Disclaimer: This content is provided for general educational and informational purposes only and does not constitute legal advice, medical advice, or official regulatory guidance. Washington laws, commission policies, and enforcement practices may change. Providers and clinics should verify current requirements directly with the Washington State Department of Health, the Washington Medical Commission, the Nursing Care Quality Assurance Commission, and the Pharmacy Quality Assurance Commission, and consult qualified healthcare legal counsel before making operational or compliance decisions.
Executive Summary
- Medical Directors in Washington must be licensed MDs or DOs in active, good standing status. Advanced registered nurse practitioners practice independently within their licensed scope under Washington law, and physician assistants must practice and prescribe pursuant to written practice agreements consistent with RCW 18.71A and related Department of Health rules.
- PA practice agreements and internal clinical governance documents should clearly outline prescriptive authority, communication expectations, consultation and referral pathways, escalation procedures, and structured quality monitoring activities such as chart review and periodic oversight meetings.
- Washington telehealth standards require the establishment of a valid provider–patient relationship through appropriate clinical evaluation, complete and accurate documentation, and adherence to a standard of care equivalent to in-person services under applicable state statutes and Department of Health guidance.
- Controlled substances, including phentermine, require an active DEA registration, compliance with Washington controlled substance laws, and a documented review of the Washington Prescription Monitoring Program before prescribing. Enhanced documentation, individualized assessment, and defined follow-up protocols are expected when managing medications with misuse risk.
- GLP-1 medications such as semaglutide and tirzepatide are not federally scheduled substances, but their prescribing remains subject to Washington standards of care, Pharmacy Quality Assurance Commission oversight, compounding regulations when applicable, and evolving federal and state guidance.
- Clinical decision-making must remain under licensed provider authority consistent with Washington Corporate Practice of Medicine principles. While nonphysician entities may furnish administrative or management services, they may not control diagnosis, treatment planning, prescribing decisions, or required supervision of licensed staff.
- Washington Medical Commission: Regulates physician licensure, professional conduct, delegation, supervision of PAs, and enforcement under RCW 18.71 and the Uniform Disciplinary Act.
- Nursing Care Quality Assurance Commission: Oversees ARNP licensure, independent practice authority, and prescribing within scope under RCW 18.79.
- Washington Pharmacy Quality Assurance Commission: Regulates dispensing, compounding, pharmacy operations, and medication-related compliance, including controlled substances and GLP-1 therapies.
- Corporate Practice of Medicine principles: Limit nonlicensed control over clinical judgment and safeguard licensed provider authority over patient care decisions.
Quick Compliance Checklist
Weight loss and telehealth clinics in Washington must align provider oversight, prescribing authority, and marketing practices with Department of Health regulations and state law. Use this as a recurring internal compliance review:
- Clinical services are organized to preserve licensed provider authority over diagnosis, treatment planning, prescribing, and supervision, consistent with Washington Corporate Practice of Medicine principles. Administrative functions remain separate from clinical control.
- The medical director maintains an active, unrestricted Washington MD or DO license and participates in documented oversight and quality monitoring activities.
- ARNP independent practice status is confirmed where applicable. If a PA is prescribing, a current written practice agreement is in place in accordance with RCW 18.71A and related Washington rules.
- Routine chart audits and quality assurance reviews are conducted on a defined schedule and supported by written documentation.
- Telehealth encounters comply with Washington telemedicine requirements, including proper establishment of a provider-patient relationship, appropriate documentation, and secure electronic health record maintenance.
- Prescribers maintain active DEA registration when ordering controlled substances and comply with the Washington Prescription Monitoring Program and electronic prescribing requirements.
- GLP-1 sourcing and any compounding arrangements comply with Washington Pharmacy Quality Assurance Commission rules and applicable federal regulations.
- Advertising and website content avoid misleading statements, guarantees of results, or language suggesting that unlicensed individuals perform medical evaluations or issue prescriptions.
The Legal Frame: CPOM and Who Can Be a Medical Director
Under Washington law, Corporate Practice of Medicine principles limits the ability of nonphysicians and business entities to control the delivery of medical care. In practical application, this means:
- A Washington-licensed physician must maintain decision-making authority over core clinical functions, including patient assessment, diagnosis, treatment planning, prescribing, and required supervision of licensed staff.
- A separate management services or administrative company may handle operational support, such as staffing logistics, office space, marketing strategy, and billing administration. However, it cannot dictate clinical protocols, influence prescribing decisions, or interfere with provider judgment.
- When financial or operational arrangements cross into clinical control, the Washington Medical Commission may view the structure as noncompliant and subject to investigation or disciplinary action.
The designation of “medical director” alone does not establish compliance. What regulators evaluate is whether the physician meaningfully directs clinical policy, delegation structures, and quality monitoring processes in actual day-to-day operations.
Who Can Be a Medical Director?
A medical director for a Washington weight loss clinic or telehealth program is typically a Washington-licensed MD or DO in active, good standing status. Although a specific specialty is not required, the physician must have sufficient knowledge of the services offered and must participate in active supervision and quality monitoring.
Physicians trained in family medicine, internal medicine, psychiatry, or other related disciplines may serve in this role, provided that delegation structures, PA practice agreements where applicable, prescribing oversight, and quality assurance responsibilities are clearly documented and consistently carried out.
Delegation and Prescriptive Authority: Documents That Matter
Delegation of Medical Acts
In Washington, physicians may assign certain medical functions, including procedures, diagnostic services, IV therapy, and telehealth-related treatment, to licensed clinicians when those duties fall within the individual’s scope of practice and documented training. The delegating provider must ensure the clinician is appropriately educated, credentialed, and competent to perform the service.
Written policies should define which services may be delegated, outline supervision expectations for PAs, clarify provider availability for consultation, and establish documentation requirements consistent with RCW 18.71, RCW 18.71A, RCW 18.79, and applicable Department of Health regulations.
Collaboration and Supervisory Agreements
Prescribing by physician assistants in Washington must be supported by a written practice agreement with a supervising physician that accurately reflects how care is delivered. Advanced registered nurse practitioners may prescribe independently within their licensed scope, but clinics should maintain internal policies that clearly define prescribing standards and oversight expectations.
Practice agreements and related policies typically address:
- Scope of authorized services and prescriptive authority, including weight management medications such as GLP-1 agents or phentermine
- Consultation and referral procedures
- Supervising physician availability and communication pathways
- Emergency coverage protocols
- Quality monitoring processes, such as structured chart or case review
Agreements and policies should be reviewed regularly and revised when staffing models or service offerings change.
Delegation Limits
Weight Loss Clinics — What Washington Requires
Who Can Prescribe Weight Loss Medications?
- MD or DO: May prescribe within the scope of an active Washington license and in accordance with the applicable standard of care.
- ARNP: May prescribe independently within the scope of Washington licensure, including weight management medications, consistent with state and federal requirements.
- PA: May prescribe pursuant to a written practice agreement with a supervising physician that defines prescriptive authority and oversight responsibilities.
- RNs, estheticians, and nutritionists: May not prescribe medications.
Phentermine and Other Controlled Substances
- Requires an active DEA registration.
- Prescribers must check the Washington Prescription Monitoring Program before issuing Schedule II–V prescriptions, consistent with Washington controlled substance laws and Department of Health requirements.
- Clinical documentation should support medical necessity, clearly describe the treatment rationale, and outline a defined follow-up plan.
- Prescribing decisions should reflect individualized clinical assessment rather than reliance on uniform or template-based protocols.
GLP-1 Medications and Similar Agents
- These medications are not federally scheduled controlled substances, but prescribing must meet Washington standards of care and include an appropriate clinical evaluation and documentation.
- If compounded formulations are used, sourcing must comply with federal law and Washington Pharmacy Quality Assurance Commission requirements, along with applicable Department of Health regulations.
- ARNPs may prescribe within their independent scope of practice, and PAs may prescribe pursuant to a written practice agreement, provided the medication falls within their authorized scope under Washington law.
IV Therapy, Supplements, and Adjunct Services
- All infusion and adjunct treatment protocols should be reviewed and approved by the responsible Washington-licensed provider, including the supervising physician for PAs where applicable.
- Individuals administering these services must have documented training, validated competency, and clearly established emergency response procedures, including written protocols for managing adverse reactions and complications.
Advertising Standards
- Promotional content must accurately reflect provider licensure, professional credentials, and the applicable supervision or practice agreement structure under Washington law.
- Avoid exaggerated, guaranteed, or unsupported claims regarding clinical results or weight loss outcomes.
- Marketing materials must not imply that unlicensed personnel are providing medical care or exercising independent medical authority.
Telehealth in Washington — Compliance Standards
Practitioner–Patient Relationship
- A valid provider–patient relationship must be established through an appropriate clinical assessment conducted either in person or through real-time audiovisual technology, consistent with Washington telemedicine laws and Department of Health regulations.
- Online intake forms or questionnaires alone are not sufficient to support diagnosis or prescribing.
- The applicable standard of care for telehealth services must be equivalent to that required for in-person treatment under Washington law.
Washington Telehealth Expectations
- Document patient identity, informed consent, clinical assessment findings, and the resulting treatment plan in accordance with Washington documentation standards.
- Electronic prescribing is permitted when compliant with Washington and federal law, including applicable controlled substance and Prescription Monitoring Program requirements.
- Medical records must be securely stored and readily accessible for supervising physician review where required, quality monitoring, and potential regulatory inquiry.
Delegation in Telehealth
- Written PA practice agreements and internal prescribing policies should specifically address telehealth services and remote prescribing authority under Washington law. Although ARNPs practice independently, clinics should define clear consultation and oversight pathways for virtual care.
- Escalation procedures must be established for urgent or high-risk situations, including psychiatric emergencies or medication-related adverse events.
- Supervising physicians for PAs must maintain reliable remote access to patient records to support chart review, quality monitoring, and compliance oversight.
Telehealth Weight Loss Prescribing
- GLP-1 medications may be prescribed via telehealth once an appropriate provider–patient relationship has been properly established and the medical record supports clinical necessity under Washington standards of care.
- Controlled substances, including phentermine, require an active DEA registration and a documented review of the Washington Prescription Monitoring Program before the prescription is issued.
- As a best practice, clinics should conduct at least one in-person or live audiovisual evaluation before starting controlled medications for weight management, along with clearly documented monitoring and follow-up protocols.
Psychiatry & Mental Health Clinics
Many telehealth weight loss programs overlap with psychiatric prescribing, including appetite suppressants or medications that carry potential misuse risk. In these environments, heightened compliance controls are appropriate:
- PA practice agreements and internal prescribing policies should clearly define authorized medication categories and scope of authority.
- Quality monitoring processes should include enhanced review of controlled substance prescribing patterns.
- Crisis management and emergency response protocols must be clearly outlined and documented within clinic policies.
FAQs
Can a nurse practitioner run a weight loss clinic in Washington?
Can GLP-1 medications be prescribed via telehealth?
Is prescribing phentermine allowed via telemedicine?
Do practice agreements need to list specific drugs?
How Medical Director Co. Supports Washington Weight Loss & Telehealth Clinics
Operating a compliant weight loss or telehealth clinic in Washington requires more than appointing a physician. Medical Director Co. provides structured oversight and compliance support designed for outpatient practices throughout the state:
- Washington Licensed Physicians: Matched to your clinic’s service lines, including weight management, telehealth, psychiatry, and general outpatient care, with familiarity in Washington regulatory expectations.
- Practice Agreement & Supervision Support: Written PA practice agreements and clinical oversight frameworks aligned with Washington law, defining prescriptive authority, communication pathways, escalation protocols, and quality monitoring responsibilities.
- Quality Oversight Systems: Practical chart review schedules, structured meeting templates, and documentation tracking tools built to withstand review by the Washington Medical Commission or Department of Health.
- Telehealth Compliance Guidance: Support for establishing valid provider–patient relationships, structuring remote prescribing workflows, meeting documentation standards, and ensuring appropriate medical record access for oversight.
- Medication Compliance Insight: Operational guidance for controlled substances such as phentermine and non-controlled medications such as GLP-1 agents, including Washington Prescription Monitoring Program requirements and pharmacy regulatory considerations.
- Practice Structure Review: Assessment of ownership and management arrangements to help ensure compliance with Washington Corporate Practice of Medicine principles and preservation of licensed provider authority over clinical care.
Areas We Serve
We provide licensed medical directors and compliance support for clinics across Washington, including major metro areas:
Who We Serve
Our Medical Director and Supervising Physician services are designed for:
- Advanced Registered Nurse Practitioners (ARNPs): Support with independent practice compliance under Washington law, structured prescribing frameworks, and regulatory alignment to ensure clinic operations remain within scope and properly documented.
- Registered Nurses (RNs): Physician-led oversight for launching and operating medspas, weight management clinics, and wellness practices, including defined delegation protocols and scope-of-practice safeguards under Washington standards.
- Physician Assistants (PAs): Written practice agreements, prescriptive authority alignment, and supervision structures consistent with RCW 18.71A and Washington professional practice requirements.
- Estheticians in Medical Spas: Development of provider-approved treatment protocols and oversight systems that support compliant delivery of aesthetic services within Washington licensure boundaries.
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.
