Telehealth General Psychiatry Prescribing: What Psychiatric NPs Can Do in Michigan

If you’re a psychiatrist or psychiatric nurse practitioner navigating the world of telehealth prescribing in 2026, you’ve probably realized one thing: the rules are all over the map. Can you prescribe stimulants via video in Texas? Does a PMHNP need a collaborating psychiatrist in Florida? What’s the deal with the DEA’s controlled substance rules?

Let’s cut through the noise. This guide breaks down what you actually need to know about prescribing authority, scope of practice differences between MDs and NPs, and state-specific telehealth rules across the six states where demand for psychiatric care is highest: California, Texas, Florida, New York, Pennsylvania, and Illinois.

The Federal Foundation: DEA Rules and Telehealth Prescribing of Controlled Substances

Before we dive into state quirks, let’s talk federal law—because if you’re prescribing Schedule II stimulants (Adderall, Ritalin) or benzodiazepines via telehealth, you need to know where the DEA stands.

Historically, the Ryan Haight Act required an in-person medical evaluation before prescribing controlled substances. That changed during COVID-19, when the DEA waived this requirement under public health emergency powers. Good news: As of early 2026, that flexibility remains in place through December 31, 2025, extended by federal rule.

What this means for you:

• Psychiatrists can initiate controlled substance prescriptions (including Schedule II) via telehealth to new patients nationwide, without an initial in-person visit
• This covers the bread-and-butter of telepsychiatry: ADHD stimulants, anti-anxiety medications, even buprenorphine for opioid use disorder
• The catch: The DEA has proposed new permanent rules that could re-impose some in-person requirements (possibly with exceptions for 30-day supplies or provider referrals). Those rules haven’t been finalized yet, but expect clarity by late 2024 or early 2025

Stay alert. When the permanent DEA rule drops, you may need to adjust your workflow—potentially requiring an in-person visit after an initial telemedicine prescription, or registering for a special telemedicine controlled-substance designation. For now, though, you’re clear to prescribe remotely under the federal waiver.

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Psychiatrist vs PMHNP: Who Can Prescribe What, and Where?

Here’s where it gets messy. Psychiatrists (MD/DO) have full, independent prescribing authority in all 50 states. No supervision, no collaboration agreements, no hoops. If you’re an MD, you can diagnose, treat, and prescribe any psychiatric medication—stimulants, antipsychotics, MAOIs, whatever the patient needs—under your own license and DEA registration.

PMHNPs? It’s complicated, and it depends entirely on where you’re licensed.

The Three Tiers of NP Practice Authority

State laws governing nurse practitioners fall into three categories:

1. Full Practice Authority (FPA): NPs can practice independently—no physician oversight, no mandatory collaboration. About 34 states plus DC now grant this. Examples: Washington, Oregon, Colorado, Arizona, New Mexico. In FPA states, a PMHNP functions almost identically to a psychiatrist: independent evaluation, diagnosis, and prescribing (including controlled substances under their own DEA license).

2. Reduced Practice: NPs need a collaborative practice agreement with a physician, but only for certain aspects of care (usually prescribing). The physician isn’t supervising day-to-day—they’re available for consult and may review charts periodically. Examples: New York and Illinois (both with transition-to-independence pathways).

3. Restricted Practice: NPs must practice under continuous physician supervision or delegation. Every diagnosis, every prescription is technically delegated from a supervising MD. Examples: Texas, Florida (for psych NPs), Pennsylvania.

Let’s break down the priority states.

California: Transitioning to Independence

Psychiatrists: Full independence, always.

PMHNPs: California is in the middle of a phased rollout toward NP independence, thanks to AB 890 (passed in 2020).

• As of January 2023: Experienced NPs (≥3 years post-certification) can apply to become ‘103 NPs’, allowing them to practice without physician supervision in group settings (clinics, health systems) that have physicians on staff—but not under direct oversight.

• Starting January 2026: Those NPs can further certify as ‘104 NPs’, which grants full independent practice even outside group settings. This means a seasoned PMHNP in California can open a private practice and prescribe independently, just like a psychiatrist.

• New grads: If you’re a newly certified PMHNP in California, you’ll still need to work under physician-supervised ‘standardized procedures’ (collaborative protocols outlining your scope and prescriptive authority) for at least three years before applying for 103 NP status.

Telehealth note: California permits prescribing via telemedicine with a ‘good faith exam’—and a video evaluation counts. You must check CURES (California’s Prescription Drug Monitoring Program) before prescribing Schedule II–IV medications. Private insurers in CA are required to cover telehealth at parity with in-person visits under state law (AB 744, 2019).

Bottom line: By 2026, experienced California PMHNPs will have near-parity with psychiatrists. New NPs will still need a supervising psychiatrist for their first few years, but the trajectory is clear—California is moving toward full NP independence.

Texas: Physician Supervision Required, No Exceptions

Psychiatrists: Full independence.

PMHNPs: Restricted practice. Texas does not allow NPs to practice or prescribe independently—ever. Every aspect of an NP’s practice is considered delegated from a supervising physician.

Here’s what that means in practice:

• A Texas PMHNP must have a written Prescriptive Authority Agreement with a Texas-licensed physician (often a psychiatrist, for psych NPs)
• The agreement must specify what the NP can prescribe, outline supervision (monthly face-to-face meetings for the first 3 years, then quarterly), and include a quality assurance plan
• One physician can supervise no more than 7 NPs/PAs at a time
• Controlled substances: Texas NPs generally cannot prescribe Schedule II controlled substances (like Adderall or Ritalin) in outpatient settings, except in very narrow circumstances (e.g., terminal illness, or children with ADHD under specific protocols). They can prescribe Schedule III–V (like Suboxone or certain anxiolytics) if delegated by the physician.

Telehealth: Texas allows telemedicine prescribing if the standard of care is met (video evaluation with real-time audio-visual). The state prohibits tele-prescribing of Schedule II opioids for chronic pain, but mental health treatment is explicitly allowed. So a Texas psychiatrist can prescribe ADHD stimulants via telehealth under current federal allowances—but a Texas NP likely cannot, due to the Schedule II outpatient restriction.

Reality check: Texas has one of the worst psychiatrist-to-population ratios in the nation (about 1 psychiatrist per 8,500 residents), yet the state stubbornly maintains restrictive NP laws. Many Texas PMHNPs work for large telehealth companies or clinics that provide the supervising psychiatrist (often for a fee), because independent practice simply isn’t an option.

Bottom line: If you’re a PMHNP in Texas, you’ll be operating under a psychiatrist’s delegation. If you’re a psychiatrist, you can practice freely—but you may end up supervising NPs as part of your practice model.

Florida: Psychiatric NPs Excluded from Autonomy

Psychiatrists: Full independence.

PMHNPs: Restricted, with a twist. In 2020, Florida passed HB 607, which created a pathway for certain NPs to practice autonomously without physician supervision—but only in primary care (family medicine, internal medicine, pediatrics). Psychiatric NPs were explicitly excluded from this autonomy.

So here’s the deal:

• Florida PMHNPs must practice under a supervising physician’s protocol (usually a psychiatrist)
• They can prescribe controlled substances, but with limits: Schedule II prescriptions are normally capped at 7 days for NPs, except if the NP is a ‘psychiatric nurse’ (defined as a PMHNP with ≥2 years post-grad experience under a psychiatrist) treating a mental health disorder. In that case, the 7-day limit doesn’t apply to psychotropic medications.
• This means a Florida PMHNP can prescribe a 30-day supply of Adderall for ADHD (under physician collaboration), whereas a family NP in Florida could not

Telehealth: Florida is actually one of the most permissive states for telehealth controlled-substance prescribing. Florida Statute 456.47 explicitly allows teleprescribing of controlled substances for psychiatric treatment (along with hospice, inpatient, and nursing home care). This is a notable exception—most states are more cautious. So a Florida-licensed psychiatrist can initiate stimulants or benzodiazepines via video without issue. NPs can too, under their collaborative agreement.

Workforce context: Florida has a severe psychiatrist shortage (1 per ~9,000 residents) and about 7.8 million Floridians in mental health professional shortage areas. Advocacy groups have pushed to extend autonomy to psych NPs, and bills have been introduced (e.g., HB 771 in 2024), but as of 2026 they haven’t passed.

Bottom line: Florida PMHNPs need a supervising psychiatrist, but they can do substantial work once they qualify as a ‘psychiatric nurse’ under state law. Telehealth prescribing is wide open. If you’re a psychiatrist in Florida, you’ll have ample opportunity to collaborate with (and supervise) NPs—and plenty of patients.

New York: Transition to Independence After 3,600 Hours

Psychiatrists: Full independence.

PMHNPs: Reduced practice transitioning to FPA. New York has one of the more progressive NP frameworks in the country, thanks to the Nurse Practitioner Modernization Act (2015, made permanent in 2022).

Here’s how it works:

• New PMHNPs must enter a written collaborative agreement with a physician (often a psychiatrist for psych NPs) and follow written practice protocols for their first 3,600 hours of practice (roughly 2 years full-time)
• During this period, the physician must be available for consultation, but New York doesn’t mandate routine chart co-signing or specific meeting frequencies—it’s more of a safety net and mentorship
• After 3,600 hours: The NP files an attestation with the state and can practice independently, without a written agreement or ongoing supervision. They must maintain a ‘collaborative relationship’ with physicians (essentially, professional contacts for referrals and consults), but it’s informal—no charts to review, no oversight

What this means: An experienced PMHNP in New York has essentially the same prescribing authority as a psychiatrist. They can diagnose, treat, and prescribe controlled substances independently (including Schedule II stimulants), under their own nursing license and DEA registration.

Telehealth: New York has strong telehealth support. The state finalized regulations in 2023–25 that align New York’s controlled-substance prescribing rules with federal DEA waivers—so as long as the DEA allows teleprescribing, New York does too. NY requires e-prescribing for all controlled substances (no paper scripts) and mandates checking the I-STOP prescription monitoring database before prescribing Schedule II–IV drugs.

Workforce note: New York has a high concentration of psychiatrists in NYC (about 1 per 2,900 residents statewide), but upstate regions are severely underserved. The 2022 law that made NP independence permanent was specifically aimed at filling those gaps.

Bottom line: New York is one of the best states for PMHNPs—after two years of practice, you’re autonomous. If you’re a psychiatrist, you can practice as always, but you’ll increasingly see NPs as peers rather than supervised extenders.

Pennsylvania: Collaboration Required, No Pathway to Independence (Yet)

Psychiatrists: Full independence.

PMHNPs: Reduced practice, indefinitely. Pennsylvania currently requires all NPs to maintain a collaborative agreement with a physician for the entirety of their career. There’s no transition-to-independence pathway (though legislation has been introduced multiple times and may eventually pass).

Key details:

• The collaborative agreement must be filed with the PA State Board of Nursing and must specify the NP’s scope of practice and prescribing authority
• PA NPs can prescribe Schedule II–V controlled substances if the collaborating physician delegates it and it’s within the NP’s specialty—but Schedule II prescriptions are limited to a 30-day supply for initial prescriptions, and the physician must be notified within 24 hours
• The collaborating physician must also review a portion of the NP’s charts periodically (often 10% per quarter, though requirements vary)

Telehealth: Pennsylvania has no unique restrictions on telehealth prescribing beyond federal law. The state deferred to the DEA’s emergency waivers during COVID and hasn’t imposed additional barriers. PA Medicaid and most commercial payers cover telepsychiatry at parity, though the state doesn’t yet have a comprehensive telehealth parity statute (efforts are ongoing).

Workforce: Pennsylvania has a good supply of NPs (many training programs), but without full practice authority, some leave for neighboring states like Ohio or New York. Rural central PA has significant shortages—the state needs about 65 more psychiatrists to eliminate mental health HPSAs.

Bottom line: Pennsylvania PMHNPs must find a collaborating psychiatrist (or other physician comfortable with mental health). Many work for healthcare systems or telehealth companies that provide the supervising physician. If you’re a psychiatrist, you’ll likely be asked to collaborate with NPs—and there’s demand for that role.

Illinois: Pathway to Full Practice After 4,000 Hours

Psychiatrists: Full independence.

PMHNPs: Reduced practice with pathway to FPA. Illinois implemented a transition-to-independence model via the Nurse Practice Act update in 2017 (effective 2018).

Here’s the process:

• New NPs must practice under a Written Collaborative Agreement with a physician for 4,000 hours (about 2 years full-time) and complete 250 hours of continuing education in advanced pharmacology and related topics
• During this period, the NP’s prescriptions are under the physician’s delegated authority (the physician’s name appears on scripts as the delegating practitioner)
• After meeting the 4,000-hour and CE requirements, the NP can apply to the Illinois Department of Financial and Professional Regulation (IDFPR) for an ‘Illinois Full Practice Authority’ APRN license, which allows independent practice and prescribing of controlled substances

Controlled substances: Once an Illinois NP has FPA, they apply for their own mid-level controlled substance registration and can prescribe Schedule II–V independently. Before FPA, Schedule II prescriptions (like stimulants) require physician consultation and are limited to 30-day supplies.

Telehealth: Illinois is a leader in telehealth parity. The state’s Telehealth Act and 2021 amendments (SB 667) require private insurers to reimburse telehealth at parity with in-person care through at least 2027, especially for behavioral health. Illinois Medicaid also fully covers telepsychiatry at equal rates.

Unique detail: Illinois is one of a handful of states that allows clinical psychologists with specialized training to prescribe a limited formulary of mental health medications under a psychiatrist’s supervision. It’s not common, but it adds to the state’s prescriber capacity.

Workforce: Illinois has about 291 practitioners needed to eliminate mental health shortages, with high demand in rural areas and some underserved urban neighborhoods.

Bottom line: Illinois offers a clear path to NP independence—put in your 4,000 hours and 250 CE hours, and you’re autonomous. If you’re a psychiatrist, you can practice freely, and you may supervise NPs during their transition period.

Reimbursement: What You’ll Actually Get Paid for Med Management

Let’s talk money. Whether you’re billing Medicare, Medicaid, or private insurance, understanding reimbursement for psychiatric medication management is critical to your practice sustainability—and telehealth has made it easier.

Common CPT Codes for Psychiatric Med Management

• 90792 (Psychiatric Diagnostic Evaluation with Medical Services): Used for initial evaluations, typically 60 minutes. Medicare pays ~$173 (2026 national average).
• 99213 (Established patient, 15-20 minutes, moderate complexity): Standard follow-up med check. Medicare pays ~$95.
• 99214 (Established patient, 25-30 minutes, higher complexity): Longer or more complex med management. Medicare pays ~$136.
• 99215 (40+ minutes, very complex): Rarely used for routine follow-ups. Medicare pays ~$192.

If you’re doing therapy and med management in the same visit, you can bill an add-on psychotherapy code (e.g., 90833 for 16-37 minutes of therapy) in addition to the E/M code. But for pure med management—checking in on efficacy, side effects, adjusting doses—you’re typically billing 99213 or 99214.

Telehealth Parity: You’ll Get Paid the Same

Here’s the good news: Medicare and most private insurers now reimburse telehealth visits at the same rate as in-person visits for mental health services. This is thanks to pandemic-era flexibilities that have been extended (Medicare through at least 2025, and many states have made parity permanent via legislation).

What this means:

• A 15-minute video med check is billed and paid the same as an in-office visit (99213 = $95 from Medicare, often $120-150+ from commercial plans depending on region)
• You don’t need to discount your services or worry about lower telehealth fees—parity laws and Medicare policy have you covered

Medicare quirks: Medicare does require an in-person visit every 6-12 months for ongoing tele-mental health patients (the frequency has toggled in recent legislation). Plan for occasional in-person check-ins if you’re seeing Medicare patients exclusively online—but this is a billing rule, not a clinical prohibition.

PMHNP Reimbursement: 85% of Physician Rates (Usually)

If you’re a PMHNP, be aware: Medicare reimburses nurse practitioners at 85% of the physician fee schedule when you bill under your own NPI. So a 99213 that pays a psychiatrist $95 will pay an NP about $81.

Some private insurers follow this 85% model, while others credential NPs at full physician rates or pay based on negotiated contracts. A few states (like Nevada and Maryland) have equal reimbursement laws mandating that NPs be paid the same as MDs for the same service—but this isn’t universal.

Workaround: In some settings, NPs can bill their services ‘incident to’ a physician (meaning the physician is on-site and the NP is functionally extending the physician’s practice). This can yield 100% reimbursement—but it doesn’t work for telehealth, since the physician isn’t physically supervising.

Bottom line: If you’re a PMHNP, expect to generate about 85% of the revenue per visit compared to an MD in most payer scenarios. It’s a consideration for practice economics, but the demand for psychiatric services is so high that many NPs have full schedules regardless.

Private Insurance and Medicaid

Commercial plans often pay more than Medicare, especially in high-cost areas. A major insurer might pay $150 for a 99213 and $200 for a 99214 in a metro market. Rates vary widely by region and negotiation.

Medicaid typically pays less per visit (e.g., $60-80 for a 15-minute med check in Florida Medicaid), but Medicaid enrollees are a large and underserved population—high volume can offset lower rates. Many states’ Medicaid programs have enhanced behavioral health payments and care management codes.

Parity laws: States like Illinois (SB 667), California (AB 744), New York, and others have passed laws requiring private insurers to reimburse telehealth at parity with in-person care. This is especially strong for behavioral health services.

New Reimbursement Models

• Collaborative Care Model (CoCM): If you’re serving as a psychiatric consultant to primary care teams, you can bill CoCM codes (e.g., 99492 for the first month, $161 from Medicare) for monthly oversight of patients managed by PCPs. This is a growing revenue stream for telepsychiatrists.
• Audio-only telehealth: Medicare and some states now reimburse for mental health services delivered via phone (no video) at the same rate as office visits, to address the digital divide. If you do brief phone check-ins, this can be billable in appropriate cases.

The Economics of Patient Acquisition: Why Klarity Health Makes Sense

Here’s the reality most solo practitioners or small groups don’t talk about: acquiring a qualified psychiatric patient through DIY marketing is expensive and uncertain.

Let’s break down the actual costs:

• SEO: Takes 6-12 months of consistent investment before you see meaningful patient flow. You’ll pay an agency or consultant $1,500-3,000+/month, plus your own time, with no guarantee of results.
• Google Ads: Mental health keywords are competitive—$15-40+ per click. Most clicks don’t convert to booked patients. Realistically, you’ll spend $200-400+ per booked patient once you factor in ad spend, testing, and no-shows.
• Directory listings: Psychology Today charges monthly fees and you’re competing with hundreds of other providers on the same page. Zocdoc charges per booking ($35-100+ per new patient) plus a monthly subscription. Total monthly cost adds up quickly.
• Failed campaigns: Many providers spend $3,000-5,000/month on marketing with uncertain ROI. You’re gambling that your ads will convert, your SEO will rank, and your leads will show up.

The alternative: Platforms like Klarity Health use a pay-per-appointment model—you pay a standard listing fee only when a pre-qualified patient books with you. No upfront marketing spend, no monthly subscriptions, no wasted ad dollars on clicks that don’t convert.

Value props:

• Pre-qualified patients: Klarity matches patients to your specialty and availability, so you’re not chasing cold leads
• Built-in telehealth infrastructure: No need to pay separately for a video platform or EHR integration
• Both insurance and cash-pay patient flow: Flexibility to build the practice you want
• You control your schedule: Only pay when you actually see patients—guaranteed ROI vs. gambling on marketing channels

Frame it this way: Instead of spending $3,000-5,000/month on uncertain marketing, you pay only when a qualified patient sits down (virtually) for an appointment. That’s predictable economics, not a bet on SEO or ad performance.

For most providers—especially those starting out, scaling, or expanding to new states—a platform that handles patient acquisition removes the risk entirely. You focus on clinical care; the platform handles the pipeline.

Compliance Essentials: What You Must Do to Stay Legal

Whether you’re a psychiatrist or PMHNP, telehealth prescribing comes with compliance responsibilities. Here’s your checklist:

1. Licensure in the Patient’s State

You must be licensed in the state where the patient is located at the time of the consult. If you’re treating patients across multiple states, you’ll need multiple licenses. The Interstate Medical Licensure Compact (IMLC) helps physicians expedite licensure in member states—Texas, Pennsylvania, and Illinois are members; New York, Florida, and California are not (so you’ll need to go through the traditional process for those).

2. DEA Registration

If you’re prescribing controlled substances, you need a DEA registration in the state where you’re practicing. Some states (like Texas) require a separate state-level controlled substance registration as well.

3. Prescription Monitoring Program (PMP) Checks

Most states require checking the PMP database before prescribing Schedule II–IV medications:

• Texas: Must check the Texas PMP before prescribing any controlled substance
• New York: Must check the I-STOP database before prescribing Schedule II–IV
• California: Must check CURES and document it
• Florida, Pennsylvania, Illinois: Similar requirements

Failure to check the PMP can result in board discipline, even if the prescription was clinically appropriate.

4. Standard of Care and Documentation

Your telehealth evaluation must meet the same standard as an in-person exam. That means:

• Conducting a thorough psychiatric history and mental status exam
• Verifying the patient’s identity and location
• Documenting the technology used (video platform, etc.) and confirming the patient’s consent for telehealth
• Having an emergency protocol if the patient is in crisis (e.g., if a suicidal patient disconnects)

States like Texas and California explicitly require informed consent for telehealth and documentation of the telehealth modality.

5. Collaborative Agreements (for NPs in Restricted States)

If you’re a PMHNP in Texas, Florida, or Pennsylvania, ensure your collaborative practice agreement is:

• Current and filed with the appropriate state board
• Specific about your prescribing authority (what drugs, what schedules)
• Compliant with chart review and meeting frequency requirements
• Updated if you change practice sites or supervisors

Missing or outdated agreements can jeopardize your license.

State-by-State Quick Reference Table

Final Takeaway: Know Your State, Stay Compliant, and Focus on Patients

If there’s one thing to remember, it’s this: prescribing authority and telehealth rules vary wildly by state, and the regulations are still evolving.

• Psychiatrists have it easiest—you can practice independently everywhere, and current federal waivers allow you to prescribe controlled substances via telehealth across all states (subject to state law nuances).
• PMHNPs face a patchwork: some states (NY, IL, CA soon) grant full autonomy after a transition period, while others (TX, FL, PA) require ongoing physician oversight.

The key is to stay informed. Check your state board’s website for updates, monitor DEA announcements for changes to controlled-substance prescribing rules, and ensure your collaborative agreements (if applicable) are current.

And if you’re tired of navigating patient acquisition on your own—spending thousands on ads that may or may not work, waiting months for SEO to pay off, or competing on crowded directory listings—consider joining a platform like Klarity Health, where you pay only when a pre-qualified patient books with you. No upfront marketing costs, no wasted ad spend, no uncertainty. Just patients who need your expertise, and infrastructure that supports your practice.

Ready to simplify your practice and focus on what you do best—treating patients? Explore Klarity Health’s provider network and see how telehealth can work for you, without the headaches of DIY marketing.

Frequently Asked Questions

Q: Can I prescribe Adderall or Ritalin via telehealth in 2026?
A: Yes, under current federal rules (DEA waiver extended through Dec 31, 2025). However, this depends on your state—some states like Texas have additional restrictions for NPs. Psychiatrists can generally prescribe Schedule II stimulants via telehealth nationwide, as long as they comply with state telehealth laws. Stay alert for DEA rule changes in late 2024 or 2025.

Q: Do PMHNPs get paid less than psychiatrists for the same visit?
A: Often, yes—Medicare reimburses NPs at 85% of the physician fee schedule when billed under the NP’s NPI. Private insurers vary; some pay equal rates, others follow the 85% model. A few states mandate equal reimbursement by law (e.g., Nevada, Maryland), but it’s not universal.

Q: What’s the difference between a collaborative agreement and full practice authority?
A: A collaborative agreement requires an NP to work under a physician’s oversight (chart reviews, periodic meetings, etc.). Full Practice Authority (FPA) means the NP can practice independently, with no physician supervision—they diagnose, treat, and prescribe under their own license. About half of U.S. states now grant FPA to experienced NPs.

Q: Can I treat patients in multiple states via telehealth?
A: Yes, but you must be licensed in each state where your patients are located at the time of the consultation. The Interstate Medical Licensure Compact (IMLC) can expedite physician licensure in member states (Texas, Pennsylvania, Illinois are members; New York, Florida, California are not). NPs may have similar compacts (APRN Compact), but scope-of-practice laws still apply in each state.

Q: How much does it cost to acquire a psychiatric patient through DIY marketing?
A: Realistically, $200-500+ per qualified patient when you factor in all costs—agency fees, ad spend, staff time to handle leads, no-show rates, and months of SEO investment. SEO takes 6-12 months before generating meaningful patient flow. Google Ads for mental health keywords cost $15-40+ per click, and most clicks don’t convert. Platforms like Klarity Health eliminate this uncertainty by charging only when a patient books with you.

Q: What happens if the DEA changes the controlled-substance telehealth rules?
A: The DEA has proposed new permanent rules that could re-impose some in-person requirements (e.g., a 30-day prescription limit without an in-person visit, or requiring a special telemedicine registration). These haven’t been finalized yet. When they are, you’ll need to adjust your practice—possibly requiring an in-person visit after an initial telehealth prescription, or limiting refills until an in-person exam. Monitor DEA announcements and consult legal/compliance experts when the final rule drops.

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