A telehealth medical director owns clinical scope, signed protocols for each condition or drug class, oversight and chart review of every prescriber, collaboration or supervision where state law requires it, adverse-event review, and clinical sign-off on intake and marketing claims, with written authority to pause anything that puts patients at risk.
A telehealth medical director is responsible for what the clinicians do: the clinical protocols, the scope of what the service treats, oversight and peer review of every prescriber, and escalation of clinical risk to the people who run the business. The role is not a signature on a website. In a telehealth company the medical director is often the only physician with authority over how a growth plan touches patients, and prosecutors and boards look at that person first when something goes wrong.
What does the medical director own?
- Clinical scope. Which conditions are treated by telehealth, which are excluded, and the criteria that send a patient to in-person care.
- Protocols. One per condition or drug class: history and exam elements, required labs, contraindications, follow-up intervals, refill rules and discontinuation criteria. Signed, dated and versioned.
- Prescriber oversight. Chart review of a sample of every clinician's visits, prescribing pattern reports (volume, drug mix, early refills, overrides of protocol), and peer review when outliers appear.
- Collaboration and supervision. In states that require a collaborating or supervising physician for nurse practitioners or physician assistants, either serving in that role where licensed or making sure someone is. Requirements differ widely by state; see NP collaboration requirements by state.
- Adverse events and complaints. Review, root cause and protocol change.
- Clinical input on product and marketing. Sign-off on intake questions, on which answers stop a visit, and on any advertising claim about outcomes. See the advertising claims checklist.
Where does the role go wrong?
A rubber stamp for prescriptions issued by others, a reviewer who sees only what the company chooses to send, or someone whose pay rises with prescription volume. A medical director should have the written authority to pause a protocol, a clinician or a marketing campaign on clinical grounds, and a reporting line that reaches the board or owners directly.
Why did the Done Global case change the stakes?
In November 2025 a federal jury in San Francisco convicted Done Global's founder, Ruthia He, and its clinical president, David Brody, of conspiracy to distribute controlled substances, distribution of controlled substances and conspiracy to commit health care fraud, according to the Justice Department's November 19, 2025 press release. The release described initial appointments "less than half the length of a typical psychiatric examination," auto-refill technology, and patients who were not discharged despite concerns about addiction. On July 7, 2026, according to published reports of the sentencing, He received six years in prison and a $1 million fine, and Brody received two years and a $1 million fine. The clinical leader went to prison too. See what the Done Global prosecution means for operators.
Which licenses does a telehealth medical director need?
At minimum, an active license in the state where the professional entity is organized. In practice, the director should hold licenses in the states where they review charts or supervise, and must hold them wherever they personally treat patients or serve as a required collaborating physician. The Interstate Medical Licensure Compact can shorten that work in member states; see IMLC for chief medical officers. If the director prescribes controlled substances, they need a DEA registration in each state where they prescribe.
Does the medical director need to own the practice?
In states with a strong corporate practice of medicine doctrine, the professional entity that employs clinicians usually must be owned by licensed physicians, and the medical director is often that owner. That makes the director's independence from the management company a structural question, not just a job description. See the friendly PC and MSO model and have counsel review the arrangement in each state.
How much time does the job take?
It scales with the number of prescribers, the risk of the drugs, and the number of states. A small practice prescribing non-controlled medications might need a few hours a week; a multi-state program prescribing controlled substances needs a larger commitment and probably more than one physician reviewer. Write the expected hours and chart-review percentages into the agreement.
Which terms belong in the medical director agreement?
- Duties listed specifically, including chart-review percentage and frequency.
- Authority to stop a protocol, clinician or campaign, and to escalate to the board.
- Fixed compensation at fair market value, not tied to prescriptions or revenue.
- Access to all clinical data, complaint logs and prescribing reports.
- Malpractice and directors and officers coverage that names the role.
- A transition plan, since a sudden vacancy can leave states without a required collaborating physician.
We draft protocols and the oversight cadence as part of our Telehealth Launch Blueprint ($4,950). Structure questions go into a Counsel-Ready Structure Packet ($950) for your lawyer. See pricing.
Common questions
- Is a telehealth medical director legally responsible for other clinicians' prescriptions?
- Each prescriber is responsible for their own prescriptions, but a medical director who sets protocols and oversees clinicians can face board or criminal exposure for how the program runs. In the Done Global case, the company's clinical president was convicted and sentenced to two years in prison.
- Does a telehealth medical director need a license in every state?
- Not necessarily for oversight alone, but they need a license wherever they treat patients or act as a required collaborating or supervising physician, and a DEA registration in each state where they prescribe controlled substances.
- How should a telehealth medical director be paid?
- A fixed fee at fair market value for defined duties. Pay tied to prescription volume or revenue undermines the director's independence and can raise kickback and fee-splitting issues.
Planning a Telehealth Service Line?
We research every state's rules for your service line, write the policies and consent forms, file telehealth registrations and keep it current, at published prices.