A synchronous video visit can start testosterone for a new patient in 40 of 51 jurisdictions, as of September 24, 2026. Three more allow it with an in-person string attached: New Hampshire, New York and Georgia. Eight require an in-person exam first or bar it outright: Alabama, Arkansas, Connecticut, Louisiana, Minnesota, Missouri, Pennsylvania and Rhode Island.
All of it sits on top of the federal rule. Testosterone is Schedule III, and the DEA flexibilities that waive the Ryan Haight in-person requirement run through December 31, 2026 under 21 C.F.R. § 1307.41. They cover real-time, two-way visits. A questionnaire reviewed later has never qualified. What happens after that date is a separate question, and the state table below assumes the federal door is open.
The eight states where video cannot start testosterone
These are the states where a clean video visit with a new patient at home is not enough, whatever the federal rule says.
- Connecticut is the strictest. Conn. Gen. Stat. § 19a-906(c) bars prescribing any Schedule I, II or III controlled substance through telehealth, with carve-outs only for medication-assisted treatment and for psychiatric disability or substance use disorder (as amended by P.A. 25-168, effective June 30, 2025). A prior in-person visit does not fix it for testosterone.
- Alabama requires a synchronous visit and an in-person encounter with the prescriber within the preceding 12 months, under Ala. Code § 34-24-704(b). The prescriber also needs an Alabama controlled substance certificate, and the board has said a federal DEA waiver does not stand in for it.
- Arkansas requires an in-person exam before Schedule II to V prescribing for physicians (17 CAR § 140-3201(b)(5)) and Schedule III to V for APRNs (17 CAR § 123-1202), with narrow exceptions for consults, cross-coverage and an ongoing relationship.
- Louisiana bars any controlled substance before “an appropriate in-person patient history or physical examination” (La. R.S. 40:1223.4(B)(6)). The board rule requires an in-person visit within the past year. The statutory exception covers patients at a licensed, DEA-registered facility, not at home.
- Minnesota requires an in-person exam before Schedule III to V prescribing (Minn. Stat. § 151.37, subd. 2(e)). The telehealth exceptions reach erectile dysfunction drugs and opioid use disorder medication only. An earlier in-person exam by anyone in the same group practice satisfies it, so a hybrid model works. Minnesota also schedules hCG, which matters if your protocol adds it.
- Pennsylvania requires an initial physical exam before any controlled substance (49 Pa. Code § 16.92(a)(1)). The rule text does not say in-person, but the board’s December 2024 preamble describes it as an in-person physical examination requirement. The CRNP rule is parallel. An exam by another licensed provider within the prior 30 days is the recognized workaround.
- Missouri changed on August 28, 2026. Mo. Rev. Stat. § 334.108.3 now bars prescribing a 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 under § 191.1146, so the two sections pull against each other. Until the board or a court reads them together, we treat a video-only start as barred.
- Rhode Island is contested. The binding regulation, 216-RICR-40-05-1 § 1.5.9(H), is silent on in-person exams. The board’s posted telemedicine guideline says prescribing controlled substances “without an established in-person physician-patient relationship is prohibited.” We follow the guideline until the board withdraws it.
Three states that allow it with a string attached
Georgia reads its rules (Ga. Comp. R. & Regs. 360-3-.02(5)) to require one in-person exam before the first controlled substance prescription and diligent efforts at an annual one. On January 8, 2026 the board voted to extend telemedicine flexibilities through the end of 2026 “in alignment with the DEA and HHS.” The rule text did not change, only the board’s enforcement position. Georgia reverts on January 1, 2027 unless the board acts again.
New York requires an in-person evaluation before any controlled substance under 10 NYCRR § 80.63(d)(1), effective May 21, 2025. The telehealth exception holds only “when consistent with” DEA rules, so it narrows when the federal flexibilities do. A PMP check is required before every Schedule II to IV prescription.
New Hampshire allows a telemedicine start for Schedule II to IV but requires a subsequent in-person exam at least once a year under RSA 318-B:2, XVI. The 2025 physician-statute amendment softened the wording. The controlled-drug statute did not, so plan on the annual visit.
The full table
| State | Video start for a new patient | What you still need |
|---|---|---|
| Alabama | No | In-person within 12 months; state CS certificate |
| Alaska | Yes | Follow-up available; offer records to PCP; database check |
| Arizona | Yes | Documented therapeutic purpose |
| Arkansas | No | In-person exam first |
| California | Yes | Documented consent; CURES check first and every 6 months |
| Colorado | Yes | Standard of care |
| Connecticut | No | Schedule III barred by telehealth |
| Delaware | Yes | Delaware CS registration |
| District of Columbia | Yes | Standard of care |
| Florida | Yes | PDMP check before every prescription |
| Georgia | Through Dec 31, 2026 | Board extension only; annual in-person effort |
| Hawaii | Yes | Documented evaluation; no questionnaire-only |
| Idaho | Yes | Compliance with federal law |
| Illinois | Yes | Standard of care |
| Indiana | Yes | Indiana CS registration; audio-video only; INSPECT |
| Iowa | Yes | Video, not audio-only |
| Kansas | Yes | Same rules as in person |
| Kentucky | Yes | Relevant exam; KASPER review; APRN 30-day cap |
| Louisiana | No | In-person first; annual visit |
| Maine | Yes | Standard of care |
| Maryland | Yes | Maryland CDS registration |
| Massachusetts | Yes | State CS registration |
| Michigan | Yes | MAPS check over 3-day supply; state CS license |
| Minnesota | No | In-person exam within the group first |
| Mississippi | Yes | Mississippi license; testosterone exempt from MPMP check |
| Missouri | No | Read conservatively after Aug 28, 2026 |
| Montana | Yes | Standard of care |
| Nebraska | Yes | Standard of care |
| Nevada | Yes | PMP report first and every 90 days; state CS registration |
| New Hampshire | Yes | In-person exam at least yearly |
| New Jersey | Yes | Standard of care (in-person rule is Schedule II only) |
| New Mexico | Yes | State CS registration |
| New York | While DEA flexibilities last | PMP check before every prescription |
| North Carolina | Yes | CSRS participation |
| North Dakota | Yes | Exam equivalent to in person; no audio-only |
| Ohio | Yes | Identity and Ohio location verified; no athletic use |
| Oklahoma | Yes | OBNDD registration |
| Oregon | Yes | Standard of care |
| Pennsylvania | No | Physical exam first, or one within 30 days by another provider |
| Rhode Island | No (contested) | Board guideline requires in-person relationship |
| South Carolina | Yes | History at each encounter; state PMP participation; state CS registration |
| South Dakota | Yes | Real-time audio-video exam |
| Tennessee | Yes | History, exam, diagnosis and plan first |
| Texas | Yes | Synchronous audio-video; follow-up duties |
| Utah | Yes | Identity check; telehealth consent |
| Vermont | Yes | Documented diagnosis; no questionnaire-only |
| Virginia | Yes, if all nine conditions are met | Virginia location or referral ability; plan credentialing if insured |
| Washington | Yes | Standard of care |
| West Virginia | Yes (physicians) | NPs: open question under § 30-1-26 |
| Wisconsin | Yes | PDMP review before prescribing |
| Wyoming | Yes | Tracking program search before first prescription |
“Yes” means state law does not require an in-person exam before a Schedule III prescription by live video. It does not mean the rest of the chart can be thin. Every state still requires a license where the patient sits, a documented evaluation that meets the standard of care, and in most, a DEA registration in that state.
The conditions that catch programs
The in-person rule gets the attention. These are the requirements that more often produce the board letter.
- Database checks. California, Florida, Kentucky, Michigan, Nevada, New York, Wisconsin and Wyoming require a prescription monitoring check that reaches testosterone, some before every prescription. Several other states limit the mandate to opioids and benzodiazepines.
- State controlled substance registration. Alabama, Delaware, Indiana, Maryland, Massachusetts, Michigan, Nevada, New Mexico, Oklahoma and South Carolina require one on top of DEA.
- Nurse practitioner rules. The table reflects physician rules. NP rules can be stricter. Kentucky caps APRN Schedule III prescriptions at a 30-day supply with no refill. Pennsylvania’s CRNP rule mirrors the physician exam requirement. West Virginia’s telehealth statute carries a 12-month in-person standard that may reach NPs.
- Audio-only. Iowa, North Dakota, Indiana and Tennessee exclude it from what counts as a telehealth visit. Build every testosterone visit on live video.
- Athletic use. Ohio bars testosterone for athletic enhancement, and Arizona treats non-therapeutic anabolic steroid prescribing as unprofessional conduct. Document the diagnosis and the labs behind it.
Where MDside stands
Our testosterone visits are synchronous, with the prescriber on live video, and we offer them only in states whose rules allow it. In the states above that require an in-person exam first, we do not start patients by video. That is narrower than much of the market, and it is deliberate: a board in Pennsylvania or Louisiana does not care what the federal flexibility says. Programs we support run through the same good faith exam workflow as every other prescription, and the state rules are applied before the visit is booked. MDside is LegitScript certified, and what reviewers ask a telehealth TRT program follows the same map.
What this means for you
Pull your patient list by state and check it against the table this week. Stop new video starts in the eight “No” states and route those patients to an in-person path. Add Georgia and New York to your December plan, because both depend on the federal date. Confirm each prescriber’s state controlled substance registration and database access for every state they serve. Then read the hormone therapy service page for how we structure the program behind it.
Related reading
- DEA Telemedicine Flexibilities Expire December 31, 2026: What TRT Clinics Must Do
- What Happens January 1, 2027
- Asynchronous Telehealth by State
- DEA Registration by Location
Frequently asked questions
Can testosterone be prescribed through telehealth?
Yes, in most states, as of September 2026. Federal DEA flexibilities allow a controlled substance by live audio-video without a prior in-person exam through December 31, 2026. State law adds its own layer: 40 jurisdictions allow a video start for a new patient, three attach conditions, and eight require an in-person exam first or bar telehealth prescribing of testosterone.
Which states require an in-person visit before prescribing testosterone by telehealth?
Alabama, Arkansas, Louisiana, Minnesota and Pennsylvania require an in-person exam first. Connecticut bars Schedule III telehealth prescribing outright. Missouri’s August 2026 amendment and Rhode Island’s board guideline point the same way. Georgia requires in-person care after its board extension ends on December 31, 2026, and New Hampshire requires an annual in-person exam.
Can a testosterone prescription come from an online questionnaire?
No. Testosterone is Schedule III, and the federal telemedicine flexibility covers real-time, two-way visits. Store-and-forward questionnaires fall outside it in every state. Several states, including Hawaii, Vermont, North Dakota and South Dakota, also bar questionnaire-only prescribing in their own telehealth statutes. A live video visit with the prescriber is the minimum.
What happens to telehealth TRT after December 31, 2026?
It depends on whether the DEA extends the flexibilities again or finalizes a special registration rule. If neither happens, the federal in-person requirement returns for patients the prescriber has never examined in person. Georgia and New York tie their state rules to the federal one, so they would tighten on the same date.
Do nurse practitioners follow the same telehealth testosterone rules?
Not always. NP rules sit with the board of nursing and can be stricter. Kentucky limits APRN Schedule III prescriptions to a 30-day supply with no refill. Pennsylvania’s CRNP rule requires the same initial physical exam as physicians. Check the nursing board rule in every state where an NP prescribes.
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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.