Tessic Health

AZ · STATE RULES

Telehealth rules in Arizona

A clinician licensed in another state can treat Arizona patients by telehealth under a board registration instead of a full Arizona license (A.R.S. 36-3606), and unlike Colorado's version, that registration can cover controlled prescribing once the clinician joins the state's CSPMP database. Arizona's tighter rules cluster around Schedule II: those drugs follow only an in-person or live video exam, and Schedule II opioids are the one class state law requires to be e-prescribed. Other Arizona first visits can run asynchronously when the evaluation fits the condition.

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Controlled drugs
Schedule II: video or in-person
Nurse practitioners
Full practice

Rules checked September 2026 · 29 sources cited

ONLY IN ARIZONA

What is different about Arizona

Each rule here is true of Arizona and of none of the states that border it. Beside each one: what the neighbours do instead.

  1. 01 · Prescribing

    Only Schedule II opioids must be e-prescribed

    Arizona's electronic-prescribing statute reaches one class of drug: every Schedule II opioid order must be transmitted electronically to the dispensing pharmacy (A.R.S. 36-2525(N)). Schedule II stimulants and all Schedule III–V drugs fall outside the state mandate, and the opioid rule itself has exceptions for system outages, VA, military and tribal pharmacies, and medication-assisted treatment.

    Source: A.R.S. 36-2525

    Across the border

    • California

      California requires nearly every prescription, controlled or not, to be issued as an electronic data transmission, with listed exceptions such as system failures and out-of-state pharmacies (Cal. Bus. & Prof. Code 688).

      Source: Cal. Bus. & Prof. Code 688

    • Nevada

      Nevada requires every controlled-substance prescription to reach the pharmacy by electronic transmission, with exceptions such as technology failures and Board of Pharmacy hardship waivers of up to one year (NRS 639.23535).

      Source: NRS 639.23535

    • Utah

      Utah Code 58-37-22 requires most controlled-substance prescriptions, not only opioids, to be transmitted electronically, according to the Division of Professional Licensing's e-prescription guidance.

      Source: Utah DOPL: e-prescription information

    • New Mexico

      New Mexico's Board of Pharmacy requires all controlled-substance prescriptions to be transmitted electronically, with carve-outs for hospice, compounded and facility-patient prescriptions (16.19.20.42 NMAC).

      Source: 16.19.20.42 NMAC

    • Colorado

      Colorado requires Schedule II, III and IV prescriptions to go to the pharmacy electronically, with exceptions that include prescribers writing 24 or fewer controlled prescriptions a year (C.R.S. 12-30-111).

      Source: C.R.S. 12-30-111

  2. 02 · Prescribing

    Schedule II needs a video or in-person exam

    Arizona bars its health boards from demanding an in-person exam before a prescription, then carves out one exception: Schedule II drugs may be prescribed only after an in-person or audio-visual examination (A.R.S. 36-3602(E)). In Arizona, an audio-only call or a store-and-forward review cannot support a Schedule II prescription, and federal DEA rules apply on top.

    Source: A.R.S. 36-3602

    Across the border

    • California

      California's telehealth statute covers any information and communication technology, synchronous or store-and-forward, and names no separate exam format for Schedule II drugs (Cal. Bus. & Prof. Code 2290.5).

      Source: Cal. Bus. & Prof. Code 2290.5

    • Nevada

      Nevada lets the prescriber relationship for Schedule II–IV drugs rest on an exam done in person, electronically or telephonically within the six months before the prescription (NRS 639.235).

      Source: NRS 639.235

    • Utah

      Utah's rule is drug-neutral: no diagnosis or prescription based only on an online questionnaire, an email or a patient-written history, and no Schedule II exam format of its own (Utah Code 26B-4-704).

      Source: Utah Code 26B-4-704

    • New Mexico

      New Mexico's board rule treats questionnaire-only prescribing of any drug as unprofessional and names face-to-face videoconferencing as the telehealth route, with no provision singling out Schedule II (16.10.8 NMAC).

      Source: 16.10.8 NMAC

    • Colorado

      Colorado draws its line by credential rather than exam format: an out-of-state telehealth registrant may not prescribe any controlled substance at all (C.R.S. 12-30-124(11), added by SB24-141).

      Source: Colorado SB24-141

  3. 03 · Licenses

    Out-of-state registrants can prescribe controlled drugs

    A clinician licensed elsewhere can register with the matching Arizona board instead of getting a license, and the registration does not bar controlled prescribing: A.R.S. 36-3606 only requires the registrant to join the Arizona CSPMP first. Registrants need an unrestricted license with no past or pending discipline, malpractice insurance and an Arizona statutory agent.

    Source: A.R.S. 36-3606

    Across the border

    • California

      California has no telehealth registration; practicing on a patient in California without a California certificate is a public offense under Cal. Bus. & Prof. Code 2052, so every prescriber holds a full license.

      Source: Cal. Bus. & Prof. Code 2052

    • Nevada

      Nevada requires a Nevada license before a distant-site provider diagnoses or prescribes (NRS 629.515); physicians elsewhere can instead get a special purpose license that also demands specialty board certification (NRS 630.261).

      Source: NRS 629.515

    • Utah

      Utah offers no telehealth registration: out-of-state physicians need a Utah license, apart from narrow exemptions such as unpaid public-service practice by physicians licensed ten years or more (Utah Code 58-67-305).

      Source: CCHP: Utah telehealth policy

    • New Mexico

      New Mexico issues a telemedicine license instead, a limited medical license for physicians located outside the state that is renewed each July 1 (16.10.2 NMAC).

      Source: 16.10.2 NMAC

    • Colorado

      Colorado opened an out-of-state telehealth registration on January 1, 2026, but its registrants may not prescribe any controlled substance (C.R.S. 12-30-124(11)), so controlled prescribing there takes a full Colorado license.

      Source: Colorado SB24-141

  4. 04 · Licenses

    Under ten visits a year needs no filing

    An out-of-state clinician who gives fewer than ten telehealth encounters to Arizona patients in a calendar year needs neither an Arizona license nor a registration (A.R.S. 36-3606). Once registered, the clinician updates the registration every year and reports the number of Arizona patients served and the total number and type of encounters.

    Source: A.R.S. 36-3606

    Across the border

    • California

      California has no visit-count threshold: any practice on a patient in California without a California certificate falls under Cal. Bus. & Prof. Code 2052, whatever the volume.

      Source: Cal. Bus. & Prof. Code 2052

    • Nevada

      Nevada's license rule for telehealth diagnosis and prescribing has a single exception, for work with an urban Indian organization, and no low-volume carve-out (NRS 629.515).

      Source: NRS 629.515

    • Utah

      Utah's exemptions turn on the kind of practice, not a visit count: the out-of-state physician exemption covers only noncommercial public service by physicians licensed ten years or more (Utah Code 58-67-305).

      Source: CCHP: Utah telehealth policy

    • New Mexico

      New Mexico requires its telemedicine license for any physician outside the state who practices on New Mexico patients, and 16.10.2 NMAC sets no minimum number of encounters before it applies.

      Source: 16.10.2 NMAC

    • Colorado

      Colorado's registration law, C.R.S. 12-30-124, sets no visit-count exemption and no annual patient-count report; any telehealth to a Colorado patient needs the registration or a Colorado license.

      Source: Colorado SB24-141

PRACTICE RULES

How telehealth works in Arizona

Arizona's telehealth article, A.R.S. Title 36, Chapter 36, sets the consent, modality and record rules for every board-licensed clinician. Arizona case law on who may own a medical practice remains unsettled.

  1. 01

    Consent can be spoken, but it is written down

    Before an Arizona telehealth visit, the treating clinician obtains verbal or written informed consent, including by electronic means, from the patient or the patient's health care decision maker, and records verbal consent in the chart (A.R.S. 36-3602(A)). Arizona waives consent in emergencies where the patient cannot give it and for sending diagnostic images or results to a consultant.

    Source: A.R.S. 36-3602

  2. 02

    Phone-only visits need a reason

    Arizona's definition of telehealth covers audio, video, store-and-forward and remote monitoring, but an audio-only call counts only when an audio-visual visit is not reasonably available because of the patient's functional status or lack of technology or phone and internet service, as judged by the clinician. Fax, instant messages, voicemail and email are excluded (A.R.S. 36-3601).

    Source: A.R.S. 36-3601

  3. 03

    Telehealth records are medical records

    Records of an Arizona telehealth visit become part of the patient's medical record, and the confidentiality protections of A.R.S. 12-2292 apply to them. Images of a telehealth patient may not be used for research or teaching without consent unless another law authorizes it (A.R.S. 36-3602(B)–(D)).

    Source: A.R.S. 36-3602

  4. 04

    Who may own the practice is unsettled

    The Arizona Supreme Court announced the state's corporate practice doctrine (CPOM, the rule against lay companies practicing a licensed profession) in the Funk Jewelry and Sears cases. In Midtown Medical Group v. State Farm, the Court of Appeals let a lay-owned corporation hold an outpatient treatment center license and employ physicians, but called its ruling narrow. An Arizona MSO and friendly-PC split warrants counsel review.

    Source: Midtown Medical Group v. State Farm (Ariz. Ct. App.)

  5. 05

    Professional corporations can have lay owners

    Arizona's professional corporation statute lets people without a license hold up to 49 percent of a professional corporation's voting shares unless the licensing board sets a different figure, and licensed shareholders may be licensed in Arizona or another state (A.R.S. 10-2220). The physician-owned PC in an Arizona friendly-PC model keeps licensed holders in control.

    Source: A.R.S. 10-2220

FIRST VISIT

Can a first visit happen without a live call in Arizona?

Yes

Yes for most drugs: Arizona lets the exam that must come before a prescription happen through telehealth, which by statute includes store-and-forward review, when the clinical evaluation fits the patient and the condition (A.R.S. 32-1401(27)(tt)). Schedule II drugs are the exception under A.R.S. 36-3602(E).

Arizona writes its first-visit rule into the Medical Board's list of unprofessional conduct rather than the telehealth article, and it ties the exam standard to the patient's condition instead of to a modality.

  1. 01

    An exam comes before any prescription

    Under Arizona's Medical Practice Act, prescribing, dispensing or furnishing a prescription drug or device is unprofessional conduct unless the physician first conducts a physical or mental health status exam or already has a doctor-patient relationship. The Arizona exam may be conducted through telehealth as defined in A.R.S. 36-3601, with a clinical evaluation appropriate for the patient and the presenting condition (A.R.S. 32-1401(27)(tt)).

    Source: A.R.S. 32-1401

  2. 02

    Store-and-forward counts as telehealth

    A.R.S. 36-3601 names asynchronous store-and-forward technology inside Arizona's definition of telehealth, so a clinician's review of an intake history and photos can serve as the required exam when that format suits the condition. Instant messages, voicemail and email sit outside the definition, so they cannot carry the Arizona exam on their own.

    Source: A.R.S. 36-3601

  3. 03

    Boards cannot demand an office visit first

    Arizona's health boards may not enforce any statute, rule or policy that would require an in-person exam before a prescription, except where federal law requires one and for Schedule II drugs (A.R.S. 36-3602(E)). The same Arizona subsection states that a physical or mental health status exam may be conducted during a telehealth encounter.

    Source: A.R.S. 36-3602

PRESCRIBING

Prescriptions and controlled drugs in Arizona

Arizona's controlled-substance rules run through the CSPMP, the Controlled Substances Prescription Monitoring Program that serves as the state's prescription-monitoring database, plus a short list of drug-specific statutes.

  1. 01

    Every prescriber joins the CSPMP

    Any prescriber who holds an Arizona license and a DEA registration must register with the Arizona CSPMP (A.R.S. 36-2606). Out-of-state clinicians working under an A.R.S. 36-3606 telehealth registration must also register with the CSPMP before prescribing a controlled substance to a patient in Arizona.

    Source: A.R.S. 36-2606

  2. 02

    When the CSPMP must be checked

    Before prescribing an opioid analgesic or a benzodiazepine in Schedule II, III or IV, an Arizona prescriber pulls a CSPMP patient report at the start of each new course of treatment and at least quarterly after that. Arizona exempts hospice, palliative, cancer and dialysis patients. The trigger names only opioids and benzodiazepines, so testosterone or phentermine alone does not set it off (A.R.S. 36-2606).

    Source: A.R.S. 36-2606

  3. 03

    Pharmacies check a year of history

    Before dispensing a Schedule II controlled substance, an Arizona dispenser must obtain the patient's CSPMP report covering the preceding twelve months (A.R.S. 36-2606). That CSPMP lookup by the pharmacy is a second check on top of the prescriber's own report for opioid and benzodiazepine courses.

    Source: A.R.S. 36-2606

  4. 04

    First opioid scripts are capped at five days

    An initial Schedule II opioid prescription in Arizona is limited to a five-day supply, or fourteen days after surgery (A.R.S. 32-3248). Patients with active cancer, traumatic injury, burns, hospice or end-of-life status, palliative needs, skilled nursing placement or medication-assisted treatment are exempt from Arizona's cap.

    Source: A.R.S. 32-3248

Federal rules apply on top of every state's. Prescribing controlled substances by telehealth without an in-person visit runs on DEA flexibilities currently extended through December 31, 2026, with a permanent rule still pending.

LICENSES

Who can treat patients in Arizona

Arizona gives out-of-state clinicians three routes: a full Arizona license, a compact license through the Interstate Medical Licensure Compact (IMLC, a faster multi-state license for physicians), or a board telehealth registration under A.R.S. 36-3606.

  1. 01

    Arizona is in the compact

    Arizona enacted the Interstate Medical Licensure Compact at A.R.S. 32-3241, so a physician whose principal license is in another member state can obtain an Arizona license through the compact's expedited process. A compact license is a full Arizona license, without the office and in-person limits that come with a 36-3606 registration.

    Source: A.R.S. 32-3241

  2. 02

    What the registration asks for

    An A.R.S. 36-3606 registration goes to the board that licenses comparable Arizona clinicians. Applicants need a current, unrestricted license elsewhere with no past or pending discipline, malpractice insurance and an Arizona statutory agent. The Arizona Medical Board charges physicians a $500 non-refundable application fee, and registrants update the registration every year.

    Source: Arizona Medical Board: MD telehealth registration checklist

  3. 03

    Registrants stay remote

    An Arizona telehealth registrant may not open an office in the state, except as part of a multistate group that includes at least one Arizona-licensed clinician, and may not see patients in person in Arizona without a license (A.R.S. 36-3606). The board may check applications against the National Practitioner Data Bank and revoke Arizona privileges for noncompliance.

    Source: A.R.S. 36-3606

  4. 04

    Nurse practitioners prescribe on their own

    The American Association of Nurse Practitioners rates Arizona a Full Practice state, so nurse practitioners licensed by the Arizona State Board of Nursing evaluate, diagnose and prescribe without a supervising or collaborating physician. That makes Arizona NPs a direct route for brands that staff first visits with nurse practitioners.

    Source: AANP: Arizona

  5. 05

    PAs can drop supervision at 8,000 hours

    Under Arizona's physician assistant law as amended by HB 2043, a PA with at least 8,000 clinical hours certified by the Arizona Regulatory Board of Physician Assistants practices collaboratively without a supervision agreement. Below 8,000 hours, a written Arizona supervision agreement must state whether the PA may prescribe Schedule II–V drugs.

    Source: Arizona House summary of HB 2043

ADVERTISING

Marketing to patients in Arizona

Arizona polices health advertising through the Medical Board's list of unprofessional conduct, which reaches a physician's staff, employer and representatives, and through the Arizona Consumer Fraud Act.

  1. 01

    Brand ads count as the doctor's ads

    A.R.S. 32-1401(27)(c) makes false, fraudulent, deceptive or misleading advertising unprofessional conduct when done by a physician or by the physician's staff, employer or representative. A brand that employs or contracts Arizona prescribers can therefore put their Arizona licenses at risk with a misleading claim.

    Source: A.R.S. 32-1401

  2. 02

    No false specialist claims

    Claiming to be a medical specialist when that is not true is separate unprofessional conduct under A.R.S. 32-1401(27)(cc), so an Arizona clinician bio that names a specialty has to match the specialty the clinician actually holds.

    Source: A.R.S. 32-1401

  3. 03

    No splitting fees for referrals

    A.R.S. 32-1401(27)(v) bars dividing a professional fee for patient referrals among providers or institutions, and any contractual arrangement with the same effect. Because the clause reaches contracts and not only direct payments, per-referral pricing between an Arizona practice and a marketing or management company falls within its words.

    Source: A.R.S. 32-1401

  4. 04

    Consumer fraud law covers health ads

    Arizona's Consumer Fraud Act, A.R.S. 44-1522(A), makes it unlawful to use deception, a false promise, misrepresentation or the omission of a material fact in connection with selling or advertising merchandise, whether or not anyone was actually misled. Price, discount and results claims made to Arizona buyers sit within that standard.

    Source: A.R.S. 44-1522

  5. 05

    Phone sales need a state filing

    A seller that solicits consumers located in Arizona by phone must first file a verified registration statement and a bond with the Arizona Secretary of State (A.R.S. 44-1272). A.R.S. 44-1278 separately bans caller-ID blocking and prerecorded calls without prior express consent, and requires keeping do-not-call requests for ten years.

    Source: A.R.S. 44-1272

TESSIC HEALTH IN ARIZONA

How Tessic Health's providers cover Arizona

Tessic Health's providers treat Arizona patients under the brand's name, and each one holds an Arizona license, a compact license under A.R.S. 32-3241 or an A.R.S. 36-3606 telehealth registration.

  1. 01

    Every Arizona prescriber is on file

    Each clinician treating Arizona patients for a brand is credentialed under the brand and holds an Arizona license, a compact license or a board registration. Registrants are enrolled in the Arizona CSPMP before any controlled prescription, as A.R.S. 36-3606 requires, and never see Arizona patients in person.

  2. 02

    Schedule II visits happen on live video

    Tessic Health's providers issue a Schedule II prescription to an Arizona patient only after a live audio-video or in-person exam, never after an audio-only call or a store-and-forward review, matching A.R.S. 36-3602(E). Other Arizona first visits may run asynchronously when the clinician judges the format fits the condition.

  3. 03

    CSPMP checks before opioids and benzodiazepines

    A CSPMP patient report is pulled before any opioid analgesic or benzodiazepine prescription to an Arizona patient and at least quarterly during treatment, as A.R.S. 36-2606 requires, and the check is documented in the brand's patient record.

  4. 04

    Every Arizona prescription goes out electronically

    Arizona requires electronic transmission only for Schedule II opioids, but Tessic Health's providers send every Arizona prescription, controlled or not, by e-prescribing, using EPCS for controlled substances.

  5. 05

    Pharmacies shipping in hold Arizona permits

    Prescriptions for Arizona patients are filled at 0% markup by pharmacies holding an Arizona State Board of Pharmacy permit, including the nonresident permit that A.A.C. R4-23-607 requires to ship into Arizona, with cold-chain shipping for GLP-1s and other temperature-sensitive drugs.

COMMON QUESTIONS

Questions about telehealth in Arizona

  • Yes for most drugs: A.R.S. 32-1401(27)(tt) lets the required exam happen through telehealth, and A.R.S. 36-3601 counts store-and-forward review as telehealth. The Arizona evaluation has to fit the patient and condition, and Schedule II drugs need a live video or in-person exam.

  • It lets a clinician licensed in another state treat Arizona patients by telehealth without an Arizona license, including controlled prescribing after joining the CSPMP (A.R.S. 36-3606). Arizona registrants cannot open an office in the state or see patients there in person.

  • No: A.R.S. 36-3602(E) allows Schedule II prescriptions only after an in-person or audio-visual exam, and federal DEA telemedicine rules apply as well. Arizona's clause does not reach Schedule III–V drugs.

  • Not under Arizona's mandate: A.R.S. 36-2606 requires the CSPMP check only before opioid analgesics and benzodiazepines in Schedule II–IV. A prescriber with an Arizona license and a DEA registration must still be registered with the CSPMP.

  • No: A.R.S. 36-2525(N) mandates electronic transmission only for Schedule II opioid orders. Tessic Health's providers e-prescribe every Arizona prescription anyway, using EPCS for controlled drugs.

  • Up to nine telehealth encounters a calendar year: A.R.S. 36-3606 exempts an out-of-state clinician who gives fewer than ten. It also exempts Arizona emergencies, consults with an Arizona-licensed clinician who keeps authority over treatment, and after-care for a procedure done in person in another state.

SOURCES

Rules checked September 2026 · 29 sources cited. A planning summary, not legal advice. Statutes, board rules and enforcement priorities change; a brand's own counsel should review its model and marketing before launch.

OTHER STATES

Rules in other states

Each state page is researched from that state's own statutes and board rules.

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