Washington Telehealth Compliance for Cash-Pay Clinics: The Uniform Telehealth Act, Licensure and Corporate Practice
Washington regulates telehealth through a single statute, the Uniform Telehealth Act, which allows out-of-state practitioners to serve Washington patients only with Washington authorization or in narrow cases, and holds telehealth to the same standard as in-person care.
Key Highlights
- Under the Uniform Telehealth Act an out-of-state practitioner needs Washington authorization, including through a compact Washington belongs to, with only narrow exceptions and no registration route.
- A relationship can be formed by telehealth but not by email, instant message, text or fax alone, and telehealth includes asynchronous technology.
- Telehealth gets the same professional practice standard as in-person care, and boards may not set a different telehealth-only standard.
- Washington's corporate-practice doctrine is judge-made, and a 2026 bill to codify it did not advance.
Licensure
Washington's Uniform Telehealth Act allows an out-of-state practitioner to serve a patient located in Washington only with a Washington license or other Washington authorization, including a compact Washington belongs to, or with an out-of-state license in good standing for one of a few narrow forms of care. Those forms are a consultation with a Washington practitioner who remains responsible, a specialty assessment or recommendation without treatment, and continuity follow-up for an established patient who is temporarily in Washington. There is no registration route; the idea was dropped from the 2024 legislation. Washington is a member of the Interstate Medical Licensure Compact.
The Relationship and the Standard of Care
The act says a relationship can be formed by telehealth but not by email, instant message, text or fax alone. Telehealth is defined to include asynchronous technology. Telehealth gets the same professional practice standard as in-person care, and boards may not set a different standard for telehealth. The Medical Commission rescinded its separate telemedicine policy in December 2024 as superseded by the statute. We found no physician-specific questionnaire ban or drug-specific in-person rule, though the Nursing Commission's non-binding advisory for advanced practice nurses says history and evaluation must precede any prescription.
Consent
There is no telehealth-specific consent procedure, and ordinary informed-consent law applies. The Nursing Commission's advisory suggests documenting consent and credentials. The act also says not to bill a patient directly for non-insurance-defined telehealth without prior consent.
Prescribing and Monitoring
We found no Washington ban on prescribing Schedule III drugs by telehealth and nothing specific to ketamine or testosterone. Physicians prescribing Schedule II through V controlled substances must register with the prescription monitoring program, and the query duties attach to opioids and to the drugs listed in the state's administrative code, which do not include testosterone or ketamine. Out-of-state pharmacies serving Washington residents must be licensed by the Department of Health.
NPs and PAs
Advanced registered nurse practitioners may prescribe Schedule II through V and must hold a Washington license when treating Washington patients; the title becomes advanced practice registered nurse in mid-2027. Physician assistants practice under a collaboration agreement with a Washington physician or the PA's employer.
Corporate Practice
Washington's corporate practice doctrine comes from case law, with a leading case reported by a law firm. In 2026 a bill that would have codified the doctrine and restricted PC and management-company arrangements did not advance in the Senate. As reported, it would have exempted telemedicine-exclusive medical groups from the ownership rules while still covering them under licensing restrictions. A separate 2026 law on ownership reporting was reported as signed in March. We found no board or Attorney General statement on telehealth and management-company structures.
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.