Ownership: Colorado's Medical Practice Act states that corporations shall not practice medicine, and a professional service entity practicing medicine must be owned by Colorado-licensed physicians (PAs may hold minority shares).
Certificate of need: No.
Nurse practitioners: AANP classifies Colorado as full practice; to gain prescriptive authority an NP must complete 750 hours of experience under a mentorship agreement with a physician or APRN.
Who can own a medical clinic in Colorado
Colorado's Medical Practice Act states that corporations shall not practice medicine, and a professional service entity practicing medicine must be owned by Colorado-licensed physicians (PAs may hold minority shares). By statute, hospitals and other licensed health care facilities may employ physicians as long as they do not control the physician's independent judgment; non-physician investors otherwise typically use an MSO structure.
Sources: codes.findlaw.com, codes.findlaw.com
Business entity and registration
Physicians form a professional service corporation, professional LLC or registered LLP under C.R.S. 12-240-138, with physician shareholders, a president who is a shareholder and director, and a name that includes professional company, professional corporation or prof. Entities are filed with the Colorado Secretary of State.
Sources: codes.findlaw.com, coloradosos.gov
Certificate of need in Colorado
No. Colorado has no CON program, so physician offices, ASCs and imaging centers do not need a CON.
Sources: ncsl.org
Licenses, registrations and state agencies
CDPHE licenses facility types including ambulatory surgical centers, community clinics and community clinics with emergency rooms, freestanding emergency departments, dialysis treatment clinics, birth centers, rural health clinics, comprehensive outpatient rehab facilities and portable x-ray services. Ordinary physician offices are not on CDPHE's regulated facility list.
Sources: cdphe.colorado.gov, cdphe.colorado.gov
Colorado-specific requirements to know
Colorado prescribers are required to use the state PDMP, run by the Division of Professions and Occupations. A PA collaborating physician must have a regular and reliable physical presence in Colorado; telehealth-only practice does not qualify. NPs need 750 mentored hours before independent prescriptive authority, which affects NP-led clinic staffing.
Sources: dpo.colorado.gov, dpo.colorado.gov, storage.aanp.org
Agencies you will deal with
- Medical board: Colorado Medical Board
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Colorado Secretary of State
- Facility licensing: Colorado Department of Public Health and Environment, Health Facilities and Emergency Medical Services Division
- Medicaid enrollment: Health First Colorado (Department of Health Care Policy and Financing)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Colorado as full practice; to gain prescriptive authority an NP must complete 750 hours of experience under a mentorship agreement with a physician or APRN.
Sources: storage.aanp.org
Physician assistants: Since SB23-083, PAs practice under a written collaborative agreement with a physician or physician group, and PAs with fewer than 5,000 practice hours (or fewer than 3,000 hours in a new practice area) must use a supervisory agreement that includes collaboration during the first 160 hours and a performance evaluation.
Sources: dpo.colorado.gov
Med spas, injectables and IV therapy in Colorado
Physicians may delegate medical services to unlicensed persons only under Colorado Medical Board Rule 800 (adopted under C.R.S. 12-240-107(3)(l), now recodified in 3 CCR 713-1), and because corporations may not practice medicine, a med spa providing medical services generally needs a physician-owned professional entity, an MSO arrangement, or a structure supported by Colorado counsel. Confirm the details with the state board and a healthcare attorney.
Sources: sos.state.co.us, codes.findlaw.com
Planning an aesthetic or IV business? See how to start a med spa and how to start an IV therapy business.
Step-by-step checklist in Colorado
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Colorado’s corporate practice of medicine rules. Colorado's Medical Practice Act states that corporations shall not practice medicine, and a professional service entity practicing medicine must be owned by Colorado-licensed physicians (PAs may hold minority shares).
- Form the entity with the Colorado Secretary of State. Physicians form a professional service corporation, professional LLC or registered LLP under C.R.S. 12-240-138, with physician shareholders, a president who is a shareholder and director, and a name that includes professional company, professional corporation or prof.
- Get federal numbers. Apply for an EIN from the IRS, then a Type 2 NPI for the practice and Type 1 NPIs for each clinician through NPPES.
- Confirm licenses with the Colorado Medical Board. Every physician needs a Colorado license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. No. Colorado has no CON program, so physician offices, ASCs and imaging centers do not need a CON.
- Register to prescribe. Register with the DEA for controlled substances and complete any Colorado controlled substance registration and prescription monitoring program enrollment. Colorado prescribers are required to use the state PDMP, run by the Division of Professions and Occupations.
- Set up lab, safety and privacy basics. Get a CLIA certificate if you will run any lab tests, including waived tests, and put HIPAA privacy and security and OSHA policies in place.
- Enroll with Medicare, Medicaid and insurers. Enroll in Medicare through PECOS, enroll with Health First Colorado (Department of Health Care Policy and Financing) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Colorado as full practice; to gain prescriptive authority an NP must complete 750 hours of experience under a mentorship agreement with a physician or APRN.
- Launch your marketing before opening day. Claim your Google Business Profile, publish a website with online booking and start ads and content four to eight weeks before you open, so the schedule is not empty on day one.
The national steps are explained in more detail in our guide to how to start a medical clinic, and costs are broken down in how much it costs to start a clinic.
Marketing a new clinic in Colorado
New clinics usually fail on cash flow before they fail on care. The fastest fix is patients booked before opening day: a complete Google Business Profile, a website with online booking, local search ads and a few weeks of social content showing the team and the space. We run that launch for new clinics and keep it going once the doors open.
Plan your Colorado launch with us →
Sources
- https://codes.findlaw.com/co/title-12-professions-and-occupations/co-rev-st-sect-12-240-138/
- https://codes.findlaw.com/co/title-25-health/co-rev-st-sect-25-3-103-7/
- https://www.coloradosos.gov/biz/
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://storage.aanp.org/www/documents/no-index/state-fact-sheets/colorado.pdf
- https://dpo.colorado.gov/Medical/PAAgreements
- https://cdphe.colorado.gov/health-facilities/regulated-facilities
- https://cdphe.colorado.gov/health-facilities
- https://www.sos.state.co.us/CCR/NumericalCCRDocList.do?deptID=18&agencyID=68
- https://dpo.colorado.gov/PDMP