Ownership: Florida does not explicitly prohibit non-physicians from owning a medical practice, but a clinic that bills third parties and is not wholly owned by licensed health care practitioners (or their spouse, parent, child or sibling) must hold an AHCA health care clinic license.
Certificate of need: Florida's CON program now covers only hospices, freestanding inpatient hospice facilities, skilled nursing facilities and intermediate care facilities for the developmentally disabled.
Nurse practitioners: AANP classifies Florida as restricted practice; APRNs generally practice under a supervising physician protocol, but an APRN with 3,000 supervised clinical hours in the prior five years plus required coursework can register with the Board of Nursing for autonomous practice limited to primary care (family medicine, general pediatrics, general internal medicine).
Who can own a medical clinic in Florida
Florida does not explicitly prohibit non-physicians from owning a medical practice, but a clinic that bills third parties and is not wholly owned by licensed health care practitioners (or their spouse, parent, child or sibling) must hold an AHCA health care clinic license. Physician-owned practices usually hold a certificate of exemption instead, and an MSO deal that moves ownership outside that group ends the exemption.
Sources: natlawreview.com, leg.state.fl.us, physicianspractice.com
Business entity and registration
Physicians commonly form a professional service corporation (often styled P.A.) or a professional limited liability company (PLLC); owners must be licensed in the same profession. Entities are filed with the Florida Department of State, Division of Corporations (Sunbiz).
Sources: natlawreview.com, dos.fl.gov
Certificate of need in Florida
Florida's CON program now covers only hospices, freestanding inpatient hospice facilities, skilled nursing facilities and intermediate care facilities for the developmentally disabled. Outpatient services, major medical equipment and hospitals are excluded, so typical physician offices, ASCs and imaging centers do not need a CON.
Sources: ahca.myflorida.com, ncsl.org
Licenses, registrations and state agencies
AHCA licenses health care clinics under the Health Care Clinic Act (Ch. 400, Part X) unless exempt; practitioner-owned practices file for a certificate of exemption, renewed every two years, and must post a schedule of charges. Licensed clinics must appoint a medical or clinic director who accepts legal responsibility for compliance. AHCA also licenses ambulatory surgical centers (Ch. 395), and pain-management clinics must register with the Department of Health.
Sources: ahca.myflorida.com, ahca.myflorida.com, leg.state.fl.us, ahca.myflorida.com
Florida-specific requirements to know
Pain-management clinics (those advertising pain services or where most patients in a month get opioids, benzodiazepines, barbiturates or carisoprodol for chronic nonmalignant pain) must register with the Department of Health, be physician-owned or AHCA-licensed, and name a designated physician. Prescribers must check the E-FORCSE PDMP before prescribing controlled substances to patients 16 and older. Out-of-state clinicians can treat Florida patients by telehealth only after registering with the relevant Florida board, and Schedule II drugs generally cannot be prescribed by telehealth.
Sources: flsenate.gov, flhealthsource.gov, leg.state.fl.us
Agencies you will deal with
- Medical board: Florida Board of Medicine (Florida Board of Osteopathic Medicine licenses DOs)
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Florida Department of State, Division of Corporations (Sunbiz)
- Facility licensing: Agency for Health Care Administration (AHCA), Hospital and Outpatient Services Unit
- Medicaid enrollment: Florida Medicaid (AHCA, Florida MMIS)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Florida as restricted practice; APRNs generally practice under a supervising physician protocol, but an APRN with 3,000 supervised clinical hours in the prior five years plus required coursework can register with the Board of Nursing for autonomous practice limited to primary care (family medicine, general pediatrics, general internal medicine).
Sources: aanp.org, flsenate.gov
Physician assistants: PAs practice under a supervising physician who must be easily available (telecommunication counts) or physically present, and a physician may supervise no more than 10 PAs at one time.
Sources: leg.state.fl.us
Med spas, injectables and IV therapy in Florida
Florida statutes do not define a med spa, and non-physicians may own one; in that case the business falls under the Health Care Clinic Act and needs an AHCA clinic license with a medical director who accepts legal responsibility for compliance. Physician supervision is required for certain procedures such as laser treatments. Confirm the details with the state board and a healthcare attorney.
Sources: pbglaw.com, leg.state.fl.us, leg.state.fl.us
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 Florida
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Florida’s corporate practice of medicine rules. Florida does not explicitly prohibit non-physicians from owning a medical practice, but a clinic that bills third parties and is not wholly owned by licensed health care practitioners (or their spouse, parent, child or sibling) must hold an AHCA health care clinic license.
- Form the entity with the Florida Department of State, Division of Corporations (Sunbiz). Physicians commonly form a professional service corporation (often styled P.A.) or a professional limited liability company (PLLC); owners must be licensed in the same profession.
- 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 Florida Board of Medicine (Florida Board of Osteopathic Medicine licenses DOs). Every physician needs a Florida license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. Florida's CON program now covers only hospices, freestanding inpatient hospice facilities, skilled nursing facilities and intermediate care facilities for the developmentally disabled.
- Register to prescribe. Register with the DEA for controlled substances and complete any Florida controlled substance registration and prescription monitoring program enrollment. Pain-management clinics (those advertising pain services or where most patients in a month get opioids, benzodiazepines, barbiturates or carisoprodol for chronic nonmalignant pain) must register with the Department of Health, be physician-owned or AHCA-licensed, and name a designated physician.
- 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 Florida Medicaid (AHCA, Florida MMIS) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Florida as restricted practice; APRNs generally practice under a supervising physician protocol, but an APRN with 3,000 supervised clinical hours in the prior five years plus required coursework can register with the Board of Nursing for autonomous practice limited to primary care (family medicine, general pediatrics, general internal medicine).
- 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 Florida
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 Florida launch with us →
Sources
- https://natlawreview.com/article/navigating-floridas-corporate-practice-medicine
- http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0400/Sections/0400.9905.html
- https://www.physicianspractice.com/view/a-florida-mso-deal-can-cost-your-practice-its-clinic-license-exemption
- https://dos.fl.gov/sunbiz/
- https://ahca.myflorida.com/health-quality-assurance/bureau-of-health-facility-regulation/certificate-of-need-and-commercial-managed-care-unit/certificate-of-need-con-program-overview.html
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://www.aanp.org/advocacy/florida
- https://www.flsenate.gov/Laws/Statutes/2025/464.0123
- http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0458/Sections/0458.347.html
- https://ahca.myflorida.com/health-quality-assurance/bureau-of-health-facility-regulation/hospital-outpatient-services-unit/health-care-clinics.html
- https://ahca.myflorida.com/health-quality-assurance/bureau-of-health-facility-regulation/hospital-outpatient-services-unit/health-care-clinics/exemption-from-licensure.html
- http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0400/Sections/0400.9935.html
- https://ahca.myflorida.com/health-quality-assurance/bureau-of-health-facility-regulation/hospital-outpatient-services-unit/ambulatory-surgical-center.html
- https://www.pbglaw.com/blog/floridas-med-spa-boom-is-testing-the-limits-of-the-law/
- https://www.flsenate.gov/Laws/Statutes/2025/458.3265
- https://flhealthsource.gov/FloridaTakeControl/pdmp
- http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0456/Sections/0456.47.html