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 Pennsylvania State Board of Medicine, State Board of Osteopathic Medicine, Pennsylvania Department of Health, and the Pennsylvania Department of State (BPOA). Seek advice from qualified legal counsel before making decisions or taking action.
Executive Summary
- Pennsylvania requires physician-led clinical control for weight-loss and telehealth clinics; MSOs may manage business operations but cannot influence diagnosis, treatment, prescribing, or medical records.
- Medical directors must be Pennsylvania-licensed MDs or DOs who exercise real, documented oversight rather than holding a nominal title.
- CRNPs and PAs may prescribe weight-loss medications only under written agreements, with CRNP collaborative agreements filed in PALS and PA supervisory agreements maintained and available to regulators.
- Telehealth prescribing is permitted, but encounters must meet the same standard of care as in-person visits, including adequate evaluation, documentation, and follow-up.
- Controlled substances (e.g., phentermine) require DEA registration, mandatory PDMP checks, documented medical necessity, and heightened monitoring.
- GLP-1 medications are not controlled substances but require clear authorization in agreements, lawful sourcing, and increased scrutiny for compounded products.
- Clinics must maintain documented quality assurance, including chart reviews, QA meetings, incident tracking, and physician access to records.
- Advertising and marketing must avoid misleading claims, improper use of titles, or implications of unlicensed or unsupervised practice.
- Common enforcement risks include outdated agreements, inadequate telehealth documentation, improper compounding, MSO overreach, and missing PDMP records.
Quick Compliance Checklist (Pennsylvania — Weight Loss & Telehealth)
- Structure & Ownership
- Physician-led clinical entity retains control over diagnosis, treatment, and prescribing; any MSO is limited to nonclinical functions.
(Medical Practice Act of 1985, 63 P.S. § 422.41; Unprofessional Conduct, 49 Pa. Code § 16.61)
- Physician-led clinical entity retains control over diagnosis, treatment, and prescribing; any MSO is limited to nonclinical functions.
- Medical Director Credentials
- Medical director is a Pennsylvania-licensed MD or DO in good standing.
(63 P.S. § 422.41; PALS verification)
- Medical director is a Pennsylvania-licensed MD or DO in good standing.
- CRNP / PA Prescriptive Authority
- CRNPs: Written collaborative agreement filed in PALS before practice/prescribing.
(49 Pa. Code §§ 21.285–21.287) - PAs: Written supervising physician agreement describing scope, supervision, and prescribing; available to the Board on request.
(49 Pa. Code §§ 18.141–18.148)
- CRNPs: Written collaborative agreement filed in PALS before practice/prescribing.
- Agreement Content (Weight Loss)
- Agreements define authorized drug classes (e.g., GLP-1s; Schedule IV agents such as phentermine), communication/consultation criteria, and QA/chart-review expectations.
(49 Pa. Code §§ 21.285–21.287; §§ 18.141–18.148)
- Agreements define authorized drug classes (e.g., GLP-1s; Schedule IV agents such as phentermine), communication/consultation criteria, and QA/chart-review expectations.
- Quality Assurance (QA)
- Documented chart reviews and QA meetings at the cadence stated in agreements/policies (monthly or quarterly as adopted).
(49 Pa. Code § 16.61)
- Documented chart reviews and QA meetings at the cadence stated in agreements/policies (monthly or quarterly as adopted).
- Telehealth Standards
- Telehealth visits meet the standard of care, establish a valid practitioner–patient relationship, include an adequate clinical evaluation, and maintain in-person-equivalent documentation.
(Board guidance; 49 Pa. Code § 16.61)
- Telehealth visits meet the standard of care, establish a valid practitioner–patient relationship, include an adequate clinical evaluation, and maintain in-person-equivalent documentation.
- Controlled Substances (e.g., Phentermine)
- Active DEA registration; PDMP query prior to prescribing; documentation of medical necessity and follow-up.
(Controlled Substance, Drug, Device and Cosmetic Act, 35 P.S. § 780-101 et seq.; PDMP requirements)
- Active DEA registration; PDMP query prior to prescribing; documentation of medical necessity and follow-up.
- GLP-1 Sourcing & Compounding
- Medication sourcing/compounding complies with FDA, USP, and Pennsylvania Board of Pharmacy requirements; advertising is accurate and non-misleading.
(Federal FDA/USP standards; PA pharmacy oversight)
- Medication sourcing/compounding complies with FDA, USP, and Pennsylvania Board of Pharmacy requirements; advertising is accurate and non-misleading.
- Advertising & Titles
- Marketing avoids misleading claims and improper use of titles; complies with Pennsylvania Unfair Trade Practices and Consumer Protection Law.
(73 P.S. § 201-1 et seq.)
- Marketing avoids misleading claims and improper use of titles; complies with Pennsylvania Unfair Trade Practices and Consumer Protection Law.
The Legal Frame: CPOM and Medical Director Role
Corporate Practice of Medicine in Pennsylvania
Pennsylvania does not have a single Corporate Practice of Medicine statute. Instead, CPOM principles are enforced through unlawful practice provisions, physician unprofessional conduct rules, and licensing and supervision requirements. Arrangements allowing nonphysicians to influence diagnosis, treatment, prescribing, or medical records may trigger Board discipline or consumer protection enforcement.
Who Can Be a Medical Director?
A medical director for a Pennsylvania weight-loss or telehealth clinic must be a Pennsylvania-licensed MD or DO. No specialty is required, but the physician must be competent to supervise obesity treatment, medication prescribing, telehealth care, and delegated clinicians, and must exercise real, documented clinical oversight rather than holding a nominal title.
Delegation and Prescriptive Authority: Documents That Matter
Physicians may delegate certain medical tasks to RNs and LPNs within the scope of nursing practice and pursuant to physician or CRNP orders. Tasks requiring independent medical judgment may not be delegated. Delegation must be supported by written protocols, training, and supervision.
(Professional Nursing Law, 63 P.S. § 211; 49 Pa. Code § 21.14; Medical Practice Act of 1985, 63 P.S. § 422.41)
Each CRNP prescribing weight-loss medications must have a written collaborative agreement, filed in PALS, that defines:
- Scope of practice
- Diagnostic and prescriptive authority
- Controlled substance authority (Schedule II limitations apply)
- Consultation and referral requirements
- Chart-review and quality-assurance processes
- Emergency protocols
- Authorized practice locations, including telehealth
PA Supervisory Agreements
Supervising physicians must maintain written agreements with PAs specifying:
- Delegated medical procedures
- Prescriptive authority
- Chart-review frequency
- Supervision method (including telehealth or remote supervision, if used)
- Physician availability requirements
Agreements must be maintained and produced to the Board upon request.
Controlled Substances (Phentermine – Schedule IV)
Prescribing phentermine requires:
- Active DEA registration
- Mandatory PDMP query prior to prescribing or dispensing
- Documented medical necessity and individualized treatment planning
- Ongoing monitoring and follow-up
(Controlled Substance, Drug, Device and Cosmetic Act, 35 P.S. § 780-101 et seq.; Pennsylvania PDMP)
GLP-1 Medications (Semaglutide, Tirzepatide)
GLP-1 medications are not controlled substances. CRNPs and PAs may prescribe them only if authorized under their collaborative or supervisory agreement. Compounded GLP-1 products are subject to heightened regulatory scrutiny.
(FDA Drug Compounding Guidance; Pennsylvania State Board of Pharmacy)
Weight Loss Clinics — What Pennsylvania Requires
Who May Prescribe Weight-Loss Medications
- MD/DO: May prescribe independently if licensed in Pennsylvania.
- CRNP: Must practice and prescribe pursuant to a written collaborative agreement filed in PALS.
- PA: Must prescribe pursuant to a written supervising physician agreement.
- RNs, LPNs, nutritionists, health coaches: May not prescribe medications.
(Medical Practice Act of 1985, 63 P.S. § 422.41; 49 Pa. Code §§ 21.285–21.287; 49 Pa. Code §§ 18.141–18.148)
Phentermine (Schedule IV Controlled Substance)
Prescribing phentermine requires DEA registration and compliance with Pennsylvania’s PDMP requirements, including PDMP review prior to prescribing, documentation of medical necessity, and ongoing monitoring. Clinical records should support BMI, comorbidities, prior lifestyle interventions, and follow-up planning. Telehealth prescribing is permitted when the standard of care is met and evaluation is clinically adequate.
(Controlled Substance, Drug, Device and Cosmetic Act, 35 P.S. § 780-101 et seq.; Pennsylvania PDMP)
GLP-1 Medications (Semaglutide, Tirzepatide)
GLP-1 medications are not controlled substances. CRNPs and PAs may prescribe only if authorized by their collaborative or supervisory agreement. Clinics must ensure lawful sourcing and heightened oversight of compounded products and should document informed consent addressing known risks, availability issues, and treatment expectations.
(Pennsylvania State Board of Pharmacy; FDA Drug Compounding Guidance)
IV Therapy, Supplements, and Adjuncts
IV therapy and prescription adjuncts require physician-approved protocols, written nursing procedures, documented competency for IV access and monitoring, and emergency preparedness (e.g., anaphylaxis response). Delegation must remain within nursing scope and supported by supervision and training records.
(Professional Nursing Law, 63 P.S. § 211; 49 Pa. Code § 21.14; 49 Pa. Code § 16.61)
Advertising Rules
- Advertisements must not imply that nonphysicians are doctors, independent prescribers, or providing medical care without physician involvement.
- Weight-loss claims must be truthful, substantiated, and not misleading; guarantees or unrealistic results (e.g., “guaranteed weight loss”) create enforcement risk.
- Marketing materials are subject to enforcement by the Pennsylvania Attorney General and professional licensing boards. (Unfair Trade Practices and Consumer Protection Law.)
Telehealth in Pennsylvania — Compliance Rules (2026)
Practitioner–Patient Relationship
- Must be established through a clinically appropriate interaction that meets the same standard of care as an in-person visit.
- Questionnaires alone are insufficient to establish a practitioner–patient relationship.
- Synchronous audio-video is strongly preferred when prescribing medications or making clinical diagnoses; audio-only may be inadequate depending on clinical context.
(Medical Practice Act of 1985, 63 P.S. § 422.41; 49 Pa. Code § 16.61)
Telehealth Documentation Requirements
- Verification of patient identity
- Informed consent for telemedicine
- History, clinical evaluation, diagnosis, and treatment plan
- Medication reconciliation and contraindication review
- Follow-up and monitoring plan
- Records accessible to supervising physicians for QA and chart review
(49 Pa. Code § 16.61; Frequently Asked Questions About Telemedicine in Pennsylvania)
Delegation in Telehealth
- CRNP collaborative agreements and PA supervising agreements must explicitly authorize telemedicine practice and prescribing.
- Supervising physicians must have timely access to medical records for chart review and oversight.
- Written escalation and emergency referral protocols are required for red-flag symptoms or adverse events.
(49 Pa. Code §§ 21.285–21.287; 49 Pa. Code §§ 18.141–18.148)
Telehealth Weight-Loss Prescribing
- GLP-1 medications: Permitted via telehealth when a valid practitioner–patient relationship exists and standard of care is met.
- Phentermine (Schedule IV): Permitted but requires:
- Mandatory PDMP query before prescribing
- Documented medical necessity and individualized treatment plan
- Heightened follow-up and monitoring
- Synchronous video evaluation strongly recommended prior to initiation
Best Practice:
- At least one real-time audio-video evaluation before initiating controlled substances.
(Controlled Substance, Drug, Device and Cosmetic Act, 35 P.S. § 780-101 et seq.; Pennsylvania PDMP Act (Act 191 of 2014))
Common Compliance Risks in Pennsylvania (2026)
- Missing, outdated, or unfiled CRNP Collaborative Agreements in PALS before practice or prescribing begins.
- Supervising physicians failing to meet documented chart-review and QA obligations described in CRNP or PA agreements.
- Telehealth encounters that lack adequate clinical evaluation, video examination when clinically required, or complete documentation.
- Improper GLP-1 sourcing or compounding, including use of unverified pharmacies or non-compliant compounded products.
- Marketing language that may be interpreted as misleading, deceptive, or unlicensed practice of medicine.
- MSO arrangements that influence diagnosis, treatment decisions, prescribing, or access to medical records, creating CPOM risk.
- Failure to document PDMP queries, DEA registration, or controlled-substance safeguards for medications such as phentermine.
FAQs
Can a nurse practitioner run a weight loss clinic in Pennsylvania?
Yes. A CRNP may own a business entity and provide clinical services within scope, but prescribing requires a filed Collaborative Agreement with a physician, and clinical practice must comply with Board supervision and QA requirements.
Can GLP-1 medications be prescribed via telehealth in Pennsylvania?
Yes, provided the encounter meets the standard of care, establishes a valid practitioner–patient relationship, and satisfies Pennsylvania Board telemedicine documentation expectations.
Is phentermine prescribing allowed via telemedicine?
Yes, but it requires DEA registration, PDMP checks, documented medical necessity, heightened follow-up, and a clinically appropriate evaluation (video strongly recommended).
Do CRNP/PA agreements need to list specific drugs?
No. Agreements must describe authorized categories or classes of drugs (e.g., controlled substances, GLP-1s) and the conditions under which prescribing is permitted.
Can RNs or health coaches prescribe or adjust medications?
No. Prescribing authority is limited to MDs, DOs, CRNPs (with a collaborative agreement), and PAs (under supervision).
How Medical Director Co. Supports Pennsylvania Medspa Compliance (2026)
Medical Director Co. helps Pennsylvania medspas implement real, defensible medical oversight, not just nominal physician arrangements. Our services are structured to align with Pennsylvania State Board of Medicine and Board of Nursing enforcement standards and include:
- Pennsylvania-licensed MDs and DOs experienced in medspa and aesthetic services, including injectables, lasers/IPL, energy-based devices, microneedling, and IV therapy.
- CRNP collaborative agreements and PA supervising agreements drafted and reviewed to comply with Pennsylvania scope-of-practice rules, prescriptive authority requirements, quality-assurance obligations, and PALS filing standards.
- Sustainable quality-assurance systems, including chart-review cadence guidance, QA meeting templates, incident tracking, and audit-ready documentation expected by Pennsylvania regulators.
- Delegation and clinical protocol development for aesthetic and device-based procedures, with physician oversight, competency validation, and adverse-event preparedness.
- MSO and governance alignment, ensuring business structures do not create unlicensed-practice risk or improper control over medical decision-making.
- Telemedicine compliance guidance for medspa-related services, addressing practitioner–patient relationship standards, documentation requirements, and controlled-substance safeguards where applicable.
- Ongoing regulatory monitoring, tracking Pennsylvania Board guidance, enforcement trends, and statutory updates so agreements, protocols, and policies remain current.
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.
Find a Licensed Pennsylvania Medical Director for Your Clinic Today
Medical Director Co. connects you with experienced, Pennsylvania-licensed physicians who provide real clinical oversight—not just a name on paper.
Areas we serve:
Pennsylvania Resources and References
Pennsylvania Statues: https://codes.findlaw.com/pa/title-63-ps-professions-and-occupations-state-licensed/pa-st-sect-63-422-41/
Pennsylvania Code and Bulletin: https://www.pacodeandbulletin.gov
Pennsylvania Licensing System (PALS): https://www.pals.pa.gov
Pennsylvania Prescription Drug Monitoring Program (PDMP): https://www.pa.gov/agencies/health/healthcare-and-public-health-professionals/pdmp
Pennsylvania PDMP Act (Act 191 of 2014): https://palrb.gov/getfile.cfm?file=resources/preservation-project/pltiftopdf/20002099/2014/0/act/0191.pdf&view=true
DEA Diversion Control Division (Controlled Substances): https://www.deadiversion.usdoj.gov
Pennsylvania Unfair Trade Practices & Consumer Protection Law: https://www.attorneygeneral.gov/wp-content/uploads/2018/02/Unfair_Trade_Practices_Consumer_Protection_Law.pdf
Pennsylvania Department of Health (DOH): https://www.health.pa.gov
