Hiring a new physician is stressful enough without adding a legal curveball — but here’s one coming your way. Effective July 1, 2026, Virginia is now requiring every employer, including small medical practices, to put an actual salary range in job postings. No more “competitive pay” or “salary DOE” with a blank where the numbers should be. If you’re recruiting a physician, that means the range goes right on the job ad, right next to the job description, for anyone to see.
For most industries, that’s a manageable ask. For physician recruiting, it’s a little more complicated. Are you hiring someone fresh out of residency, or a physician with a decade of experience and their own patient base? Is most of their pay a flat salary, or does it swing wildly based on how many patients they see and how productive they are? A range that’s honest about all of that can start to look enormous — and it turns out, posting a range that’s too wide can get you in just as much trouble as not posting one at all.
So, let’s break down what the law actually says, and more importantly, how to build a salary range for a physician opening that’s realistic, defensible, and doesn’t scare off good candidates or invite a lawsuit.
The Basics
A few things about this law are worth knowing up front:
- It applies to every employer, no matter how small. A two-physician practice is covered just like a large health system.
- The range has to be set “in good faith,” and the law specifically says that how wide your range is will be part of judging that good faith. A range like $150,000–$500,000, thrown up just to avoid a lawsuit, isn’t a safe harbor — it’s a red flag.
- Employees and candidates can sue directly. Most states with pay transparency laws only let a state agency enforce them. Virginia lets people sue on their own, and anyone — not just applicants — can flag a bad posting in writing. You get 15 business days to fix it before you can be sued, but that clock starts fast.
- It covers postings for remote roles too, as long as you have employees in Virginia, and it covers anything posted on your behalf.
- Penalties run up to $1,000 for a first violation and $5,000 for each one after that, on top of actual damages in a private lawsuit.
Bottom line: compensation used to be something you negotiated quietly and revealed late in the process. Now it has to be public — on your website, on Indeed, on physician job boards, in locums postings — from the moment you post the job.
Why Physician Pay Doesn’t Fit Neatly Into One Number
Physician compensation is messier than most jobs, for a few reasons:
- Training stage matters a lot. Someone straight out of residency is worth a very different number than someone with ten years of experience and an established patient panel.
- Pay usually isn’t just salary. Most physicians have a base salary plus productivity pay — wRVU incentives, a cut of collections, quality bonuses, call pay, sign-on bonuses.
- Productivity swings are huge. Two physicians with the same base salary in the same role can end up hundreds of thousands of dollars apart in total pay, just based on how many patients they see and how fast they ramp up.
That creates a real tension: the law wants a meaningful range, but if you try to capture every possible dollar a physician could earn, the range balloons into something that looks made up. Here’s how to avoid that.
The Fix: Separate the Guaranteed Pay from the Upside
The cleanest approach — and the one most in line with how good-faith ranges are supposed to work — is to post a range for the part of the pay that’s fixed, and describe the variable part separately instead of cramming it into the range.
1. Range the base salary, not base-plus-unlimited-bonus. Post the actual guaranteed base range you’d offer for this role — say, “$220,000–$260,000 base salary.” Don’t fold in a productivity bonus that could theoretically double someone’s pay. That’s exactly the kind of inflated range the law is watching for.
2. Describe the extra pay — don’t necessarily put a number on it. Add a line like: “Plus wRVU-based productivity incentive, sign-on bonus, relocation assistance, and CME allowance.” You can give target ranges for these too if you want (candidates appreciate it), but the base salary range is what actually satisfies the law, and it’s the part that gets scrutinized.
3. If you do want to advertise total comp, use real numbers — not a best-case scenario. Look at what physicians in this role actually earned in total compensation over the past 1–3 years, and use the middle 50% of that (the 25th to 75th percentile) rather than what your top producer happened to hit. That’s a defensible, data-backed range — not a number pulled out of thin air.
New Grad vs. Experienced Hire: Don’t Force Them Into One Posting
If you’re hiring for a role that could go to a brand-new grad or a physician with a decade of experience, the cleanest move is usually to not use one posting for both.
- If the role really is open to any experience level, it’s fine to post one wider range — but back it up with an actual internal comp structure showing how experience maps to pay, so you can point to something real if it’s ever challenged.
- If you actually have two different roles in mind (say, an associate-track new grad vs. a partner-track experienced hire), post them separately with tighter ranges for each. This is almost always the safer move, and it’s more honest with candidates about what they’re actually being considered for.
- Either way, build a simple internal pay grid — tied to years of experience, board certification, subspecialty training — that your posted ranges are based on. This is the single most useful document to have if anyone ever questions a posting.
Quick Tips for Building Compliant Physician Salary Ranges:
- Build a physician comp grid — by specialty, experience level, certifications, and location if you have multiple sites.
- Split postings by experience tier instead of trying to stretch one range from new grad to veteran.
- Range the guaranteed base pay; describe the variable pay separately.
- If you range total comp, base it on real historical earnings (the middle 50% of what physicians actually made), not a best-case number.
- Skip the mega-ranges. A $180,000–$450,000 range invites exactly the scrutiny the law is designed to catch.
- Update every job board and recruiter, not just your careers page — you’re on the hook for postings even if you didn’t personally write them.
- Train hiring managers not to ask about salary history, and give them a simple script for what to do if a candidate brings it up unprompted (you can only use it to justify a higher offer, never a lower one).
- Revisit your ranges periodically as your comp grid changes, not just once and forget it.
Bottom Line
You don’t need to find one perfect number for a physician role — you need a range that’s real, documented, and actually tied to how you pay people. Separate the guaranteed pay from the productivity upside, split postings by experience level instead of stretching one range across an entire career, and keep a simple internal comp structure to back it all up. Do that, and you’re not just compliant — you’re actually giving candidates a clearer, more honest picture of the job.
This article is for general informational purposes and does not constitute legal advice. Medical practices should consult with employment counsel with questions regarding compliance with Virginia’s Wage Transparency Act.
