TRT telehealth and the Dec 31, 2026 DEA deadline: what it means

The short answer

TRT telehealth depends on a temporary federal rule. Testosterone is a Schedule III controlled substance. Through December 31, 2026, a DEA-registered provider may prescribe it after a video visit without an in-person exam, if federal and state rules are met. A permanent DEA rule was under review as of October 31, 2026. If nothing new is published, federal law again expects one in-person evaluation with the prescriber.

Key takeaways

• The federal telemedicine flexibilities for controlled medicines, including testosterone, run through December 31, 2026.
• As of October 31, 2026, DEA's final telemedicine prescribing rule was under review at the Office of Information and Regulatory Affairs, not yet published.
• Under the Ryan Haight Act, one in-person evaluation with your prescriber permits later remote prescribing; state rules can add requirements.
• Some states set their own in-person or exam rules for testosterone in addition to federal law.
• An in-person evaluation with the provider who prescribes meets the federal requirement; that provider still decides on treatment.

What is the DEA telehealth deadline?

The DEA telehealth deadline is the end of the fourth temporary extension of the COVID-era telemedicine flexibilities, which run through December 31, 2026^[1]. DEA and HHS published that extension in the Federal Register on December 31, 2025 (90 FR 61301, FR Doc. 2025-24123). It says: "This rule is effective January 1, 2026 through December 31, 2026"^[1].

Until then, a DEA-registered practitioner may prescribe Schedule II-V controlled medicines by video to a patient they have never evaluated in person, as long as the other conditions in the rule are met^[1]. The prescription must still be for a legitimate medical purpose, and state law still applies^[1].

What is the Ryan Haight Act?

The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 is the federal law behind the deadline. It generally requires at least one in-person medical evaluation before a controlled substance is prescribed over the internet, and it defines that as an evaluation "conducted with the patient in the physical presence of the practitioner"^[11].

In DEA's words, a practitioner may prescribe controlled substances remotely "only after conducting at least one in-person medical evaluation of that patient in the course of their practitioner-patient relationship," with some exceptions^[1].

After that first in-person evaluation, the Act's remote-prescribing requirements no longer apply to that practitioner and patient. The Federal Register notice says the practitioner may "remotely prescribe controlled substances to that patient indefinitely, regardless of how much time has passed since the initial in-person medical evaluation," as long as federal and state rules are followed^[1].

The temporary flexibilities are an exception to the in-person requirement. If they end without a replacement, DEA describes the result as "the reinstatement of the pre-pandemic restrictions imposed by the CSA"^[1].

Why does the DEA deadline matter for TRT telehealth?

Testosterone is a controlled substance. The federal Schedule III list in 21 CFR 1308.13 names testosterone^[5], so the telemedicine rules for controlled medicines cover testosterone therapy too.

Whether the deadline affects you depends on how your care started:

• If you started TRT after an in-person visit with the provider who prescribes it, that earlier evaluation is what the Ryan Haight Act looks for^[1]. That evaluation counts for that prescriber and you. If a different provider takes over your prescriptions, they may need their own in-person visit. State rules can still add requirements.
• If you started TRT by video and your prescriber has never seen you in person, your prescriptions rely on the temporary flexibilities^[1]. What happens after December 31, 2026 depends on whether DEA publishes a new rule or another extension.

Before you start or continue treatment, read the testosterone important safety information.

Can testosterone be prescribed via telehealth after December 31, 2026?

As of October 31, 2026, the federal rule for after that date had not been published. Three documents show where it stands.

1. On January 17, 2025, DEA published a proposed rule on special registrations for telemedicine (90 FR 6541)^[2]. It "would establish a Special Registration framework and authorize three types of Special Registration"^[2]. One of them, the Telemedicine Prescribing Registration, "would authorize the prescribing of Schedules III through V controlled substances by clinician practitioners"^[2]. The proposal also adds "heightened prescription, recordkeeping, and reporting requirements"^[2].
2. The final version of that rule is under review at the Office of Information and Regulatory Affairs. Its review page, checked on October 31, 2026, lists it as pending regulatory review at the final rule stage, received on August 25, 2026^[3].
3. The 2026 Unified Agenda lists the final action for November 2026^[4]. An agenda date is a planning target, and the rule has no publication date yet.

As of October 31, 2026, no final rule and no fifth extension had been published in the Federal Register. The final rule may differ from the proposal.

How an in-person visit at a local office fits in

The federal law looks for one in-person medical evaluation with the practitioner who prescribes^[1][11]. A visit on its own does not mean you will be prescribed testosterone, and it does not mean treatment will continue without interruption. A licensed provider reviews your history, an exam and the testosterone blood test panel, and decides whether treatment is appropriate. Some states set their own timing for in-person care.

Vitality has local offices, so you can find a Vitality office near you and have that visit with your prescribing provider, then continue follow-up by video where your state allows it. You can read how care at Vitality works, from first visit to follow-up.

State rules still apply

States can require more than federal law. A state's rule generally applies based on where you are during the visit; Louisiana's rule, for example, refers to "the state in which the patient is located"^[6]. We checked these examples against the state texts on November 1, 2026. They are general information, not legal advice:

• Louisiana: a physician may not use telemedicine to prescribe a controlled substance unless "the physician has had at least one in-person visit with the patient within the past year," with limited exceptions, such as patients treated at certain licensed facilities^[6].
• Minnesota: prescriptions for drugs in the state's controlled schedules need a documented examination, and the rule is met when "an in-person examination has been completed" under the listed circumstances^[7]. Testosterone is in Minnesota's schedules^[8].
• New Jersey: a practitioner may not prescribe testosterone unless "a full physical examination has been performed," among other conditions^[9]. The rule does not address video visits.
• Pennsylvania: "an initial physical examination shall be conducted prior to prescribing controlled substances," except in emergencies, and a recent exam recorded by another licensed provider may be considered within a time limit the rule sets^[10].

Other states have their own rules. Your provider can confirm the requirements for the state you are in before your visit, and our locations page shows where Vitality offers care. Testosterone therapy at Vitality is offered only where our providers are licensed.

Testosterone is a Schedule III controlled substance. Depending on your state, and on federal telemedicine rules that are currently set to change after December 31, 2026, an in-person exam may be required before or during treatment.

What this means for you

Unless DEA publishes a new rule or another extension, the federal rules for testosterone prescribed by video without an in-person visit change after December 31, 2026.

• If you take testosterone and your prescriber has never seen you in person, ask them how your care will work after December 31, 2026.
• If an in-person visit makes sense for you, a visit at a local office with the provider who prescribes meets the federal in-person evaluation requirement. Your state may add its own rules.
• Don't stop or change your dose on your own because of the deadline. Talk to your provider first.
• Keep up with your follow-up labs and visits.
• If you have new or worrying symptoms while on treatment, contact your provider. For a medical emergency, call 911.

We checked the Federal Register and reginfo.gov on October 31, 2026. This page will be updated promptly after DEA publishes a final rule or another extension.

Questions

Sources

1. Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications (90 FR 61301, FR Doc. 2025-24123). DEA and HHS, Federal Register. Accessed 2026-10-31. www.federalregister.gov/documents/2025/12/31/2025-24123/fourth-temporary-extension-of-covid-19-telemedicine-flexibilities-for-prescription-of-controlled
2. Special Registrations for Telemedicine and Limited State Telemedicine Registrations, proposed rule (90 FR 6541, FR Doc. 2025-01099). DEA, Federal Register. Accessed 2026-10-31. www.federalregister.gov/documents/2025/01/17/2025-01099/special-registrations-for-telemedicine-and-limited-state-telemedicine-registrations
3. OIRA review: Special Registrations for Telemedicine and Limited State Telemedicine Registrations (RIN 1117-AB40), Final Rule stage. Office of Information and Regulatory Affairs, reginfo.gov. Accessed 2026-10-31. www.reginfo.gov/public/do/eoDetails?rrid=1510512
4. Unified Agenda 2026: Special Registrations for Telemedicine and Limited State Telemedicine Registrations (RIN 1117-AB40). Office of Information and Regulatory Affairs, reginfo.gov. Accessed 2026-11-01. www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=1117-AB40
5. 21 CFR 1308.13 Schedule III. Code of Federal Regulations (Cornell LII copy). Accessed 2026-10-31. www.law.cornell.edu/cfr/text/21/1308.13
6. La. Admin. Code tit. 46, Part XLV, §7513 (telemedicine; controlled substances). Louisiana State Board of Medical Examiners (Cornell LII copy). Accessed 2026-11-01. www.law.cornell.edu/regulations/louisiana/La-Admin-Code-tit-46-SS-XLV-7513
7. Minn. Stat. §151.37 (prescription drug orders; examination). Minnesota Office of the Revisor of Statutes. Accessed 2026-11-01. www.revisor.mn.gov/statutes/cite/151.37
8. Minn. Stat. §152.02 (schedules of controlled substances). Minnesota Office of the Revisor of Statutes. Accessed 2026-11-01. www.revisor.mn.gov/statutes/cite/152.02
9. N.J.A.C. 13:35-7.9 (prescribing testosterone). New Jersey State Board of Medical Examiners (Cornell LII copy). Accessed 2026-11-01. www.law.cornell.edu/regulations/new-jersey/N-J-A-C-13-35-7-9
10. 49 Pa. Code §16.92 (prescribing controlled substances). Pennsylvania Code. Accessed 2026-11-01. www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/049/chapter16/s16.92.html
11. 21 U.S.C. 829(e) (controlled substances dispensed by means of the Internet). United States Code (Cornell LII copy). Accessed 2026-11-01. www.law.cornell.edu/uscode/text/21/829