Everything a Physician Practice Needs

Medicine is regulated state by state. When you see a patient by telehealth, the practice of medicine takes place where the patient is located, and that state's laws apply. A physician in one state treating a patient who lives in, or is traveling in, another generally needs a license from that second state. The Interstate Medical Licensure Compact says it plainly for its own process: the location of medical practice is the state where the patient is located.

The Interstate Medical Licensure Compact (IMLC) is a faster path to those additional licenses for physicians who qualify. It does not issue a national or compact license. You choose a state of principal license, that state verifies your eligibility and issues a letter of qualification, and each additional member state then issues its own full license. Medicare treats a license obtained through a compact as a valid, full license for enrollment purposes.

Not every physician qualifies, and the compact asks each physician to make a self-determination of eligibility before applying. We check your record against the requirements below first. If you do not qualify, or a state you need is not a member, we file a traditional application with that state's board instead.

A DEA registration is tied to a state. DEA requires a separate registration for each principal place of professional practice where controlled substances are dispensed, and its registration guidance says a practitioner who practices in more than one state needs a separate DEA registration in each state. DEA also requires that all of that state's licensing requirements be met first, because federal registration rests on your authority to handle controlled substances under that state's law.

Some states add a state controlled substance registration of their own, issued separately from the medical license and renewed on its own cycle. The order matters: medical license first, then the state registration where one is required, then the DEA registration for that state. We build that sequence into your license plan so you are not holding a license you cannot prescribe under.

The Consolidated Appropriations Act of 2023 added a one-time, eight-hour training requirement on treating substance use disorders for DEA-registered practitioners. You affirm it on the DEA application the first time it is asked, initial or renewal, and it is not repeated at later renewals. Telemedicine prescribing of controlled substances follows separate federal rules that have changed several times; the current status is shown below, and we track the state rules that sit on top of it.

Payers and hospitals verify the same facts about you, each on its own forms. For Medicare Advantage plans, CMS requires a written application, verification of information from primary and secondary sources, and confirmation that you are eligible for payment under Medicare, then recredentialing at least every three years. At recredentialing the plan re-verifies your license from the primary source, your board certification if it was due for renewal, admitting privileges, malpractice coverage and your DEA or state controlled substance certificate, and runs a new National Practitioner Data Bank search.

Board certification shows up in more places than most physicians expect: it is an IMLC requirement, and payers and hospitals verify it at credentialing and again when it comes due for renewal. Hospital and surgery center privileges have their own applications, references and case logs, and reappointment comes around on the medical staff's schedule.

Medicare enrollment has its own clock. For physicians, billing privileges start on the later of the date your enrollment application is filed or the date you begin seeing patients at the new location, with a limited retrospective billing window. Late filing means visits you cannot bill, so we file as soon as your license and practice location are in place. Medicare revalidation follows every five years.

Every physician who sees Medicare patients makes one decision early: enroll and bill Medicare for covered services, or opt out and contract privately with each Medicare patient. For concierge and direct primary care practices, this decision shapes the membership agreement, the fee schedule and how claims are handled, so we settle it before anything else is built.

Opting out is done with a signed affidavit filed with every Medicare Administrative Contractor that would otherwise process your claims. The opt-out period is two years and renews automatically. To leave at the end of a period, you notify each contractor in writing at least 30 days before the next two-year period starts. You can end an initial opt-out within its first 90 days; after an automatic renewal, you cannot end it early.

While opted out, you must sign a private contract with each Medicare patient before treating them, you cannot opt out for some Medicare patients or services and not others, and you cannot use a private contract with a patient who needs emergency or urgent care. Opted-out physicians can still order and certify Medicare items and services for their patients, which matters for labs, imaging and equipment.

Most physician revenue runs through evaluation and management (E/M) codes. For office and outpatient visits, the visit level is selected by medical decision making or by the total time you personally spent on the patient that day. When you choose by time and spend at least 15 minutes beyond the maximum time for the highest level, 99205 or 99215, Medicare's prolonged service code G2212 applies, once for each full 15 minutes. Medicare also pays the add-on code G2211 for office and outpatient visits, and from 2026 for home or residence visits, that are part of an ongoing relationship, where you are the continuing focal point for the patient's care or are managing a single serious or complex condition over time.

These add-ons have rules that trip practices up. G2211 is not paid when the base visit carries modifier 25, except when the same practitioner also furnishes an annual wellness visit, a vaccine administration or a Part B preventive service that day. Documentation has to show why the visit was medically necessary and why the add-on applies. Our coders review each claim against the note before it goes out.

Telehealth is where licensing, prescribing and billing rules meet. The license has to match the state where the patient is located during the visit, controlled substance prescribing has to satisfy both federal and state telemedicine rules, and Medicare and commercial payers each set their own telehealth billing rules. The current Medicare telehealth status is shown below.

Our telehealth platform runs video visits from a browser, under your practice's name, connected to scheduling, charting and payments. Before you open a new state, our licensing team confirms the license and registrations you need there, and our billing team applies that state's payer rules to the claims.

Every covered practice, solo or group, needs a documented HIPAA program: a security risk analysis of the systems that hold patient information, a designated security official, written policies, workforce training and business associate agreements with each vendor that handles patient data. Telehealth, patient portals, ad pixels and texting tools all count as systems to assess.

We run the risk analysis, write the policies for your practice, train your staff, collect the BAAs and repeat the cycle every year. Where you treat patients in more than one state, we also track each state's telehealth and prescribing rules as part of the program.

Opening a practice is a sequence where each step waits on another: the license before the DEA registration, the entity before the tax ID and organizational NPI, the NPI before payer enrollment, and payer enrollment before the first insured patient. We run that sequence for you, coordinate the entity with your attorney and accountant so it fits your state's corporate practice of medicine rules, and set up your EHR, patient portal, payment processing and website so they are live on opening day.

For a growing practice, the same work applies to each new location, physician and state: licenses and registrations first, then credentialing and group linkage, then billing.