Last updated: November 2026
Florida’s Health Care Clinic Act requires covered clinics to hold an AHCA license, subject to statutory exclusions and the no-fault billing rule. This service is for new clinics, practice owners and buyers assessing license or exemption readiness. Integral Healthcare Solutions (IHS) organizes ownership, billing and service evidence and drafts application materials for counsel and owners to review and submit.
What is a Florida health care clinic license?
Governing text: the 2026 Florida Statutes, Health Care Clinic Act and Part II of Chapter 408, which 400.991(1)(a) applies. Sources: 400.990, 400.9905, 400.991, 400.9935, 408.806, 408.8065 (page opened November 5, 2026 for each).
- Applicant (400.9905(2)). An individual owner, corporation, partnership, firm, business, association or other entity that owns or controls, directly or indirectly, 5 percent or more of an interest in the clinic and that applies for a clinic license.
- Locations (400.991(1)). Clinic locations require separate licenses despite shared names or management. A portable equipment provider instead licenses one administrative office and need not report quarterly projected street locations.
- No-fault billing (400.9905(4), closing sentence). Notwithstanding the exclusions, an entity is deemed a clinic and must be licensed under the part in order to receive reimbursement under the Florida Motor Vehicle No-Fault Law, unless exempted under section 627.736(5)(h), which counsel reads.
The definition also lists what the part does not cover, in paragraphs (a) through (q). Two entries owners ask about:
- (4)(f) and (4)(g). These exclusions cover sole proprietorships, group practices, partnerships and corporations meeting the respective conditions. Paragraph (f) requires services by physicians covered by section 627.419, their direct supervision, and ownership wholly by one or more such physicians or by a physician and that physician’s spouse, parent, child or sibling. Paragraph (g) covers services by practitioners licensed under its listed provisions; ownership must be wholly by licensed practitioners or by the listed practitioners and a practitioner’s spouse, parent, child or sibling. A licensed practitioner owner must supervise business activities and accept legal responsibility for compliance with federal and state laws. Supervision cannot exceed the practitioner’s licensed scope, except for a clinic owned by a section 456.053(3)(b) licensee that provides only services authorized there and is supervised by a licensee specified there.
- (4)(n). This exclusion covers entities employing at least 50 chapter 458 or 459 practitioners and billing medical services under one tax identification number. The application must include the owning entity’s name, residence and business addresses and phone number; officers’ and directors’ names and contacts; each employed Florida practitioner’s name, residence and business addresses and medical license number; the corporate tax ID; services offered; and an independent CPA’s certified statement that the entity and its clinics received no PIP payments for health care services during the preceding year. AHCA may deny or revoke the exemption if it determines the entity received PIP payments for medical services.
Who needs it and what triggers it?
An entity that provides health care services in Florida and tenders charges for reimbursement must settle one question first: licensed or exempt. Triggers:
- A new clinic is forming, whether it has one owner or several.
- Ownership of a practice is changing. A new investor is a reason to re-read paragraphs (4)(f) and (4)(g), which require wholly owned practices. An application for initial licensure due to a change of ownership must be received by the agency at least 60 days before the change (408.806(2)(b)).
- The business will bill no-fault insurance or run a mobile clinic.
- A buyer or lender is asking whether a clinic holds a license or relies on an exemption.
The question comes first because a charge or claim by a clinic that is required to be licensed but is not is an unlawful charge and is noncompensable and unenforceable, whether or not a service is rendered or the charge is paid (400.9935(3)).
How IHS helps
IHS maps the clinic’s facts and documents to the governing text for client review.
- Gap assessment. Review ownership, billing, services and locations; prepare an exemption worksheet for counsel.
- Evidence mapping. Identify missing records and organize the financial package for the client’s certified public accountant.
- Drafting. Prepare application content, the director agreement and operating policies, with clinical content for the client’s clinicians to approve. Map billing-review responsibilities to section 400.9935(1)(g), including immediate correction of unlawful charges and its conditional imaging-clinic CFO alternative.
- Mock review and readiness support. Check the packet against the cited requirements, identify unresolved items and maintain the filing calendar.
Owners supply accurate records, counsel, the director and accountant, approve the materials and handle filing. IHS provides no legal advice, decides no exemption, makes no promise of approval and does not contact or submit materials to AHCA.
What to have ready
Checklist references are to the 2026 Florida Statutes, page opened November 5, 2026 for each; this is a preparation list, not every licensing requirement.
- Services supplied directly or by contract and the number and discipline of professional staff (400.991(3)).
- Identify direct and indirect owners/controllers of at least 5 percent, the medical or clinic director or similarly titled day-to-day operator, the financial officer or equivalent, and licensed practitioners. Level 2 screening covers applicants and personnel as required by section 408.809(1)(e), pursuant to chapter 435 and section 408.809; it is not an unqualified all-personnel rule (400.991(4)).
- The director’s written acceptance of the listed responsibilities (400.9935(1)); the billing preparer’s qualifications as chief financial officer, including at least a bachelor’s degree from an accredited university in accounting, finance or a related field (400.9905(3)).
- For initial or ownership-change licensure: independent evidence that startup, working-capital and contingency funds exist and will be available; two-year projected balance sheet, income-and-expense statement and cash-flow statement showing sufficient assets, credit and revenue for liabilities and expenses; and estimated startup costs and funding sources through break-even. Show at least three months of average projected expenses, with contingency funding of at least one month of average projected expenses. Prepare the documents under generally accepted accounting principles; compilation form is permitted. A CPA must sign the financial statements (408.8065(1)).
- Each applicant’s explanation of Medicare or Medicaid exclusions, permanent suspensions or terminations, submitted with the application; ownership-and-control disclosure compliance proof may be accepted instead (400.991(4)(c)).
- Clinic locations, mobile clinics’ projected street locations reported at least quarterly, and any portable provider’s single administrative office (400.991(1)).
- The published schedule of uninsured cash, check, credit-card and debit-card prices. For urgent care centers, section 400.9935(1)(i) also requires conspicuous reception-area posting covering at least the 50 most frequent services, on a sign of at least 15 square feet or an electronic board of at least 3 square feet (400.9935(1)(i)).
Under section 408.806, renewal applications must arrive 60–120 days before expiration; failure to apply before expiration voids the license. Applications require agency forms, oath or attestation and the appropriate fee. Within 30 days after receiving an application, AHCA must notify the applicant in writing of apparent errors or omissions and request additional information. Omitted information, other than an inspection, is due within 21 days after AHCA’s request, or the application is deemed incomplete, withdrawn and the fees forfeited. AHCA must approve or deny within 60 days of receiving a complete application. Licenses are biennial unless the category specifies a shorter period.
Discuss missing preparation items at the free introductory call below.
How it compares
A certificate documents an exempt entity’s status; it is not a third category separate from being outside the clinic definition. Compare the Florida license and exemption certificate with the distinct programs below.
- Part X license. Required when no exclusion fits, for each location and each mobile clinic.
- Certificate of exemption. A health-services provider outside the clinic definition may apply voluntarily using AHCA’s form, explaining the exemption and supplying names, addresses and other requested information. Validity may be up to two years; it is not transferable. Before issuance, document a maintained schedule of uninsured cash, check, credit-card and debit-card prices, conspicuously posted in reception, covering at least the 50 most frequent services on a posting of at least 15 square feet. Grouping into three price levels is permitted (400.9935(6)).
- Federal rural health clinic certification. A Medicare program with its own text, covered on the rural health clinic page.
- Florida home medical equipment provider license. A separate license under another part of Chapter 400.
What it costs
For an exemption certificate, section 400.9935(6) permits a fee of 100 dollars or actual processing cost, whichever is less. The statutes reviewed do not specify a clinic license-fee amount; this is not a statement that licensing is free. Verify current fees with AHCA.
Engagement scope depends on locations, ownership and existing records. IHS scopes each engagement after a free introductory call.
What this is not
This is not legal advice. IHS is a consulting firm, not a law firm, and counsel decides whether the entity is a clinic and whether an exemption applies.
It is not a guarantee that AHCA will issue a license. The agency decides. It is not IHS acting for you with the state: IHS does not contact AHCA, and the owners file and answer the agency.
Frequently asked questions
What is a Florida health care clinic under Part X of Chapter 400?
Under section 400.9905(4), a clinic is an entity where health care services are provided to individuals and which tenders charges for reimbursement for such services, including a mobile clinic and a portable equipment provider. Section 400.990(1) lets Part X be cited as the Health Care Clinic Act.
Who issues the clinic license?
The Agency for Health Care Administration (AHCA). Section 400.991(1)(a) requires a license issued by the agency in order to operate a clinic in Florida. The applicant submits the application. IHS does not deal with the agency.
Does a practice owned by physicians or other licensed practitioners need a license?
Not solely because practitioners own it. Counsel must test the entity against section 400.9905(4)(f) or (g), including the applicable ownership, service and supervision conditions described above, and the separate no-fault billing rule.
Does a large physician group need a license?
Not necessarily. Section 400.9905(4)(n) has the staffing, single-tax-ID billing and application conditions described above, including an independent CPA’s certification about the preceding year’s PIP payments. AHCA may deny or revoke this exemption if it determines the entity received PIP payments for medical services.
Does no-fault insurance billing change the answer?
Yes. An entity is deemed a clinic and must be licensed under the part in order to receive reimbursement under the Florida Motor Vehicle No-Fault Law, unless exempted under section 627.736(5)(h). Counsel reads that section first.
Does each location need its own license?
Each clinic location requires a separate license despite shared names or management. Each mobile clinic needs a separate license and must report its projected street location to AHCA at least quarterly. A portable equipment provider licenses one administrative office and need not submit quarterly projected street locations (400.991(1)).
What happens if a clinic that needs a license does not have one?
Charges by or on behalf of an unlicensed clinic required to be licensed are unlawful, noncompensable and unenforceable regardless of service or payment; section 400.9935(3) also covers clinics otherwise violating Part X. Under section 400.9935(4)(a), knowingly establishing, owning, operating, managing or maintaining a clinic requiring licensure without a license, or knowingly offering or advertising services requiring clinic licensure without a license, is a third-degree felony regardless of agency notice. A second or subsequent conviction is a second-degree felony under section 400.9935(4)(c).
What does IHS prepare and what does counsel confirm?
IHS prepares the exemption worksheet, financial package structure, application content, director agreement and operating policies. Counsel confirms exemption eligibility, a certified public accountant signs the financial statements, and owners complete and file the agency application.