Disclaimer: This material is provided for educational and informational purposes only. It does not constitute legal, medical, or regulatory advice. Requirements and interpretations may vary and change over time. Always verify current rules directly with the Michigan Department of Licensing and Regulatory Affairs (LARA) and the Michigan Board of Medicine, and seek advice from qualified legal counsel before making decisions or taking action.
Executive Summary
- Medical directors must be Michigan-licensed MDs or DOs.
- APRNs may prescribe medications under Michigan’s written authorization model and within scope.
- Physician Assistants prescribe under a physician-PA practice agreement.
- Telehealth is permitted under Michigan law if the provider is Michigan-licensed and the standard of care matches in-person services.
- Controlled substances require a Michigan controlled substance license, DEA registration, and reporting to the Michigan Automated Prescription System (MAPS).
- GLP-1 medications are not controlled substances, but remain subject to pharmacy, FDA, and professional board oversight.
- Michigan follows corporate practice restrictions that prevent non-physicians from controlling medical decision-making, though MSO structures are permitted.
- Michigan Department of Licensing and Regulatory Affairs (LARA): Oversees professional licensure, controlled substance licensing, and regulatory compliance.
- Michigan Board of Medicine: Regulates physician licensure, supervision, and professional conduct.
- Michigan Board of Nursing: Governs APRN scope, delegation, and prescribing authorization.
- Michigan Board of Pharmacy: Oversees dispensing, compounding, advertising, and prescription drug compliance.
Quick Compliance Checklist
Navigating the complexities of healthcare regulations can be challenging. A medical director is critical in ensuring your clinic complies with Michigan medical laws and professional standards. Here’s how a compliant structure supports your clinic:
- Physician-owned professional entity for clinical services, paired with an MSO for non-clinical business operations.
- The medical director is a Michigan-licensed MD or DO with authority over clinical protocols and medical decision-making.
- Written authorization in place for every APRN prescribing weight loss medications, and a physician–PA practice agreement for PAs.
- Ongoing chart reviews and quality assurance oversight conducted and documented according to clinic policy.
- Telehealth workflows, including audiovisual visits, e-prescribing, and medical recordkeeping, meet Michigan telemedicine standards and in-person equivalency requirements.
- DEA registration and Michigan controlled substance license in place for controlled substances, with required checks and reporting through the Michigan Automated Prescription System (MAPS).
- Pharmacy compliance for GLP-1 medication sourcing, dispensing, compounding, and advertising under Michigan and federal regulations.
- Advertising and marketing materials avoid unsubstantiated claims, guarantees, or representations of unlicensed individuals providing medical care.
The Legal Frame: CPOM and Who Can Be a Medical Director
Under Michigan’s corporate practice principles, non-physicians may not practice medicine or control medical judgment. In practical terms, this means:
- A physician-owned professional entity must control and deliver clinical services.
- A management services organization (MSO) may provide non-clinical support such as staffing, office space, marketing, or billing, but may not direct diagnoses, treatment decisions, or prescribing.
- Improper control of medical judgment can result in licensing discipline, civil penalties, or enforcement action by regulatory authorities.
Who Can Be a Medical Director?
Only a Michigan-licensed MD or DO in good standing may serve as medical director. Specialty training is less important than demonstrated competence and the ability to fulfill oversight, delegation, and quality assurance responsibilities. Family medicine physicians, internists, psychiatrists, and other qualified physicians may serve, provided clinical supervision and delegation are meaningful and documented.
Delegation and Prescriptive Authority: Documents That Matter
- Governed by Michigan’s Public Health Code and applicable administrative rules.
- Must clearly define scope of delegated acts, required training, and supervision parameters.
- The delegating physician remains responsible for the delegated medical acts.
- APRNs prescribe under written authorization from a delegating physician, not a collaborative practice agreement.
- Physician Assistants prescribe under a physician–PA practice agreement.
- Authorizations and agreements must be in writing and available for regulatory review.
Prescribing documents should identify:
- Categories of medications authorized (e.g., GLP-1 medications, controlled substances such as phentermine).
- Consultation and referral expectations.
- Communication availability between the physician and delegate.
- Emergency and escalation procedures.
- Quality oversight expectations, including chart review and clinical monitoring.
Authorizations and practice agreements should be reviewed periodically and updated as clinical operations evolve.
Delegation Limits
Michigan does not impose a fixed numerical cap on the number of APRNs or PAs a physician may delegate to. However, supervision must be reasonable, defensible, and sufficient to ensure patient safety and compliance with professional standards.
Weight Loss Clinics — What Michigan Requires
Who Can Prescribe Weight Loss Medications?
- MD/DO: May prescribe within scope if licensed in Michigan.
- APRN: May prescribe under written physician authorization and within scope.
- PA: May prescribe under a physician–PA practice agreement.
- RNs, estheticians, nutritionists: May not prescribe medications.
Phentermine (Controlled Substance, Schedule IV)
- Requires DEA registration and a Michigan controlled substance license.
- Prescriptions must be reported to and monitored through the Michigan Automated Prescription System (MAPS).
- Clinical rationale, follow-up, and monitoring should be documented.
- Prescribing patterns should reflect individualized evaluation, not standardized or automatic refills.
GLP-1 Medications (Semaglutide, Tirzepatide, etc.)
- Not classified as controlled substances under Michigan law.
- Pharmacy sourcing and dispensing are subject to Michigan Board of Pharmacy and FDA oversight.
- Compounded products must comply with applicable state and federal pharmacy standards.
- APRNs and PAs may prescribe if expressly authorized within their written delegation or practice agreement.
IV Therapy, Supplements, and Adjunct Services
- Infusion and adjunct protocols should be reviewed and approved by the medical director.
- Staff must demonstrate competency and maintain training documentation.
- Clinics should maintain adverse event response protocols, including emergency procedures.
Advertising Rules
- Non-physicians may not be represented as “doctors.”
- Marketing must avoid guarantees, exaggerated outcomes, or misleading weight loss claims.
- Michigan regulators may take action against deceptive or unlicensed medical advertising.
Telehealth in Michigan — Compliance Rules (2026)
Practitioner–Patient Relationship (Michigan Public Health Code)
- Must be established through a clinically appropriate evaluation, which may occur via real-time, interactive audio-visual technology or in person.
- Questionnaires alone are insufficient to establish a valid practitioner–patient relationship.
- The standard of care must be equivalent to an in-person encounter.
Michigan Telehealth Standards
- Patient identity, informed consent, assessment, diagnosis, and treatment must be documented.
- Electronic prescribing is permitted and must follow the same clinical and legal standards as in-person care.
- Medical records for telehealth encounters must be maintained securely and available for chart review and quality oversight.
Delegation in Telehealth
- Written authorizations for APRNs and physician–PA practice agreements must expressly allow telehealth prescribing if used.
- Escalation pathways should be defined for red-flag cases, including medication complications or mental health concerns.
- The supervising physician must have timely remote access to medical records for quality assurance and oversight.
Telehealth Weight Loss Prescribing
- GLP-1 medications: Permitted via telehealth when a valid practitioner–patient relationship is established and documented.
- Phentermine: Permitted under Michigan law but subject to heightened scrutiny due to controlled substance status. Prescribers must document MAPS review, clinical rationale, and follow-up.
- Best practice: Require at least one in-person or live audio-visual evaluation before initiating controlled substance prescriptions.
Psychiatry & Mental Health Clinics
Because many telehealth weight loss clinics intersect with mental health considerations, including appetite suppression, stimulant exposure, and misuse risk, the following standards apply:
- Written authorizations or practice agreements must clearly identify permitted drug classes.
- Enhanced quality assurance expectations for controlled substance prescribing.
- Emergency escalation and referral protocols must be documented and operational.
FAQs
Can a nurse practitioner run a weight loss clinic in Michigan?
Can GLP-1 medications be prescribed via telehealth?
Is phentermine prescribing allowed via telemedicine?
Do prescribing authorizations need to list specific drugs?
Psychiatry & Mental Health Clinics
Operating a Michigan weight loss or telehealth clinic without strong compliance controls carries meaningful regulatory risk, particularly where appetite suppressants, stimulants, or mental health considerations overlap. That’s where Medical Director Co. provides structured support:
- Licensed Michigan Physicians: Matched to your clinic’s specialty needs, including weight loss, telehealth, psychiatry, med spas, and general practice.
- Written Authorization & Practice Agreement Templates: Structured documents aligned with Michigan’s delegation and prescribing framework.
- Quality Assurance Systems: Chart review schedules, oversight workflows, and documentation tools to support ongoing compliance.
- Telehealth Support: Guidance on Michigan telemedicine standards, e-prescribing workflows, and HIPAA-compliant operations.
- Drug-Specific Guidance: Controlled substances versus non-controlled medications, MAPS obligations, compounding considerations, and advertising boundaries.
- MSO Alignment: Review of management arrangements to reduce corporate practice and medical control risk.
Find a Licensed Michigan Medical Director for Your Clinic Today
Who We Serve
We offer Medical Director and physician oversight services for:
- Advanced Practice Registered Nurses (APRNs): Including written authorization for prescribing, clinical oversight, and regulatory alignment under Michigan law.
- Registered Nurses (RNs): Oversight support for launching med spas, weight loss clinics, and wellness practices with physician-approved protocols.
- Physician Assistants (PAs): Practice agreement support, supervision frameworks, and compliance guidance.
- Estheticians in Medical Spas: Physician-approved protocols to support compliant advanced aesthetic services.
Michigan Resources and References
- Michigan Department of Licensing and Regulatory Affairs — Professional Licensing & Enforcement
- Michigan Public Health Code — Medical Practice & Prescribing Standards
- Michigan Board of Medicine — Physician Oversight
- Michigan Board of Nursing — APRN Delegation & Scope
- Michigan Board of Pharmacy — Dispensing, compounding, and advertising
- Michigan Automated Prescription System (MAPS) — Controlled substance monitoring
Bolton M. Harris, J.D., is a seasoned attorney with a formidable background in criminal law and a focus on healthcare law and compliance. As the in-house legal counsel at Medical Director Co., Harris brings a unique blend of prosecutorial experience and regulatory expertise to support healthcare professionals across Texas. Her career spans roles as a prosecutor in multiple counties and now as a trusted advisor on the legal intricacies of medical practice operations.
Education & Early Career
Bolton Harris completed her undergraduate studies at Southern Methodist University (SMU) in 2013. During her time at SMU, she was not only a dedicated student but also a competitive athlete on the university’s women’s swimming team. She went on to earn her Juris Doctor from Texas A&M University School of Law in 2016 and became a member of the Texas Bar that same year. Armed with a strong academic foundation and discipline honed as a student-athlete, Harris embarked on a career in criminal law immediately after law school.
Prosecutorial Experience in Texas
Bolton Harris began her legal career in public service as a criminal prosecutor. She served as an Assistant District Attorney in multiple jurisdictions, where she quickly rose through the ranks and handled a broad spectrum of cases. Some highlights of her prosecutorial career include:
- Assistant District Attorney, Dallas County, Texas: Prosecuted a high volume of criminal cases in one of the state’s busiest DA offices, gaining extensive trial experience in both misdemeanor and felony courts.
- Assistant District Attorney, Ellis County, Texas: Continued to hone her courtroom advocacy skills, known for meticulous case preparation and a tenacious pursuit of justice on behalf of the community.
- Assistant District Attorney, Navarro County, Texas: Broadened her legal expertise by handling diverse criminal matters in a smaller county, working closely with law enforcement and community leaders to uphold the law.
Through these roles, Harris built a reputation for being a tough but fair advocate. She brought numerous cases to trial and developed an in-depth understanding of the criminal justice system. This distinguished prosecutorial background laid a strong foundation for the next phase of her career in the private sector.
Healthcare Law & Compliance at Medical Director Co.
After her tenure as a prosecutor, Harris shifted her focus to healthcare law, applying her legal acumen to the medical field. She recognized that the same attention to detail and tenacity that served her in criminal law could benefit healthcare providers navigating complex regulations. Embracing this new direction, Harris became well-versed in the intricate laws governing medical practices – from licensing requirements to patient safety and privacy standards – and is passionate about helping practitioners stay compliant.
In her current role as the in-house attorney for Medical Director Co., Bolton Harris oversees all legal and compliance matters for the organization and its clients. Medical Director Co. is a nurse-owned firm that connects nurse practitioners (NPs), physician assistants (PAs), and registered nurses with qualified medical directors and collaborating physicians, offering fast placements and comprehensive compliance support for healthcare practices. Harris ensures that each of these partnerships and clinical ventures adheres to all applicable state and federal laws. She is responsible for drafting and reviewing collaborative practice agreements, advising on regulatory requirements, and providing ongoing legal counsel as clients establish and grow their clinics. Drawing on her prosecutorial eye for risk management, Harris proactively identifies potential legal issues and addresses them before they escalate, giving healthcare professionals peace of mind.
Bolton M. Harris’s multifaceted expertise – spanning high-stakes courtroom litigation to detailed healthcare compliance – makes her a formidable legal ally. Whether advocating in front of a jury or guiding a medical practice through regulatory hurdles, she remains committed to the highest standards of the legal profession. Her blend of courtroom-tested skill and healthcare law knowledge ensures that clients of Medical Director Co. receive elite-level counsel and steadfast protection in an ever-evolving legal landscape.
