Testosterone is where telehealth compliance gets harder, because it's a Schedule III controlled substance. Everything that applies to a GLP-1 brand applies here, plus federal controlled substance law, DEA registration and a telemedicine rule that has been "temporary" since 2020.
LegitScript certifies TRT and HRT programs. It reviews them with the controlled-substance questions front and center.
The DEA rule you're relying on
The Ryan Haight Act generally requires an in-person medical evaluation before a controlled substance is prescribed via the internet. Since 2020, DEA has kept temporary telemedicine flexibilities in place that waive that in-person requirement. The fourth extension runs through December 31, 2026, while DEA works on a final special registration rule.
So a TRT brand prescribing testosterone to a patient it has never seen in person is, today, relying on a temporary rule with an end date. LegitScript's Legal Compliance standard asks whether you're compliant now. A good application also shows you've thought about what happens if the flexibilities lapse or change: an in-person pathway, a partner network, or a special registration plan.
DEA registration and state licensure
- State license: the prescriber must be licensed in the patient's state. No exceptions.
- DEA registration: controlled substance prescribing needs DEA registration, and in most cases registration tied to the states where you practice. See DEA registration by location.
- State controlled substance registration: some states require their own CSR on top of DEA.
- PDMP checks: many states require checking the prescription drug monitoring program before prescribing a controlled substance.
Reviewers compare the states on your website to the licenses and registrations in your file. Testosterone is where that mismatch shows up most, because DEA and state CSR coverage is often thinner than medical licensure.
Clinical protocol: what a valid TRT prescription looks like
Standard 7 asks whether prescriptions are valid. For testosterone, reviewers and regulators expect a protocol that looks like medicine, not a subscription:
- Symptoms plus confirmed low testosterone on repeat morning labs before starting
- Baseline hematocrit, PSA where indicated, and a documented discussion of fertility
- Screening for contraindications, including untreated prostate or breast cancer and uncontrolled erythrocytosis
- Scheduled follow-up labs and dose adjustments
- Rules for when to hold therapy or refer
Our hormone therapy protocols are written per state and reviewed by a physician.
TRT marketing copy that fails review
| Don't write | Why |
|---|---|
| "Get testosterone without a doctor visit" | Undercuts prescription validity and Ryan Haight compliance |
| "Guaranteed approval" / "everyone qualifies" | Implies prescribing is decided before evaluation |
| "Build muscle fast," bodybuilding imagery | Implies non-medical, performance use of a controlled substance |
| "Anti-aging testosterone" for normal-T patients | Off-label, unsubstantiated claim |
| Nationwide availability | Almost never true for controlled substances; list states |
Women's HRT and non-controlled hormones
Estradiol and progesterone aren't controlled, so the DEA layer drops away, but prescription validity, licensure and transparency still apply. Compounded bioidentical hormone claims ("safer than" or "natural alternative to" FDA-approved HRT) are a common Transparency problem. Testosterone for women is still Schedule III.
TRT LegitScript checklist
Where MDside fits
MDside is LegitScript certified and builds controlled-substance programs with physicians licensed and registered in the states you serve, written TRT protocols, and a plan for the post-2026 DEA rule. Our testosterone visits are synchronous, a real-time audio-video visit with the prescriber, and we offer them only in the states whose rules allow it. See which states allow a video start. Book a call if you're launching or certifying a TRT program.
Frequently asked questions
Can a TRT telehealth company get LegitScript certified?
Yes. It must show prescribers licensed in every patient state, appropriate DEA and state controlled substance registrations, valid prescribing protocols, and compliance with federal telemedicine rules for controlled substances.
Can I prescribe testosterone via telehealth without an in-person visit in 2026?
Under DEA's temporary telemedicine flexibilities, extended through December 31, 2026, DEA-registered practitioners can prescribe Schedule II–V medications via telemedicine without a prior in-person exam, subject to state law. State rules may be stricter.
What happens to TRT telehealth after December 31, 2026?
That depends on whether DEA finalizes a special registration rule or extends the flexibilities again. Programs should plan an in-person or special-registration pathway rather than assume another extension.
Is testosterone a controlled substance?
Yes. Testosterone and its esters are Schedule III controlled substances under federal law.
Do I need labs before prescribing testosterone for LegitScript?
LegitScript reviews whether prescriptions are valid and follow the standard of care. Confirmed low testosterone on repeat morning labs and baseline safety labs are the accepted standard before starting therapy.
Related reading
Sources
- LegitScript: certification standards
- LegitScript: process and pricing
- Federal Register: fourth temporary extension of telemedicine flexibilities
- DEA: telemedicine flexibilities extended
Launching or certifying a TRT program?
Licensed, DEA-registered physicians and protocols that hold up to review.