Florida's Out-of-State Telehealth Registration for Physicians, NPs and PAs

Florida created its out-of-state telehealth registration in 2019 (ch. 2019-137, Laws of Florida), and it remains the template other states point to. The idea is simple: a health care practitioner licensed in another state can register with the Florida board for their profession, then treat patients located in Florida by telehealth, without a Florida license. Physicians register with the Board of Medicine or the Board of Osteopathic Medicine, PAs with the board that regulates them, and APRNs with the Board of Nursing. For counselors and social workers, our sister sites cover the Florida registration; this post is about physicians, NPs and PAs.

Who is eligible?

Under Fla. Stat. § 456.47(4)(b), the board must register a practitioner who:

1. Completes the Department of Health's application.
2. Holds an active, unencumbered license from another state, the District of Columbia or a U.S. territory that is "substantially similar" to the corresponding Florida license.
3. Has not been the subject of disciplinary action relating to that license in the five years before applying.
4. Designates a duly appointed registered agent for service of process in Florida.
5. Shows professional liability coverage or financial responsibility that includes telehealth to patients outside the provider's home state, in an amount at least equal to what Florida requires of its own licensees under §§ 456.048, 458.320 or 459.0085.

Section 456.47(4)(d) adds a bar: no registration if the license is subject to a pending disciplinary investigation or action, or has been revoked, in any jurisdiction. The Department uses the National Practitioner Data Bank to verify the application. The statute sets no registration fee.

What does Florida publish about registrants?

More than most practitioners expect. Section 456.47(4)(h) requires the Department to publish, for every registrant: name, occupation, training and education with completion dates, the out-of-state license and number, the Florida registration number, specialty, board certification, a five-year disciplinary history, the malpractice insurance carrier and policy limits (including whether the policy covers claims arising in Florida), and the registered agent's name and address.

The registrant's own website must also "prominently display a hyperlink" to the Department page with that information (§ 456.47(4)(c)). For a telehealth company, that means a link per clinician, or a clinician directory page that links each registrant to the Department listing. It is easy to miss and easy to check.

What can a registrant not do?

Under § 456.47(4)(f), a registrant "may not open an office in this state and may not provide in-person health care services to patients located in this state." Unlike Arizona, Florida has no multistate-group exception for offices. A practice that wants a Florida clinic needs Florida-licensed clinicians to staff it.

Registrants must also report any new license restriction or disciplinary action in any state within five business days (§ 456.47(4)(d)). Failure to report, discipline elsewhere, violating the section or committing any act that is grounds for discipline under Florida law can lead to suspension or revocation of the registration, a reprimand or a letter of concern (§ 456.47(4)(i)).

Which Florida practice rules follow a registrant?

All of them. A registrant treats Florida patients "within the applicable scope of practice established by Florida law or rule" (§ 456.47(4)(a)) and owes the standard of care of an in-person Florida practitioner (§ 456.47(2)(a)). That carries several rules with it:

• Schedule II. No Schedule II prescribing by telehealth except for a psychiatric disorder, hospital inpatients, hospice patients and nursing home residents (§ 456.47(2)(c)). See Florida's Schedule II limits.
• NP and PA formulary limits. Florida's APRN and PA formularies cap Schedule II at a 7-day supply, with an exception for psychiatric medications prescribed by psychiatric nurses (§ 464.012(6)(a); § 458.347). A registrant NP from a full-practice state is still bound by Florida's limits for Florida patients.
• PDMP. A check of E-FORCSE before prescribing a controlled substance to a patient 16 or older (§ 893.055(8)).
• Records. Telehealth services documented to the same standard as in-person care (§ 456.47(3)).
• Abortion. Telehealth may not be used to perform an abortion (§ 456.47(2)(f)).

A DEA registration for Florida is a separate question, and the answer affects any registrant prescribing controlled substances to Florida patients. Our sisters handle DEA filings: White Glove APRN for NPs, White Glove PA for PAs and White Glove IMLC for physicians.

What does Florida allow clinically by telehealth?

Quite a lot. Telehealth includes synchronous and asynchronous technology, excluding only email and fax (§ 456.47(1)(a)). A provider who conducts an evaluation sufficient to diagnose and treat does not need to research the patient's medical history or do a physical exam first (§ 456.47(2)(b)). Florida's telehealth statute has no telehealth-specific consent requirement, though general informed-consent law applies. See asynchronous telehealth by state.

Who does not need to register?

Section 456.47(6) exempts an out-of-state licensed provider treating a Florida patient by telehealth in response to an emergency medical condition, or in consultation with a Florida-licensed provider who keeps ultimate authority over diagnosis and care. There is no follow-up care or low-volume exemption, unlike Arizona's ten-encounter rule. A patient you saw in your home state who moves to Florida needs you to register or license before the next video visit.

Where would a dispute be heard?

For this section, care is deemed delivered where the patient is located or in the patient's county of residence. Venue for an action by the Department, a board or a patient against an out-of-state telehealth provider may be the patient's county of residence or Leon County (§ 456.47(5)).

Registration or a Florida license?

• Registration fits telehealth-only practice with no plan for Florida clinics, for clinicians with a clean five-year record.
• A full license or the IMLC fits physicians who may see Florida patients in person or want to supervise Florida clinicians. Florida joined the Interstate Medical Licensure Compact in 2024, according to the Board of Medicine. White Glove IMLC covers it in its Florida physician licensing guide.
• Any discipline in the past five years rules out registration. Plan for a license instead.

Our Telehealth Registration Filing service ($395 per clinician, per state) prepares Florida registrations for physicians, NPs and PAs, including the registered agent and coverage documentation. Florida's full set of telehealth rules is on the Florida page of our law index. This is research for your counsel, not legal advice.