Hormone programs look like weight management from the outside and are regulated very differently, because one of the drugs is a controlled substance.
The federal deadline nobody has planned for
Testosterone is Schedule III. The Ryan Haight Act’s in-person evaluation requirement was never repealed; telehealth prescribing of controlled substances has run on temporary flexibilities, currently extended through December 31, 2026. A special registration framework was proposed in 2023 and never finalised, so nobody can register under it yet.
Every telehealth TRT clinic in the country is operating inside that exception. A program with no plan for what happens after it lapses is carrying a dated risk, and the plan usually involves an in-person pathway.
What a hormone program needs
- Providers licensed and DEA-registered in the patient’s state, with the drug class driving whether a live visit is required.
- Baseline and monitoring labs with an ordering provider and documented review — a low result on a single draw is a clinical finding, not a formality.
- Protocols covering dosing, monitoring intervals, haematocrit and PSA surveillance where indicated, and stopping criteria.
- For menopausal hormone therapy, marketing that reflects what actually changed in the 2026 label revisions — several risk statements were removed, the endometrial cancer warning was not, and compounded preparations were untouched.
- Sourcing documented, particularly for compounded pellets and creams.
What MDside provides
- Medical direction and the professional entity per state.
- Licensed, registered providers and a workflow that routes controlled-substance requests correctly rather than treating every request the same.
- Lab ordering, result review and documentation.
- Pharmacy relationships for both branded and compounded preparations.
- A structure that survives the end of the federal exception rather than one that assumes an extension.
Frequently asked questions
Can testosterone be prescribed by telehealth?
Currently yes, under temporary federal flexibilities running to December 31, 2026. That is an exception with an expiry date, not a settled rule.
Do you require repeat labs before starting?
No. A single low result is a clinical finding; requiring a confirmatory second draw as a matter of policy delays care without adding information. What matters is that a provider reviews the result and documents the reasoning.
Is the HRT boxed warning gone?
Partly. Label changes approved in February 2026 removed cardiovascular, breast cancer and dementia statements for several products. The endometrial cancer warning remains for systemic estrogen-only products, and compounded preparations were not addressed.
Can an NP prescribe testosterone?
Where their state scope and DEA registration permit it. Georgia is a notable exception — an APRN may not issue a Schedule I or II order under a nurse protocol, though Schedule III sits outside that particular bar.
General information, not legal or medical advice. Requirements differ by state and change often. Confirm your obligations with counsel licensed where you operate.