Medical Director Co. main logo
Hire Medical Director
(214) 227-9886
Medical Director Co. main logo
Hire Medical Director
214.227.9886

California Weight Loss Clinic and Telehealth Compliance Guide (2025)

Medical director services Tallahassee | California Weight Loss Clinic & Telehealth Compliance Guide

Disclaimer: This material is for educational and informational purposes only. It is not legal or medical advice. Requirements change. Always verify with the Medical Board of California, California Board of Pharmacy, and the California Department of Consumer Affairs, and consult qualified counsel before acting.

Executive Summary

  • California maintains one of the most regulated frameworks for weight-loss and telehealth clinics in the nation. The Corporate Practice of Medicine (CPOM) doctrine strictly separates medical judgment from business operations, while prescribing, delegation, and telehealth activities are governed by detailed state and federal rules.
  • Clinic Structure and Oversight. All clinical services must be delivered through a physician-owned professional corporation (PC or PLLC). Non-physician entities (MSOs) may manage administrative operations—such as staffing, marketing, or billing—but may not influence or control clinical policy, provider supervision, or patient records. A California-licensed MD or DO must serve as medical director and retain full authority over medical decision-making, delegation, prescribing, and quality assurance (QA).
  • Delegation and Prescriptive Authority. Nurse Practitioners (NPs) practice under Standardized Procedures developed jointly with physicians, unless they qualify for independent practice under AB 890.
  • Physician Assistants (PAs) operate under a written Practice Agreement with physician supervision. Following SB 697, supervision requirements are flexible but must be clearly defined and documented.
  • Prescribing and Controlled Substances. Clinics must maintain DEA registration and perform CURES database checks before prescribing any Schedule II–IV medication such as phentermine, rechecking at least every four months if therapy continues.
  • GLP-1 medications (e.g., semaglutide, tirzepatide) are not controlled but face close scrutiny from pharmacies and payers. Compounded formulations must follow FDA, USP, and California Board of Pharmacy standards for 503A/503B facilities.
  • Telehealth and Documentation. Telehealth encounters must include informed patient consent and maintain the same standard of care as in-person visits. Each visit should document patient identity, consent, clinical findings, and treatment plan, using secure, HIPAA-compliant platforms and e-prescribing capability. A valid practitioner–patient relationship can be established via telehealth when care meets the required standard.
  • Advertising and Representation. California law prohibits false or misleading claims in healthcare advertising. Clinics may not use exaggerated results, unsubstantiated statements, or titles that imply physician status for non-physicians. All marketing must truthfully identify licensed providers and comply with Business & Professions Code §651.
  • Enforcement Risks. Common violations include CPOM breaches, improper delegation, unlicensed practice, false advertising, inadequate prescribing documentation, and telehealth consent failures. These can trigger Medical Board of California investigations, DEA audits, civil penalties, or license discipline.

Quick Compliance Checklist

Weight-loss / telehealth clinics should maintain and document:

Clinic Structure

Clinical services must be delivered via a physician-owned professional corporation (PC or PLLC). A separate MSO may manage nonclinical operations (staffing, billing, marketing), but it must have no authority over clinical decisions.

Medical Director

Must be a California-licensed MD or DO in good standing. The medical director is responsible for clinical policy, protocol approval, supervision, QA, escalation, and coverage documentation. Read here at the Medical Board of California.

NP / PA Framework

NPs operate under Standardized Procedures, unless they meet AB 890 criteria for limited independent practice. PAs work under a written practice agreement. Under SB 697, there is no longer a fixed statewide supervision ratio; practices must define supervision and oversight in the agreement.

Written Delegation Protocols

Written delegation protocols Agreements should specify which drug classes are allowed (e.g. GLP-1s, phentermine), escalation paths, communication methods, and QA / chart review schedules.

Controlled Substances

Maintain valid DEA registration. Prior to prescribing any Schedule II–IV drug, query CURES / PDMP. If therapy continues, re-query at defined intervals (law says every 4 months for continued therapy).

Telehealth Workflows

Use documented informed consent (verbal or written) per BPC § 2290.5; maintain the same standard of care as in-person; use electronic prescribing capability where required.

Pharmacy / Compounding

Source GLP-1s or weight-loss medications from compliant 503A/503B pharmacies. Be cautious about compounding “essentially a copy” medications. Avoid making misleading claims about compounded products.

Advertising & Claims

Comply with BPC § 651 — no deceptive or misleading claims or implications of independent practice by non-physicians. Ensure all marketing clearly reflects scope, supervision, and licensed status.

The Legal Frame: CPOM and Who Can Be a Medical Director

CPOM in California

 
California strictly enforces the Corporate Practice of Medicine (CPOM) doctrine — non-physicians and lay entities may not practice medicine, employ physicians to deliver medical care under direction, or control clinical judgment. All medical services must be delivered through a physician-owned professional corporation (PC) as required by Business & Professions Code §2400. A compliant Management Services Organization (MSO) may manage business operations (staffing, billing, marketing, space) but must expressly exclude any control over medical decisions, supervision, or access to patient records in its management agreement.
Texas Weight Loss Clinic & Telehealth Compliance Guide

Who Can Be a Medical Director?

Only a California-licensed physician (MD/DO) in good standing may serve as a medical director for a weight-loss or telehealth clinic. Specialty is flexible, but the physician must demonstrate competence in delegation, prescribing oversight, quality assurance (QA), and supervision of allied staff, consistent with California’s Medical Practice Act (BPC §2052).

Delegation & Prescriptive Authority in California

Nurse Practitioners (NPs)

By default, NPs must practice under Standardized Procedures jointly developed with physicians. These written protocols outline permitted assessments, treatments, device use, and prescribing limits within the NP’s scope and competency.

Under AB 890, qualified NPs (Categories 103 and 104) may practice without standardized procedures in defined settings after meeting experience, certification, and Board filing requirements. However, in most aesthetic and weight-loss practices, physician collaboration through standardized procedures remains the operational norm.

Physician Assistants (PAs)

All PAs must work under a written Practice Agreement with a supervising physician that defines delegated tasks, prescribing authority, and communication protocols.

Following SB 697, California no longer enforces a fixed statewide physician-to-PA ratio. Each clinic must define supervision internally within the practice agreement, ensuring it is adequate, continuous, and proportionate to the PA’s training, patient complexity, and clinic volume. Supervising physicians must remain readily available, by electronic or direct means, for consultation and chart review, consistent with Physician Assistant Board (PAB) and Medical Board of California (MBC) standards.

Prescribing in California Weight Loss Clinics —

Phentermine (Schedule IV Controlled Substance)

Phentermine remains a Schedule IV controlled substance under both state and federal law. Prescribers must hold active DEA registration and perform a CURES check before issuing any Schedule II–IV prescription, and re-query at least every four months if therapy continues. Treatment plans should include an individualized evaluation, documentation of diet and activity counseling, and scheduled follow-up visits.

GLP-1 Medications (Semaglutide, Tirzepatide, etc.)

These are not controlled substances, but remain under heightened payer and pharmacy oversight due to cost, supply, and compounding issues.

Compounded GLP-1 formulations must comply with FDA human-drug compounding policies and California Board of Pharmacy standards for 503A/503B facilities.
 Clinics should verify the pharmacy’s registration, documentation of ingredients, and avoid “essentially a copy” compounding of FDA-approved products.

NP / PA Authority:

  • Nurse Practitioners (NPs): May prescribe within their authorized scope under Standardized Procedures or independently under AB 890, if qualified.
  • Physician Assistants (PAs): May prescribe medications authorized in their written Practice Agreement.

IV Therapy and Nutritional Supplements

All IV infusions and injectable nutrients must follow physician-approved protocols specifying indications, contraindications, dosing, and monitoring. Clinics must maintain competency records, emergency supplies, and conduct periodic anaphylaxis or code drills. Also visit Medical Board of California.

Advertising Rules in California

Under Business & Professions Code §651, all advertising by physicians and allied health professionals must be truthful, not misleading, and not deceptive.

Prohibited practices include:

  • False or exaggerated claims, such as “guaranteed weight loss” or “permanent results.”
  • Misuse of professional titles, where non-physicians (e.g., RNs, NPs, PAs, or MSO owners) imply physician status or independent medical authority.
  • Unsubstantiated statements regarding FDA approval, clinical outcomes, or comparative superiority.
  • Testimonials or before/after photos that lack proper patient consent or misrepresent typical results.

Telehealth in California — Compliance Rules

Practitioner–Patient Relationship & Consent

Under Business & Professions Code §2290.5, providers must inform patients that telehealth will be used and document their verbal or written consent before care is delivered. Telehealth may establish a valid practitioner–patient relationship if it meets the same standard of care as an in-person visit.

Standards & Records

California law requires the same standard of care and recordkeeping for telehealth as in-person encounters.
Clinics must:

  • Document identity verification, consent, patient history, assessment, and treatment plan;
  • Use secure, HIPAA-compliant platforms for communication;
  • Maintain e-prescribing capability for all prescription transactions.

Also visit Medical Board of California – Telehealth Guidance and CA Board of Pharmacy – eRx FAQ for more information.

Prescribing via Telehealth

  • GLP-1 Medications (e.g., Semaglutide, Tirzepatide): May be prescribed via telehealth when clinically appropriate and when a valid provider–patient relationship exists.
  • Phentermine / Controlled Substances: May also be prescribed via telehealth if the prescriber is properly registered with the DEA and complies with all federal and state rules, including CURES database checks before and during ongoing therapy.

Enforcement Risks in California

Corporate Practice of Medicine (CPOM) Violations

Operating a clinic where non-physicians (e.g., MSOs, investors) influence or control medical decisions violates the Corporate Practice of Medicine rule.

Risk: Cease-and-desist orders, civil penalties, and referral to the Medical Board of California (MBC) for unlicensed practice.

Unlicensed Practice or Improper Delegation

Allowing estheticians, medical assistants, or unqualified staff to perform injections, prescribe, or use devices (e.g., lasers, IV therapy) violates B&P §2052.

Risk: Misdemeanor prosecution, fines, and board discipline for aiding and abetting unlicensed practice.

False or Misleading Advertising

Any deceptive claim (e.g., “guaranteed weight loss,” unverified credentials, or use of “Dr.” by non-physicians) breaches B&P §651.

Risk: MBC citation, fines, and potential license suspension or revocation.

Prescribing & Controlled Substance Violations

Failure to check CURES (H&S §11165.4) before prescribing Schedule II–IV drugs, or inadequate chart documentation, can trigger investigations for overprescribing or unsafe practice.

Risk: DEA audits, MBC discipline, or criminal liability for prescription fraud.

Telehealth Noncompliance

Missing telehealth consent (B&P §2290.5) or failing to meet the same standard of care as in-person care may constitute unprofessional conduct.

Risk: MBC enforcement action, malpractice exposure, or payer audit recoupments.

FAQs

Can a nurse practitioner run a weight-loss clinic in California?

Yes—if AB 890 requirements are met for independent practice, but CPOM still bars lay/NP control of physician practice; structure must keep clinical control with physicians.

Yes, with telehealth consent, proper evaluation, and follow-up consistent with the standard of care.

Yes—if DEA-compliant and CURES is checked as required, with robust documentation and monitoring.

Best practice: yes. Standardized Procedures/practice agreements should specify authorized categories (e.g., GLP-1s, Sched. IV anorectics) and escalation rules.

How Medical Director Co. Supports California Weight-Loss & Telehealth Clinics

California-licensed physicians with experience in weight management and telehealth compliance provide direct clinical oversight and ensure adherence to state and federal regulations.

Standardized Procedures & Practice Agreements
Turnkey NP standardized procedures and PA practice agreements are customized for weight-loss and telehealth models, fully aligned with California scope-of-practice laws and AB 890 / SB 697 requirements.

Quality Oversight & Documentation
Comprehensive QA frameworks with meeting agendas, chart-review templates, and audit-ready logs demonstrate active supervision, delegation review, and compliance with Medical Board of California standards.

Prescribing & Protocol Support
Development and review of written prescribing protocols covering GLP-1 medications, phentermine, IV therapy, and nutritional treatments—ensuring DEA registration, CURES compliance, and safe prescribing workflows.

Telehealth & Technology Compliance
Guidance on telehealth consent (B&P §2290.5), documentation, e-prescribing requirements, and record retention to maintain parity with in-person care standards.

MSO & CPOM Alignment
Review of management agreements to maintain clear separation between business operations and clinical authority under California’s Corporate Practice of Medicine rule.

Regulatory Monitoring
Continuous tracking of legislative and board updates—covering CURES, telehealth, compounding, and advertising rules—with proactive compliance guidance for medical directors and clinic managers.

Find a California-Licensed Medical Director for Your Clinic Today

Find a California Medical Director with Medical Director Co.

We place licensed medical directors and build compliance frameworks for medspas across California.
Los Angeles
San Francisco
San Diego
Sacramento
Fresno
Long Beach
Oakland
Newport Beach

Who We Serve

California Resources & References

Scroll to Top

Medical Director
Match in 24 Hours

Medical Director Match in 24 Hours

Fast, Easy, Compliant.

Trusted by 300+ med spas, IV clinics, wellness clinics, weight loss centers and speciality clinics. 

HIPAA
secure

Cancel
anytime

Same-day
intro call

All compliance documents included

HIPAA
secure

  • No setup fees
  • Cancel anytime
  • Same-day intro call
  • All compliance documents included
  • HIPAA secure

$200 Off Your First Month — Limited Time

$200 Off Your First Month

Limited Time

5/5 Rating Across 300+ Clinics

Nationwide Medical Directors • Fully Compliant • Easy Onboarding