Ownership: We did not find a Pennsylvania statute, board rule or law firm source that clearly bars non-physicians from owning a medical practice.
Certificate of need: Pennsylvania has no Certificate of Need program, so physician offices, ASCs and imaging centers do not need CON approval.
Nurse practitioners: AANP classifies Pennsylvania as reduced practice: NPs (CRNPs) need a career-long written collaborative agreement with one or more physicians, and those with prescriptive authority need a prescriptive authority collaborative agreement with at least two physicians.
Who can own a medical clinic in Pennsylvania
We did not find a Pennsylvania statute, board rule or law firm source that clearly bars non-physicians from owning a medical practice. A professional corporation itself must be owned entirely by licensed persons (15 Pa.C.S. 2923), so lay-owned clinics usually use an ordinary business entity or an MSO arrangement; confirm the structure with Pennsylvania counsel.
Sources: law.justia.com
Business entity and registration
Physicians commonly form a professional corporation under 15 Pa.C.S. Chapter 29, whose share owners must all be licensed persons, or another business entity, filed with the Pennsylvania Department of State Bureau of Corporations and Charitable Organizations through the Business Filing Services portal.
Sources: law.justia.com, pa.gov
Certificate of need in Pennsylvania
Pennsylvania has no Certificate of Need program, so physician offices, ASCs and imaging centers do not need CON approval.
Sources: ncsl.org
Licenses, registrations and state agencies
The Pennsylvania Department of Health licenses ambulatory surgical facilities (28 Pa. Code Chapter 551) and hospitals, but private physician and dentist offices are excluded from the ASF definition unless they have a distinct part used solely for outpatient surgery on a regular and organized basis. We found no state license for ordinary physician offices or urgent care clinics.
Sources: law.cornell.edu
Pennsylvania-specific requirements to know
Prescribers must enroll in and use the Pennsylvania PDMP, which monitors Schedules II to V, and Pennsylvania requires electronic prescribing of controlled substances. NP collaborative agreements and PA written agreements involve filings with the respective boards. Pennsylvania licenses MDs through the State Board of Medicine and DOs through a separate State Board of Osteopathic Medicine.
Sources: pdmpassist.org, storage.aanp.org, law.cornell.edu
Agencies you will deal with
- Medical board: Pennsylvania State Board of Medicine
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Pennsylvania Department of State, Bureau of Corporations and Charitable Organizations
- Facility licensing: Pennsylvania Department of Health
- Medicaid enrollment: Pennsylvania Medical Assistance (DHS PROMISe)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Pennsylvania as reduced practice: NPs (CRNPs) need a career-long written collaborative agreement with one or more physicians, and those with prescriptive authority need a prescriptive authority collaborative agreement with at least two physicians.
Sources: storage.aanp.org
Physician assistants: Pennsylvania PAs practice under a Board-approved written agreement with one or more supervising physicians (one MD designated as primary) that lists delegated functions, describes supervision and practice locations, and requires physician countersignature of PA records within a set period (49 Pa. Code 18.142).
Sources: law.cornell.edu
Med spas, injectables and IV therapy in Pennsylvania
We found no Pennsylvania rule specific to med spa ownership. Under State Board of Medicine rule 49 Pa. Code 18.402, a physician may delegate a medical service such as injections or laser treatment to a practitioner or technician only if the delegation matches accepted practice, the physician knows the person is trained and competent, the patient is informed and does not object, and the physician stays responsible and available; services needing skills not ordinarily held by non-physicians may not be delegated.
Sources: law.cornell.edu
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 Pennsylvania
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Pennsylvania’s corporate practice of medicine rules. We did not find a Pennsylvania statute, board rule or law firm source that clearly bars non-physicians from owning a medical practice.
- Form the entity with the Pennsylvania Department of State, Bureau of Corporations and Charitable Organizations. Physicians commonly form a professional corporation under 15 Pa.C.S.
- 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 Pennsylvania State Board of Medicine. Every physician needs a Pennsylvania license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. Pennsylvania has no Certificate of Need program, so physician offices, ASCs and imaging centers do not need CON approval. The Pennsylvania Department of Health licenses ambulatory surgical facilities (28 Pa.
- Register to prescribe. Register with the DEA for controlled substances and complete any Pennsylvania controlled substance registration and prescription monitoring program enrollment. Prescribers must enroll in and use the Pennsylvania PDMP, which monitors Schedules II to V, and Pennsylvania requires electronic prescribing of controlled substances.
- 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 Pennsylvania Medical Assistance (DHS PROMISe) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Pennsylvania as reduced practice: NPs (CRNPs) need a career-long written collaborative agreement with one or more physicians, and those with prescriptive authority need a prescriptive authority collaborative agreement with at least two physicians.
- 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 Pennsylvania
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 Pennsylvania launch with us →
Sources
- https://law.justia.com/codes/pennsylvania/title-15/chapter-29/section-2923/
- https://www.pa.gov/agencies/dos/programs/business
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://storage.aanp.org/www/documents/no-index/state-fact-sheets/pennsylvania.pdf
- https://www.law.cornell.edu/regulations/pennsylvania/49-Pa-Code-SS-18-142
- https://www.law.cornell.edu/regulations/pennsylvania/28-Pa-Code-SS-551-3
- https://www.law.cornell.edu/regulations/pennsylvania/49-Pa-Code-SS-18-402
- https://www.pdmpassist.org/pdf/state_summaries/Pennsylvania_Summary_Profile.pdf