The Solo Practitioner’s Guide To Starting a Telemedicine Practice Across State Lines

Solo telemedicine practitioners rarely stay confined to one state for long. A therapist in Ohio picks up patients from three neighboring states. A psychiatrist in Colorado gets referrals from a former colleague’s practice in Texas. Within a year, what started as a single-state license has become a patchwork of applications, renewal dates, and compliance rules nobody mentioned at the outset.

Expanding across state lines is one of the fastest ways for a solo practice to grow, but it comes with more moving parts than most providers expect. Here is what actually needs to happen, in the order it needs to happen.

Telemedicine provider's desk with laptop and licensing documents for multi-state practice

Licensing Comes Before Everything Else

The state where your patient is physically located at the time of the visit governs that encounter, not the state where you sit. That means a separate license (or license recognition) for every state you intend to serve.

The Interstate Medical Licensure Compact has made this considerably less painful for physicians. Arizona is one of 42 member states, along with the District of Columbia and Guam, and the compact offers an expedited pathway that can save a physician in good standing several months of processing time and roughly $1,000 to $3,000 in fees compared to applying for a full license from scratch. For a solo practitioner trying to open up four or five new states, that difference is real.

The compact has limits worth knowing before you build a plan around it. It applies to physicians, not nurse practitioners or physician assistants, who have their own compacts (the Nurse Licensure Compact and emerging PA compact frameworks) with different eligibility rules and different adoption by state. And it requires a clean disciplinary and licensure history — a single prior board action can disqualify you. Check your specific pathway before assuming the compact will cover you.

DEA Registration Still Follows The State, Not The Patient

Federal telemedicine flexibilities for prescribing controlled substances have been extended again. On December 30, 2025, the DEA and HHS published a fourth temporary extension of the COVID-era prescribing flexibilities, running through December 31, 2026. That extension buys time, but it does not eliminate the underlying registration requirement.

A DEA proposed rule released in January 2025 would create a Special Registration pathway for telemedicine prescribing, including a limited and less expensive State Telemedicine Registration as an alternative to a full registration in every state. As of this writing, that rule has not been finalized. Until it is, solo practitioners prescribing controlled substances across state lines should plan on registering in each state where they practice, not assume a simplified path will be ready in time to matter.

Medicare Enrollment Ties Directly To Where You Practice

CMS enrollment is location-specific, and the agency has tightened that requirement rather than loosened it. As of February 2026, providers must re-verify the patient’s location at every telehealth visit, not just at initial enrollment. For a solo practitioner billing Medicare in multiple states, this means enrollment records, practice locations, and location verification all need to be current and accurate for every state where claims are submitted — not just the state where the practice originally started.

Arizona Has Its Own Rules For Out-Of-State Providers

Arizona allows out-of-state providers to deliver telehealth to patients physically located in the state, but it sets specific conditions. The provider must hold a current license from another state that is substantially similar to an Arizona license, must have held that license for at least one year, and must register with the appropriate Arizona board before treating any Arizona patient. Professional liability insurance must cover telemedicine services rendered in Arizona specifically.

Out-of-state registration has a hard boundary: it covers telehealth only. Providers cannot use it to see Arizona patients in person or to open a physical office without pursuing full Arizona licensure. Registered providers also submit to Arizona’s jurisdiction for any disciplinary or legal matter connected to care delivered in the state.

The Address Requirement That Catches Almost Everyone Off Guard

Here is where solo practitioners most often stall out. DEA registration, state medical board registration, and Medicare enrollment all generally require a legitimate business address in the state where you’re registering — not a home address, and in many cases not a P.O. box or virtual mailbox service. The DEA in particular scrutinizes the registered location closely, since it ties directly to controlled substance recordkeeping.

For a practitioner who doesn’t live in Arizona and has no plans to relocate, this becomes the practical bottleneck in an otherwise straightforward expansion. You need a real, verifiable medical office address you can use for licensing, DEA registration, and Medicare enrollment, without signing a long-term commercial lease for a state where you may see patients only virtually.

This is exactly the gap Viva MedSuites was built to close. Telemedicine providers use a Viva address in Scottsdale or Mesa to satisfy Arizona licensing, DEA, and Medicare location requirements, with memberships starting at $199 a month, well below the cost of a traditional lease. If you’re weighing Arizona as your next state, you can read more at vivamedsuites.com/telemedicine-az-address/ or call 480-616-2400 to talk through what your specific specialty and license type will require.

John Groberg is the founder of Viva MedSuites, Arizona’s largest medical coworking community, with locations in Scottsdale and Mesa serving independent practitioners since 2017.