Disclaimer: This material is provided for educational and informational purposes only. It does not constitute legal or medical advice or regulatory guidance. Requirements and interpretations may vary and change over time. Always verify current rules directly with the State Medical Board of Ohio, the Ohio Board of Nursing, and the Ohio Board of Pharmacy, and seek advice from qualified legal counsel before making decisions or taking action.
Executive Summary
- Physician control is mandatory: Ohio requires physicians to retain authority over diagnosis, treatment, prescribing, delegation, and quality assurance; business owners and MSOs may handle only nonclinical functions.
- Medical director eligibility: An Ohio-licensed MD or DO in good standing must actively supervise care, prescribing, chart review, and QA—titles without real oversight create enforcement risk.
- APRN and PA prescribing hinges on agreements: APRNs must practice under a valid Standard Care Arrangement; PAs must operate under a written Supervision Agreement that reflects real scope, prescribing authority, and oversight.
- Quality assurance must be documented: Regulators expect routine chart reviews, QA meetings with minutes, adverse-event tracking, and corrective actions—undocumented QA is treated as nonexistent.
- Telehealth equals in-person standards: A valid practitioner–patient relationship, appropriate evaluation, informed consent, and complete documentation are required; questionnaires alone are insufficient.
- Controlled substances require heightened safeguards: Phentermine prescribing requires DEA registration, OARRS checks, individualized medical justification, and careful telehealth compliance.
- GLP-1 prescribing still carries risk: While not controlled substances, GLP-1s require proper authorization under agreements, informed consent, lawful pharmacy sourcing, and truthful advertising.
- Advertising is scrutinized: Weight-loss claims must be substantiated; nonphysicians may not be marketed as doctors or independent prescribers.
- Common enforcement triggers: Weak supervision, stale agreements, improper telehealth prescribing, misleading marketing, and MSO interference with medical judgment.
- Compliance is structural and operational: Ohio has no single “weight-loss clinic” statute—regulators assess compliance through supervision, delegation, telehealth, prescribing, and consumer-protection standards working together.
Quick Compliance Checklist
Entity & Ownership Structure
- The physician retains authority over diagnosis, treatment planning, prescribing, and clinical protocols, consistent with physician responsibilities under Ohio Revised Code 4731.22.
- Business owners or MSOs handle nonclinical operations only (marketing, billing, staffing) and do not influence medical judgment.
- Management arrangements preserve physician independence in clinical decision-making, consistent with State Medical Board guidance on physician control.
Medical Board guidance:
Medical Director Credentials
- Active, unencumbered Ohio MD or DO license in good standing.
- Familiarity with obesity medicine, metabolic care, or primary care appropriate to services offered.
- Availability for chart review, supervision, and escalation as required by Ohio Medical Board standards. License verification.
Prescribing & Collaboration Structure
- Practice and prescribe only pursuant to a written Standard Care Arrangement, as required by Ohio Revised Code 4723.431.
- SCA defines scope of services, prescriptive authority, consultation and referral processes, and quality review.
- Practice and prescribe under a written Supervision Agreement consistent with Ohio Revised Code 4730.19.
- Agreement reflects actual delegated services, prescribing authority, and supervision.
- Ohio does not impose a fixed numeric supervision cap, but supervision must be reasonable, ongoing, and documentable under Ohio Medical Board expectations.
Quality Assurance
- Routine chart reviews conducted by or under the direction of the medical director.
- QA meetings with documented agendas, minutes, and follow-up actions.
- Adverse-event and medication-reaction tracking.
- Corrective action documentation when issues arise, supporting physician oversight under Ohio Revised Code 4731.22.
Telehealth Workflow Compliance
- Practitioner–patient relationship established through clinically appropriate interaction, with synchronous audio-video visits used when necessary to meet the standard of care.
- Documentation supports diagnosis, treatment rationale, informed consent, and follow-up.
- Medical records securely maintained and accessible to the medical director for supervision and QA.
- Telehealth guidance: https://med.ohio.gov/wps/portal/gov/med/for-licensees/telehealth
Telehealth statute: Ohio Revised Code 4731.228
Controlled Substance Compliance (Phentermine – Schedule IV)
- DEA registration maintained for prescribing clinicians, as required under federal and Ohio law.
- OARRS query performed before prescribing and periodically thereafter, consistent with Ohio Revised Code 4729.75.
- Individualized medical justification documented.
- Follow-up visits documented and clinically appropriate.
GLP-1 Medication Compliance
- Prescribing authority clearly defined in the applicable Standard Care Arrangement or Supervision Agreement.
- Informed consent addresses risks, expectations, and monitoring requirements.
- Medication sourcing limited to properly licensed pharmacies.
- Compounding complies with FDA standards and Ohio Board of Pharmacy requirements.
Advertising & Representation
- No misleading claims (e.g., “guaranteed weight loss” or unsupported outcomes).
- Nonphysicians are not marketed as “doctors” or independent prescribers.
- Advertising aligns with scope of practice, medical evidence, and Ohio’s consumer protection standards under Ohio Revised Code 1345.02.
The Legal Frame: Who Can Be a Medical Director in Ohio
Who Can Serve as Medical Director
In Ohio, a medical director for a weight loss or telehealth clinic must be an Ohio-licensed MD or DO in good standing. No specialty is required, but the physician must be clinically competent and available to supervise prescribing, delegation, chart review, and quality-assurance activities consistent with Ohio Medical Board expectations.
Corporate Practice of Medicine Considerations
Ohio allows physicians to provide services through business entities, but compliance risk arises if non-physicians influence diagnosis, treatment, prescribing, or supervision. Medical Board position statements emphasize that physicians must retain independent medical judgment, while management entities may handle only nonclinical operations without directing patient care.
Delegation & Prescribing: The Documents That Matter
Standard Care Arrangement (APRNs)
- Required for APRN practice and prescribing under Ohio Revised Code 4723.431.
- Must be in writing and reflect actual clinical practice, including telehealth services if used.
- Must define:
- Scope of services provided by the APRN
- Prescriptive authority, including any controlled substances
- Consultation and referral requirements
- Emergency coverage arrangements
- A systematic quality-assurance and chart-review process
Supervision Agreement (Physician Assistants)
- Required for PA practice and prescribing under Ohio Revised Code 4730.19.
- Must be in writing and maintained by the supervising physician.
- Must describe:
- Delegated medical services and procedures
- Prescriptive authority and limitations
- Physician availability and supervision method (including telehealth, if applicable)
- Chart-review and oversight expectations
Weight Loss Clinics: What Ohio Requires
Who Can Prescribe Weight-Loss Medications
- MD/DO: May prescribe weight-loss medications if licensed in Ohio and practicing within the standard of care, consistent with physician authority under Ohio Revised Code 4731.22.
- APRNs / PAs: May prescribe only within the scope and limitations of a valid Standard Care Arrangement or Supervision Agreement, as required under Ohio Revised Code 4723.431 (APRNs) and 4730.19 (PAs).
- RNs, health coaches, nutritionists: May not prescribe medications or independently adjust drug therapy.
Phentermine (Schedule IV Controlled Substance)
- Prescribers must maintain active DEA registration, as required under federal and Ohio controlled-substance laws.
- OARRS (Ohio PDMP) queries are required prior to prescribing and during ongoing treatment, consistent with Ohio Revised Code 4729.80 and Medical Board rules.
- Telehealth prescribing is permitted but subject to heightened scrutiny, including appropriate evaluation, documentation, and follow-up under Ohio telehealth and controlled-substance rules.
- Clinics should avoid standardized or “cookie-cutter” protocols and document individualized medical necessity, monitoring, and response.
GLP-1 Medications (e.g., Semaglutide, Tirzepatide)
- GLP-1 medications are not federally controlled substances, but prescribing remains subject to the same standard of care as in-person treatment under Ohio Medical Board oversight.
- APRNs and PAs may prescribe GLP-1s only if authorized by their SCA or Supervision Agreement.
- Clinics must comply with Ohio Board of Pharmacy requirements for lawful sourcing and compounding and ensure advertising is truthful and non-misleading under Ohio Revised Code 1345.02.
Telehealth in Ohio: Compliance Rules
Practitioner–Patient Relationship
- Must be established through a clinically appropriate interaction that supports diagnosis and treatment, consistent with the physician standard of care under Ohio Revised Code 4731.22.
- Questionnaire-only models are insufficient to establish a practitioner–patient relationship under State Medical Board guidance.
- The standard of care for telehealth is the same as in-person care, as required by Ohio Revised Code 4731.228 and related Board rules.
Telehealth Prescribing
- GLP-1 medications may be prescribed via telehealth when clinically appropriate and when the encounter meets Ohio’s standard-of-care and documentation requirements.
- Controlled substances prescribed via telehealth must comply with the Medical Board’s controlled-substance telehealth rule in Ohio Administrative Code 4731-11-09, including evaluation, documentation, and OARRS requirements.
- Best practice: Conduct at least one real-time audio-video evaluation before initiating controlled medications to reduce enforcement risk and support medical necessity.
Common Ohio Enforcement Risks
- Inadequate supervision of APRNs or PAs, including failure to perform chart review or meaningful oversight as required under physician supervision and collaboration standards in Ohio Revised Code Chapters 4723 and 4730.
- Missing, outdated, or non-reflective Standard Care Arrangements or PA Supervision Agreements, which are required for APRN and PA practice under Ohio Revised Code 4723.431 and 4730.19.
- Improper telehealth prescribing of controlled substances, including failure to meet evaluation, documentation, and OARRS requirements enforced by the State Medical Board under Ohio Administrative Code 4731-11-09.
- Deceptive or misleading weight-loss advertising, such as guaranteed results or improper provider representations, which may trigger enforcement under Ohio’s Consumer Sales Practices Act, enforced by the Ohio Attorney General.
- Business or MSO interference with medical judgment, where non-physicians influence diagnosis, treatment, prescribing, or protocols, creating unprofessional conduct risk under Ohio Revised Code 4731.22 and State Medical Board guidance.
FAQs
Can a nurse practitioner run a weight-loss clinic in Ohio?
Yes. An APRN may own or operate a business entity, but prescribing and medical services must be provided pursuant to a valid Standard Care Arrangement with physician collaboration, as required under Ohio Revised Code 4723.431. Independent medical practice without an SCA is not permitted.
Can GLP-1 medications be prescribed via telehealth in Ohio?
Yes. GLP-1 medications may be prescribed via telehealth when a valid practitioner–patient relationship is established and the standard of care equivalent to an in-person visit is met, consistent with Ohio Medical Board telehealth rules and Ohio Revised Code 4731.228.
Is phentermine allowed via telemedicine?
Yes, but it carries higher regulatory risk. Prescribing must comply with federal DEA requirements, mandatory OARRS checks, and Ohio’s controlled-substance telehealth rule enforced under Ohio Administrative Code 4731-11-09.
Do APRN or PA agreements need to list specific drugs?
No. Standard Care Arrangements and PA Supervision Agreements must define the scope and categories of prescribing authority, consultation requirements, and review processes, rather than listing every individual medication, consistent with Ohio Revised Code 4723.431 and 4730.19.
How Medical Director Co. Supports Ohio Weight Loss & Telehealth Compliance
Medical Director Co. delivers physician-led compliance support for Ohio weight-loss and telehealth clinics, including:
- Ohio-licensed medical directors with experience in obesity medicine, metabolic care, and telehealth models regulated by the Ohio State Medical Board.
- Standard Care Arrangement and PA Supervision Agreement support, aligned with Ohio scope-of-practice, prescriptive authority, and documentation requirements.
- Sustainable QA systems, including chart-review cadence guidance, QA meeting templates, and audit-ready documentation workflows.
- Telehealth compliance guidance, covering practitioner–patient relationship standards, documentation expectations, and escalation planning.
- Medication-specific compliance support, distinguishing GLP-1 therapy oversight from controlled-substance requirements such as phentermine, OARRS, and DEA obligations.
- Entity and MSO structure reviews, focused on preserving physician clinical control and reducing regulatory risk under Ohio’s permitted business frameworks.
Areas We Serve in Ohio
We provide licensed medical directors and compliance support across Ohio, including major metros:
Who We Serve
- Nurse Practitioners (NPs): Collaborative agreements, prescriptive authority, compliance support.
- Registered Nurses (RNs): Oversight for medspas, wellness centers, weight-loss programs.
- Physician Assistants (PAs): Supervision, protocols, chart audits.
- Estheticians: Safe treatment protocols under physician approval.
Ohio Resources You Should Bookmark
- State Medical Board of Ohio: https://med.ohio.gov
- Ohio Administrative Code: https://codes.ohio.gov
- Ohio Board of Nursing: https://nursing.ohio.gov
- Ohio Attorney General (Advertising & Consumer Protection): https://www.ohioattorneygeneral.gov
- Justia U.S. Law – Ohio Revised Codes: https://law.justia.com/codes/ohio/title-47/chapter-4731/section-4731-22/
- Legal Information Institute – Ohio Administrative Code: https://www.law.cornell.edu/regulations/ohio
