Can Testosterone Be Prescribed by Telehealth Without an In-Person Visit in 2026?
Telehealth Strategy
•
Can Testosterone Be Prescribed by Telehealth Without an In-Person Visit in 2026?
By Kris Zizzo, CEO | Last updated September 24, 2026
Testosterone can be prescribed by telehealth without a prior in-person medical evaluation in 2026 when a DEA-registered practitioner uses a qualifying audio-video encounter and the federal temporary-rule conditions are met. The current temporary rule runs through December 31, 2026, while DEA's permanent telemedicine framework is under White House review.
DEA sent the final Special Registrations for Telemedicine rule to the Office of Information and Regulatory Affairs on August 25, 2026. The Reginfo Unified Agenda entry for RIN 1117-AB40 lists final action for November 2026.
What does federal law allow for telehealth testosterone prescribing right now?
The current federal pathway allows DEA-registered practitioners to prescribe Schedule II through V controlled substances through qualifying audio-video telemedicine encounters without first conducting an in-person medical evaluation, provided the other federal and state requirements are met. The Fourth Temporary Extension published in the Federal Register is effective from January 1 through December 31, 2026.
DEA's December 2025 announcement describes the general Schedule II through V pathway as audio-video telemedicine. Its audio-only language is limited to certain Schedule III through V narcotic controlled medications approved for maintenance or withdrawal management of opioid use disorder.
Testosterone is Schedule III and falls outside that audio-only opioid-use-disorder pathway. A clinic should build its remote testosterone workflow around the encounter requirements that apply to the medication and prescribing scenario.
The temporary rule also explains what changes once the same practitioner has conducted at least one in-person medical evaluation of that patient. The Ryan Haight Act's specific remote-prescribing restrictions no longer apply to that practitioner-patient relationship, although other DEA requirements and applicable federal and state law still do.
What changed in the rulemaking process in August 2026?
DEA's permanent telemedicine rule is in final-rule review at the White House Office of Information and Regulatory Affairs. OIRA's public docket lists the Special Registrations for Telemedicine and Limited State Telemedicine Registrations rule as received on August 25, 2026, with a status of Pending Review and a stage of Final Rule.
The Reginfo Unified Agenda entry for RIN 1117-AB40 lists final action for November 2026.
If that timetable holds, clinics could have a short implementation window before the temporary federal framework expires at the end of the year. The final requirements are not public yet, so proposed special-registration requirements should not be treated as current law.
Clinics can prepare now by identifying the parts of their TRT workflow that depend on the temporary authority. That creates a defined change list when DEA publishes the final rule.
Why does testosterone need its own controlled-substance workflow?
Testosterone is a Schedule III controlled substance under DEA's drug scheduling guidance. Telehealth TRT therefore sits inside the federal controlled-substance prescribing framework.
A single DEA registration generally does not authorize controlled-substance prescribing in every patient state. DEA says practitioners generally must hold a separate DEA registration in each state where a patient is located when the prescription is made, unless an applicable exception applies. The agency's telemedicine registration guidance describes those registration requirements and exceptions.
State professional licensure remains a separate requirement. Telehealth.HHS.gov says a provider generally must be licensed or otherwise legally permitted to practice in the state where the patient is located. Its licensure guidance explains that state rules can differ by profession and telehealth pathway. The agency's cross-state licensing guidance also tells providers to verify the patient's location before an appointment.
A useful TRT coverage map should include more than a state-license column.
Workflow layer | What the clinic should verify |
|---|---|
Patient location | Where the patient is physically located at the time of care |
State authority | Whether the clinician is licensed or otherwise legally permitted to treat that patient in that state |
DEA authority | Whether the clinician has the DEA registration and controlled-substance authority required for that patient state and scenario, or is relying on a valid exception |
Encounter modality | Whether the visit format satisfies the federal and state rules that apply to testosterone prescribing |
Clinical pathway | Whether diagnosis, labs, follow-up, and monitoring meet the clinic's clinical protocol and applicable standards |
Pharmacy path | Whether the dispensing pharmacy can lawfully fill and ship the prescribed testosterone product for that patient and state |
What makes the clinical workflow for testosterone different from a generic telehealth prescription?
A credible TRT workflow begins before the prescription. The American Urological Association guideline on testosterone deficiency says the diagnosis of low testosterone should be made only after two total testosterone measurements taken on separate occasions, both in the early morning. The same guideline says the clinical diagnosis also requires low total testosterone combined with symptoms or signs.
Ongoing monitoring is part of treatment as well. The Endocrine Society testosterone therapy guideline recommends evaluating treatment response and adverse effects and monitoring measures such as serum testosterone and hematocrit. It also addresses prostate monitoring and fertility considerations where they apply.
For a telehealth clinic, those requirements affect operations. The patient journey may need lab collection before treatment, a way to surface results to the clinician, follow-up timing, a documented refill review, and a process for handling results or symptoms that require additional evaluation.
FDA's current Testosterone Information page says the agency requested updates to testosterone prescribing information in June 2026, including removal of certain limitation-of-use language related to age-associated hypogonadism and revisions to prostate-cancer and benign-prostatic-hyperplasia safety information.
Clinics should keep patient education, intake language, consent language, and provider reference material current with the labeling and clinical guidance for the testosterone product they prescribe.
What should a TRT clinic audit before DEA publishes the final rule?
Start with the patients and providers who would be affected if the federal telemedicine pathway changes.
Identify active testosterone patients whose prescribing relationship began without a prior in-person medical evaluation by the current prescriber.
Map each TRT prescriber's state license, DEA registrations, controlled-substance authority, and any exception the clinic currently relies on by patient state.
Confirm that the workflow records the patient's physical location and the encounter modality used for controlled-substance visits.
Review the diagnostic and monitoring path, including how required labs are ordered, received, reviewed, and tied to treatment or refill decisions.
Audit refill controls, prescription-history checks, pharmacy eligibility, early-refill handling, lost-or-stolen medication requests, and documentation.
Assign an owner for the DEA final rule so the clinic can update provider credentials, visit requirements, recordkeeping, patient messaging, and routing when the final text is published.
This audit separates workflows that already have an in-person relationship from workflows that depend on the temporary remote-prescribing authority. The two groups may require different implementation work when the permanent rule arrives.
How Healthaide supports a controlled-substance and TRT workflow
Healthaide separates the software and administrative layer from clinical care. Healthaide LLC provides the platform, while clinical services in Healthaide-supported programs are delivered through Healthaide Medical Group P.C. or through a clinic's own provider network, depending on the configured care model.
The public Provider & Licensure page explains that clinicians who prescribe controlled substances maintain DEA registration as required by law. It also describes state and location checks, laboratory currency requirements when clinically indicated, refill timing controls, synchronous follow-up when required, prescription-history checks where required or permitted, and documentation of prescribing and refill decisions.
For clinics using an Own Provider Network, Healthaide's provider onboarding SOP includes NPI, state licenses and registrations, DEA information when applicable, prescription signature, calendar sync, and availability for synchronous visits.
State Coverage > Exam Routing by State lets the clinic configure each state as Your Clinic, Healthaide, or Disabled. The Exam Routing by State FAQ explains how provider licensure and treatment Exam Assignment also affect who handles care.
Healthaide's refill workflow is patient initiated. Patients request a refill through the portal, complete required clinical questions when applicable, and the request goes through provider review before a new prescription becomes active.
Medication fulfillment is handled through licensed U.S. pharmacy partners. Healthaide's pharmacy source FAQ says the specific pharmacy depends on the medication, patient location, clinical fit, availability, and network routing.
For a TRT program, the clinic still needs to verify provider authority, visit type, clinical monitoring, refill review, product availability, and pharmacy eligibility for the specific patient and state.
Frequently asked questions
Can testosterone be prescribed by telehealth without an in-person visit in 2026?
Yes. Under the current federal temporary rule, a DEA-registered practitioner may prescribe Schedule II through V controlled substances through a qualifying audio-video telemedicine encounter without first conducting an in-person medical evaluation when the applicable conditions are met. The current temporary authority runs through December 31, 2026.
Is an audio-only visit enough for telehealth testosterone prescribing?
Clinics should not treat audio-only as the general federal pathway for testosterone. DEA describes the current Schedule II through V telemedicine flexibility as audio-video. The audio-only authority in DEA's current announcement is limited to certain Schedule III through V narcotic medications used for opioid use disorder.
Does one DEA registration cover testosterone prescribing in every state?
A single DEA registration generally does not authorize controlled-substance prescribing in every patient state. DEA says practitioners generally need a separate registration in each state where a patient is located when the prescription is made, unless an applicable exception applies. State licensure and state controlled-substance authority must also be verified.
What lab workflow should a telehealth TRT clinic have?
The AUA guideline says low testosterone should be diagnosed only after two total testosterone measurements on separate occasions, both in the early morning, together with symptoms or signs. A TRT workflow should also support ongoing clinical monitoring, including treatment response and appropriate laboratory follow-up.
What happens to telehealth testosterone prescribing after December 31, 2026?
The current temporary federal rule expires after December 31, 2026. DEA's permanent Special Registrations for Telemedicine rule is under OIRA review, and the Reginfo Unified Agenda entry lists final action for November 2026. The final requirements will depend on the rule DEA ultimately publishes.
Build the TRT change plan before the final rule arrives
TRT clinics can map their exposure to the current temporary rule now. Identify the patients, prescribers, states, encounter types, lab workflows, refill controls, and pharmacy paths that depend on remote controlled-substance prescribing.
When DEA publishes the permanent framework, that map becomes the implementation plan.
Book a Healthaide demo to review your provider, state-routing, and controlled-substance workflow.
Sources
Related insights
Can Testosterone Be Prescribed by Telehealth Without an In-Person Visit in 2026?
Telehealth Strategy
•
Can Testosterone Be Prescribed by Telehealth Without an In-Person Visit in 2026?
By Kris Zizzo, CEO | Last updated September 24, 2026
Testosterone can be prescribed by telehealth without a prior in-person medical evaluation in 2026 when a DEA-registered practitioner uses a qualifying audio-video encounter and the federal temporary-rule conditions are met. The current temporary rule runs through December 31, 2026, while DEA's permanent telemedicine framework is under White House review.
DEA sent the final Special Registrations for Telemedicine rule to the Office of Information and Regulatory Affairs on August 25, 2026. The Reginfo Unified Agenda entry for RIN 1117-AB40 lists final action for November 2026.
What does federal law allow for telehealth testosterone prescribing right now?
The current federal pathway allows DEA-registered practitioners to prescribe Schedule II through V controlled substances through qualifying audio-video telemedicine encounters without first conducting an in-person medical evaluation, provided the other federal and state requirements are met. The Fourth Temporary Extension published in the Federal Register is effective from January 1 through December 31, 2026.
DEA's December 2025 announcement describes the general Schedule II through V pathway as audio-video telemedicine. Its audio-only language is limited to certain Schedule III through V narcotic controlled medications approved for maintenance or withdrawal management of opioid use disorder.
Testosterone is Schedule III and falls outside that audio-only opioid-use-disorder pathway. A clinic should build its remote testosterone workflow around the encounter requirements that apply to the medication and prescribing scenario.
The temporary rule also explains what changes once the same practitioner has conducted at least one in-person medical evaluation of that patient. The Ryan Haight Act's specific remote-prescribing restrictions no longer apply to that practitioner-patient relationship, although other DEA requirements and applicable federal and state law still do.
What changed in the rulemaking process in August 2026?
DEA's permanent telemedicine rule is in final-rule review at the White House Office of Information and Regulatory Affairs. OIRA's public docket lists the Special Registrations for Telemedicine and Limited State Telemedicine Registrations rule as received on August 25, 2026, with a status of Pending Review and a stage of Final Rule.
The Reginfo Unified Agenda entry for RIN 1117-AB40 lists final action for November 2026.
If that timetable holds, clinics could have a short implementation window before the temporary federal framework expires at the end of the year. The final requirements are not public yet, so proposed special-registration requirements should not be treated as current law.
Clinics can prepare now by identifying the parts of their TRT workflow that depend on the temporary authority. That creates a defined change list when DEA publishes the final rule.
Why does testosterone need its own controlled-substance workflow?
Testosterone is a Schedule III controlled substance under DEA's drug scheduling guidance. Telehealth TRT therefore sits inside the federal controlled-substance prescribing framework.
A single DEA registration generally does not authorize controlled-substance prescribing in every patient state. DEA says practitioners generally must hold a separate DEA registration in each state where a patient is located when the prescription is made, unless an applicable exception applies. The agency's telemedicine registration guidance describes those registration requirements and exceptions.
State professional licensure remains a separate requirement. Telehealth.HHS.gov says a provider generally must be licensed or otherwise legally permitted to practice in the state where the patient is located. Its licensure guidance explains that state rules can differ by profession and telehealth pathway. The agency's cross-state licensing guidance also tells providers to verify the patient's location before an appointment.
A useful TRT coverage map should include more than a state-license column.
Workflow layer | What the clinic should verify |
|---|---|
Patient location | Where the patient is physically located at the time of care |
State authority | Whether the clinician is licensed or otherwise legally permitted to treat that patient in that state |
DEA authority | Whether the clinician has the DEA registration and controlled-substance authority required for that patient state and scenario, or is relying on a valid exception |
Encounter modality | Whether the visit format satisfies the federal and state rules that apply to testosterone prescribing |
Clinical pathway | Whether diagnosis, labs, follow-up, and monitoring meet the clinic's clinical protocol and applicable standards |
Pharmacy path | Whether the dispensing pharmacy can lawfully fill and ship the prescribed testosterone product for that patient and state |
What makes the clinical workflow for testosterone different from a generic telehealth prescription?
A credible TRT workflow begins before the prescription. The American Urological Association guideline on testosterone deficiency says the diagnosis of low testosterone should be made only after two total testosterone measurements taken on separate occasions, both in the early morning. The same guideline says the clinical diagnosis also requires low total testosterone combined with symptoms or signs.
Ongoing monitoring is part of treatment as well. The Endocrine Society testosterone therapy guideline recommends evaluating treatment response and adverse effects and monitoring measures such as serum testosterone and hematocrit. It also addresses prostate monitoring and fertility considerations where they apply.
For a telehealth clinic, those requirements affect operations. The patient journey may need lab collection before treatment, a way to surface results to the clinician, follow-up timing, a documented refill review, and a process for handling results or symptoms that require additional evaluation.
FDA's current Testosterone Information page says the agency requested updates to testosterone prescribing information in June 2026, including removal of certain limitation-of-use language related to age-associated hypogonadism and revisions to prostate-cancer and benign-prostatic-hyperplasia safety information.
Clinics should keep patient education, intake language, consent language, and provider reference material current with the labeling and clinical guidance for the testosterone product they prescribe.
What should a TRT clinic audit before DEA publishes the final rule?
Start with the patients and providers who would be affected if the federal telemedicine pathway changes.
Identify active testosterone patients whose prescribing relationship began without a prior in-person medical evaluation by the current prescriber.
Map each TRT prescriber's state license, DEA registrations, controlled-substance authority, and any exception the clinic currently relies on by patient state.
Confirm that the workflow records the patient's physical location and the encounter modality used for controlled-substance visits.
Review the diagnostic and monitoring path, including how required labs are ordered, received, reviewed, and tied to treatment or refill decisions.
Audit refill controls, prescription-history checks, pharmacy eligibility, early-refill handling, lost-or-stolen medication requests, and documentation.
Assign an owner for the DEA final rule so the clinic can update provider credentials, visit requirements, recordkeeping, patient messaging, and routing when the final text is published.
This audit separates workflows that already have an in-person relationship from workflows that depend on the temporary remote-prescribing authority. The two groups may require different implementation work when the permanent rule arrives.
How Healthaide supports a controlled-substance and TRT workflow
Healthaide separates the software and administrative layer from clinical care. Healthaide LLC provides the platform, while clinical services in Healthaide-supported programs are delivered through Healthaide Medical Group P.C. or through a clinic's own provider network, depending on the configured care model.
The public Provider & Licensure page explains that clinicians who prescribe controlled substances maintain DEA registration as required by law. It also describes state and location checks, laboratory currency requirements when clinically indicated, refill timing controls, synchronous follow-up when required, prescription-history checks where required or permitted, and documentation of prescribing and refill decisions.
For clinics using an Own Provider Network, Healthaide's provider onboarding SOP includes NPI, state licenses and registrations, DEA information when applicable, prescription signature, calendar sync, and availability for synchronous visits.
State Coverage > Exam Routing by State lets the clinic configure each state as Your Clinic, Healthaide, or Disabled. The Exam Routing by State FAQ explains how provider licensure and treatment Exam Assignment also affect who handles care.
Healthaide's refill workflow is patient initiated. Patients request a refill through the portal, complete required clinical questions when applicable, and the request goes through provider review before a new prescription becomes active.
Medication fulfillment is handled through licensed U.S. pharmacy partners. Healthaide's pharmacy source FAQ says the specific pharmacy depends on the medication, patient location, clinical fit, availability, and network routing.
For a TRT program, the clinic still needs to verify provider authority, visit type, clinical monitoring, refill review, product availability, and pharmacy eligibility for the specific patient and state.
Frequently asked questions
Can testosterone be prescribed by telehealth without an in-person visit in 2026?
Yes. Under the current federal temporary rule, a DEA-registered practitioner may prescribe Schedule II through V controlled substances through a qualifying audio-video telemedicine encounter without first conducting an in-person medical evaluation when the applicable conditions are met. The current temporary authority runs through December 31, 2026.
Is an audio-only visit enough for telehealth testosterone prescribing?
Clinics should not treat audio-only as the general federal pathway for testosterone. DEA describes the current Schedule II through V telemedicine flexibility as audio-video. The audio-only authority in DEA's current announcement is limited to certain Schedule III through V narcotic medications used for opioid use disorder.
Does one DEA registration cover testosterone prescribing in every state?
A single DEA registration generally does not authorize controlled-substance prescribing in every patient state. DEA says practitioners generally need a separate registration in each state where a patient is located when the prescription is made, unless an applicable exception applies. State licensure and state controlled-substance authority must also be verified.
What lab workflow should a telehealth TRT clinic have?
The AUA guideline says low testosterone should be diagnosed only after two total testosterone measurements on separate occasions, both in the early morning, together with symptoms or signs. A TRT workflow should also support ongoing clinical monitoring, including treatment response and appropriate laboratory follow-up.
What happens to telehealth testosterone prescribing after December 31, 2026?
The current temporary federal rule expires after December 31, 2026. DEA's permanent Special Registrations for Telemedicine rule is under OIRA review, and the Reginfo Unified Agenda entry lists final action for November 2026. The final requirements will depend on the rule DEA ultimately publishes.
Build the TRT change plan before the final rule arrives
TRT clinics can map their exposure to the current temporary rule now. Identify the patients, prescribers, states, encounter types, lab workflows, refill controls, and pharmacy paths that depend on remote controlled-substance prescribing.
When DEA publishes the permanent framework, that map becomes the implementation plan.
Book a Healthaide demo to review your provider, state-routing, and controlled-substance workflow.