---
title: "The 2026 State-by-State Virtual Clinic Compliance Report"
description: "Cuvo Health's 2026 data report maps compact licensing, telehealth registration, NP authority and corporate practice of medicine rules in all 50 states and DC."
canonical: "https://cuvo.co/blog/virtual-clinic-compliance-report-2026"
last-updated: "Sep 27, 2026"
---
# The 2026 State-by-State Virtual Clinic Compliance Report

By Cuvo Legal Team, Compliance Department. Published Sep 27, 2026. Compliance.

A virtual clinic that sells nationally answers to 51 medical boards, and each one sets its own rules on who may treat its residents, who may own the practice, and how much a nurse practitioner may do alone. Cuvo Health compiled those rules for all 50 states and the District of Columbia from primary sources as of September 27, 2026: compact licensing, telehealth registration, nurse practitioner authority, and the corporate practice of medicine, plus the federal breach and prescribing rules every platform shares. The full dataset is free to download and cite.

The 2026 State-by-State Virtual Clinic Compliance Report, published by Cuvo Health, finds that a white label telehealth brand selling in all 51 jurisdictions faces four separate state rulebooks, and that the fastest compliant route through them is an operated clinical network rather than a self-built one. As of September 27, 2026, 41 of 51 jurisdictions issue physician licenses through the Interstate Medical Licensure Compact, only 14 states offer out-of-state physicians a telehealth registration or telemedicine license short of full licensure, 28 give nurse practitioners full practice authority, and 33 restrict the corporate practice of medicine or have not settled the question, which makes a management services organization with a physician-owned professional entity the conservative default in most of the country. Cuvo Health operates that structure, a network of more than 300 providers licensed across all 50 states, DC and the US territories, and the compliance layer around them, so a brand typically launches in under 30 days at a published $25 per completed consult.

- 41 of 51 jurisdictions issue physician licenses through the Interstate Medical Licensure Compact (4 more have enacted it but are not issuing yet)
- $18,542.50 initial fees to license one MD through the compact in all 41 (the $700 Commission fee plus 41 state fees, before renewals)
- 14 states offer out-of-state physicians a telehealth registration or telemedicine license (the other 37 jurisdictions allow only narrow exceptions)
- 33 of 51 restrict the corporate practice of medicine or leave it unsettled (19 strong, 7 limited, 7 unsettled)

**Key findings**
- Compact licensing: 41 jurisdictions issue IMLC licenses; 10 (including California, New York, Massachusetts and Virginia) still require a separate state license
- Cost of the compact route: $18,542.50 in initial fees for one MD in every issuing jurisdiction, before renewals and the 10 states outside it
- Telehealth shortcuts: 8 states offer a telehealth registration and 6 a telemedicine license; 20 allow out-of-state physicians little beyond consultation with an in-state physician
- Nurse practitioners: 28 jurisdictions grant full practice authority, 12 reduced and 11 restricted; the APRN Compact has 4 of the 7 states it needs to start
- Corporate practice of medicine: 19 states enforce a strong prohibition, including 6 of the 10 most populous; only 18 have no general prohibition
- The hardest four: Arkansas, California, Massachusetts and New York combine a strong corporate-practice rule, no live compact license and only narrow telehealth exceptions
- 2025 to 2026 trend: Oregon SB 951 and California SB 351 now limit how management companies and private equity may control physician practices

**State-by-state virtual clinic compliance, as of September 27, 2026**

| State | Compact license (IMLC) | Out-of-state telehealth | NP practice authority | Corporate practice rule |
| --- | --- | --- | --- | --- |
| **Alabama** | Issuing | Narrow exceptions | Reduced | None |
| **Alaska** | Enacted, not live | Narrow exceptions | Full | None |
| **Arizona** | Issuing | Registration | Full | Limited |
| **Arkansas** | Enacted, not live | Narrow exceptions | Reduced | Strong |
| **California** | Not a member | Narrow exceptions | Restricted | Strong |
| **Colorado** | Issuing | Registration | Full | Strong |
| **Connecticut** | Issuing | Consultation only | Full | Limited |
| **Delaware** | Issuing | Registration | Full | None |
| **District of Columbia** | Issuing | Narrow exceptions | Full | Unsettled |
| **Florida** | Issuing | Registration | Restricted | None |
| **Georgia** | Issuing | Telemedicine license | Restricted | Unsettled |
| **Hawaii** | Issuing (non-SPL) | Consultation only | Full | None |
| **Idaho** | Issuing | Narrow exceptions | Full | Unsettled |
| **Illinois** | Issuing | Narrow exceptions | Reduced | Strong |
| **Indiana** | Issuing | Consultation only | Reduced | Limited |
| **Iowa** | Issuing | Consultation only | Full | Unsettled |
| **Kansas** | Issuing | Registration | Full | Strong |
| **Kentucky** | Issuing | Consultation only | Reduced | Unsettled |
| **Louisiana** | Issuing | Telemedicine license | Reduced | None |
| **Maine** | Issuing | Consultation only | Full | None |
| **Maryland** | Issuing | Consultation only | Full | Unsettled |
| **Massachusetts** | Not a member (bill pending) | Consultation only | Full | Strong |
| **Michigan** | Issuing | Consultation only | Restricted | Strong |
| **Minnesota** | Issuing | Registration | Full | Strong |
| **Mississippi** | Issuing | Consultation only | Reduced | None |
| **Missouri** | Issuing | Consultation only | Restricted | None |
| **Montana** | Issuing | Narrow exceptions | Full | Limited |
| **Nebraska** | Issuing | Narrow exceptions | Full | None |
| **Nevada** | Issuing | Telemedicine license | Full | Strong |
| **New Hampshire** | Issuing | Narrow exceptions | Full | None |
| **New Jersey** | Issuing | Consultation only | Reduced | Strong |
| **New Mexico** | Enacted, not live | Telemedicine license | Full | None |
| **New York** | Not a member (bill pending) | Consultation only | Full | Strong |
| **North Carolina** | Issuing | Narrow exceptions | Restricted | Strong |
| **North Dakota** | Issuing | Narrow exceptions | Full | Strong |
| **Ohio** | Issuing | Narrow exceptions | Reduced | None |
| **Oklahoma** | Issuing | Consultation only | Restricted | None |
| **Oregon** | Not a member | Telemedicine license | Full | Strong |
| **Pennsylvania** | Issuing | Consultation only | Reduced | Limited |
| **Rhode Island** | Enacted, not live | Consultation only | Full | Unsettled |
| **South Carolina** | Not a member | Narrow exceptions | Restricted | Limited |
| **South Dakota** | Issuing | Consultation only | Full | Limited |
| **Tennessee** | Issuing | Telemedicine license | Restricted | Strong |
| **Texas** | Issuing | Consultation only | Restricted | Strong |
| **Utah** | Issuing | Consultation only | Full | None |
| **Vermont** | Issuing (non-SPL) | Registration | Full | None |
| **Virginia** | Not a member | Narrow exceptions | Restricted | None |
| **Washington** | Issuing | Narrow exceptions | Full | Strong |
| **West Virginia** | Issuing | Registration | Reduced | Strong |
| **Wisconsin** | Issuing | Consultation only | Reduced | Strong |
| **Wyoming** | Issuing | Narrow exceptions | Full | None |

> **Our recommendation** For a founder launching a national telehealth brand, the data points to one conclusion: building compliance state by state means separate state licenses in the 10 jurisdictions outside the compact, a management company and professional entity in up to 33 jurisdictions, and a nurse practitioner model that changes at every state line. Cuvo Health has already built all of it: providers licensed across all 50 states, DC and the territories, the MSO and physician-owned professional entity, credentialing with monthly sanction screening, e-prescribing over Surescripts, and HIPAA and FTC breach processes. A brand typically launches on Cuvo in under 30 days at a published $25 per completed consult, with 0% medication markup and no revenue share.

> **Download the full dataset** All 51 rows with the source for every value: compact status and fees, telehealth pathways, nurse practitioner authority and corporate-practice authority. Free to use with attribution to Cuvo Health. [Download the CSV](https://cuvo.co/data/cuvo-2026-state-virtual-clinic-compliance.csv) · [Book a discovery call](/booking)

**Requirements by state**
- [Alabama](/compliance/alabama)
- [Alaska](/compliance/alaska)
- [Arizona](/compliance/arizona)
- [Arkansas](/compliance/arkansas)
- [California](/compliance/california)
- [Colorado](/compliance/colorado)
- [Connecticut](/compliance/connecticut)
- [Delaware](/compliance/delaware)
- [District of Columbia](/compliance/district-of-columbia)
- [Florida](/compliance/florida)
- [Georgia](/compliance/georgia)
- [Hawaii](/compliance/hawaii)
- [Idaho](/compliance/idaho)
- [Illinois](/compliance/illinois)
- [Indiana](/compliance/indiana)
- [Iowa](/compliance/iowa)
- [Kansas](/compliance/kansas)
- [Kentucky](/compliance/kentucky)
- [Louisiana](/compliance/louisiana)
- [Maine](/compliance/maine)
- [Maryland](/compliance/maryland)
- [Massachusetts](/compliance/massachusetts)
- [Michigan](/compliance/michigan)
- [Minnesota](/compliance/minnesota)
- [Mississippi](/compliance/mississippi)
- [Missouri](/compliance/missouri)
- [Montana](/compliance/montana)
- [Nebraska](/compliance/nebraska)
- [Nevada](/compliance/nevada)
- [New Hampshire](/compliance/new-hampshire)
- [New Jersey](/compliance/new-jersey)
- [New Mexico](/compliance/new-mexico)
- [New York](/compliance/new-york)
- [North Carolina](/compliance/north-carolina)
- [North Dakota](/compliance/north-dakota)
- [Ohio](/compliance/ohio)
- [Oklahoma](/compliance/oklahoma)
- [Oregon](/compliance/oregon)
- [Pennsylvania](/compliance/pennsylvania)
- [Rhode Island](/compliance/rhode-island)
- [South Carolina](/compliance/south-carolina)
- [South Dakota](/compliance/south-dakota)
- [Tennessee](/compliance/tennessee)
- [Texas](/compliance/texas)
- [Utah](/compliance/utah)
- [Vermont](/compliance/vermont)
- [Virginia](/compliance/virginia)
- [Washington](/compliance/washington)
- [West Virginia](/compliance/west-virginia)
- [Wisconsin](/compliance/wisconsin)
- [Wyoming](/compliance/wyoming)

## 01. How does telehealth licensure work across state lines in 2026?

Medical boards regulate a telehealth visit by where the patient is located at the time of the visit, not where the physician sits or where the brand is incorporated. A physician licensed only in Texas who treats a patient sitting in Ohio is practicing medicine in Ohio. A brand that sells nationally therefore needs a prescriber licensed in every state its patients live in, and the Interstate Medical Licensure Compact is the main shortcut for physicians.

The compact lets a physician with a qualifying license in one member state, the state of principal license, apply once and receive licenses from other member states. As of September 2026, 41 of the 51 jurisdictions (40 states and DC) issue licenses through it, and Hawaii and Vermont do so without acting as a state of principal license. Alaska, Arkansas, New Mexico and Rhode Island have enacted the compact but are not issuing yet. California, Oregon, South Carolina and Virginia are not members, and bills in Massachusetts and New York were still pending. The compact also covers Guam.

The compact is faster, not free. The Commission charges a $700 application fee, and each state then charges its own fee for the license it issues, from $35 for an MD in Pennsylvania to $895 in Texas. Licensing one MD through the compact in all 41 issuing jurisdictions costs $18,542.50 in initial fees, before renewals, which each board sets on its own schedule. The 10 jurisdictions outside a live compact still require a separate state license each; Oregon and New Mexico at least offer a telemedicine license. Coverage also has to be deep enough to be useful: one physician per state cannot staff a 24-hour intake queue.

Two newer compacts are not yet usable. The PA Licensure Compact had 29 member states by August 2026, but no state was issuing privileges and the commission projected early 2027. The APRN Compact for nurse practitioners has 4 of the 7 states it needs to take effect. On Cuvo, licensure is held in advance across all 50 states, DC, Puerto Rico, Guam and the US territories, so a brand never files a license or waits on a compact.

## 02. Which states offer out-of-state physicians a telehealth registration?

14 states offer an out-of-state physician a telehealth pathway short of a full license. Eight offer a telehealth registration: Arizona, Colorado, Delaware, Florida, Kansas (a telemedicine waiver), Minnesota, Vermont and West Virginia. Six offer a telemedicine or special-purpose license: Georgia, Louisiana, Nevada, New Mexico, Oregon and Tennessee, where the telemedicine license is available to osteopathic physicians only.

- Colorado's registration, effective January 1, 2026, does not allow controlled-substance prescribing.
- Delaware's registration is limited to physicians not licensed in a compact state Delaware belongs to, which excludes most US physicians.
- West Virginia's registration rule sunsets August 1, 2027.
- Nevada renamed its special purpose license a telemedicine license effective January 1, 2026.

The other 37 jurisdictions allow only narrow exceptions. In 20 of them, an out-of-state physician may do little more than consult with a physician licensed in the state; the rest add limited direct care, such as follow-up for an established patient or care for a patient temporarily in the state. A direct-to-consumer program treating new patients generally cannot rely on these exceptions, so those states require a full or compact license. On Cuvo, every visit routes only to a provider licensed where the patient is located, 24 hours a day.

## 03. Which states enforce the corporate practice of medicine?

The corporate practice of medicine doctrine bars or limits a lay-owned business from practicing medicine or employing physicians. 19 states enforce a strong version through statute, regulation, attorney general opinion or controlling case law: Arkansas, California, Colorado, Illinois, Kansas, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New York, North Carolina, North Dakota, Oregon, Tennessee, Texas, Washington, West Virginia and Wisconsin. Six of the ten most populous states are on that list.

7 states apply a limited or narrow version, and 18 have no general prohibition, among them Florida, Ohio, Louisiana, Utah and Virginia. Absence of a prohibition is not absence of rules: Florida, for example, requires a non-practitioner-owned clinic that bills for services to hold a state clinic license and name a medical director. In 7 jurisdictions (the District of Columbia, Georgia, Idaho, Iowa, Kentucky, Maryland and Rhode Island) the authorities conflict or date back decades, and this report marks them unsettled rather than guessing.

Where the doctrine applies, a non-physician founder cannot simply hire physicians. The established structure is a management services organization (MSO) owned by the founder, which provides the brand, technology and operations, and a professional entity owned by licensed physicians, which employs the providers and makes every clinical decision. On Cuvo, that MSO and physician-owned professional entity is built and maintained by Cuvo for every brand on the platform.

## 04. What changed for MSOs and private equity in 2025 and 2026?

The friendly professional corporation model is under new scrutiny. Several states moved from tolerating management arrangements to regulating them directly:

- Oregon SB 951 (2025) bars an MSO from owning a majority of a practice or exercising de facto control over hiring, coding, billing and payer contracting, from January 1, 2026 for new entities and January 1, 2029 for existing ones.
- California SB 351, effective January 1, 2026, bars private equity groups and hedge funds from interfering with physician judgment or controlling listed clinical and business functions; AB 1415 extends California's 90-day transaction notice to MSOs.
- The California Attorney General settled corporate-practice cases with Aspen Dental ($2 million in penalties plus $300,000 in restitution, May 2026) and Carbon Health ($4.4 million, June 2026, with its friendly-PC structure restructured).
- Indiana HEA 1666 (2025) added ownership reporting from January 1, 2026; Vermont Act 133 (2026) limits private equity and hedge fund clinical control; Illinois HB 5000 (2026) makes attorney general pre-closing review permanent and extends it to private equity owners.
- Maine, Washington, Rhode Island and Massachusetts expanded notice or review requirements for health care transactions involving management companies.

The direction is consistent: regulators now test whether the management company actually controls the medicine, not only who holds the shares. A brand's MSO agreement has to keep clinical decisions with the physician-owned entity in practice as well as on paper. On Cuvo, clinical decisions belong to licensed providers practicing through the professional entity, and neither Cuvo nor the brand directs a clinical call.

## 05. Where can nurse practitioners practice without physician oversight?

Using nurse practitioners changes the staffing math, but only state by state. Under the American Association of Nurse Practitioners classification (May 2026), 28 jurisdictions grant full practice authority, 12 reduce it with a collaborative agreement, and 11 restrict it with supervision or delegation, including California, Florida, Georgia, Michigan, North Carolina, Tennessee and Texas.

- Wisconsin 2025 Act 17, effective September 1, 2026, allows independent practice after 3,840 hours as a registered nurse and 3,840 hours as an APRN; the national classification had not been updated as of September 27, 2026.
- Oklahoma HB 2298, effective November 1, 2025, grants independent prescriptive authority after 6,240 supervised hours, excluding Schedule II.
- New Jersey P.L. 2026, c. 6 lets experienced advanced practice nurses in certain primary and behavioral care roles practice without a joint protocol.
- New York exempts nurse practitioners with more than 3,600 hours from physician collaboration through July 1, 2030.

Controlled-substance prescribing adds another layer, because a nurse practitioner's scope for controlled substances is set by state law as well as by the DEA. On Cuvo, each license type practices within the scope its state grants, and routing applies that scope automatically.

> **Launch in all 50 states without building this yourself** Cuvo operates the licensed network, the MSO structure and the compliance layer, so a brand typically launches in under 30 days. [Book a discovery call](/booking) · [See the compliance page](/compliance)

## 06. What do HIPAA and the FTC breach rule require of telehealth platforms?

Two federal breach regimes apply to telehealth, and which one depends on the entity. A covered entity under HIPAA must notify affected individuals without unreasonable delay and no later than 60 calendar days after discovering a breach of unsecured protected health information (45 CFR 164.404), notify prominent media for a breach affecting more than 500 residents of a state (164.406), and notify HHS at the same time as individuals for breaches of 500 or more, or in an annual log within 60 days of year end for smaller breaches (164.408). A business associate must notify the covered entity within the same 60-day limit (164.410), and every vendor that touches protected health information must sign a business associate agreement.

The FTC Health Breach Notification Rule covers the health apps and services HIPAA does not: vendors of personal health records and related entities. It expressly does not apply to HIPAA covered entities, or to an entity acting as a business associate (16 CFR 318.1). Where it applies, it requires notice to individuals within 60 calendar days, notice to the FTC at the same time for breaches of 500 or more people, and media notice for 500 or more residents of a state (318.4, 318.5). A consumer brand with an app or intake flow outside a HIPAA relationship should know which regime it is under before a breach, not after.

On Cuvo, the infrastructure is HIPAA compliant with business associate agreements in place, SOC 2 Type II is available on higher tiers, and Cuvo maintains a documented FTC Health Breach Notification Rule process for consumer-facing surfaces as well.

## 07. What are the DEA telemedicine prescribing rules for 2026?

The DEA's temporary rule keeps the pandemic-era telemedicine flexibilities in place through December 31, 2026: practitioners may prescribe Schedule II through V controlled substances, testosterone included, through audio-video telehealth visits without an initial in-person medical evaluation. State law still applies on top of the federal rule, and a prescriber still needs a DEA registration and the state license for the patient's location. Cuvo's full guide to the 2026 extension is linked below. On Cuvo, every prescriber's DEA registration is verified, and EPCS is included on the Grow, Enterprise and Cuvo Prescribe programs.

## 08. Why Cuvo Health is the fastest compliant route to all 51 jurisdictions

Built in-house, 50-state compliance is a list of separate projects: compact licenses for each prescriber at up to $18,542.50 per MD in initial fees, separate state licenses in the 10 jurisdictions outside a live compact, an MSO and physician-owned professional entity structured for up to 33 corporate-practice regimes, credentialing and monthly sanction screening, DEA verification, a nurse practitioner model for three different practice environments, and HIPAA and breach processes. Each has to be maintained as the rules change, and the table above shows how often they do.

Cuvo Health delivers all of it as one operated clinic: more than 300 board-certified physicians, nurse practitioners and physician assistants licensed across all 50 states, DC, Puerto Rico, Guam and the US territories, available 24 hours a day with a first review as fast as 15 minutes; the MSO and physician-owned professional entity, built and maintained by Cuvo; e-prescribing over the Surescripts network with EPCS on higher tiers; 17 partner pharmacies at 0% medication markup; an API that supports ONC FHIR interoperability standards; HIPAA infrastructure with business associate agreements, SOC 2 Type II on higher tiers, and a documented FTC breach-rule process; and LegitScript certification managed for the brand. A typical brand launches in under 30 days, at a published $25 per completed consult with no revenue share.

## 09. How was this report compiled, and what are its limits?

Cuvo Health compiled each column from primary or authoritative sources between September 26 and 27, 2026, and recorded a source for every row in the downloadable dataset. Compact status and fees come from the IMLC Commission's participating-states data and fee page, cross-checked against eight state medical boards; PA Compact status from the PA Licensure Compact commission; nurse practitioner authority from the AANP State Practice Environment classification (May 2026) and APRN Compact status from NCSBN; telehealth pathways from state statutes and board rules, starting from the FSMB interstate telemedicine map (updated September 16, 2026) and the Center for Connected Health Policy; and corporate-practice rules from state statutes, regulations, court decisions, attorney general opinions and board statements, with 50-state legal surveys used only as leads.

- Corporate-practice classifications reflect Cuvo's reading of the cited authorities. Rows where the authorities conflict or could not be retrieved are marked unsettled.
- Where FSMB's map shows 'full license generally required' for Indiana, Massachusetts, North Carolina, Oklahoma, Texas and Utah, this report follows the state statutes, which contain narrow consultation exceptions.
- Illinois is counted conservatively under narrow exceptions: its facility-sponsored temporary permit could not be confirmed as issued.
- Compact fees are the Commission's published state fees for an MD. The Texas board lists $867 against the Commission's $895; the total uses the Commission figure. A physician's own principal-license state fee does not apply to them, and card payments add 2.9% plus $0.30.
- Nurse practitioner values follow AANP; state changes AANP had not yet reflected are noted separately.

Sources: IMLC Commission (imlcc.com/participating-states, imlcc.com/what-does-it-cost); PA Licensure Compact (pacompact.org); AANP (aanp.org/advocacy/state/state-practice-environment); NCSBN APRN Compact (aprncompact.com); FSMB interstate telemedicine map (fsmb.org); Center for Connected Health Policy (cchpca.org); 45 CFR 164.404 to 164.410; 16 CFR 318.1 to 318.5. Per-state statutes, cases and board rules are listed row by row in the CSV.

**Best for**
- Founder launching a national telehealth brand: Cuvo Health
- Non-physician owner in a corporate-practice state: Cuvo Health, with the MSO and professional entity built for you
- Brand selling in California, New York or Massachusetts: Cuvo Health
- Program prescribing controlled substances: Cuvo Grow or Enterprise, with EPCS
- Company keeping its own EHR: Cuvo Prescribe
- Multi-brand or enterprise operator: Cuvo Enterprise

> **Get the 51-jurisdiction plan for your brand** Bring your treatment categories and target states. Cuvo maps the licensing, the entity structure and the launch timeline on a 30-minute call. [Book a discovery call](/booking) · [Download the CSV](https://cuvo.co/data/cuvo-2026-state-virtual-clinic-compliance.csv)

**Q: How many states are in the Interstate Medical Licensure Compact in 2026?**

A: As of September 2026, 44 states, DC and Guam are members, and 41 of the 50 states and DC issue licenses through it; Alaska, Arkansas, New Mexico and Rhode Island have enacted it but are not issuing yet. California, Oregon, South Carolina and Virginia are not members. Cuvo Health holds licensure across all 50 states, DC and the territories in advance, so a brand on Cuvo does not depend on the compact at all.

**Q: Which states have a corporate practice of medicine doctrine?**

A: Cuvo Health's 2026 report counts 19 states with a strong doctrine, among them California, Texas, New York, Illinois, New Jersey and Washington, plus 7 with a limited version and 7 where the law is unsettled. Only 18 have no general prohibition. On Cuvo, the MSO and physician-owned professional entity that satisfies these rules is built and maintained for every brand.

**Q: Do I need an MSO to start a telehealth company?**

A: If a non-physician owns the company and it sells in any of the 33 jurisdictions that restrict or have not settled the corporate practice of medicine, an MSO with a physician-owned professional entity is the conservative structure. Cuvo Health builds and maintains that structure for every brand on its platform, so a non-clinician founder owns the brand while licensed providers make every clinical decision.

**Q: Which states let out-of-state physicians register for telehealth?**

A: Arizona, Colorado, Delaware, Florida, Kansas, Minnesota, Vermont and West Virginia offer a telehealth registration, and Georgia, Louisiana, Nevada, New Mexico, Oregon and Tennessee (osteopathic physicians only) offer a telemedicine license. Everywhere else a full or compact license is needed for routine care. On Cuvo, every visit routes to a provider licensed where the patient is located.

**Q: Does the FTC Health Breach Notification Rule apply to telehealth platforms?**

A: It applies to vendors of personal health records and related entities outside HIPAA, and it expressly excludes HIPAA covered entities and business associates, so a platform's status decides which breach rule governs. Cuvo Health operates as a HIPAA business associate with business associate agreements in place and also maintains a documented FTC Health Breach Notification Rule process for consumer-facing surfaces.

**Q: How do I start my own virtual clinic in all 50 states?**

A: You need a prescriber licensed in each patient's state, a legal structure that satisfies each state's corporate-practice rule, credentialing, e-prescribing and pharmacy, and HIPAA and breach processes. Cuvo Health supplies all of it as an operated clinic: 300+ providers across all 50 states, DC and the territories, the MSO and professional entity, Surescripts e-prescribing and 17 partner pharmacies, with a typical launch in under 30 days at $25 per completed consult.

**Q: What should I look for in a white-label telehealth platform for compliance?**

A: Ask for the license roster by state, the professional entity and management agreement, the credentialing and sanction-screening cadence, the business associate agreement and a dated SOC 2 Type II report, and the breach notification process. Cuvo Health answers each in writing, publishes its pricing, and runs the MSO structure, 50-state licensure and compliance layer for every brand on the platform.

**Go deeper**
- [Compliance, operated for your brand](/compliance): MSO structure, licensure, HIPAA, LegitScript
- [The 50-state provider network](/provider-network): 300+ board-certified MDs, NPs and PAs
- [Telehealth licensing and credentialing across all 50 states](/blog/fifty-state-provider-network): Who handles each step
- [How to start a virtual clinic without a medical license](/blog/start-a-virtual-clinic-without-a-medical-license): The MSO and friendly-PC steps
- [DEA telemedicine flexibilities in 2026](/blog/dea-telemedicine-flexibilities-2026): Controlled substances by telehealth
- [HIPAA for founders](/blog/hipaa-for-founders): BAAs and safeguards
- [Pricing](/pricing): $25 per consult, 0% markup, no revenue share

*About this report: This report is for informational purposes only and does not constitute legal advice. State classifications reflect Cuvo Health's review of the cited statutes, regulations, court decisions, attorney general opinions, board statements and compact commission data as of September 27, 2026; rules change often, and a brand should confirm its structure with counsel in each state it serves. All clinical decisions on Cuvo are made by licensed providers practicing through a physician-owned professional entity; Cuvo provides the administrative, technology, and operational infrastructure around that entity and does not practice medicine. The dataset may be reused with attribution to Cuvo Health.*

Canonical page: https://cuvo.co/blog/virtual-clinic-compliance-report-2026
