Many peptide and GLP-1 telehealth sites carry the same line in their terms. The company, it says, does not practice medicine, prescribe medications or dispense them.
Further down, you find another name. It usually ends in P.A., P.C. or Medical Group. The site calls itself a management services organization, or MSO, or a technology platform.
So who is your doctor? And who answers for your care? This page works through the state laws and board publications behind that split. It is general information, not legal advice for your situation.
Two companies behind one website
The model has two parts. One company builds the website, runs marketing, takes payment and handles support.
A second entity, owned by licensed clinicians, employs or contracts the prescribers. That practice makes the medical decisions.
The disclaimer is the first company telling you it is not the second. It is a statement about who holds the license, not a warning about the care.
The reason for the split is a legal doctrine. Its name is the corporate practice of medicine.
Many of these sites also show a seal in the footer. That seal answers a different question; see what LegitScript certified means.
What California’s medical board says
California states the rule in one sentence. Business and Professions Code section 2400 reads: “Corporations and other artificial legal entities shall have no professional rights, privileges, or powers” [2].
The Medical Board of California explains the purpose. The law is “intended to prevent unlicensed persons from interfering with, or influencing, the physician’s professional judgment” [1].
The board lists decisions that belong to a California-licensed physician. They include choosing diagnostic tests and making referrals [1].
They also include “Responsibility for the ultimate overall care of the patient, including treatment options available to the patient” [1].
The board names MSOs directly. Those decisions “cannot be delegated to an unlicensed person, including (for example) management service organizations” [1].
It also lists a banned structure. That is an MSO “arranging for, advertising, or providing medical services rather than only providing administrative staff and services for a physician’s medical practice” [1].
A physician may take business advice from non-physicians. The board adds that “the physician must retain the ultimate responsibility for, or approval of, those decisions” [1].
So the “we do not practice medicine” line matches what California asks of an MSO. Whether a given company lives up to it is a separate question.
What Texas law says
Texas starts from licensure. Occupations Code section 155.001 says: “A person may not practice medicine in this state unless the person holds a license issued under this subtitle” [6].
The Texas Medical Board refers to “the prohibition of the corporate practice of medicine” in its note on hospitals [7].
That note describes exemptions for small-county, critical access and sole community hospitals [7]. A telehealth platform is not on that list.
The business code draws the same line. A section on physicians and physician assistants sharing a practice states its limit plainly [5].
It may not be read “to allow a person not licensed as a physician to direct the activities of a physician in the practice of medicine” [5].
What P.A. and P.C. mean
These letters name the legal form of the practice. They tell you licensed people own it.
Texas. A professional association is formed to provide the service of a doctor of medicine, among other listed professions [5].
The Texas professional corporation is defined to exclude “the practice of medicine by physicians, surgeons, or other doctors of medicine” [5]. That is why Texas medical practices end in P.A.
So in a Texas practice name, P.A. means professional association. It does not mean physician assistant.
Ownership is limited too. An owner of a professional entity must be an “authorized person” [5]. For an association, that means a professional licensed for the same service [5].
The association may provide care in Texas only through people licensed in Texas for that service [5].
California. Physicians use a medical corporation. It may render professional services so long as it complies with the Moscone-Knox Professional Corporation Act [3].
Section 2400’s ban does not apply to such a corporation while it complies with those statutes [3].
Its shares “may be issued only to a licensed person,” and shares issued otherwise are void [4].
California also polices the brand name. A physician practicing under any name but their own needs a fictitious name permit [8].
Without one, the board quotes section 2285, that use “constitutes unprofessional conduct” [8].
Who your doctor is
Your doctor is the licensed person who evaluates you and signs the prescription. The platform is not.
The Federation of State Medical Boards (FSMB) sets out when that relationship exists. Its telemedicine policy was adopted in April 2022 [9].
It is guidance written for state boards. Each state’s own law decides what applies to you.
The relationship “is clearly established when the physician agrees to undertake diagnosis and treatment of the patient, and the patient agrees to be treated” [9].
No prior office visit is required, “so long as the standard of care is met” [9].
A name must be attached. The FSMB says: “An appropriate physician-patient relationship has not been established when the identity of the physician may be unknown to the patient” [9].
You should be able to pick an identified physician and “not be assigned to a physician at random,” where that is available [9].
Where you are matters too. The physician must be licensed by the medical board of the state where the patient is located [9].
“The practice of medicine occurs where the patient is located at the time that telemedicine technologies are used” [9].
A questionnaire alone is not enough. Prescribing “based solely on static online questionnaires” is called not acceptable [9].
Who is responsible for your care
On the clinical side, the prescriber is. Their license is what their state board can act on.
The FSMB says telemedicine prescriptions “carry the same professional accountability as prescriptions delivered during an encounter in person” [9].
It also shields that judgment from the business. Pay or treatment advice “should not be materially based on the delivery of patient-desired outcomes (i.e., a prescription or referral)” [9].
The platform’s role is set out in your terms of service. Read how they split billing, shipping and privacy between the two companies.
Who pays if something goes wrong turns on your state’s law and the facts. That is a question for a lawyer, not a website.
For complaints about a prescriber, the FSMB points to your state medical board. It calls boards “the designated state agencies to investigate complaints about physicians” [10].
How to check your prescriber
You can confirm who is treating you in a few minutes. Here is the order that works.
- Find the practice name in the terms, the consent form or the checkout page. It is the one ending in P.A., P.C. or Medical Group.
- Find your prescriber’s name on the prescription label or in your patient portal.
- Note their license type. Physician assistants and nurses are licensed by separate boards in the same search [11].
- Search your own state’s board. California’s search shows “if a license is current, expired, or has been subject to disciplinary action” [11].
- Try DocInfo too. The FSMB describes it as free to the public, with disciplinary actions and license history [10].
- In California, a brand name can be searched as a fictitious name permit in the same tool [11].
State board profiles show, at a minimum, “licensure status and disciplinary history,” the FSMB says [10].
One check matters most. The license must cover the state where you are when you are seen, usually the state where you live.
The legal status of the drugs themselves is a separate question. It is covered in are peptides legal.
Where the Ryan Haight Act fits
One federal law often comes up in telehealth. It is the Ryan Haight Online Pharmacy Consumer Protection Act of 2008 [13].
Its rule covers controlled substances only. No controlled prescription drug “may be delivered, distributed, or dispensed by means of the Internet without a valid prescription” [12].
A valid prescription there generally requires at least one in-person medical evaluation [12]. The same subsection has an exception for telemedicine [12].
Most drugs on these sites are not controlled. Semaglutide, tirzepatide, sermorelin, tesamorelin and bremelanotide do not appear on the DEA's list. [14]
Testosterone is on it, in Schedule III [14].
So the federal in-person rule does not reach most peptide or GLP-1 prescriptions. State licensure rules and the board standards above still do.