Tennessee Telehealth Compliance for Cash-Pay Clinics: Licensure, the Internet Prescribing Rule and Supervision
Tennessee requires a Tennessee license, no longer issues telemedicine licenses to physicians, and has a clear rule that a history and physical must come before prescribing over the internet and that prescribing based solely on answers to questions is a prima facie violation.
Key Highlights
- Practicing medicine on a patient in Tennessee requires a Tennessee license, and the Board no longer issues MD telemedicine licenses.
- A history and physical examination is required before prescribing over the internet, and prescribing based solely on answers to questions is a prima facie violation.
- Telemedicine rules require verifying patient identity and location, disclosing the provider's name, location and degree, and documenting the technology used.
- The Board applies its 30-day remote-site visit rule to telemedicine nurse practitioners, with up to ten visits a year allowed by electronic means since 2022.
Licensure
Tennessee's Board rule says practicing medicine on a patient in Tennessee requires a Tennessee license, and the Board no longer issues medical doctor telemedicine licenses. Legacy holders may only do medical interpretation and may not prescribe. The exemptions are narrow, such as consults requested by a Tennessee physician. The Board's FAQ says the practice of medicine occurs where the patient is. Osteopathic physicians have a separate telemedicine license route. Tennessee is a member of the Interstate Medical Licensure Compact.
Relationship and Evaluation
Under Tennessee's 2015 telemedicine statute, a relationship is formed by mutual consent, express or implied, and duties arise on an affirmative undertaking to diagnose or treat. The Board's rules allow video and store-and-forward and define telemedicine to exclude audio-only, email and fax. The Board's internet prescribing rule requires a history and physical examination before prescribing over the internet, and prescribing based solely on answers to questions is a prima facie violation. Patients under 18 need a facilitator, and the statute excludes pain management clinics and chronic non-malignant pain treatment.
Consent and Documentation
The telemedicine rule requires the provider to verify the patient's identity and location, to disclose the provider's name, location and degree, and to document the technology used. We did not find a separate written telehealth consent requirement.
Prescribing
We found no Tennessee bar on Schedule III prescribing by telehealth and no ketamine-specific rule. The internet prescribing rule governs, and the Board's July 2025 advisory restating it for telephone prescribing is non-precedential. The controlled substance monitoring database must be checked for opioids and benzodiazepines, and we did not find testosterone on that list, though the statute should be confirmed.
NPs and PAs
The Board states that its 30-day remote-site visit rule for supervising physicians applies even to telemedicine nurse practitioners. Since April 2022, up to ten of those visits a year may be done by HIPAA-compliant electronic means. The supervisor and the nurse practitioner or physician assistant must both be Tennessee-licensed.
Corporate Practice
A Board ruling cites corporate practice principles that bar physician employment absent legislation, with hospital-employment exceptions in the statutes. It involved an out-of-state hospital and not telehealth. We found no management-company or telehealth-specific authority.
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.