How to Start a Medical Clinic in Maryland (2026)

Ownership: Maryland has no single CPOM statute and its courts have never expressly adopted the doctrine, but the Board of Physicians and the Attorney General have indicated that entities owned by non-licensed persons may not practice medicine.

Certificate of need: The Maryland Health Care Commission runs a CON program.

Nurse practitioners: AANP classifies Maryland as full practice; a first-time NP applicant must name a certified NP or physician mentor who will consult and collaborate with them for 18 months (Health Occ. 8-302.1).

Who can own a medical clinic in Maryland

Maryland has no single CPOM statute and its courts have never expressly adopted the doctrine, but the Board of Physicians and the Attorney General have indicated that entities owned by non-licensed persons may not practice medicine. Physician-owned professional associations and LLCs are typical, and non-physician investors usually work through management services arrangements.

Sources: gfrlaw.com

Business entity and registration

Physicians commonly form a professional corporation or professional association under Title 5 of the Corporations and Associations Article (limited to a single profession or related professions) or an LLC. Charter filings go to the State Department of Assessments and Taxation (SDAT), mostly online through Maryland Business Express.

Sources: mgaleg.maryland.gov, dat.maryland.gov, businessexpress.maryland.gov

Certificate of need in Maryland

The Maryland Health Care Commission runs a CON program. Since October 1, 2019 an ambulatory surgical facility needing a CON is one with three or more operating rooms; a center with up to two ORs is a physician outpatient surgery center that needs a determination of coverage from MHCC rather than a CON. Ordinary physician offices are not reviewed.

Sources: mhcc.maryland.gov, ncsl.org

Licenses, registrations and state agencies

The Office of Health Care Quality licenses freestanding ambulatory surgical centers, which must first obtain a CON or a determination of coverage from MHCC; OHCQ also licenses freestanding medical facilities. We found no OHCQ license for ordinary physician offices or urgent care clinics.

Sources: health.maryland.gov, mhcc.maryland.gov

Maryland-specific requirements to know

Anyone who dispenses, prescribes or administers controlled dangerous substances needs a state CDS registration (permit) from the MDH Office of Controlled Substances Administration in addition to DEA registration. Prescribers must pull at least 4 months of PDMP data before starting an opioid or benzodiazepine and at least every 90 days during ongoing treatment, with listed exemptions. A surgery center with up to two ORs still needs an MHCC determination of coverage before OHCQ licensure.

Sources: mgaleg.maryland.gov, health.maryland.gov, mgaleg.maryland.gov, health.maryland.gov

Agencies you will deal with

Medical board: Maryland Board of Physicians
Board of nursing: Board of nursing
Board of pharmacy: Board of pharmacy
Business registration: Maryland State Department of Assessments and Taxation (SDAT)
Facility licensing: Maryland Department of Health, Office of Health Care Quality (OHCQ)
Medicaid enrollment: Maryland Medicaid (enrollment through MPRIME)

Nurse practitioners and physician assistants

Sources: storage.aanp.org, mgaleg.maryland.gov

Physician assistants: Under the Physician Assistant Modernization Act of 2024 (effective October 1, 2024), Maryland PAs practice under a collaboration agreement with a physician or physician group, notified to the Board of Physicians before practice, which replaced the former delegation agreement.

Sources: mbp.state.md.us, mgaleg.maryland.gov

Med spas, injectables and IV therapy in Maryland

Board of Physicians regulations (COMAR 10.32.09) govern cosmetic medical procedures and devices such as lasers: a physician may delegate to a PA or assign to another licensed provider whose board says it is within scope, and the individual must complete required training. The delegating physician must personally do the initial assessment, write a treatment plan, keep written protocols, and provide onsite supervision whenever a non-physician performs the procedure, with a limited exception for board-approved PA arrangements.

Sources: regs.maryland.gov, regs.maryland.gov

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 Maryland

Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Maryland’s corporate practice of medicine rules. Maryland has no single CPOM statute and its courts have never expressly adopted the doctrine, but the Board of Physicians and the Attorney General have indicated that entities owned by non-licensed persons may not practice medicine.
Form the entity with the Maryland State Department of Assessments and Taxation (SDAT). Physicians commonly form a professional corporation or professional association under Title 5 of the Corporations and Associations Article (limited to a single profession or related professions) or an LLC.
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 Maryland Board of Physicians. Every physician needs a Maryland license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
Check certificate of need and facility licensing. The Maryland Health Care Commission runs a CON program.
Register to prescribe. Register with the DEA for controlled substances and complete any Maryland controlled substance registration and prescription monitoring program enrollment. Anyone who dispenses, prescribes or administers controlled dangerous substances needs a state CDS registration (permit) from the MDH Office of Controlled Substances Administration in addition to DEA registration.
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 Maryland Medicaid (enrollment through MPRIME) and start commercial credentialing early, because payer enrollment often takes months.
Plan staffing around NP and PA rules. AANP classifies Maryland as full practice; a first-time NP applicant must name a certified NP or physician mentor who will consult and collaborate with them for 18 months (Health Occ. 8-302.1).
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 Maryland

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 Maryland launch with us →

Important. This guide is general information checked against official and professional sources in October 2026. It is not legal advice. Rules change and details depend on your services, so confirm your plan with a healthcare attorney licensed in Maryland and with the agencies listed above.

Sources

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How to start a medical clinic in Maryland.