How to Start a Medical Clinic in Utah (2026)

Ownership: Utah does not follow a corporate practice of medicine doctrine and has no statute barring business entities from owning a medical practice or employing physicians, so non-physician ownership is generally possible.

Certificate of need: Utah does not have a Certificate of Need program, so physician offices, ASCs and imaging centers do not need CON approval.

Nurse practitioners: AANP classifies Utah as full practice: NPs may evaluate, diagnose and prescribe under Board of Nursing licensure without a required physician agreement, and AANP's state fact sheet lists no transition-to-practice period.

Who can own a medical clinic in Utah

Utah does not follow a corporate practice of medicine doctrine and has no statute barring business entities from owning a medical practice or employing physicians, so non-physician ownership is generally possible. Physicians still often use professional corporations or PLLCs, and Utah's fee-splitting rule (R156-67-502) and licensure laws still apply to how fees and clinical control are structured.

Sources: hollandhart.com, discern.com

Business entity and registration

Physicians commonly form a professional corporation (Utah Code 16-11) or a professional LLC (Utah Code 48-3a, Part 11), or may use an ordinary LLC or corporation given the lack of a CPOM bar. Entities are registered with the Utah Division of Corporations and Commercial Code through a UtahID account.

Sources: discern.com, corporations.utah.gov

Certificate of need in Utah

Utah does not have a Certificate of Need program, so physician offices, ASCs and imaging centers do not need CON approval.

Sources: ncsl.org

Licenses, registrations and state agencies

Utah DHHS licenses health care facilities such as hospitals, ambulatory surgical facilities, birthing centers, end stage renal disease facilities and abortion clinics, but Utah Code 26B-2-201 expressly excludes the offices of private physicians, individual or group, from the definition of a health care facility.

Sources: le.utah.gov, dlbc.utah.gov

Utah-specific requirements to know

Prescribers of controlled substances need a Utah Controlled Substance license from DOPL in addition to DEA registration; it is tied to the practitioner's professional license. Prescribers must create an account with Utah's Controlled Substance Database (CSD), the state PDMP, to use it.

Sources: commerce.utah.gov, commerce.utah.gov

Agencies you will deal with

Medical board: Utah Division of Professional Licensing (DOPL), Physician and Surgeon licensing
Board of nursing: Board of nursing
Board of pharmacy: Board of pharmacy
Business registration: Utah Division of Corporations and Commercial Code
Facility licensing: Utah Department of Health and Human Services, Division of Licensing and Background Checks
Medicaid enrollment: Utah Medicaid (PRISM provider portal)

Nurse practitioners and physician assistants

Sources: aanp.org, storage.aanp.org

Physician assistants: Under Utah Code 58-70a-307 (amended May 2026), PAs with fewer than 8,500 post-graduate hours must practice under written collaboration policies and collaborate with a physician for their first 4,000 hours, PAs between 4,000 and 8,500 hours need a written collaborative agreement with a physician or a PA with more than 8,500 hours in the same specialty, and the section sets no collaboration agreement requirement above 8,500 hours.

Sources: le.utah.gov

Med spas, injectables and IV therapy in Utah

Utah Code 58-1-506 (effective January 1, 2026) requires nonablative cosmetic medical procedures, including laser hair removal, to be supervised by a Utah physician or APRN with an unrestricted license; a physician, NP or PA must develop the treatment plan and evaluate the patient (in person or live telemedicine) for non-hair-removal procedures; delegates such as RNs, PAs, master estheticians, estheticians, LPNs and medical assistants need documented training (at least 80 hours for hair removal) and work under direct, indirect or general supervision depending on their credential; and the facility must post the supervisor's name and license. The statute does not address injectables or IV therapy, and no Utah law barring lay ownership of a med spa was identified.

Sources: le.utah.gov, hollandhart.com

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 Utah

Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Utah’s corporate practice of medicine rules. Utah does not follow a corporate practice of medicine doctrine and has no statute barring business entities from owning a medical practice or employing physicians, so non-physician ownership is generally possible.
Form the entity with the Utah Division of Corporations and Commercial Code. Physicians commonly form a professional corporation (Utah Code 16-11) or a professional LLC (Utah Code 48-3a, Part 11), or may use an ordinary LLC or corporation given the lack of a CPOM bar.
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 Utah Division of Professional Licensing (DOPL), Physician and Surgeon licensing. Every physician needs a Utah license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
Check certificate of need and facility licensing. Utah does not have a Certificate of Need program, so physician offices, ASCs and imaging centers do not need CON approval.
Register to prescribe. Register with the DEA for controlled substances and complete any Utah controlled substance registration and prescription monitoring program enrollment. Prescribers of controlled substances need a Utah Controlled Substance license from DOPL in addition to DEA registration; it is tied to the practitioner's professional license.
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 Utah Medicaid (PRISM provider portal) and start commercial credentialing early, because payer enrollment often takes months.
Plan staffing around NP and PA rules. AANP classifies Utah as full practice: NPs may evaluate, diagnose and prescribe under Board of Nursing licensure without a required physician agreement, and AANP's state fact sheet lists no transition-to-practice period.
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 Utah

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 Utah 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 Utah and with the agencies listed above.

Sources

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How to start a medical clinic in Utah.