Telehealth General Psychiatry Prescribing: What Prescribers Can Do in Michigan

If you’re a psychiatrist or psychiatric nurse practitioner trying to figure out whether you can prescribe ADHD meds via video visit, or whether you need a collaborating physician in your state, you’ve probably found a lot of vague or outdated information. The reality is that prescribing rules in telepsychiatry are state-specific, constantly evolving, and often confusing — especially when it comes to controlled substances like stimulants and benzodiazepines.

Here’s what you actually need to know in 2026 about prescribing psychiatric medications through telehealth, broken down by what matters most: your credentials (MD vs NP), your state, and the medications you prescribe.

Can You Prescribe Controlled Substances via Telehealth?

Short answer for psychiatrists: Yes, in nearly all states — for now.

Short answer for PMHNPs: It depends entirely on your state’s scope-of-practice laws.

The federal Ryan Haight Act historically required an in-person exam before prescribing controlled substances (Schedule II–V drugs like Adderall, Xanax, or Suboxone). But since 2020, the DEA has waived this requirement under public health emergency powers, and those flexibilities have been extended through December 31, 2025 (texasnp.org) (natlawreview.com).

This means right now, psychiatrists can initiate Schedule II stimulants for ADHD or benzodiazepines for anxiety via a video visit without ever seeing the patient in person. The catch? The DEA is expected to finalize permanent rules by late 2024 or early 2025, and those could reimpose some in-person requirements (though likely with exceptions for mental health treatment). Stay alert and monitor DEA announcements.

State-level exceptions matter too. Some states explicitly permit or restrict telehealth prescribing of controlled substances beyond federal law:

• Florida: Explicitly allows controlled substance prescribing via telehealth for psychiatric treatment (www.flsenate.gov). If you’re treating depression, anxiety, or ADHD, you can prescribe remotely. The only prohibition is for chronic pain management via telehealth.

• Texas: Allows telehealth prescribing of controlled substances for mental health conditions but prohibits it for chronic pain (www.cchpca.org). You can prescribe a 30-day supply of Adderall via video visit, but you must check the Texas Prescription Monitoring Program (PMP) database before every controlled substance prescription.

• New York: Recently updated regulations to align with federal telehealth allowances, removing state-level barriers to controlled substance prescribing via telemedicine (www.nixonpeabody.com). New York psychiatrists can currently prescribe controlled meds via telehealth under the DEA waiver.

• California: No specific state prohibition on telehealth controlled substance prescribing. California requires a ‘good faith exam’ before prescribing, but telehealth exams qualify (natlawreview.com). You must check the CURES database (California’s PMP) before prescribing Schedule II–IV medications.

The practical takeaway: As a psychiatrist, you can prescribe controlled substances via telehealth in these states right now, but prepare for potential changes when the DEA finalizes permanent rules. For PMHNPs, your ability to prescribe controlled substances remotely depends not just on federal telehealth rules but on whether your state even allows you to prescribe controlled substances independently — which brings us to the next critical question.

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Psychiatrist vs PMHNP Prescribing Authority: The State-by-State Reality

Here’s where it gets complicated. Psychiatrists (MD/DO) have full, independent prescribing authority in all 50 states. Period. No collaborative agreements, no supervision requirements, no caps on what you can prescribe (beyond standard of care).

PMHNPs? Your prescribing authority is entirely dependent on your state’s scope-of-practice laws, which fall into three broad categories:

Full Practice Authority States (~34 states)

In these states, experienced PMHNPs can practice independently — diagnose, treat, and prescribe (including Schedule II–V controlled substances) without any physician oversight. Examples include Washington, Oregon, Colorado, Minnesota, Arizona, New Mexico, and increasingly New York and Illinois (after meeting transition requirements).

New York: PMHNPs must complete 3,600 hours (roughly 2 years) under a collaborative agreement, after which they can practice fully independently (www.jdsupra.com). Once you hit that threshold, you can prescribe stimulants, antipsychotics, antidepressants — anything within your scope — without a psychiatrist reviewing your charts or co-signing prescriptions.

Illinois: PMHNPs must complete 4,000 hours of collaborative practice plus 250 hours of continuing education, then apply for Full Practice Authority licensure (www.nursepractitionerlicense.com). Until then, you must have a written collaborative agreement with a physician, and technically your prescriptions are under delegated authority.

California: AB 890 created a transition pathway. As of 2023, PMHNPs with ≥3 years of experience can become ‘103 NPs’ and practice without direct physician supervision in group settings. By January 1, 2026, experienced NPs can apply to become ‘104 NPs’ and practice fully independently, even solo (www.rn.ca.gov). New grads still need physician-supervised protocols for their first three years.

Reduced Practice States

In these states, PMHNPs can diagnose and treat, but need a collaborative practice agreement with a physician to prescribe medications. Pennsylvania is a prime example: all PMHNPs, regardless of experience, must maintain a written collaborative agreement with a physician (www.pacnp.org). The agreement must specify which medications you can prescribe, and Schedule II prescriptions are limited to 30-day supplies with physician notification within 24 hours.

Restricted Practice States

These states require continuous physician supervision or delegation for all PMHNP practice. Texas and Florida are the big ones here.

Texas: PMHNPs cannot prescribe anything without a Prescriptive Authority Agreement with a Texas-licensed physician (www.bon.texas.gov). The physician must meet with you monthly for the first three years, then quarterly thereafter. And here’s the kicker: Texas NPs generally cannot prescribe Schedule II controlled substances in outpatient settings (www.cchpca.org). There are very narrow exceptions (terminally ill patients, children with ADHD in specific programs), but if you’re a PMHNP in Texas, your collaborating psychiatrist will typically handle the initial stimulant prescriptions. Additionally, one physician can supervise no more than 7 NPs/PAs at a time (capitol.texas.gov), which can limit your ability to find a collaborator.

Florida: Even more complicated. Florida passed a law in 2020 allowing some NPs to practice autonomously, but psychiatric NPs were explicitly excluded (www.npschools.com). Only family medicine, general internal medicine, and pediatric NPs can apply for autonomous practice. PMHNPs still need a supervising physician.

However, Florida does define a special category called ‘psychiatric nurse’ — a PMHNP with ≥2 years of post-grad experience under a psychiatrist. If you meet that definition, you can prescribe psychotropic controlled substances (including Schedule II) for mental health treatment in collaboration with a psychiatrist, and you’re exempt from the 7-day supply limit that applies to other NPs (www.flsenate.gov). But you still need that collaborating psychiatrist.

What this means practically: If you’re a PMHNP in Texas or Florida, you cannot hang your own shingle and start prescribing independently. You must find a collaborating psychiatrist (which can be difficult and expensive — many charge $1,000–3,000/month for collaboration agreements). In New York, Illinois, or California, you have a clear pathway to independence after gaining experience. In Pennsylvania, you’ll need a collaborator indefinitely unless the law changes.

The Business Case for Telepsychiatry Platforms Like Klarity

Here’s the reality of patient acquisition in psychiatry: DIY marketing is expensive, slow, and uncertain.

If you’re thinking about building your own telehealth practice, here’s what it actually costs to acquire patients:

• SEO: Takes 6–12 months of consistent investment (content creation, technical optimization, backlinks) before you see meaningful patient volume. Most solo providers don’t have the expertise or patience.

• Google Ads: Mental health keywords cost $15–40+ per click. Most clicks don’t convert to booked patients. A realistic cost per booked patient through PPC is $200–400+ when you factor in testing, optimization, and no-show rates from cold leads.

• Psychology Today and directory listings: You pay monthly subscription fees ($30–100/month) and compete with hundreds of other providers on the same page. Zocdoc charges per booking ($35–100+), and your total monthly cost including subscription can easily run $500+.

• Agency/consultant costs: If you hire someone to manage your marketing, add $2,000–5,000/month in retainer fees.

When you add it all up — agency fees, ad spend, failed campaigns, staff time to handle and qualify leads, no-shows from unvetted leads — acquiring a qualified psychiatric patient through DIY marketing typically costs $200–500+ per patient.

And that’s assuming you eventually figure it out. Many providers spend $3,000–5,000/month for 6+ months with minimal results.

Klarity Health’s model is different: You pay a standard listing fee per new patient appointment — similar to Zocdoc’s model, but with pre-qualified patients already matched to your specialty and availability. No upfront marketing spend. No monthly subscriptions. No wasted ad budget on clicks that don’t convert.

You only pay when a qualified patient books with you.

Here’s why that matters:

• Guaranteed ROI: Instead of gambling $5,000/month on marketing channels that might not work, you pay only when you see patients. Every dollar you spend directly generates revenue.

• Pre-qualified patients: Klarity matches patients to providers based on specialty, state licensure, availability, and insurance acceptance. You’re not sorting through unqualified leads or dealing with no-shows from people who can’t afford your services.

• No platform costs: You get built-in telehealth infrastructure (video platform, scheduling, EHR integration) without paying for separate subscriptions to Doxy.me, SimplePractice, or other tools.

• Both insurance and cash-pay flow: Klarity works with major insurers and also serves cash-pay patients, giving you volume and payer mix flexibility.

• You control your schedule: Set your availability, and Klarity fills your slots. Want to see 20 patients a week? 40? You decide.

Compare the economics: If you’re spending $4,000/month on marketing to acquire 10 new patients (at $400 each), and Klarity’s listing fee per patient is comparable or lower, you’re getting the same patient volume with zero risk and zero wasted spend on campaigns that don’t convert.

For PMHNPs in restricted states like Texas or Florida, platforms like Klarity also solve the collaboration problem — they provide the physician oversight and collaborative agreements you need to prescribe legally, removing a major barrier to practice.

Reimbursement: What Medication Management Actually Pays

Understanding reimbursement is critical because it determines whether your practice is sustainable.

Medicare reimbursement (2026 national averages):

• Initial psychiatric evaluation with medication management (CPT 90792): ~$173 (therathink.com)
• 15-minute med check follow-up (99213): ~$95 (therathink.com)
• 25-minute med check follow-up (99214): ~$136 (therathink.com)

PMHNPs are reimbursed at 85% of these rates when billing under their own NPI (www.nursepractitioneronline.com), unless you can bill ‘incident to’ a physician (which doesn’t apply in telehealth).

Private insurance typically pays better — often $150–200 for a 99213 and $200–250 for a 99214 in higher cost-of-living areas. Many insurers have adopted telehealth parity laws, meaning they pay the same rate for video visits as in-person.

States with strong telehealth parity:

• Illinois: SB 667 (2021) mandates equal reimbursement for telehealth through at least 2027
• California: AB 744 (2019) requires payment parity for telehealth services
• New York: Strong parity laws for tele-mental health

Medicaid rates are lower (often $60–80 for a brief med check in states like Florida), but Medicaid also offers volume — there’s enormous unmet demand in Medicaid populations.

What this means for your practice: If you’re seeing 20 patients per week for 15-minute med checks (99213), and you’re averaging $120/visit across your payer mix (Medicare, commercial, Medicaid), that’s $2,400/week or ~$9,600/month in gross revenue just from follow-ups. Add initial evaluations and longer visits, and a full-time telepsychiatry practice can generate $15,000–25,000+/month.

Documentation and Compliance: What You Actually Need to Do

Telehealth prescribing carries the same standard-of-care requirements as in-person care. Here’s what matters:

Establish a valid patient-provider relationship: Nearly every state recognizes a video visit as sufficient for establishing care, as long as it meets the standard of care. Texas law explicitly defines a valid telemedicine encounter as real-time audio-visual interaction allowing the same assessment as in-person (www.cchpca.org).

Document appropriately: Your telehealth notes should include:

• Confirmation that the visit was conducted via telemedicine
• Patient location (required for licensure and prescribing compliance)
• Technology used (video platform)
• Patient consent for telehealth
• Standard psychiatric documentation (history, mental status exam, diagnosis, treatment plan)

Check prescription monitoring programs (PMPs): Most states require checking the state PMP database before prescribing controlled substances. This applies equally to telehealth:

• Texas: Must check PMP before every controlled substance prescription
• California: Must check CURES database at least once every 4 months for ongoing controlled substance therapy
• New York: Must check I-STOP registry before prescribing Schedule II–IV drugs

Emergency protocols: Some states (like Texas) require telehealth providers to have documented protocols for patient emergencies — what happens if a suicidal patient disconnects mid-session? You need a plan (www.cchpca.org).

Licensure: You must be licensed in the state where the patient is located during the visit. The Interstate Medical Licensure Compact (IMLC) expedites licensure in member states. Among priority states, Texas, Pennsylvania, and Illinois are IMLC members. New York, Florida, and California are not, so you’ll need to go through the traditional licensure process for those states.

What’s Changing (and What to Watch)

The regulatory landscape for telepsychiatry prescribing is evolving rapidly:

Federal DEA rules: The DEA is expected to finalize permanent rules on controlled substance prescribing via telehealth by late 2024 or early 2025. Current proposals include:

• Allowing 30-day supplies of controlled substances via telehealth for new patients
• Exemptions for referrals from in-person clinicians
• Special registration requirements for telehealth prescribers

State scope-of-practice expansion: The trend is toward granting PMHNPs more autonomy. Since 2020, over a dozen states (Massachusetts, Kansas, Indiana, Louisiana, Michigan, etc.) have transitioned to full practice authority for NPs (www.nursepractitioneronline.com). Pennsylvania has legislation pending that could grant FPA.

California’s 104 NP certification: Starting January 1, 2026, experienced PMHNPs in California can apply for fully independent practice (www.rn.ca.gov). This will significantly expand psychiatric prescriber capacity in a state with 11+ million residents in mental health shortage areas.

State-by-State Quick Reference

FAQ

Can I prescribe stimulants for ADHD via telehealth if I’ve never met the patient in person?

Yes, under current federal DEA waivers extended through December 31, 2025. Psychiatrists can initiate Schedule II stimulants via video visit. However, be prepared for potential changes when the DEA finalizes permanent rules.

Do I need a DEA registration in every state I practice in?

No. You need one DEA registration with your primary practice address. However, some states require you to register your DEA number with their state-controlled substance monitoring program.

Can I prescribe across state lines via telehealth?

Only if you’re licensed in the state where the patient is located at the time of the visit. You cannot prescribe to a patient in Texas if you only have a California license, even via telehealth.

What’s the difference between ‘incident to’ billing and billing under my own NPI as a PMHNP?

‘Incident to’ billing allows you to bill at 100% of the physician fee schedule, but it requires direct physician supervision in the same physical location. This doesn’t work for telehealth. When billing under your own NPI for telehealth services, you’ll be reimbursed at 85% of the physician rate for Medicare (and often similar reductions for private payers).

Do I need malpractice insurance that specifically covers telehealth?

Most professional liability policies now cover telehealth automatically, but verify with your carrier. Some older policies may require a rider or endorsement for telemedicine coverage.

How do I find a collaborating psychiatrist if I’m a PMHNP in a restricted state?

This is genuinely difficult. Options include:

• Joining a telehealth platform or group practice that provides collaboration as part of your contract
• Networking through state NP associations
• Paid collaboration services (expect to pay $1,000–3,000+/month)
• Approaching psychiatrists in your area directly (offer to cover their chart review time)

Ready to Practice Telepsychiatry Without the Marketing Headaches?

If you’re tired of gambling thousands of dollars on marketing channels that might not work, Klarity Health offers a simpler path: pre-qualified patients matched to your specialty and availability, with no upfront costs and no monthly subscriptions.

You only pay when qualified patients book with you — guaranteed ROI, zero wasted spend.

For PMHNPs in restricted states, Klarity also provides the physician collaboration and oversight you need to prescribe legally.

Explore joining Klarity’s provider network and start seeing patients without the patient acquisition 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