Telehealth General Psychiatry Prescribing: What PMHNPs Can Do in Michigan

If you’re a psychiatrist or PMHNP wondering whether you can legally prescribe medications through telehealth—including controlled substances like Adderall, Xanax, or Suboxone—the short answer is: yes, in most cases. But the full picture depends on where you’re licensed, what you’re prescribing, and how federal and state rules interact.

As of early 2026, telepsychiatry has gone from emergency workaround to standard practice. The DEA’s temporary flexibilities allowing controlled substance prescribing without an initial in-person visit remain in effect through December 31, 2025, and most expect these will be extended or made permanent in some form. Meanwhile, states have codified telehealth into their statutes—some with carve-outs specifically for psychiatric treatment.

Let’s cut through the confusion and talk about what you can actually do, what restrictions still exist, and how the rules differ if you’re an MD/DO versus a PMHNP.

The Federal Baseline: Ryan Haight Act and DEA Waivers

Under normal circumstances, the Ryan Haight Online Pharmacy Consumer Protection Act requires an in-person medical evaluation before a provider can prescribe a controlled substance (Schedules II-V). This was written in 2008 to curb illegal online pharmacies, but it created a barrier for legitimate telemedicine in psychiatry—where many first-line treatments (stimulants for ADHD, benzodiazepines for anxiety, buprenorphine for opioid use disorder) are controlled substances.

During COVID-19, the DEA waived this requirement under public health emergency powers. That waiver has been extended multiple times, most recently through the end of 2025. This means that as of February 2026, psychiatrists can initiate controlled substance prescriptions via telehealth without ever seeing the patient in person, as long as the telehealth encounter meets the standard of care (typically a real-time audio-video consultation).

What this means practically:

• You can start a new ADHD patient on Adderall or Vyvanse after a video evaluation.
• You can prescribe benzodiazepines for panic disorder to a patient you’ve never met face-to-face.
• You can initiate buprenorphine (Suboxone) for opioid use disorder entirely via telehealth.

The DEA has proposed new rules that would create a framework for telehealth prescribing of controlled substances going forward—possibly requiring a special registration or limiting initial prescriptions to 30-day supplies—but as of early 2026, those proposals are not yet finalized. The safest assumption is that current flexibilities will continue through at least 2026, but you should monitor DEA announcements and be prepared to adapt if permanent rules impose new requirements.

Key federal requirement: You must have a valid DEA registration in the state where the patient is located at the time of the consultation. If you’re treating patients across multiple states, you’ll need DEA registrations in each state (unless you qualify for an exception like treating patients at a registered hospital site remotely).

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State-by-State Rules: Where It Gets Interesting

Federal law sets the floor, but states can—and do—add their own requirements or carve-outs. Here’s what matters in the six states where psychiatric providers are in highest demand:

California

California allows prescribing via telehealth as long as you conduct a ‘good faith exam,’ and a video telehealth encounter qualifies. There’s no state-level prohibition on controlled substances via telemedicine—California defers to federal law on that question.

Key requirement: You must check CURES (California’s prescription drug monitoring program) before prescribing any Schedule II-IV medication, whether in-person or via telehealth. Most platforms integrate PDMP checks, but if you’re flying solo, build this into your workflow.

Reimbursement: California law mandates telehealth payment parity for behavioral health services, so private insurers must reimburse video visits at the same rate as in-person.

Bottom line for psychiatrists: You can do comprehensive med management via telehealth in California—including initiating controlled meds—with minimal friction.

Texas

Texas updated its telemedicine laws in 2017 to allow prescribing via telehealth if the ‘standard of care’ is met. This generally means a real-time audio-video encounter that allows for the same clinical assessment you’d do in person.

Controlled substances: Texas prohibits prescribing Schedule II opioids for chronic pain via telemedicine (you need an in-person visit for that). But for psychiatric treatment—ADHD stimulants, benzodiazepines for anxiety, etc.—teleprescribing is allowed under the federal waiver.

PDMP: Texas requires checking the state’s Prescription Monitoring Program before prescribing any controlled substance. This applies equally to telehealth.

NP supervision quirk: If you’re a psychiatrist supervising a PMHNP in Texas, note that NPs cannot prescribe Schedule II controlled substances in outpatient settings on their own (there’s a narrow exception for terminal illness). The psychiatrist would need to write those prescriptions, or the NP would be limited to Schedule III-V.

Bottom line for psychiatrists: Texas is telehealth-friendly for psychiatric prescribing. Just avoid chronic opioid management via video, and stay on top of PDMP checks.

Florida

Florida is one of the more permissive states for telehealth controlled substance prescribing—at least for psychiatry.

Florida law (FS 456.47) explicitly allows controlled substances to be prescribed via telehealth for the treatment of psychiatric disorders. This is a carve-out that doesn’t exist for pain management (where an in-person exam is still required for chronic opioid prescribing).

What this means: A Florida-licensed psychiatrist can initiate ADHD medications, anxiety medications, or any other psychiatric controlled substance via a video visit, and it’s explicitly legal under state law—no gray area.

NP note: PMHNPs in Florida can prescribe controlled substances, but with restrictions. They must work under a supervising physician’s protocol, and Schedule II prescriptions are generally limited to a 7-day supply—except for psychiatric nurses treating mental illness, who are exempt from that limit. So a psych NP in Florida can prescribe a 30-day supply of Adderall for ADHD under the right collaborative agreement.

Bottom line for psychiatrists: Florida is a best-case scenario for telehealth prescribing in psychiatry. The state explicitly supports it.

New York

New York recently aligned its state rules with federal DEA waivers, removing potential conflicts. In mid-2025, NYSDOH finalized regulations that allow controlled substance prescribing via telehealth when consistent with federal law.

Previously, New York technically required an in-person exam for controlled substances (with emergency waivers during COVID). Now, the rule essentially says: the default is in-person, unless federal law (like the DEA’s telehealth waiver) permits otherwise, or certain exceptions apply (like if another provider saw the patient in-person within the past 12 months).

What this means: As long as the federal DEA waiver is in effect (through 2025+), New York psychiatrists can prescribe controlled meds via telehealth to new patients without an in-person visit. If/when the DEA finalizes permanent rules, New York’s regulation will automatically incorporate those requirements.

Medicare note: Starting in 2025, Medicare patients receiving tele-mental health services are supposed to have an in-person visit at least once every 6-12 months (the exact frequency has changed in legislation). This is a billing rule, not a prescribing restriction—but if you’re treating Medicare beneficiaries exclusively online, plan for periodic in-person check-ins or risk claim denials.

Bottom line for psychiatrists: New York is fully on board with telehealth prescribing. The regulatory environment is stable and aligned with federal policy.

Pennsylvania

Pennsylvania doesn’t have specific state-level restrictions on telehealth prescribing beyond federal requirements. A valid telemedicine encounter (audio-video) satisfies the exam requirement for prescribing.

Controlled substances: Pennsylvania defers to federal law. During the DEA waiver period, psychiatrists can prescribe controlled meds via telehealth to new patients.

NP supervision: If you’re supervising a PMHNP in PA, note that collaborative agreements are required indefinitely (no full practice authority yet). NPs can prescribe controlled substances if it’s in their collaborative agreement, but Schedule II prescriptions must be reported to the supervising physician within 24 hours, and the physician must co-sign a percentage of charts.

Reimbursement: Pennsylvania Medicaid covers telepsychiatry at parity. Private payer coverage is good but not universally mandated by law—most major insurers voluntarily reimburse telehealth for mental health equally.

Bottom line for psychiatrists: Pennsylvania is straightforward—standard telehealth rules apply, no special restrictions for psychiatry.

Illinois

Illinois is similar to Pennsylvania in that it follows federal law on controlled substance prescribing via telehealth. The state enacted strong telehealth parity legislation in 2021 (SB 667), requiring private insurers to reimburse telehealth services—including behavioral health—at the same rate as in-person visits through at least 2027.

Controlled substances: Illinois NPs who have achieved Full Practice Authority can prescribe Schedule II-V independently (after completing 4,000 hours of supervised practice + 250 CE hours). During their supervised period, NPs can prescribe Schedule III-V under delegation, and Schedule II only in consultation with their supervising physician (typically for a 30-day supply).

PDMP: Illinois requires checking the state’s prescription monitoring program before prescribing controlled substances.

Unique note: Illinois is one of a handful of states that allows clinical psychologists with specialized training to prescribe a limited formulary of psychiatric medications under a psychiatrist’s supervision. This doesn’t affect psychiatrist scope, but it’s worth knowing if you’re collaborating with psychologists.

Bottom line for psychiatrists: Illinois fully supports telepsychiatry prescribing, with strong reimbursement parity and no unusual state restrictions.

Psychiatrist vs PMHNP: Does Your Credential Change the Rules?

For psychiatrists (MD/DO): You have full, independent prescribing authority in all 50 states. The only limitations you face are federal (DEA requirements) and state-specific telehealth rules—but those apply to what you prescribe and how (telehealth vs in-person), not whether you need supervision. No collaborative agreements, no chart co-signatures, no physician oversight.

For PMHNPs: Your prescribing authority depends entirely on your state’s scope of practice laws. Let’s break it down:

Full Practice Authority States (FPA)

In states like Washington, Oregon, Colorado, Arizona, Montana, Alaska, and increasingly California (for experienced NPs as of 2026), PMHNPs can practice independently—no physician collaboration required. You can evaluate patients, diagnose, and prescribe all psychiatric medications (including controlled substances) under your own NP license and DEA registration.

New York and Illinois are effectively FPA states after you complete a transition period (3,600 hours in NY, 4,000 hours in IL). Once you hit that threshold, you practice independently.

In these states, you’re on equal footing with psychiatrists from a legal standpoint (though reimbursement may still differ—more on that below).

Reduced Practice States

In states like Pennsylvania (currently), PMHNPs must maintain a collaborative agreement with a physician throughout their career. The agreement specifies what you can prescribe, and the physician must be available for consultation and periodic chart review.

For psychiatric prescribing, your collaborating physician is typically a psychiatrist (some states explicitly require it for psych meds). You can prescribe controlled substances if it’s in your agreement, but there may be additional reporting requirements (e.g., notifying the physician within 24 hours of prescribing a Schedule II).

Restricted Practice States

In Texas and Florida (for psych NPs specifically), you’re practicing under physician delegation or supervision indefinitely.

Texas: You must have a Prescriptive Authority Agreement with a physician. You cannot prescribe Schedule II controlled substances in outpatient settings on your own (except very narrow exceptions). The supervising physician is limited to overseeing 7 NPs/PAs at once, and you must have monthly face-to-face meetings with them for the first 3 years.

Florida: Psych NPs were excluded from the 2020 ‘autonomous practice’ law that applied to primary care NPs. You must work under a supervising physician’s protocol. However, if you meet the definition of a ‘psychiatric nurse’ (MSN/DNP in psych + 2 years experience under a psychiatrist), you can prescribe psychotropic controlled substances for mental illness—without the 7-day Schedule II limit that applies to other NPs.

Practical impact: In restricted states, PMHNPs often work as part of a group practice or telehealth company that provides the supervising physician structure. Solo practice is functionally impossible without a collaborating MD/DO.

Reimbursement: Will You Get Paid the Same for Telehealth?

Medicare: Pays psychiatrists approximately $95 for a 15-minute follow-up (CPT 99213) and $136 for a 25-minute follow-up (99214) as of 2026. Initial psychiatric evaluations (CPT 90792) reimburse around $173. These rates apply equally to telehealth and in-person visits.

PMHNPs are reimbursed at 85% of the physician fee schedule when billing under their own NPI. So a 15-minute med check that pays a psychiatrist $95 would pay an NP about $81.

Private insurance: Most commercial payers now reimburse telehealth at parity with in-person for behavioral health, especially in states with parity laws (CA, IL, NY, MA, CT, etc.). Rates vary by region and contract, but often exceed Medicare—e.g., a major insurer might pay $150 for a 99213 in a metro area.

Some insurers still pay NPs at a slightly lower rate than MDs (85-90%), but others have moved to equal reimbursement, particularly for mental health services where there’s a recognized shortage.

Medicaid: Reimbursement is generally lower than Medicare or commercial, but many state Medicaid programs have enhanced behavioral health rates and explicitly cover telehealth at parity. For example, New York Medicaid reimburses tele-mental health at the same rate as face-to-face.

Bottom line: Telehealth reimbursement for psychiatric medication management is strong in 2026. The ‘will they pay?’ question has largely been answered: yes, if you’re providing legitimate clinical care and billing appropriately.

What You Need to Do to Stay Compliant

1. Get licensed in the state where the patient is located. You cannot treat a patient in Texas with only a California license, even if it’s via video. The Interstate Medical Licensure Compact (IMLC) can expedite multi-state licensure for MDs—Texas, Pennsylvania, and Illinois are members. California, New York, and Florida are not, so you’ll need to go through the traditional process in those states.

2. Obtain DEA registrations in each state where you prescribe controlled substances. This applies to both MDs and NPs. If you’re prescribing Adderall to patients in 3 states, you need 3 DEA registrations.

3. Check your state’s PDMP before prescribing controlled substances. Most states require this by law (CA, TX, NY, IL, PA, FL all do). Build it into your workflow—most EHR systems and telehealth platforms can integrate PDMP checks.

4. Document the telehealth encounter appropriately. Note that it was conducted via secure audio-video, verify the patient’s location, document informed consent for telehealth (required in some states like Texas and California), and ensure your clinical assessment is thorough enough to meet the standard of care.

5. If you’re a PMHNP, ensure your collaborative agreement (if required) covers telehealth and specifies which medications you can prescribe. Some agreements written pre-pandemic don’t explicitly address telemedicine—update them.

6. Stay informed on DEA rule changes. The current waiver expires December 31, 2025. Sign up for updates from the DEA, your state medical/nursing board, and professional organizations (APA, AANP, etc.). If new rules require periodic in-person visits or special registration, you’ll need to adapt quickly.

The Business Case: Why This Matters for Your Practice

Telepsychiatry isn’t just legally permissible—it’s economically rational for providers in 2026.

Patient acquisition is cheaper and faster via telehealth platforms. If you’re building a practice from scratch, DIY marketing (SEO, Google Ads, directory listings) realistically costs $200-500+ per booked patient when you factor in ad spend, agency fees, time spent qualifying leads, and no-show rates. SEO takes 6-12 months to generate meaningful traffic. Google Ads for keywords like ‘psychiatrist near me’ or ‘ADHD online’ run $15-40+ per click, and most clicks don’t convert.

Compare that to joining a platform like Klarity Health, where you pay a standard fee per completed appointment. No upfront marketing spend. No wasted ad budget on tire-kickers. Patients come pre-qualified and matched to your specialty and availability. You control your schedule, and you only pay when you actually see someone.

The math is simple: spending $3,000-5,000/month on marketing with uncertain ROI, or paying per appointment with guaranteed patient flow? For most providers—especially those starting out or scaling quickly—the latter removes all the risk.

Telehealth also improves your revenue per hour. No-show rates drop (patients find it easier to log into a video call than drive to an office). You eliminate commute time and overhead (no office lease, smaller malpractice premiums in some states for telehealth-only practice). A psychiatrist doing 4-5 video med checks per hour at $150-200 per visit can clear $600-1,000/hour in gross revenue. Even after platform fees or billing costs, that’s a strong return.

And because telehealth expands your geographic reach, you can fill your schedule faster. Instead of competing with every psychiatrist in a 10-mile radius, you’re tapping into statewide (or multistate) demand.

FAQ

Can I prescribe Adderall or other stimulants via telehealth in 2026?
Yes, as long as you’re operating under the current DEA waiver (extended through December 31, 2025, likely to continue in 2026) and you conduct a proper telehealth evaluation. This applies in all six priority states covered here. Check your state’s PDMP before prescribing, and document your clinical rationale.

Do I need to see a patient in-person at least once, even for telehealth?
Under current federal rules (as of early 2026), no. The DEA waiver allows you to initiate controlled substance prescriptions entirely via telehealth without an initial in-person visit. Some state rules (like New York’s requirement for Medicare patients to have periodic in-person visits) may apply in specific circumstances, but for the vast majority of psychiatric telehealth, you do not need to meet the patient face-to-face.

Can PMHNPs prescribe the same medications as psychiatrists via telehealth?
It depends on your state. In Full Practice Authority states (e.g., experienced NPs in California, New York after 3,600 hours, Illinois with FPA), yes—you can prescribe the full range of psychiatric medications including Schedule II controlled substances. In restricted states like Texas, NPs face significant limitations (e.g., cannot prescribe Schedule II in outpatient psych settings independently). Check your state’s scope of practice laws.

What happens if the DEA waiver expires and new rules require in-person visits?
If the DEA finalizes rules that reimpose the in-person exam requirement for controlled substances, you’d need to adapt—either by seeing patients in-person for their initial visit, arranging for another provider to conduct an in-person exam and refer to you, or limiting your telehealth practice to non-controlled medications. The DEA has proposed allowing a 30-day ’emergency’ supply via telehealth even under new rules, which would give some flexibility. Stay tuned for final rulemaking, expected in 2024-2025.

Are audio-only (phone) visits reimbursed for medication management?
In some cases, yes. Medicare covers audio-only visits for mental health services (as of 2022, extended through 2024+) at the same rate as video visits, as long as the patient cannot access video. Some states (Illinois, Massachusetts) require private payers to cover audio-only mental health similarly. However, for prescribing controlled substances, federal law (and most state laws) require real-time audio-video for the initial encounter. Audio-only might work for follow-ups in some situations, but verify with your payer and state board.

Do I need malpractice insurance that covers telehealth?
Yes. Most malpractice carriers now include telehealth in standard policies, but confirm with your insurer. Some offer lower premiums if you’re telehealth-only (no in-person office). If you’re treating patients in multiple states, ensure your policy covers all states where you’re licensed and practicing.

Can I treat patients across state lines?
Yes, if you hold an active medical or nursing license and DEA registration in each state where your patients are located. The patient’s location at the time of the consultation determines which state’s laws apply. Treating patients in 5 states means you need 5 licenses and 5 DEA registrations. The IMLC can expedite this process for physicians in member states.

What’s the difference between ‘incident to’ billing and direct NP billing for reimbursement?
‘Incident to’ billing allows an NP’s service to be billed under the supervising physician’s NPI at 100% of the physician fee schedule, but it requires the physician to be physically present in the same location (and other conditions). This doesn’t work for telehealth, where the NP and physician are not in the same space. So for telehealth, NPs typically bill under their own NPI and receive 85% of Medicare rates (or whatever their contracted rate is with private payers). Some commercial plans credential NPs and pay at parity—negotiate if you can.

Ready to Build a Telehealth Practice Without the Marketing Headache?

If you’re a psychiatrist or PMHNP looking to see more patients, earn better income, and skip the $5,000/month marketing gamble, Klarity Health offers a smarter path.

You get:

• Pre-qualified patients matched to your specialty and schedule
• No upfront marketing costs—you pay per completed appointment, not per click or per month
• Built-in telehealth platform with EHR, e-prescribing, and PDMP integration
• Both insurance and cash-pay patient flow, so you’re not leaving money on the table
• You control your availability—set your hours, take as many or as few patients as you want

Instead of spending months building SEO, testing Google Ads, and paying directory fees with no guarantee of patient volume, you can start seeing patients this week. And because you only pay when a patient actually shows up and you complete the visit, your ROI is guaranteed.

Interested? Explore joining Klarity’s provider network and see how telehealth can work for your practice—without the startup risk.

Sources and References

Source:

• https://www.bon.texas.gov/faqpracticeaprn.asp.html#:~:text=certificate%20or%20fetal%20death%20certificate,For%20additional%20information
• https://www.npschools.com/blog/guide-to-np-practice-in-florida#:~:text=match%20at%20L200%20%E2%80%9CUnder%20HB,%E2%80%9D
• https://natlawreview.com/article/telehealth-and-person-visits-tracking-federal-and-state-updates-pandemic-era#:~:text=In%20late%202024%2C%20the%20U,prescribing
• https://www.flsenate.gov/laws/statutes/2024/464.012#:~:text=,the%20treatment%20of%20mental%20disorders
• https://www.cchpca.org/texas/#:~:text=including%2C%20but%20not%20limited%20to%2C,Code%2C%20Chapters%20481%20and%20483
• https://www.cchpca.org/texas/#:~:text=,way%20communication
• https://www.nursepractitioneronline.com/articles/nurse-practitioner-practice-authority-updates/#:~:text=As%20of%202025%2C%20the%20distribution,toward%20greater%20autonomy%20for%20NPs
• https://www.nursepractitioneronline.com/articles/nurse-practitioner-practice-authority-updates/#:~:text=,Michigan%20%282025
• https://www.pacnp.org/general/custom.asp?page=ScopeofPractice#:~:text=tests%2C%20and%20deliver%20other%20health,appropriate%20experience%20can%20receive%20a
• https://www.jdsupra.com/legalnews/new-law-allows-experienced-nps-to-8292796/#:~:text=New%20York%E2%80%99s%202023%20state%20budget%2C,practice%20without%20a%20collaborative%20relationship