Ownership: North Dakota recognizes a corporate practice of medicine doctrine (1990 Attorney General advisory letter, and a 2007 case treating employment of doctors by an unlicensed owner as unlicensed practice), but by statute a licensed hospital, nonprofit entity or charitable trust may employ physicians under a written contract that protects independent medical judgment.
Certificate of need: North Dakota has no Certificate of Need program, so physician offices, ASCs and imaging need no CON; facility licensing and certification are handled by the state health department's Health Facilities Unit.
Nurse practitioners: AANP classifies North Dakota as full practice; no transition-to-practice hours requirement was found.
Who can own a medical clinic in North Dakota
North Dakota recognizes a corporate practice of medicine doctrine (1990 Attorney General advisory letter, and a 2007 case treating employment of doctors by an unlicensed owner as unlicensed practice), but by statute a licensed hospital, nonprofit entity or charitable trust may employ physicians under a written contract that protects independent medical judgment. Other medical practices are owned by licensed physicians through professional corporations or professional LLCs.
Sources: ndlegis.gov, ndlegis.gov, moriarty.com
Business entity and registration
Physicians form a professional corporation or professional LLC under the Professional Organizations Act (NDCC 10-31). Owners must be licensed for the same professional service, and the filing with the Secretary of State (through FirstStop) must include a certificate from the Board of Medicine confirming each director, voting shareholder, governor or member is licensed.
Sources: ndlegis.gov, sos.nd.gov
Certificate of need in North Dakota
North Dakota has no Certificate of Need program, so physician offices, ASCs and imaging need no CON; facility licensing and certification are handled by the state health department's Health Facilities Unit.
Sources: ncsl.org
Licenses, registrations and state agencies
The Board of Nursing states that North Dakota does not license clinics, so ordinary physician offices and outpatient clinics need no state facility license. NDCC 23-16 licenses facilities that care for two or more unrelated patients for more than 24 hours, and a physician office with no more than four emergency or transfer beds is exempt.
Sources: ndbon.org, ndlegis.gov, ncsl.org
North Dakota-specific requirements to know
Licensing boards must require prescribers of controlled substances to use the North Dakota PDMP, run by the Board of Pharmacy, so each prescriber needs a PDMP account. Non-hospital, for-profit ownership by non-physicians runs into the corporate practice doctrine, and new PAs under 4,000 hours need a written collaborative agreement.
Sources: nodakpharmacy.com, ndlegis.gov
Agencies you will deal with
- Medical board: North Dakota Board of Medicine
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: North Dakota Secretary of State (FirstStop)
- Facility licensing: North Dakota Department of Health and Human Services, Health Facilities Unit
- Medicaid enrollment: North Dakota Medicaid (Health and Human Services North Dakota)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies North Dakota as full practice; no transition-to-practice hours requirement was found.
Sources: aanp.org
Physician assistants: A PA with fewer than 4,000 hours of practice must have a written collaborative agreement with a physician (available to the Board on request); after that, collaboration is set by the practice, and every PA must work in a licensed facility, a credentialed facility, a physician-owned practice, or a Board-approved practice.
Sources: ndlegis.gov
Med spas, injectables and IV therapy in North Dakota
Board of Nursing guidance (aesthetics updated January 2026; retail IV therapy approved December 2024) says an RN may give aesthetic agents or IV therapy only on a client-specific prescriber order after a documented prescriber history and physical, standing orders are valid only within an established prescriber-client relationship, and nurses may not choose the drug, dose, device or setting. Because the state does not license clinics, the prescriber must be responsible for receiving and storing legend drugs, and a supervising physician, PA or NP must be able to respond immediately to complications.
Sources: ndbon.org, ndbon.org, ndbon.org
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 North Dakota
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits North Dakota’s corporate practice of medicine rules. North Dakota recognizes a corporate practice of medicine doctrine (1990 Attorney General advisory letter, and a 2007 case treating employment of doctors by an unlicensed owner as unlicensed practice), but by statute a licensed hospital, nonprofit entity or charitable trust may employ physicians under a written contract that protects independent medical judgment.
- Form the entity with the North Dakota Secretary of State (FirstStop). Physicians form a professional corporation or professional LLC under the Professional Organizations Act (NDCC 10-31).
- 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 North Dakota Board of Medicine. Every physician needs a North Dakota license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. North Dakota has no Certificate of Need program, so physician offices, ASCs and imaging need no CON; facility licensing and certification are handled by the state health department's Health Facilities Unit.
- Register to prescribe. Register with the DEA for controlled substances and complete any North Dakota controlled substance registration and prescription monitoring program enrollment. Licensing boards must require prescribers of controlled substances to use the North Dakota PDMP, run by the Board of Pharmacy, so each prescriber needs a PDMP account.
- 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 North Dakota Medicaid (Health and Human Services North Dakota) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies North Dakota as full practice; no transition-to-practice hours requirement was found.
- 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 North Dakota
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 North Dakota launch with us →
Sources
- https://www.ndlegis.gov/cencode/t43c17.pdf
- https://ndlegis.gov/api/assembly/67-2021/testimony/SHUMSER-2128-20210125-3125-F-TRAYNOR_PAT.pdf
- https://www.moriarty.com/content/documents/ML_PDFs/cpmd_4.10.12.pdf
- https://www.ndlegis.gov/cencode/t10c31.pdf
- https://www.sos.nd.gov/
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://www.aanp.org/advocacy/north-dakota
- https://ndbon.org/wp-content/uploads/2026/01/Aesthetic-Practice-Role-of-the-Nurse-1-2026.pdf
- https://www.ndlegis.gov/cencode/t23c16.pdf
- https://ndbon.org/wp-content/uploads/2025/07/Role-of-the-Nurse-in-Retail-IV-Therapy-Settings_Approved-12-13-2024.pdf
- https://ndbon.org/practice/
- https://www.nodakpharmacy.com/PDMP-faq.asp