Requirements vary by state and by service, and change over time — nothing on this page is legal or medical advice. Talk to us or your own counsel before making a structural decision for your clinic.