How to open a medical clinic

This guide takes a primary care or urgent care clinic from its ownership structure to its first patients: corporate practice of medicine rules, Florida's clinic license, the word "emergency" in Texas, CLIA, DEA, Medicare enrollment and insurer credentialing. The most useful finding: ownership decides everything after it. In Florida, a clinic that needed a license and did not hold one has charges the statute calls "noncompensable and unenforceable."

By Niomi AscotUpdated October 3, 202616 min read

Clinic license: None federally; Florida requires one per location unless the clinic is practitioner-owned or otherwise exempt
Lay ownership in California: Prohibited, as is a physician practice run as an LLC or general corporation
One rapid strep test: Needs a CLIA certificate, at minimum a Certificate of Waiver
Medicare enrollment fee: None for physicians, NPs and their groups and clinics
Urgent care centers: 15,101 in the US, up from about 9,000 in 2016 (Urgent Care Association)
"Emergency" in Texas: Only a licensed freestanding emergency facility may use the term

What a medical clinic is, and the models

A clinic sells visits: physicals, sick visits, vaccinations, chronic-care follow-ups and, at an urgent care, walk-in treatment for problems that cannot wait for a scheduled appointment. Texas defines the activity broadly: practicing medicine is “the diagnosis, treatment, or offer to treat a mental or physical disease or disorder … by any system or method” (Texas Occupations Code 151.002). Every model below sits inside that definition.

Independent primary care. Family medicine, internal medicine or pediatrics, insurance-based, owned by a physician or, where the state allows, led by a nurse practitioner.
Urgent care. The Urgent Care Association counts “15,101 Urgent Care Centers in the U.S.” and says that “From 2016 to 2024, Urgent Cares have grown from 9,000 to 15,000.” It ranks “the top 50 hospital-affiliated operators” and “the top 50 independent operators” separately (Urgent Care Association), so a new independent center competes with chains and health systems from the first day.
Direct primary care or a self-pay clinic. Memberships or posted cash prices. CMS says uninsured and self-pay patients usually get a good faith estimate, with a dispute open when the bill runs “at least $400 more than the estimate” (CMS).
Not a freestanding emergency room. In Texas that is a separately licensed facility, and an urgent care may not present itself as one (see Texas below).

The Census Bureau’s County Business Patterns counted 204,617 physician offices with paid staff in 2023 (NAICS 621111, every specialty, not only primary care), with 2,706,297 employees; 52.7% had fewer than five employees (Census CBP 2023). In our experience many urgent cares file under that code rather than the freestanding emergency code, so neither is an urgent care count; use the association’s figure.

The outlook

BLS figures published through O*NET show who you will hire, and where the shortage is:

Occupation	Employed, 2024	Median pay, 2025	Projected growth, 2024 to 2034	Openings, 2024 to 2034
Family medicine physicians	116,000	$117.39 an hour, $244,180 a year	Average (3% to 4%)	3,300
Nurse practitioners	320,400	$63.61 an hour, $132,300 a year	Much faster than average (7% or higher)	29,500
Medical assistants	811,000	$21.97 an hour, $45,690 a year	Much faster than average (7% or higher)	112,300

Physician supply grows slowly while nurse practitioner and medical assistant jobs grow fast, which is why most new clinics we see plan their schedules around NPs and PAs, within each state’s supervision rules.

Demand favors convenience. The association reports “89.4% of the U.S. population Within a 20-Minute Drive” of an urgent care and “5,000,000+ UC Visits “After Hours”” in a survey of encounters after 5 p.m. from January to March 2024. In the clinics we work with, the year turns on back-to-school physicals, the September and October flu-shot window, Medicare and Marketplace open enrollment, and the winter respiratory peak.

Licensing: the clinicians, the owners and the building

Five layers, none of them a single license

No federal clinic license exists. What you need depends on five layers:

Each clinician’s license from the state medical, nursing and PA boards.
Who may own the practice, under each state’s corporate practice of medicine doctrine.
Whether the clinic needs a facility license. Some states license clinics; most exempt physician-owned offices.
Federal certificates and enrollments: CLIA for any lab test, DEA for controlled substances, NPI, Medicare and Medicaid.
Fraud and abuse law, which shapes every lab, imaging and referral contract.

Physicians who will work across state lines can use the Interstate Medical Licensure Compact, “a voluntary, expedited pathway to licensure for qualified physicians who wish to practice in multiple states.” As of August 31, 2026, “38 States, DC, and Guam” processed applications as a state of principal license, and New York was listed only under “Compact Legislation Introduced” (IMLC).

Four states side by side

State	Agency	Clinic license	Key requirements, as the agency states them
California	Medical Board of California; Department of Public Health for licensed clinics	Clinic licensing statutes not verified here; ask CDPH	Lay owners and “Physician(s) operating a medical practice as a limited liability company, a limited liability partnership, or a general corporation” are prohibited
Texas	Texas Medical Board; state license for freestanding ERs	No general license found for physician-owned primary or urgent care offices	“the general rule against corporate practice of medicine”; no “emergency” wording without a freestanding emergency facility license
Florida	Agency for Health Care Administration	Required for each location unless exempt	Exempt if wholly owned by physicians or licensed practitioners with one supervising; licensed clinics publish prices, and urgent cares post their 50 most frequent services
New York	State Education Department; Department of Health	Article 28 facilities go through Certificate of Need	“business corporations cannot hire a licensee to provide professional services”; a professional service corporation “in which all shareholders must be licensees of one profession”

California: the strictest ownership rules

The Medical Board quotes Business and Professions Code 2400, “Corporations and other artificial entities shall have no professional rights, privileges, or powers,” which “is intended to prevent unlicensed persons from interfering with, or influencing, the physician’s professional judgment” (Medical Board of California). Prohibited structures include “Non-physicians owning or operating a business that offers patient evaluation, diagnosis, care and/or treatment” and “Management service organizations arranging for, advertising, or providing medical services rather than only providing administrative staff and services.”

The board lists decisions that must stay with a California physician, including “how many patients a physician must see in a given period of time,” hiring and firing of clinical staff for competency, “Setting the parameters under which the physician will enter into contractual relationships with third-party payers” and “Decisions regarding coding and billing procedures.” A medical corporation may have other licensed professionals as minority shareholders, up to the 49% ceiling in Corporations Code 13401.5. California’s separate clinic licensing statutes could not be opened for this guide; confirm with the Department of Public Health and a California health care attorney whether your model needs a clinic license.

Texas: corporate practice and the word “emergency”

The Texas Medical Board describes “the general rule against corporate practice of medicine,” with exceptions for nonprofit health organizations that “must be incorporated and directed by physicians licensed by TMB” and certain charitable health centers (TMB). A physician who “directly or indirectly aids or abets the practice of medicine by a person, partnership, association, or corporation that is not licensed to practice medicine by the board” faces discipline (Texas Occupations Code 164.052).

Naming matters in Texas. “A person may not establish or operate a freestanding emergency medical care facility in this state without a license,” and an unlicensed facility “may not hold itself out to the public as a freestanding emergency medical care facility or use any similar term … that would give the impression that the facility or person is providing emergency care” (Texas Health and Safety Code 254.051). Keep “emergency” and “ER” out of an urgent care’s name, signs and ads. Advertising is regulated too: the board treats “board eligible” claims and undisclosed paid testimonials as misleading (22 TAC 164.3).

Florida: a clinic license and posted prices

Florida’s Health Care Clinic Act covers “an entity where health care services are provided to individuals and which tenders charges for reimbursement for such services, including a mobile clinic.” It exempts a practice “wholly owned by one or more” physicians and “directly supervised by one or more of such physicians,” practices wholly owned by licensed practitioners, APRNs included, when an owner “is supervising the business activities and is legally responsible for the entity’s compliance,” and Medicaid providers (Florida Statutes 400.9905). Unless separately exempted, a practice still needs the license to bill under Florida’s motor vehicle no-fault law.

Otherwise, “Each clinic location shall be licensed separately,” and anyone owning “5 percent or more” is an applicant subject to background screening (Florida Statutes 400.991). The medical director agrees “in writing to accept legal responsibility,” must “Conduct systematic reviews of clinic billings,” and ensures the clinic publishes “the prices charged to an uninsured person.” An urgent care posts its schedule “in a conspicuous place in the reception area,” covering “the 50 services most frequently provided,” on a sign “at least 15 square feet in size or through an electronic messaging board that is at least 3 square feet,” with fines of “not more than $1,000, per day” for failing to. Exempt entities can obtain a certificate of exemption, for “$100 or the actual cost of processing” as of October 2026, and still post a schedule of charges (Florida Statutes 400.9935).

New York: professional entities and Certificate of Need

NYSED: “Professional services can be offered only by a licensed person or an organization otherwise authorized by law,” with exemptions for “Health maintenance organizations and hospitals regulated under the Public Health Law” (NYSED). A physician practice is a professional service corporation or PLLC. Facilities licensed under the Public Health Law go through Certificate of Need, which “regulates the establishment, construction, renovation, and acquisition of major medical equipment for healthcare facilities, including hospitals, nursing homes, home care agencies, and diagnostic and treatment centers,” under a revised regulation posted August 6, 2025 (New York Department of Health). Which route fits a clinic with outside investors is a question for New York counsel.

This guide quotes each regulator as it states its rules. It is not legal advice: California’s board itself encourages licensees to discuss their business structures “with knowledgeable legal counsel,” and every structure involving a non-physician owner should be reviewed by a health care attorney in your state.

CLIA, DEA, NPI and HIPAA

CLIA. “CMS regulates laboratory testing performed on humans in the U.S.” through CLIA, whose rules “are based on the complexity of the test method” (CMS CLIA). A clinic testing patients needs a current certificate, from a waiver through accreditation, unless it is CLIA-exempt (42 CFR 493.3). Rapid strep, flu and urine dipsticks are the waived tests most clinics start with. You file Form CMS-116 with your state agency and “Apply for the certificate that matches the highest level of test complexity your facility performs.” A Certificate of Waiver needs a laboratory director, with “no federal education or experience qualifications”; non-waived testing, including provider-performed microscopy, needs a director who meets “specific CLIA education, training, and experience requirements” (CMS, apply for a CLIA certificate). Fees vary with the certificate and volume and are paid online. Each location files its own waiver application (42 CFR 493.35).

DEA. Prescribing or stocking controlled substances takes a DEA registration for each location (21 CFR 1301.12), applied for online on DEA Form 224 (DEA registration). The practitioner fee in the federal table is $888 as of October 2026, and registrations run 36 months (21 CFR 1301.13).

NPI and HIPAA. CMS requires an NPI of every HIPAA-covered provider, “whether individuals or organizations” (CMS), so each clinician and the clinic entity apply. A clinic that bills insurance electronically meets the covered entity definition in 45 CFR 160.103 and needs HIPAA policies, training and business associate agreements before the first patient.

Medicare, Medicaid and insurer credentialing

Physicians and NPs enroll in Medicare individually on the CMS-855I, and “Clinics and group practices” on the CMS-855B. CMS lists physicians, non-physician practitioners and their organizations among those who “don’t pay a Medicare enrollment application fee.” Its inspectors make “unannounced site visits,” and a failed visit can mean denial, so apply once the space is open and signed. You then have 90 days to choose whether to participate; a non-participating clinic is held to “the limiting charge, 115% of the Medicare Physician Fee Schedule amount,” and ownership or location changes are reported “within 30 days” (CMS enrollment booklet). Medicaid enrollment runs through your state’s Medicaid agency.

Commercial plans mostly draw on DataSpring, formerly CAQH, which offers “a single credentialing application” across all 50 states (DataSpring). In the clinics we have seen open, each payer took months, and the clinics that started credentialing before signing the lease opened with patients they could bill.

Stark and anti-kickback. A physician with “a financial relationship with an entity” may not refer Medicare patients to it for designated health services, which include “Clinical laboratory services” and “Physical therapy services,” unless an exception such as “In-office ancillary services” applies (42 U.S.C. 1395nn). Paying or receiving “any remuneration (including any kickback, bribe, or rebate)” for federal program referrals is a felony, with fines up to $100,000 and up to 10 years in prison (42 U.S.C. 1320a-7b). Have counsel review in-house lab and imaging arrangements.

Urgent care accreditation is voluntary. The CAUCQ program says it has accredited more than 2,500 centers after “a thorough in-person, onsite survey,” with accreditation “granted for 36 months,” and “You can apply for Early Accreditation up to twelve months prior to opening” (CAUCQ). It pitches accreditation as useful “during payer negotiations.”

Setting up the business

Entity. The SBA’s general advice is that “LLCs protect you from personal liability in most instances” (SBA), but medical practices follow state professional entity law: a medical corporation in California, a professional service corporation or PLLC in New York. Lay investors usually own a management services company that contracts with the physician-owned practice, which California limits to administrative services and Florida treats as an owner if it holds 5% or more of the clinic. Each entity takes a free EIN from the IRS.

Insurance. Malpractice for each clinician and the entity; Florida physicians show financial responsibility, one route being “$100,000 per claim, with a minimum annual aggregate of not less than $300,000” (Florida Statutes 458.320). Add general liability, property and cyber. Workers’ compensation differs by state: Florida’s definition covers non-construction employers with “four or more employees” (Florida Statutes 440.02), while Texas private employers “can choose to carry workers’ compensation insurance coverage” (Texas Department of Insurance).

Local approvals. Zoning and a certificate of occupancy for medical use, a fire inspection, a regulated medical waste contract and, if you add X-ray, registration with the state radiation control program.

Space, lab, equipment and software

The layouts we see work: exam rooms in a loop around a central workstation, a lab corner sized to the CLIA certificate you chose, a vaccine refrigerator with temperature logs, and accessible entry and restrooms. Urgent care adds procedure rooms and usually X-ray. Start with waived tests and add moderate-complexity testing only once a qualified director is in place. Buy vaccines and drugs through the practice’s own accounts with licensed distributors, and keep controlled substances only at a DEA-registered location.

Software means an EHR and practice management system that bills cleanly, a clearinghouse, online booking and call handling. Zocdoc now lets “Any provider” join its network “for free,” charging a booking fee only when it brings a new patient (Zocdoc); that is the company’s own release, so get its fee in writing.

Pricing and money

Insurers and Medicare pay per visit and code under contracted fee schedules; self-pay clinics post cash prices; direct primary care charges memberships. No current per-visit price from an open source was found, and no startup cost with a stated method, so this guide quotes neither. Price transparency is a legal duty in places: Florida clinics publish cash prices, Florida urgent cares post their top 50 services, and federal good faith estimates apply to self-pay patients everywhere.

Cash flow is tightest in the first year. Credentialing gaps leave a new clinic seeing commercial patients it cannot yet bill in network, the Medicare participation decision affects every claim, and volume swings with flu season, physicals and January insurance changes.

Hiring and safety

Physicians, NPs, PAs, medical assistants and front desk staff, with NP and PA supervision or collaboration set by each state. Florida screens every 5% owner and the medical director as applicants. Check each clinician’s license on the board’s public lookup before making an offer. OSHA requires an employer with occupational exposure to “establish a written Exposure Control Plan designed to eliminate or minimize employee exposure” and to offer the hepatitis B vaccine at no cost (29 CFR 1910.1030), which covers anyone drawing blood or giving injections.

Finding the first patients

Google Business Profile. “Doctors, dentists, lawyers, financial planners, and insurance or real estate agents are all individual practitioners” to Google, and their profiles may carry a title such as Dr. or MD (Google Business Profile guidelines). The clinic keeps its own profile, and each public-facing clinician may have one. Verify the clinic’s profile before opening day, with hours and accepted plans that match the front desk; our Google Business Profile work covers clinic and provider profiles.

Local Services Ads. Google has no “medical clinic” category; “Primary care physician” is the general-medicine one, with the Google Verified badge after provider and practice checks and NPI verification (Google Local Services Ads requirements). “Booking leads aren’t available for health care verticals,” so leads arrive as calls (Google Local Services Ads).

Search ads. LocaliQ’s median for General Practice & Family Medicine search campaigns from October 2024 to September 2025 was $62.80 per lead with an 11.63% conversion rate (LocaliQ), a market figure rather than a forecast. New clinics usually start Google Ads on “urgent care near me” and “primary care accepting new patients” searches in the neighborhoods they can serve.

Insurer directories. Being in network, and listed correctly in each payer’s directory, is a channel of its own. Check every listing the week credentialing completes.

Ads and claims. In Florida, any ad for a free or discounted exam must carry a capitalized statement of the patient’s 72-hour refund rights (Florida Statutes 456.062). In Texas, keep emergency language out of urgent care ads.

Reviews and privacy. Google prohibits businesses that “selectively solicit positive reviews from customers” (Google contribution policy), so ask every patient. Never confirm in a reply that the reviewer was a patient: the Office for Civil Rights settled one such case for “$23,000” (Mintz). The FTC and HHS wrote to “approximately 130 hospital systems and telehealth providers” about tracking tools such as “the Meta/Facebook pixel and Google Analytics” (FTC and HHS letter), so keep ad tags off intake and portal pages. Here is how a review routine runs, and the medical clinic marketing page covers what comes after opening.

What trips up new owners

Choosing the ownership structure before checking the law. California prohibits lay ownership; New York bars business corporations from employing physicians.
A lay investor in a Florida clinic. The practitioner-owned exemption ends, and unlicensed charges become uncollectable.
No price sign in a Florida urgent care. Up to $1,000 a day.
Running a rapid test without CLIA. Even waived tests need a certificate for each location.
“ER” in a Texas urgent care’s name. Reserved for licensed freestanding emergency facilities.
Credentialing started late. Site visits and payer approvals outlast most build-outs.

Questions founders ask about opening a medical clinic

Can a non-doctor own a medical clinic?

It depends on the state. California prohibits it, New York bars business corporations from providing medical services, Texas allows only recognized structures, and in Florida a lay owner brings an AHCA clinic license and a medical director.

Does the clinic itself need a license?

In Florida, yes, for each location, unless it is practitioner-owned or otherwise exempt. In New York, licensed diagnostic and treatment centers go through Certificate of Need; in Texas, freestanding ERs are licensed while physician offices generally are not.

Do I need CLIA if I only run rapid tests?

Yes: a Certificate of Waiver at minimum, applied for on Form CMS-116 through your state agency, one per location.

Do I need a DEA registration?

Yes, for each location where you prescribe, stock or dispense controlled substances. The practitioner fee is $888 for a 36-month registration as of October 2026.

How long does insurance credentialing take?

No official figure exists; plan for months per payer and start before you sign the lease. Medicare adds an unannounced site visit, so the space must be open when you apply.

Is urgent care accreditation required?

No federal requirement was found. CAUCQ accreditation is voluntary, lasts 36 months and can begin up to twelve months before opening.

What must a Florida urgent care post?

A schedule of cash prices covering at least its 50 most frequent services, in the reception area, on a sign of at least 15 square feet or an electronic board of at least 3 square feet.

How much does it cost to open a medical clinic?

We found no sourced figure, so we give none. Build the budget from quotes for the lease and build-out, equipment, malpractice cover, software and the months of payroll before payers pay.

Sources

Checked on October 3, 2026. Rules and fees change, and many are set state by state or city by city: confirm the current requirements with the agency that issues them before you apply.

Starting out, or ready to grow?

One team, operating since 2015, runs local SEO, ads, reviews, websites and the CRM for local businesses. Every business that reaches out gets a free consult, an honest evaluation and a plan it keeps.

Get a free plan Marketing for primary care, urgent care and independent medical clinics