In Pennsylvania, a video visit alone cannot start testosterone for a new patient. 49 Pa. Code § 16.92(a)(1) requires an initial medical history and an initial physical examination before prescribing any controlled substance, and the State Board of Medicine calls that exam in-person. Testosterone is Schedule III. The one shortcut: an exam recorded by another licensed provider within the preceding 30 days.
That holds as of September 2026, while the federal DEA flexibilities under 21 C.F.R. § 1307.41 run through December 31, 2026. They waive a federal requirement and leave the state rule alone. For every other state, see telehealth testosterone by state.
The rule reaches every schedule
Section 16.92 covers every controlled substance, not only Schedule II or opioids. The operative sentence reads: “an initial medical history shall be taken and an initial physical examination shall be conducted prior to prescribing controlled substances unless emergency circumstances justify otherwise.”
The rule also sets the exam’s contents: “an objective evaluation of the heart, lungs, blood pressure and body functions that relate to the patient’s specific complaint.” For testosterone, the chart should show the findings behind the prescription.
The text never says in-person. The Board does. Its December 2024 rulemaking (54 Pa.B. 8252) calls it “the in-person physical examination requirement.” Its one telehealth exception, § 16.92(a)(9), covers opioid treatment programs using buprenorphine or methadone, and even there a full in-person exam must follow within 14 days.
The Board already answered the federal question
The same preamble addressed opioid treatment programs that read a federal rule change as permission to examine by telehealth. The Board wrote that if they did, “they would be subject to discipline by the Board at the State level.” The logic carries to testosterone: a federal flexibility changes federal law, and § 16.92 stays in force until the Board amends it.
Two boards, one requirement
Physicians and physician assistants regulated by the State Board of Medicine follow § 16.92. Certified registered nurse practitioners follow the Board of Nursing’s parallel rule, 49 Pa. Code § 21.284b, amended effective November 1, 2025.
| Board of Medicine (§ 16.92) | CRNPs (§ 21.284b) | |
|---|---|---|
| Schedules covered | All controlled substances | All controlled substances |
| Initial history and physical exam | Required first | Required first |
| Exam contents | Heart, lungs, blood pressure, body functions related to the complaint | Heart, lungs, vital signs, pain level, body functions related to the complaint |
| 30-day provision | Exam “recorded by another licensed health care provider” | Exam “recorded by another health care provider” |
| Telehealth exception | Opioid treatment programs only | None |
Osteopathic physicians have no parallel rule. The Osteopathic Board’s prescribing standard, 49 Pa. Code § 25.211, was reserved in 1998 and never replaced, so a DO answers to the general standard of care and the records rule at § 25.213.
We did not locate a parallel rule for osteopathic physicians, who sit under a separate board. Until counsel confirms, a DO should follow the § 16.92 standard. A CRNP also needs a current collaborative agreement on file with the state, covered in Pennsylvania files your CRNP agreement.
The 30-day provision is the only shortcut
Both rules let the prescriber rely on someone else’s work within a window. The medical rule reads: “Medical history and physical examination information recorded by another licensed health care provider may be considered if the medical history was taken and the physical examination was conducted within the immediately preceding 30 days.”
The exam still happens in a room. Only the examiner changes. A primary care visit or a documented exam at your clinic can satisfy the rule if it falls inside 30 days and the prescriber reviews it. “May be considered” leaves the judgment with the prescriber, so an exam that skipped the heart, lungs or blood pressure is a weak foundation.
The rule says licensed health care provider, not physician, so a CRNP or physician assistant who documents the required elements fits the text. The borrowed exam still has to cover the heart, lungs, blood pressure and the body functions tied to the complaint. No Pennsylvania board has said in public whether a registered nurse’s assessment counts, so do not build a program on it.
The path that works in Pennsylvania
This sequence fits both rules as written:
- License the prescriber in Pennsylvania and confirm the DEA registration covers the practice.
- Hold an in-person history and physical exam at a Pennsylvania site, performed by a physician, CRNP or physician assistant, covering heart, lungs, blood pressure or vital signs, and the findings behind the testosterone decision.
- Or obtain a documented exam from another provider, dated within the preceding 30 days, and have the prescriber review it before the first visit.
- Run the prescribing visit by live video and record symptoms, diagnosis, directions, and the drug’s name, strength and quantity under § 16.92(a)(4).
- Query the PDMP before the first controlled substance prescription to that patient. ABC-MAP requires a query the first time a prescriber prescribes a controlled substance to a patient.
- Schedule reevaluations matched to the condition and drug, under § 16.92(a)(2). Follow-ups can run by video.
- Watch the 30-day clock. When the exam came from someone other than the prescriber, it must fall within the 30 days before the first prescription.
A clinic with a Pennsylvania location is well placed. Its good faith exam workflow already puts a physician, CRNP or PA in front of patients, and its Pennsylvania medical director sets the protocols.
How MDside handles Pennsylvania
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. Pennsylvania requires a physical exam first, so MDside does not start Pennsylvania patients by video. The hormone therapy program is built around the in-person step here.
What this means for you
Stop sending new Pennsylvania testosterone patients to a home-video intake. Start with an in-person exam at a Pennsylvania site, or a documented exam inside 30 days, then move prescribing and follow-ups to live video. Apply the same step to CRNPs. Put the DO and RN-exam questions to counsel before you design around them, and track the federal December 31, 2026 date.
Related reading
Frequently asked questions
Can you get testosterone through telehealth in Pennsylvania?
Only after a physical exam. 49 Pa. Code § 16.92(a)(1) requires an initial history and physical exam before any controlled substance, and the State Board of Medicine calls it an in-person requirement. Testosterone is Schedule III. An exam recorded by another licensed provider within the preceding 30 days can satisfy it, and follow-ups can run by live video.
Does the DEA telehealth extension override Pennsylvania’s exam rule?
No. The DEA flexibilities under 21 C.F.R. § 1307.41 run through December 31, 2026 and waive only the federal in-person requirement. In its December 2024 rulemaking, the Pennsylvania Board warned practitioners that relying on a federal change to skip the state exam would expose them to discipline at the state level.
Can a Pennsylvania nurse practitioner prescribe testosterone by telehealth?
Only after an initial physical exam. The Board of Nursing rule, 49 Pa. Code § 21.284b(b)(1), amended effective November 1, 2025, requires a history and physical exam covering heart, lungs, vital signs and related body functions first. It has no telehealth exception. An exam by another provider within 30 days may be considered.
What does the 30-day rule in Pennsylvania mean?
It lets the prescriber rely on a history and physical exam recorded by another licensed provider within the immediately preceding 30 days. The exam still happens in person. It only changes who performs it. The prescriber must review the record, and it should include the heart, lungs and blood pressure findings the rule lists.
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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.