Updated September 2026
Short answer: For telehealth testosterone prescribing, the federal rule is clear until December 31, 2026: under DEA and HHS's fourth temporary extension, DEA-registered practitioners may prescribe Schedule III testosterone by telemedicine without a prior in-person visit. DEA's permanent special-registration rule is still pending. State law applies on top: Connecticut bars Schedule III by telehealth, Minnesota and Arkansas require an in-person exam, Missouri changed its statute in August 2026, and Louisiana, Alabama, West Virginia and New Hampshire require periodic in-person visits.
DEA telemedicine 2026: the federal baseline for TRT
The Ryan Haight Act generally requires an in-person medical evaluation before a controlled substance is prescribed over the internet. DEA and HHS have extended the COVID-era exceptions several times. The fourth extension (90 FR 61301, published December 31, 2025) runs through December 31, 2026. Until then, DEA-registered practitioners may prescribe Schedule II to V drugs, including testosterone, by telemedicine without a prior in-person visit. Prescriptions still need a legitimate medical purpose and must comply with state law.
The permanent route is DEA's special registration for telemedicine. A Federal Register search on September 23, 2026 found no final rule published this year. The Alliance for Connected Care's tracker reported the rule in OMB review in late August 2026, with a final rule forecast for November. Without a new rule or a fifth extension, the in-person requirement returns on January 1, 2027.
Testosterone and its esters are Schedule III anabolic steroids under 21 CFR 1308.13, so DEA registration, records and state PDMP rules apply to every product, compounded or not. Licensure and DEA registration across states are covered in prescribing across state lines in 2026.
TRT telemedicine rules: states that add limits
Barred, or in-person first
- Connecticut: Conn. Gen. Stat. §19a-906(c) bars telehealth prescribing of any Schedule I, II or III drug, except non-opioid Schedule II or III drugs for psychiatric disability or substance use disorder. Testosterone needs an in-person visit.
- Minnesota: under Minn. Stat. §151.37, a Schedule II to IV prescription is valid only if based on an in-person exam by the prescriber, a colleague in the same group, or a consulting or referring practitioner.
- Arkansas: a physician using telemedicine may not prescribe Schedule II to V drugs without an in-person exam or a consult or referral relationship (Medical Board rule, as summarized by the Center for Connected Health Policy).
- Missouri: HB 2372, effective August 28, 2026, changed RSMo 334.108.3 to bar prescribing "based solely on an evaluation through telemedicine" without a previously established, ongoing relationship. Read literally, that reaches first-visit telehealth testosterone. The same bill loosened another section, and no board guidance reconciling the two was found.
- Rhode Island: the medical board's telemedicine guidelines say prescribing controlled substances without an established in-person relationship is prohibited. The guideline is older and undated, so confirm how the board applies it.
Periodic in-person visits
- Louisiana: at least one in-person visit within the past year before prescribing any controlled substance by telemedicine (LAC 46:XLV.7513), with an exception for patients of licensed, DEA-registered facilities.
- Alabama: a controlled substance by telehealth needs an in-person encounter within the preceding 12 months.
- West Virginia: established telehealth patients must see an in-person practitioner within 12 months of the first telemedicine service.
- New Hampshire: RSA 318-B:2, XVI requires in-person exams at least annually for Schedule II to IV drugs prescribed by telemedicine. A 2025 amendment to the physician statute says "evaluation" instead, so the wording differs.
How the visit happens
South Dakota requires a real-time audio-video exam where in-person care would otherwise be needed, and bars controlled-substance prescribing from a questionnaire or phone-only encounter without a proper relationship. Indiana reportedly requires real-time audio-video for patients the prescriber hasn't examined.
State controlled substance registration
In our research, 23 jurisdictions require a state controlled substance registration in addition to DEA: Alabama, Connecticut, Delaware, DC, Hawaii, Idaho, Illinois, Indiana, Iowa, Louisiana, Maryland, Massachusetts, Michigan, Missouri, Nevada, New Jersey, New Mexico, Oklahoma, Rhode Island, South Carolina, South Dakota, Utah and Wyoming. Iowa's covers out-of-state practitioners prescribing to Iowa patients by telehealth, and Oklahoma's covers prescribing "within or into" the state. In Alabama, Delaware, Hawaii, Illinois, Louisiana, Missouri and Nevada, the state registration comes before the DEA registration for that state. Ohio, Virginia and West Virginia require one only in some settings. See the state registration map.
PDMP checks that cover testosterone
Most state PDMP mandates target opioids and benzodiazepines. Thirteen states' mandates reach testosterone: Alaska, California, Connecticut, Florida, Kentucky, Michigan, Nevada, New York, North Dakota, Ohio, Pennsylvania, Wisconsin and Wyoming. Timing varies. Florida and New York check before every prescription, California the first time and then every six months, Ohio once treatment passes 90 days, and Michigan above a 3-day supply. Mississippi's rules expressly exempt testosterone, and South Dakota has no query mandate. Details are in the PDMP map.
Telehealth testosterone prescribing by state: all 51 jurisdictions
"None" means no state-specific in-person or modality limit on Schedule III was found; state licensure and the standard of care still apply. † marks a row based on a secondary source, usually the Center for Connected Health Policy. The telehealth prescribing map has citations and dates.
| State | State telehealth limit on testosterone | State CS registration | PDMP check covers testosterone |
|---|---|---|---|
| Alabama | In-person visit in the prior 12 months † | Yes | No |
| Alaska | None; telemedicine businesses register † | No | Yes |
| Arizona | None for C-III (exam rule for C-II only) | No | No |
| Arkansas | In-person exam or consult/referral relationship † | No | No |
| California | None; the exam may be by telehealth | No | Yes |
| Colorado | None; in-person standards apply † | No | No |
| Connecticut | Barred (Schedules I–III) | Yes | Yes |
| Delaware | None; telehealth registration route † | Yes | No |
| District of Columbia | None † | Yes | No |
| Florida | None for C-III (C-II only) | No | Yes |
| Georgia | Limits on electronic controlled-substance prescribing † | No | No |
| Hawaii | None for C-III (opioids and cannabis only) † | Yes | Not confirmed |
| Idaho | None | Yes | No |
| Illinois | None found | Yes | No |
| Indiana | Real-time audio-video for unexamined patients † | Yes | No |
| Iowa | None; no static questionnaires † | Yes, incl. out-of-state telehealth | No |
| Kansas | Same rules as in-person care † | No | No † |
| Kentucky | None; no questionnaire-only visits † | No | Yes |
| Louisiana | In-person visit within the past year | Yes | No |
| Maine | None † | No | No |
| Maryland | None for C-III (C-II opioids only) † | Yes | No |
| Massachusetts | None † | Yes | No |
| Michigan | None | Yes | Yes |
| Minnesota | In-person exam required (C-II to C-IV) | No | No |
| Mississippi | In-person unless telemedicine is authorized by law † | No | No (testosterone exempt) |
| Missouri | Telemedicine-only prescribing barred without an ongoing relationship (Aug. 2026) | Yes | No |
| Montana | None | No | No |
| Nebraska | None | No | No |
| Nevada | No general in-person rule | Yes | Yes |
| New Hampshire | In-person exam at least annually (C-II to C-IV) | No | No |
| New Jersey | None for C-III (C-II only) | Yes | No |
| New Mexico | None found | Yes | MDs and PAs exempt; others not |
| New York | Allowed if state and DEA rules are met | No | Yes |
| North Carolina | None | No | No |
| North Dakota | None | Not confirmed | Yes |
| Ohio | None for C-III (C-II new patients only) | Only for office stock | Yes |
| Oklahoma | None for C-III (opioids, benzodiazepines only) | Yes | No |
| Oregon | None found | No | No |
| Pennsylvania | None | No | Yes |
| Rhode Island | Board guideline: in-person relationship for controlled drugs | Yes | No |
| South Carolina | None for non-narcotic C-III | Yes | No |
| South Dakota | Real-time audio-video exam; no questionnaire or phone-only prescribing | Yes | No |
| Tennessee | None found | Not confirmed | No |
| Texas | None for C-III | No | No |
| Utah | None found | Yes | No |
| Vermont | None found | No | No |
| Virginia | Virginia practice location or in-person referral path (C-II to C-V) | Only to dispense or keep stock | No |
| Washington | None found | No | No |
| West Virginia | In-person visit within 12 months (established patients) | Only to administer or dispense | No |
| Wisconsin | None found | No | Yes |
| Wyoming | None found | Yes | Yes |
Planning for January 1, 2027
- List patients whose testosterone was started by telemedicine without an in-person visit.
- In the states above that already require in-person care, schedule those visits now.
- Watch the Federal Register for DEA's special-registration rule or a fifth extension.
- Keep DEA and state registrations current in every state where your patients are.
For federal status, state rules and live FDA lookups on testosterone, see testosterone rules on MedGrid.
Frequently asked questions
Can testosterone be prescribed by telehealth in 2026?
Federally, yes, through December 31, 2026, under DEA and HHS's fourth temporary extension, which allows Schedule II to V prescribing by telemedicine without a prior in-person visit. State law can be stricter: Connecticut bars it, and Minnesota and Arkansas require an in-person exam.
What happens to TRT telemedicine after December 31, 2026?
Unless DEA publishes its special-registration rule or another extension, the Ryan Haight Act's in-person requirement returns on January 1, 2027. The special-registration rule was reported in OMB review in late August 2026, but no final rule had been published as of September 23, 2026.
Which states restrict telehealth testosterone prescribing?
Connecticut bars Schedule III by telehealth. Minnesota and Arkansas require an in-person exam, and Missouri changed its statute in August 2026. Louisiana, Alabama, West Virginia and New Hampshire require periodic in-person visits, and Rhode Island has an older board guideline on in-person relationships.
Do I need a state controlled substance registration to prescribe testosterone?
In 23 jurisdictions in our research, yes, in addition to DEA. Iowa's registration covers out-of-state practitioners prescribing to Iowa patients by telehealth. Ohio, Virginia and West Virginia require one only in some settings, such as keeping stock or dispensing.
Do I have to check the PDMP before prescribing testosterone?
In 13 states the mandate reaches testosterone, including California, Florida, New York, Ohio and Pennsylvania. Most other states limit mandatory checks to opioids and benzodiazepines, and Mississippi's rules expressly exempt testosterone.
This article is general information, not legal advice. Federal telemedicine rules may change before January 1, 2027; confirm with DEA, your state boards or a healthcare attorney before relying on it.
Check your patients' states before the flexibilities end. Open the sourced testosterone rules on MedGrid, or verify your NPI and see wholesale pricing. Sign-up is free.
Sources
- Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications, 90 FR 61301, DEA/HHS, Federal Register (2025-12-31)
- DEA Prescribing of Controlled Substances (tracker), Alliance for Connected Care (2026-08-26)
- 21 CFR 1308.13 – Schedule III, eCFR (2026-09-01)
- Chapter 368ll – Telehealth (Sec. 19a-906), revised to January 1, 2026, Connecticut General Assembly (2026-01-01)
- Minnesota Statutes 151.37, Minnesota Office of the Revisor of Statutes (2026-09-23)
- Arkansas – Professional Requirements, Center for Connected Health Policy (2026-05-26)
- RSMo 334.108 – Telemedicine or internet prescriptions (effective 8/28/2026), Missouri Revisor of Statutes (2026-08-28)
- La. Admin. Code tit. 46, XLV-7513 – Prohibitions (telemedicine), Legal Information Institute (2017-02-01)
- Alabama – Professional Requirements, Center for Connected Health Policy (2026-06-29)
- W. Va. Code 30-1-26 – Telehealth practice, West Virginia Legislature (2026-09-23)
- RSA 318-B:2 – Acts Prohibited, New Hampshire General Court (2022-06-24)
- Guidelines for the Appropriate Use of Telemedicine and the Internet in Medical Practice, Rhode Island Board of Medical Licensure and Discipline (2026-09-23)
