Ownership: Nebraska has no strong corporate practice of medicine bar: early Nebraska Supreme Court cases allowed corporations and hospital owners to employ licensed physicians.
Certificate of need: Nebraska has a Certificate of Need program, but it covers long-term care beds (skilled nursing, intermediate care, nursing facilities, long-term care hospitals), and 2024's LB 1215 exempted rehabilitation and acute care beds.
Nurse practitioners: AANP classifies Nebraska as full practice; a new NP must first complete 2,000 hours under a transition-to-practice agreement with a supervising physician or an NP who has at least 10,000 practice hours.
Who can own a medical clinic in Nebraska
Nebraska has no strong corporate practice of medicine bar: early Nebraska Supreme Court cases allowed corporations and hospital owners to employ licensed physicians. Physician-owned professional corporations or professional LLCs are still the usual structure, and a professional corporation's shareholders must be licensed in the profession.
Sources: permithealth.com, moriarty.com, horganlawfirm.com
Business entity and registration
Physicians commonly form a professional corporation under the Nebraska Professional Corporation Act (shareholders must hold the relevant Nebraska license) or a limited liability company rendering health-related professional services, which files a list of its licensed members, managers and professional employees with the Secretary of State.
Sources: horganlawfirm.com, sos.Nebraska.gov, sos.nebraska.gov
Certificate of need in Nebraska
Nebraska has a Certificate of Need program, but it covers long-term care beds (skilled nursing, intermediate care, nursing facilities, long-term care hospitals), and 2024's LB 1215 exempted rehabilitation and acute care beds. It does not reach typical physician offices, ASCs or imaging.
Sources: ncsl.org
Licenses, registrations and state agencies
DHHS licenses health clinics, but a practitioner's own clinic or office does not need a health clinic license unless it is an ambulatory surgical center, provides hemodialysis or labor and delivery, or performs 10 or more abortions in a week. ASCs and public health clinics are licensed as health clinics; federally certified rural health clinics are exempt.
Sources: dhhs.ne.gov, law.justia.com
Nebraska-specific requirements to know
Nebraska's PDMP collects all dispensed prescriptions, not just controlled substances, so prescribers should set up PDMP access. A physician office that adds surgery suites, dialysis or similar services can trigger health clinic licensure. New NPs hired into a practice need a transition-to-practice agreement until they reach 2,000 hours.
Sources: healthcareitnews.com, dhhs.ne.gov, dhhs.ne.gov
Agencies you will deal with
- Medical board: Nebraska Board of Medicine and Surgery (DHHS Licensure Unit)
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Nebraska Secretary of State, Business Services Division
- Facility licensing: Nebraska Department of Health and Human Services, Licensure Unit
- Medicaid enrollment: Nebraska Medicaid (Heritage Health managed care; enrollment via Maximus)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Nebraska as full practice; a new NP must first complete 2,000 hours under a transition-to-practice agreement with a supervising physician or an NP who has at least 10,000 practice hours.
Sources: aanp.org, campaignforaction.org, dhhs.ne.gov
Physician assistants: PAs provide services delegated by and under the supervision of a licensed physician, with at least one supervising physician per employer, and prescribe under a collaborative agreement with that supervising physician.
Sources: nebraskalegislature.gov, nebraskalegislature.gov
Med spas, injectables and IV therapy in Nebraska
The Board of Nursing's non-binding Aesthetic Nursing advisory opinion (2021) lets RNs and NPs perform neuromodulators, fillers and many laser procedures only after a licensed practitioner assesses the patient and orders each episode of care; standing orders are not acceptable, Level III procedures need the practitioner on site, and aesthetic procedures may not be delegated to unlicensed staff. No board guidance on med spa ownership or IV hydration was found.
Sources: dhhs.ne.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 Nebraska
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Nebraska’s corporate practice of medicine rules. Nebraska has no strong corporate practice of medicine bar: early Nebraska Supreme Court cases allowed corporations and hospital owners to employ licensed physicians.
- Form the entity with the Nebraska Secretary of State, Business Services Division. Physicians commonly form a professional corporation under the Nebraska Professional Corporation Act (shareholders must hold the relevant Nebraska license) or a limited liability company rendering health-related professional services, which files a list of its licensed members, managers and professional employees with the Secretary of State.
- 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 Nebraska Board of Medicine and Surgery (DHHS Licensure Unit). Every physician needs a Nebraska license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. Nebraska has a Certificate of Need program, but it covers long-term care beds (skilled nursing, intermediate care, nursing facilities, long-term care hospitals), and 2024's LB 1215 exempted rehabilitation and acute care beds.
- Register to prescribe. Register with the DEA for controlled substances and complete any Nebraska controlled substance registration and prescription monitoring program enrollment. Nebraska's PDMP collects all dispensed prescriptions, not just controlled substances, so prescribers should set up PDMP access.
- 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 Nebraska Medicaid (Heritage Health managed care; enrollment via Maximus) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Nebraska as full practice; a new NP must first complete 2,000 hours under a transition-to-practice agreement with a supervising physician or an NP who has at least 10,000 practice hours.
- 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 Nebraska
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 Nebraska launch with us →
Sources
- https://www.permithealth.com/post/nebraska-corporate-practice-of-medicine-cpom-guide
- https://www.moriarty.com/content/documents/ML_PDFs/cpmd_4.10.12.pdf
- https://horganlawfirm.com/private-equity-nebraska-professional-practices/
- https://sos.Nebraska.gov/sites/default/files/doc/Form%20PC%20LLC_7.01.2021.pdf
- https://sos.nebraska.gov/new-online-business-filing-system
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://www.aanp.org/advocacy/nebraska
- https://campaignforaction.org/nebraska-joins-19-states-d-c-modernizing-nurse-practitioner-law/
- https://dhhs.ne.gov/licensure/Documents/TransitionToPracticeAgreement.pdf
- https://nebraskalegislature.gov/laws/statutes.php?statute=38-2047
- https://nebraskalegislature.gov/laws/statutes.php?statute=38-2055
- https://dhhs.ne.gov/licensure/Pages/Health-Clinics.aspx
- https://law.justia.com/codes/nebraska/2023/chapter-71/statute-71-416
- https://dhhs.ne.gov/licensure/Documents/AestheticNursing.pdf
- https://www.healthcareitnews.com/news/nebraska-becomes-first-state-require-all-drugs-be-reported-prescription-monitoring-program