As of August 28, 2026, MDside does not start Missouri testosterone patients by video. H.B. 2372 amended RSMo § 334.108.3 to bar prescribing any controlled substance “based solely on an evaluation through telemedicine” unless “a previously established and ongoing physician-patient relationship exists.” The same act lets a telemedicine encounter establish a relationship. Until a board or court reconciles the two, the safe path starts in person.
As of September 2026, no Board of Registration for the Healing Arts rule, newsletter or minutes, no BNDD guidance, no Attorney General opinion and no court decision has reconciled § 334.108.3 with § 191.1146. The House summaries and the fiscal note describe the new relationship rule and never mention the change from telephone to telemedicine.
Testosterone is Schedule III in Missouri, listed at RSMo § 195.017.6(6)(jjj). The federal DEA flexibilities in 21 C.F.R. § 1307.41 run through December 31, 2026, as of September 2026, and they waive only a federal in-person requirement. Missouri’s text applies on its own. For the other 50 jurisdictions, see telehealth testosterone by state.
Telephone became telemedicine
From 2019 until August 27, 2026, § 334.108.3 barred prescribing “based solely on an evaluation over the telephone.” A synchronous video visit was outside that sentence. H.B. 2372, approved July 13, 2026, struck “over the telephone” and inserted “through telemedicine,” and made the same swap in the exception, which now reads “telemedicine evaluation.”
That word matters because of how Missouri defines it. Section 191.1145.1(6) defines “telehealth” or “telemedicine” to include “audiovisual and audio-only technologies” and store-and-forward. A live video visit is squarely telemedicine. The exception survives in the same form: a physician, the physician’s on-call designee, or an APRN, PA or assistant physician in a collaborative practice arrangement with that physician may prescribe on a telemedicine evaluation “if a previously established and ongoing physician-patient relationship exists between such physician and the patient being treated.”
The same act loosened everything around it
Everywhere else, H.B. 2372 loosened the rules.
- § 191.1146.1(3) still lets a physician-patient relationship be established by “a telemedicine encounter, if the standard of care does not require an in-person encounter.”
- § 191.1146.2(2) replaced the flat questionnaire bar with a conditional test, covered in asynchronous telehealth by state.
- § 334.108.1(1) now requires a physical examination only “if required to meet the standard of care.”
- § 334.108.4 replaced the internet-questionnaire bar with a bar on prescribing “in the absence of a proper provider-patient relationship.”
The House’s truly agreed summary describes all of this as loosening. It does not mention the telephone-to-telemedicine swap in § 334.108.3.
Two readings, and the one MDside follows
| Literal reading | Harmonizing reading | |
|---|---|---|
| Text relied on | § 334.108.3 as written | § 191.1146.1(3) plus the act’s evident purpose |
| First prescription at a first video visit | Barred, because no relationship was “previously established” | Allowed, because the video encounter itself establishes the relationship |
| Weak point | Sits awkwardly beside a section that lets video form the relationship | Reads “previously established and ongoing” out of the statute |
| Official reading | None found as of September 24, 2026 | None found as of September 24, 2026 |
MDside follows the literal reading. The words “previously established and ongoing” have to mean something, and a relationship formed in the same visit as the prescription is hard to call previously established. The drug is a controlled substance. The cost of being wrong lands on the prescriber’s license and DEA registration, and the cost of the conservative choice is one in-person visit. If the Board of Registration for the Healing Arts or the legislature reads it otherwise, we will update this page.
Questions for counsel before you launch
- Whether a first video visit with no prescription, followed by a second video visit, creates a “previously established and ongoing” relationship. The statute does not say.
- Whether an in-person exam by an APRN or PA establishes the relationship “between such physician and the patient” that the exception requires.
- Whether the word “solely” leaves room for a video visit supported by an in-person component, such as a clinic-drawn lab panel and vitals.
The path that works in Missouri
- Start with an in-person visit that establishes the physician-patient relationship with the prescribing physician: history, exam, labs, diagnosis and plan, documented.
- Confirm the registrations. The prescriber needs a Missouri license (§ 191.1145.3), a Missouri BNDD registration, since § 195.030.2 bars prescribing any controlled substance without one, and a DEA registration covering Schedule III.
- Put APRNs and PAs under a collaborative practice arrangement with that physician. The exception in § 334.108.3 reaches them only in that arrangement. Proximity and arrangement rules are covered in medical director in Missouri.
- Move follow-ups to synchronous video. Once the relationship is on file and ongoing, dose changes and refills fit the exception.
- Keep the relationship ongoing. Lapsed patients returning after a long gap should be treated as a new start.
The aesthetics exam question is separate: see good faith exams in Missouri.
How MDside handles Missouri
MDside is LegitScript certified, and LegitScript certification for TRT telehealth covers what reviewers check in a program like yours. Its testosterone visits are synchronous, live video with the prescriber, and offered only in states whose rules allow them. Missouri’s amended text points to an in-person exam first, so MDside does not start Missouri patients by video. See hormone therapy for how the program runs where it is offered.
What this means for you
If you launched Missouri testosterone by video before August 28, 2026, audit which patients started after that date and how. Route new Missouri patients through an in-person first visit with the prescribing physician, then move them to video. Verify BNDD and DEA registrations for every prescriber, and put APRNs and PAs under a written collaborative practice arrangement. Watch two dates: any Board guidance on § 334.108.3, and the DEA deadline on December 31, 2026.
Related reading
Frequently asked questions
Can you get testosterone through telehealth in Missouri?
Follow-up care, yes. A video-only start is doubtful after August 28, 2026. RSMo § 334.108.3 now bars prescribing a controlled substance based solely on a telemedicine evaluation unless a previously established and ongoing physician-patient relationship exists. Testosterone is Schedule III in Missouri. MDside requires an in-person first visit.
What did Missouri H.B. 2372 change about telemedicine prescribing?
It replaced “over the telephone” with “through telemedicine” in § 334.108.3, effective August 28, 2026. It also let questionnaires count under conditions, required a physical exam only when the standard of care calls for one, and kept § 191.1146’s rule that a telemedicine encounter can establish a relationship.
Does a telemedicine visit establish a physician-patient relationship in Missouri?
Under § 191.1146.1(3), yes, if the standard of care does not require an in-person encounter. The open question is whether that same visit can support a controlled substance prescription, since § 334.108.3 requires a relationship that was previously established and ongoing. We found no board rule or court decision resolving it as of September 2026.
Do you need a Missouri BNDD registration to prescribe testosterone?
Yes. RSMo § 195.030.2 bars anyone from prescribing any controlled substance without first obtaining a registration from the Department of Health and Senior Services. Testosterone is Schedule III under § 195.017. The BNDD registration is separate from, and in addition to, the prescriber’s federal DEA registration.
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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.