Ownership: A 50-state CPOM chart lists Hawaii as having no corporate practice of medicine doctrine (citing HRS 453-2).
Certificate of need: Hawaii runs a CON program through the State Health Planning and Development Agency covering hospitals, surgical centers, ambulatory health care facilities, nursing homes and other facilities, triggered by capital spending over the minimum and changes in beds or services.
Nurse practitioners: AANP classifies Hawaii as full practice, so APRNs can evaluate, diagnose, treat and prescribe under Board of Nursing licensure without a physician agreement; AANP's state page lists no transition-to-practice requirement.
Who can own a medical clinic in Hawaii
A 50-state CPOM chart lists Hawaii as having no corporate practice of medicine doctrine (citing HRS 453-2). Physicians still commonly organize as professional corporations under HRS 415A, which limit share ownership to qualified licensed persons; Hawaii-specific guidance on non-physician ownership or MSO structures was not found from a state source.
Sources: ndlegis.gov, law.justia.com
Business entity and registration
Physicians may form a professional corporation under HRS Chapter 415A, whose shares may be owned only by qualified persons eligible under that chapter; LLCs are also used. Entities are registered with the DCCA Business Registration Division, which is moving to a new online portal from July 2026.
Sources: law.justia.com, cca.hawaii.gov
Certificate of need in Hawaii
Hawaii runs a CON program through the State Health Planning and Development Agency covering hospitals, surgical centers, ambulatory health care facilities, nursing homes and other facilities, triggered by capital spending over the minimum and changes in beds or services. Private physician offices are exempt (as distinguished from organized ambulatory facilities) except for equipment purchases above the expenditure minimum, and primary care clinics under the statutory thresholds are exempt, so an ASC or larger organized clinic may need a CON.
Sources: ncsl.org, law.justia.com
Licenses, registrations and state agencies
The Department of Health's Office of Health Care Assurance licenses ambulatory surgical centers, hospitals, home health agencies, clinical laboratories and similar facilities, and certifies rural health clinics for Medicare. Its licensing list does not include ordinary physician offices or general outpatient clinics.
Sources: health.hawaii.gov
Hawaii-specific requirements to know
Anyone who prescribes, administers or dispenses controlled substances in Hawaii needs a state controlled substance registration from the Department of Law Enforcement (formerly the Department of Public Safety) in addition to DEA registration, and letting it lapse causes automatic forfeiture. CON review can apply to organized ambulatory facilities and to physician-office equipment purchases above the expenditure minimum.
Sources: law.justia.com, law.justia.com
Agencies you will deal with
- Medical board: Hawaii Medical Board (DCCA Professional and Vocational Licensing)
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Hawaii Department of Commerce and Consumer Affairs, Business Registration Division (BREG)
- Facility licensing: Hawaii Department of Health, Office of Health Care Assurance (OHCA)
- Medicaid enrollment: Hawaii Med-QUEST (Department of Human Services)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Hawaii as full practice, so APRNs can evaluate, diagnose, treat and prescribe under Board of Nursing licensure without a physician agreement; AANP's state page lists no transition-to-practice requirement.
Sources: aanp.org
Physician assistants: PAs must practice under a supervising physician at a degree the Medical Board sets, with chart review of 50 percent of records for the first six months and 25 percent for the next six for PAs with under one year of experience, then a monthly audit of at least 30 minutes; a PA without a supervising physician cannot practice.
Sources: law.justia.com, cca.hawaii.gov
Med spas, injectables and IV therapy in Hawaii
We could not find complete published guidance on med spas, injectables or IV therapy in Hawaii. Ask the medical board and the board of nursing directly, and confirm delegation and supervision with a healthcare attorney before offering these services.
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 Hawaii
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Hawaii’s corporate practice of medicine rules. A 50-state CPOM chart lists Hawaii as having no corporate practice of medicine doctrine (citing HRS 453-2).
- Form the entity with the Hawaii Department of Commerce and Consumer Affairs, Business Registration Division (BREG). Physicians may form a professional corporation under HRS Chapter 415A, whose shares may be owned only by qualified persons eligible under that chapter; LLCs are also used.
- 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 Hawaii Medical Board (DCCA Professional and Vocational Licensing). Every physician needs a Hawaii license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. Hawaii runs a CON program through the State Health Planning and Development Agency covering hospitals, surgical centers, ambulatory health care facilities, nursing homes and other facilities, triggered by capital spending over the minimum and changes in beds or services.
- Register to prescribe. Register with the DEA for controlled substances and complete any Hawaii controlled substance registration and prescription monitoring program enrollment. Anyone who prescribes, administers or dispenses controlled substances in Hawaii needs a state controlled substance registration from the Department of Law Enforcement (formerly the Department of Public Safety) in addition to DEA registration, and letting it lapse causes automatic forfeiture.
- 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 Hawaii Med-QUEST (Department of Human Services) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Hawaii as full practice, so APRNs can evaluate, diagnose, treat and prescribe under Board of Nursing licensure without a physician agreement; AANP's state page lists no transition-to-practice requirement.
- 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 Hawaii
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 Hawaii launch with us →
Sources
- https://ndlegis.gov/assembly/67-2021/testimony/SHUMSER-2128-20210125-3125-F-TRAYNOR_PAT.pdf
- https://law.justia.com/codes/hawaii/title-23/chapter-415a/section-415a-2/
- https://cca.hawaii.gov/breg/
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://law.justia.com/codes/hawaii/title-19/chapter-323d/section-323d-54/
- https://www.aanp.org/advocacy/hawaii
- https://law.justia.com/codes/hawaii/title-25/chapter-453/section-453-5-3/
- https://cca.hawaii.gov/wp-content/uploads/2026/09/FAQ-PA-final-2026.pdf
- https://health.hawaii.gov/ohca/
- https://law.justia.com/codes/hawaii/title-19/chapter-329/section-329-32/