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 Tennessee Board of Medical Examiners, the Tennessee Board of Nursing, and the Tennessee Board of Pharmacy, and seek advice from qualified legal counsel before making decisions or taking action.
Executive Summary
- Medical directors must be Tennessee-licensed physicians when overseeing medical services, delegation, and clinical decision-making.
- APRNs and PAs require written collaborative or supervisory agreements to prescribe medications. Independent practice without physician collaboration is not permitted in Tennessee.
- Collaborative Practice Agreements (CPAs) for APRNs and Supervisory Agreements for PAs must define the scope of services, prescribing authority, consultation protocols, and oversight requirements.
- Telehealth laws (TCA §63-1-155) require a valid provider-patient relationship established through mutual consent and communication, with the same standard of care as in-person visits.
- Controlled substances used in weight loss programs require DEA registration, compliance with Tennessee Board of Medical Examiners rules, and proper oversight.
- GLP-1 medications such as semaglutide or tirzepatide are not controlled substances but remain subject to pharmacy and advertising oversight.
- Tennessee follows a Corporate Practice of Medicine (CPOM) framework that prevents non-physicians from controlling clinical decision-making; compliant MSO structures may be used for business operations.
- Tennessee Board of Medical Examiners (TBME): Oversees physician licensing, delegation, supervision, and telemedicine standards.
- Tennessee Board of Nursing: Regulates APRN collaborative practice requirements and prescribing authority.
- Tennessee Code Annotated §63-1-155: Establishes telehealth rules, including consent, provider-patient relationship standards, and equivalent standards of care.
- Tennessee Board of Pharmacy: Oversees dispensing practices, advertising limitations, and controlled substance compliance.
- Corporate Practice of Medicine Doctrine: Requires physician control of clinical services, while management service organizations may handle administrative functions.
Quick Compliance Checklist
Navigating healthcare regulations can feel overwhelming, especially when launching or scaling a weight loss clinic. A qualified medical director helps ensure that clinical workflows align with Tennessee law while supporting safe patient care. Here’s how our medical director can assist you:
- Physician-owned professional entity or compliant physician-led structure for clinical services, paired with an MSO for business operations when applicable.
- The medical director must hold an active Tennessee physician license and remain available for consultation, supervision, and chart review.
- Collaborative Practice Agreement required for APRNs, outlining prescribing authority, communication protocols, and oversight expectations.
- Supervisory Agreement required for Physician Assistants, including delegated medical acts and review procedures.
- Telehealth workflows must document informed consent, verify patient identity, and establish a valid provider-patient relationship before diagnosis or prescribing.
- DEA registration and compliant prescribing practices for controlled substances such as phentermine or other scheduled medications.
- Pharmacy compliance and transparent advertising practices for GLP-1 therapies, compounded medications, and obesity management programs.
- Marketing language should avoid misleading claims, unrealistic outcomes, or suggestions that non-licensed personnel provide medical care.
The Legal Frame: CPOM and Who Can Be a Medical Director
Tennessee follows a Corporate Practice of Medicine (CPOM) framework that limits who can own or control medical services.
- Clinical decision-making must remain under physician authority, which shapes how weight loss clinics and telehealth programs structure their operations.
- A physician-owned professional entity (PC or PLLC) typically employs or contracts clinicians providing medical services. State law restricts ownership of medical professional corporations to licensed physicians or permitted professional combinations to preserve independent medical judgment.
- Management Services Organizations (MSOs) may provide administrative support such as marketing, staffing, billing, or leasing space, but they cannot direct diagnoses, treatment plans, or prescribing decisions.
- Failure to maintain proper separation between business operations and clinical authority can trigger disciplinary action from the Tennessee Board of Medical Examiners or other licensing boards.
Who Can Be a Medical Director?
A medical director overseeing clinical care should hold an active Tennessee physician license and remain responsible for supervision, delegation, and quality assurance.
Specialty certification is less important than competence within the clinic’s scope and the physician’s willingness to meet oversight duties. Physicians collaborating with APRNs or supervising PAs must maintain accessible communication and structured chart review processes.
Delegation & Prescriptive Authority: Documents That Matter
Delegation of Medical Acts (Procedures, Labs, IV Therapy)
- Delegated services must be defined through written agreements that outline scope, training requirements, and supervision standards.
- Physicians remain responsible for clinical oversight and must ensure delegated providers operate within Tennessee’s scope-of-practice laws.
Collaborative Practice Agreements (APRNs)
APRNs in Tennessee cannot practice independently and must maintain a written Collaborative Practice Agreement with a physician. These agreements outline prescribing authority, consultation protocols, and supervision expectations.
Typical CPA elements include:
- Authorized medication categories or treatment protocols
- Communication and availability expectations between providers
- Referral or escalation pathways
- Documentation and chart review procedures
Delegation Limits
- Tennessee regulations focus more on supervision structure and documentation than on fixed numerical caps.
- Physicians must maintain adequate availability and oversight to ensure patient safety and compliance with board expectations.
Weight Loss Clinics — What Tennessee Requires
Who Can Prescribe Weight Loss Medications?
- MD/DO: May prescribe within scope of licensure.
- APRNs and PAs: May prescribe only under active collaborative or supervisory agreements that authorize the medication category.
- RNs, estheticians, and wellness staff: Cannot prescribe medications.
Phentermine and Other Controlled Substances
Controlled weight loss medications require:
- DEA registration
- Compliance with Tennessee prescribing standards
- Proper documentation of medical necessity and follow-up care
Clinics should maintain individualized treatment plans and avoid standardized prescribing patterns that could raise regulatory concerns.
GLP-1 Medications (Semaglutide, Tirzepatide, etc.)
- GLP-1 therapies are not scheduled controlled substances, but clinics must still follow pharmacy rules, advertising standards, and collaborative prescribing requirements.
- If compounded medications are used, providers should verify compliance with pharmacy regulations and ensure prescriptions remain medically appropriate.
IV Therapy, Supplements, and Adjunct Treatments
- Infusion therapies and adjunct wellness services should be approved through physician-signed protocols.
- Staff must complete competency training and maintain emergency response procedures, including adverse event management and escalation pathways.
Advertising Rules
- Marketing materials must clearly represent provider credentials and avoid implying that non-physicians deliver physician-level care.
- Claims related to weight loss outcomes should remain evidence-based and avoid exaggerated or misleading promises.
Telehealth in Tennessee — Compliance Rules
Practitioner–Patient Relationship (TCA §63-1-155)
- Telehealth services must establish a legitimate provider-patient relationship through mutual consent and appropriate communication. The standard of care delivered remotely must match in-person care expectations.
- Questionnaires alone are generally insufficient to establish a clinical relationship for diagnosis or prescribing.
Telehealth Documentation Standards
Providers should document:
- Patient identity verification
- Consent for telehealth services
- Diagnosis and treatment decisions
- Secure recordkeeping for quality assurance
Supervising physicians must maintain access to telehealth records for oversight and chart review.
Delegation in Telehealth
- Collaborative and supervisory agreements should clearly address telemedicine prescribing authority. Clinics should define escalation procedures for high-risk situations, medication complications, or mental health concerns.
- Remote supervision is allowed when physicians remain available for real-time consultation and review of clinical records.
Telehealth Weight Loss Prescribing
- GLP-1 medications may be prescribed via telehealth when a valid provider-patient relationship exists and documentation standards are met.
- Controlled substances require heightened monitoring, careful documentation, and adherence to DEA and Tennessee prescribing requirements.
- Best practice includes at least one live video evaluation before initiating higher-risk medication protocols.
Psychiatry & Mental Health Clinics
Weight loss programs often overlap with behavioral health concerns, particularly when appetite suppressants or stimulant-related risks are involved. Tennessee supervision rules still apply:
- Collaborative agreements must define authorized drug classes.
- Quality assurance measures should include chart review and ongoing communication.
- Emergency escalation pathways should be documented within clinical protocols.
FAQs
Can a nurse practitioner run a weight loss clinic in Tennessee?
Can GLP-1 medications be prescribed via telehealth?
Is phentermine prescribing allowed via telemedicine?
Do collaborative or supervisory agreements need to list specific drugs?
Psychiatry & Mental Health Clinics
Running a Tennessee weight loss or telehealth clinic requires careful attention to supervision rules, prescribing standards, and telehealth documentation. Medical Director Co. supports clinics with structured compliance solutions designed around Tennessee regulations:
- Licensed Tennessee Physicians: Matched to your clinic’s specialty, including med spas, obesity medicine, telehealth services, psychiatry, and general practice.
- Collaborative & Supervisory Agreement Templates: Structured documents outlining communication protocols, escalation procedures, and oversight expectations consistent with Tennessee board requirements.
- Quality Assurance Systems: Chart review schedules, documentation workflows, and compliance tracking tools that support physician oversight and collaborative practice.
- Telehealth Support: Guidance on TCA §63-1-155 workflows, remote supervision expectations, e-prescribing considerations, and secure documentation practices.
- Medication-Specific Guidance: Support navigating controlled versus non-controlled prescribing, compounding considerations, and responsible marketing practices.
- MSO Alignment: Review of business and management agreements to help maintain CPOM-compliant clinical structures.
Areas We Serve
We provide licensed medical directors and compliance support for clinics throughout Tennessee, including major metro areas:
Who We Serve
We offer Medical Director and Collaborating Physician services for a wide range of licensed professionals:
- Nurse Practitioners (APRNs) – Collaborative agreements, prescribing oversight, and physician collaboration support designed to align with Tennessee regulations.
- Registered Nurses (RNs) – Physician oversight structures for med spas, wellness clinics, and weight loss programs operating within approved clinical protocols.
- Physician Assistants (PAs) – Supervisory agreements, delegated medical act review, and ongoing compliance support.
- Estheticians in Medical Spas – Physician-approved treatment protocols that support safe advanced aesthetic services within scope-of-practice boundaries.
Tennessee Resources and References
- Tennessee Board of Medical Examiners — Physician Licensure & Rules
- Tennessee Code Annotated §63-1-155 — Telehealth Law
- Tennessee Board of Nursing — APRN Collaborative Practice Requirements
- Tennessee Board of Pharmacy — Dispensing, Compounding, and Advertising Standards
- Tennessee Controlled Substance Monitoring Database — Prescription Monitoring Requirements
