Yes. In most states, as of September 24, 2026, a nurse practitioner can prescribe testosterone after a live video visit on the same terms as a physician. The exceptions are specific. In eight states the nursing rule is stricter than the physician rule: Kentucky, Oklahoma, Texas and Pennsylvania cap the supply, and Georgia, Missouri, Tennessee and California require a physician to examine, review or approve.
The federal layer does not distinguish. Testosterone is Schedule III, and the DEA flexibilities in 21 C.F.R. § 1307.41 let any DEA-registered practitioner, NP included, prescribe it by real-time audio-video without a prior in-person exam through December 31, 2026. What that date means is a separate problem. This post is about the state layer, and it assumes you have already read the physician map. Everything there still applies. The rules below are added on top when the prescriber is an NP.
Four states cap the supply
The most common difference is a supply limit. The program survives it. The refill clock changes.
- Kentucky limits APRN prescriptions for Schedule III to “a thirty (30) day supply without any refill” under KRS 314.011(8)(b). Every month is a new prescription. Your visit cadence and pharmacy workflow have to be built around that.
- Oklahoma limits APRNs to “no more than a 30-day supply for Schedule III-V drugs” under OAC 485:10-16-5(c). The board’s current forms apply the same cap to APRNs with independent prescriptive authority. The board has also said a single dose of a time-release Schedule III drug that releases over more than 30 days is more than a 30-day supply. It named testosterone pellets. An APRN may insert pellets on a physician’s written order but cannot prescribe them.
- Texas caps Schedule III to V at a 90-day supply, including refills, under 22 Tex. Admin. Code § 222.8(b)(1). Past the first 90 days, a refill requires consultation with the delegating physician, noted in the chart, under § 222.8(b)(2). The better-known Texas APRN limit is on Schedule II and does not reach testosterone.
- Pennsylvania lets a CRNP prescribe Schedule III for up to a 90-day supply “as identified in the collaborative agreement” (49 Pa. Code § 21.284(d)(2)). That sits on top of the in-person exam problem below.
Four states put a physician back in the loop
These rules are the ones operators miss, because they sit in collaboration rules rather than in telehealth rules.
Georgia. A patient who receives any controlled substance under a nurse protocol agreement “shall be evaluated or examined by the delegating physician” or a designated physician at least quarterly, and the physician must review and sign 100 percent of those patient records at least quarterly (Ga. Comp. R. & Regs. 360-32-.02). For an NP-run testosterone program, that is a physician encounter per patient per quarter. The rule does not say whether that evaluation may be by telemedicine. The Georgia protocol cap limits how many NPs one physician can carry.
Missouri. For conditions other than acute self-limited or well-defined problems, the collaborating physician must examine and evaluate the patient and approve the treatment plan for a new condition within two weeks of the APRN’s visit (20 CSR 2200-4.200(2)(H)). The rule permits that exam by live video only where the APRN works under the rural telehealth statute, Mo. Rev. Stat. § 335.175. The physician must also review at least 20 percent of the APRN’s controlled substance cases, with documentation submitted at least every 14 days (20 CSR 2200-4.200(3)(E)). Add Missouri’s August 2026 telemedicine amendment, covered in the physician map, and Missouri is the hardest state in this list for an NP-run video program.
Tennessee. The supervising physician must personally review and sign the chart within 30 days whenever the NP prescribes a controlled drug (Tenn. Comp. R. & Regs. 0880-06-.02(7)(e)), on top of reviewing at least 20 percent of charts every 30 days. Every testosterone start creates a physician task with a deadline.
California. An NP furnishing Schedule II or III must do so “in accordance with a patient-specific protocol approved by the treating or supervising physician” (Cal. Bus. & Prof. Code § 2836.1(f)(2)). The newer 103 pathway lets a qualified NP practice without standardized procedures, but only in listed settings where physicians also practice (§ 2837.103(a)(2)).
The in-person rules reach NPs too
A common assumption is that the physician in-person rules belong to the medical board and leave NPs alone. In the states we checked, they do not.
- Arkansas has its own nursing rule: an APRN “using telemedicine may not issue a prescription for any controlled substances” in Schedules III to V without an in-person exam, a referral or cross-coverage (17 CAR § 123-1202).
- Pennsylvania’s CRNP rule requires an initial physical exam before any controlled substance, with the same 30-day workaround as physicians (49 Pa. Code § 21.284b(b)(1)).
- Connecticut’s Schedule III telehealth bar applies to any “telehealth provider,” which includes every provider licensed under title 20, NPs among them (Conn. Gen. Stat. § 19a-906).
- Louisiana’s in-person rule covers every “healthcare provider” (La. R.S. 40:1223.4(B)(6)).
- Alabama’s medical board says CRNPs may prescribe controlled substances by telehealth only under the same § 34-24-704 conditions, and a CRNP’s state certificate reaches Schedules III to V only (Ala. Admin. Code r. 540-X-18-.07).
- New Hampshire requires the APRN to conduct a subsequent in-person exam at least annually (RSA 326-B:2, XII).
- Minnesota’s in-person rule in Minn. Stat. § 151.37 is written for practitioners generally.
Two states people get wrong
Florida. The APRN seven-day cap applies to Schedule II only (Fla. Stat. § 464.012(6)(a); Fla. Admin. Code r. 64B9-4.016). Testosterone carries no NP-specific supply limit. The NP still works under a supervisory protocol unless registered as autonomous (§ 464.012(3)).
West Virginia. Summaries claiming a Schedule III limit for West Virginia NPs still circulate. The current rule limits Schedule II narcotics to a three-day supply and states “no other limitations” (W. Va. Code R. § 19-8-5.1). The nursing board’s telehealth rule, 19 CSR 16, contains no 12-month in-person requirement. The telehealth statute, W. Va. Code § 30-1-26, does carry one for established patients, and whether it binds NPs directly is unresolved.
The table
These are the differences we found as of September 2026. States not listed follow the physician map for testosterone, subject to the NP’s own collaboration or practice agreement listing Schedule III.
| State | NP rule that differs | What it does to a TRT program |
|---|---|---|
| Kentucky | 30-day supply, no refill | New prescription every month |
| Oklahoma | 30-day supply, Schedule III to V | Monthly prescriptions; no NP-prescribed pellets |
| Texas | 90-day supply including refills | Physician consult noted in the chart before later refills |
| Pennsylvania | In-person exam first; 90-day supply | Local exam within 30 days, then video |
| Georgia | Physician evaluation at least quarterly | One physician encounter per patient per quarter |
| Missouri | Physician exam within two weeks; 20% chart review every 14 days | Physician visit for every new start |
| Tennessee | Physician chart signature within 30 days of a controlled drug | Signature queue for every start |
| California | Patient-specific protocol for Schedule III | Physician-approved protocol per patient |
| Arkansas | Nursing rule bars Schedule III by telemedicine without in-person exam | Same as physicians: no video starts |
| Connecticut, Louisiana | Physician bar applies to NPs | Same as physicians: no video starts |
| Alabama | Same § 34-24-704 conditions; state certificate | In-person within 12 months |
| New Hampshire | Annual in-person exam | Yearly visit |
| Florida | Schedule II cap only | No Schedule III difference |
| West Virginia | No Schedule III cap in current rule | Statute question open |
What this means for you
Apply the stricter of the nursing rule and the medical rule, state by state, before you let an NP carry testosterone patients alone. In Kentucky and Oklahoma, build a monthly prescribing cycle. In Georgia, Missouri and Tennessee, put the physician’s review and visit obligations on a calendar with names attached, because a board will ask for the dates. If the physician work is heavy enough that the NP cannot run the program alone, that is a staffing question, and our NP scope of practice guide has the ratios. MDside is LegitScript certified, and our testosterone visits are synchronous and offered only where state rules allow; the hormone therapy page shows how the program is structured.
Related reading
- Telehealth testosterone by state: where a video visit can start TRT
- Nurse Practitioner Scope of Practice by State
- PDMP checks for testosterone by state
- DEA Telemedicine Flexibilities Expire December 31, 2026: What TRT Clinics Must Do
Frequently asked questions
Can a nurse practitioner prescribe testosterone online?
Yes, in most states, by live video, as of September 2026. Federal DEA flexibilities cover NPs the same as physicians through December 31, 2026. A questionnaire alone does not qualify. Eight states add NP-specific limits: Kentucky, Oklahoma, Texas and Pennsylvania cap the supply, and Georgia, Missouri, Tennessee and California require physician examination, review or approval.
How many days of testosterone can a nurse practitioner prescribe?
It depends on the state. Kentucky allows a 30-day supply with no refill. Oklahoma allows 30 days for Schedule III to V. Texas allows 90 days including refills, then requires a documented physician consult. Pennsylvania allows up to 90 days as set in the collaborative agreement. Most other states set no NP-specific cap for Schedule III.
Can a nurse practitioner prescribe testosterone pellets?
Not in Oklahoma. The nursing board treats a pellet that releases over more than 30 days as exceeding the 30-day Schedule III cap, so a physician must prescribe it. An APRN trained in insertion may still place pellets on a physician’s written order. Check other states with supply caps before adding pellets to an NP’s formulary.
Does a nurse practitioner need a physician to prescribe testosterone by telehealth?
In several states, yes. Georgia requires a physician evaluation at least quarterly for controlled substance patients under a nurse protocol. Missouri requires a physician exam within two weeks of a new start. Tennessee requires physician chart review within 30 days. California requires a physician-approved patient-specific protocol for Schedule III.
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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.