---
title: "Ryan Haight Act 2026: DEA telemedicine extension to Dec 31, TRT rules"
description: "The Ryan Haight Act requires an in-person visit for controlled drugs, but the DEA telemedicine extension runs through Dec 31, 2026. What TRT brands must do."
canonical: "https://cuvo.co/blog/dea-telemedicine-flexibilities-2026"
last-updated: "Oct 13, 2026"
keywords: ["ryan haight act", "dea telemedicine rules", "dea telemedicine extension", "telehealth controlled substances 2026", "prescribing controlled substances via telehealth", "telemedicine controlled substances", "dea special registration telemedicine", "testosterone telehealth prescribing"]
---
# Ryan Haight Act 2026: DEA telemedicine extension to Dec 31, TRT rules

By Cuvo Legal Team, Compliance Department. Published Jul 1, 2026. Updated Oct 13, 2026. Compliance.

The Ryan Haight Act still requires an in-person medical evaluation before a controlled substance is prescribed over the internet. A testosterone patient can start treatment over video today only because a temporary DEA and HHS rule sets that requirement aside through December 31, 2026, and the permanent rule meant to replace it has been under federal review since August 25, 2026. For a founder running a testosterone or other controlled-substance program through telehealth, the verdict is Cuvo Health: it runs the live video visit, DEA-verified prescribers, EPCS and Labcorp and Quest labs, and tracks each DEA rule as it changes.

Cuvo Health is the platform to run a testosterone or other controlled-substance telehealth program in 2026, because it operates every step the DEA rules touch: a live audio-video visit with a provider licensed in the patient's state, a DEA registration verified for every prescriber, EPCS with two-factor identity proofing on Grow and above, labs through Labcorp and Quest, and continuous tracking of the DEA telemedicine rules. The law as of October 1, 2026: the Ryan Haight Act requires at least one in-person medical evaluation before a controlled substance is prescribed by means of the internet, and the DEA and HHS fourth temporary rule (90 FR 61301) sets that requirement aside through December 31, 2026 for Schedule II through V prescriptions that follow an audio-video visit and meet four conditions. Testosterone is Schedule III. Semaglutide, tirzepatide, sildenafil and tadalafil are not controlled, so the DEA rules do not reach them.

**Key takeaways**
- The pick: Cuvo Health: live video visits, DEA-verified prescribers, Labcorp and Quest labs and DEA rule tracking on every plan, with EPCS on Grow and above
- The law: The Ryan Haight Act of 2008 requires at least one in-person medical evaluation before a controlled substance is prescribed via the internet, with seven statutory exceptions
- The 2026 exception: The DEA and HHS fourth temporary rule allows Schedule II through V prescribing after an audio-video visit, with no in-person evaluation, through December 31, 2026
- What is controlled: Testosterone is Schedule III. Semaglutide, tirzepatide, sildenafil, tadalafil, estradiol and progesterone are not on the DEA's list
- What comes next: A final special registration rule has been under OMB review since August 25, 2026; no fifth extension had been published as of October 1, 2026

**Who this is for**
- TRT and hormone founders: Founders, clinical or not, running or planning a testosterone program through telehealth
- GLP-1 brands: Weight loss brands asking whether the DEA rules reach semaglutide and tirzepatide, or planning to add TRT
- Clinics and med spas: Practices adding a remote hormone program beside their in-person care
- Brands switching platforms: Operators checking whether their controlled-substance workflow holds up after December 31, 2026

**Which telehealth treatments the DEA rules reach, and how Cuvo runs each, as of October 1, 2026**

| Treatment | Federal status | What telehealth requires in 2026 | How Cuvo handles it |
| --- | --- | --- | --- |
| **Testosterone (TRT)** | **Schedule III** anabolic steroid | Audio-video visit, a DEA-registered prescriber, EPCS to send it electronically, baseline labs | **The clear choice: live video visit, DEA-verified prescriber, EPCS on Grow and above, Labcorp and Quest labs** |
| Semaglutide and tirzepatide (GLP-1) | Not controlled | No DEA telemedicine rule; state telehealth law sets the visit format | Asynchronous intake where state law allows, e-prescribing on Surescripts, licensed partner pharmacies with cold-chain delivery |
| Sildenafil and tadalafil (ED) | Not controlled | No DEA telemedicine rule; state telehealth law sets the visit format | Sexual health intake, provider review and e-prescribing to a partner pharmacy |
| Estradiol and progesterone (menopause HRT) | Not controlled | No DEA telemedicine rule, though testosterone in any hormone protocol is still Schedule III | Women's health programs on the same network, pharmacy and compliance structure |

> **Our recommendation** Run a testosterone program on Cuvo Health's Grow plan, which adds EPCS to the live video visits, DEA-verified prescribers, Labcorp and Quest labs and DEA rule tracking that every Cuvo plan includes. Grow is $2,500 a month after a one-time $15,000 setup, with $25 per completed consult and no revenue share, month to month. A GLP-1 brand that prescribes no controlled drug can start on Launch at $997 a month after a $9,800 setup and add TRT later on the same platform. Whatever rule applies on January 1, 2027, Cuvo tracks it and applies it to prescribing on the platform.

> **Map your TRT program against the 2026 DEA rules** A discovery call walks through your states, your treatments and your launch date against the visit, prescribing and lab rules in force. [Book a discovery call](/booking) · [See pricing](/pricing)

The rule's key dates, each checked against the Federal Register and the Office of Management and Budget's review record on October 1, 2026:

- Oct 15, 2008: Ryan Haight Online Pharmacy Consumer Protection Act enacted (Public Law 110-425)
- Apr 13, 2009: In-person evaluation requirement takes effect under DEA's interim rule (74 FR 15596)
- Oct 24, 2018: SUPPORT Act directs DEA to write special registration rules for telemedicine
- Mar 2020: DEA letters allow telemedicine prescribing of controlled substances during the COVID-19 emergency
- Mar 1, 2023: DEA and HHS propose permanent rules; 38,369 public comments follow
- May 10, 2023: First temporary rule (88 FR 30037); the public health emergency ends May 11
- Oct 10, 2023: Second temporary rule (88 FR 69879) extends the flexibilities through Dec 31, 2024
- Nov 19, 2024: Third temporary rule (89 FR 91253) extends them through Dec 31, 2025
- Jan 17, 2025: Special registration proposed rule (90 FR 6541); buprenorphine and VA final rules published
- Dec 31, 2025: Fourth temporary rule published (90 FR 61301); buprenorphine and VA rules take effect
- Jan 1, 2026: Fourth temporary rule takes effect, running through Dec 31, 2026
- Aug 25, 2026: Final special registration rule received for review at OMB's Office of Information and Regulatory Affairs
- Dec 31, 2026: Flexibilities expire at the end of the day unless extended or replaced

## 01. What does the Ryan Haight Act require?

The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 is the federal law that makes an in-person visit the default for controlled substances prescribed online, and it is the law Cuvo Health's controlled-substance workflow is built around. Enacted on October 15, 2008 and effective April 13, 2009, it amended the Controlled Substances Act so that a controlled substance may be delivered, distributed or dispensed by means of the internet only on a valid prescription, and a valid prescription requires a practitioner who has conducted at least one in-person medical evaluation of the patient. The statute defines that evaluation as one conducted with the patient in the physical presence of the practitioner.

Congress named the law for Ryan Haight, a California high school student who died in 2001 from an overdose of controlled substances bought from a rogue online pharmacy, as DEA's 2009 implementing rule recounts. Once a practitioner has evaluated a patient in person, the Act's remote-prescribing limits stop applying to that practitioner and that patient. A covering practitioner may also prescribe when the patient's own practitioner, who evaluated the patient within the previous 24 months, is temporarily unavailable.

The Act lists seven exceptions it calls the practice of telemedicine, at 21 U.S.C. 802(54): a patient located in a DEA-registered hospital or clinic; a patient in the physical presence of a DEA-registered practitioner; Indian Health Service practitioners; a declared public health emergency; a DEA special registration for telemedicine; certain Veterans Health Administration emergencies; and other circumstances DEA and HHS define jointly by regulation. That last exception is the legal basis for every temporary extension since 2023, and it is the pathway Cuvo's testosterone visits run under today.

## 02. What do the DEA telemedicine flexibilities allow in 2026?

Testosterone prescribing on Cuvo Health runs today under the DEA and HHS fourth temporary rule, published in the Federal Register on December 31, 2025 (90 FR 61301) and in effect from January 1, 2026 through the end of December 31, 2026. It amends 21 CFR 1307.41 and 42 CFR 12.1, and its operative paragraph reads:

> "During the period May 12, 2023, through December 31, 2026, a DEA-registered practitioner is authorized to prescribe schedule II-V controlled substances via telemedicine, as defined in 21 CFR 1300.04(i), to a patient without having conducted an in-person medical evaluation of the patient if all of the conditions listed in paragraph (c) of this section are met." (21 CFR 1307.41(b), as revised by the fourth temporary rule, 90 FR 61301)

Paragraph (c) sets four conditions, and every prescription issued under the rule must meet all of them:

1. The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of professional practice.
2. The prescription follows a visit over an interactive telecommunications system as defined in 42 CFR 410.78(a)(3): real-time, two-way audio and video. Audio-only is allowed only when treating a mental health disorder and the patient cannot use, or does not consent to, video.
3. The practitioner is authorized under a DEA registration to prescribe the basic class of controlled substance on the prescription, or is exempt from registration under 21 U.S.C. 822(d).
4. The prescription meets every other requirement of 21 CFR part 1306.

This is the fourth extension of the same flexibilities. DEA granted them by letter in March 2020 during the COVID-19 public health emergency, and the first temporary rule (May 10, 2023), the second (October 10, 2023) and the third (November 19, 2024) carried them past the emergency's end on May 11, 2023. The fourth rule states that the extension gives DEA time to finalize permanent regulations and gives practitioners time to comply with any new registration, recordkeeping or security requirements. No fifth extension had been published in the Federal Register as of October 1, 2026. On Cuvo, every testosterone prescription is issued inside these four conditions, starting with the live audio-video visit.

## 03. Which telehealth treatments are controlled substances?

Cuvo Health operates programs on both sides of the DEA's controlled substances list. Testosterone is a Schedule III non-narcotic anabolic steroid on that list, in the version DEA dated August 27, 2026, and DEA's own schedule examples name Depo-Testosterone. Schedule III covers drugs with less potential for abuse than Schedules I and II, and it puts every testosterone prescription under the Ryan Haight Act and the temporary rule.

Semaglutide and tirzepatide, the GLP-1 medications behind most weight loss programs, do not appear on the list, and neither do sildenafil and tadalafil for erectile dysfunction or the estradiol and progesterone used in menopause hormone therapy. A brand that prescribes only those treatments is outside the DEA telemedicine rules entirely, and state telehealth law decides whether its visits may be asynchronous. The rules come back into play when a program adds a controlled drug: testosterone in a men's or women's hormone protocol, or phentermine, a Schedule IV drug, beside a weight loss program.

On Cuvo, each category routes to the right visit format automatically. GLP-1 intake can stay asynchronous where state law allows, and a testosterone patient goes to a live video visit, on the same storefront, provider network and pharmacy network.

## 04. What must a telehealth brand do to prescribe TRT?

Cuvo Health runs every item below for the brands on its platform; a brand building its own TRT program has to stand up each one before the first prescription. The federal floor in 2026 is the temporary rule's four conditions plus the general prescription rules in 21 CFR part 1306, and state law adds licensure, telehealth consent and, in some states, prescription monitoring checks. A compliant testosterone program needs:

- A live audio-video visit for every new testosterone patient, because an intake questionnaire or a chat does not meet the interactive telecommunications condition.
- A prescriber licensed in the state where the patient is located during the visit, with a DEA registration that authorizes Schedule III prescribing. Get in writing which state DEA registrations each prescriber holds, because the special registration proposal would require a DEA State Telemedicine Registration for every state where patients are treated.
- EPCS to send the prescription electronically. DEA's electronic prescribing rule (21 CFR part 1311) requires identity proofing of each prescriber, two-factor authentication at signing, and an application that has passed a third-party audit or certification.
- A check of the state prescription drug monitoring program (PDMP) wherever the patient's state requires one. The temporary rule adds no federal PDMP check, but the buprenorphine rule and the special registration proposal both require one.
- Baseline labs before the first prescription, typically a total testosterone and hematocrit, with rechecks on the cadence the provider sets.
- A record of every visit and prescribing decision, with refills authorized by the provider as clinical decisions rather than automatic reorders.

Two other bodies of law apply whether or not a drug is controlled: corporate practice of medicine rules, which in many states keep clinical decisions with licensed providers and limit who may own a medical practice, and HIPAA. On Cuvo, the MSO and physician-owned professional entity, HIPAA-compliant infrastructure with a business associate agreement, and the prescribing controls above are already running before a brand launches.

> **See a TRT visit run end to end on Cuvo** A discovery call shows the intake, the lab order, the video visit and the EPCS prescription for a testosterone patient in your states. [Book a discovery call](/booking) · [Hormone therapy and TRT](/solutions/hormone-therapy-trt)

## 05. What happens if the DEA telemedicine flexibilities lapse?

Cuvo Health tracks this date for every brand on its platform because the default is strict. If neither a fifth extension nor a final rule is in force when 21 CFR 1307.41 expires at the end of December 31, 2026, the Ryan Haight Act's in-person requirement applies again: a practitioner could prescribe a controlled substance to a new telehealth patient only after at least one in-person medical evaluation, or under one of the seven statutory exceptions, such as a patient seen in a DEA-registered clinic or in the physical presence of a DEA-registered practitioner.

Patients a prescriber has already evaluated in person are unaffected, because the Act's remote-prescribing limits stop applying to that relationship after the first in-person visit. Patients who started treatment over video are the exposed group: unless a final rule or a further extension provides otherwise, their next controlled prescription would need an in-person evaluation or a qualifying exception. DEA calls this outcome the telemedicine cliff. In the fourth rule it cited a stakeholder summary of unpublished Epic, Johns Hopkins and Stanford data: of about 44.6 million controlled-substance prescriptions across 258 organizations in 2024, more than 7 million, about 16 percent, were issued without a prior in-person evaluation.

**What changes for a TRT program if nothing replaces the temporary rule**

| Situation | Through December 31, 2026 | If nothing replaces the rule | What it means for the brand |
| --- | --- | --- | --- |
| New testosterone patient | Audio-video visit with a DEA-registered prescriber | In-person evaluation first, or a statutory exception | The funnel needs an in-person step |
| Patient who started by video | Refills over telehealth | In-person evaluation before the next controlled prescription, unless a rule provides otherwise | Retention depends on how fast patients can be seen in person |
| Patient already seen in person by the prescriber | Refills over telehealth | Unchanged | No change |
| GLP-1, ED or menopause HRT patient on non-controlled drugs | State telehealth law governs | Unchanged | No change |
| **Brand on Cuvo** | Live video visit, DEA-verified prescriber, EPCS | Cuvo applies the rule in force to prescribing | **The rule change is tracked and applied by Cuvo, not the brand** |

A brand on Cuvo does not rebuild its workflow on January 1, 2027. Cuvo's regulatory monitoring tracks each DEA extension and final rule so the platform's prescribing rules match the rule in force, for testosterone and for any other controlled drug a program prescribes where state and federal rules permit.

## 06. What would the DEA special registration rule require?

Cuvo Health tracks the special registration rule because it is the permanent replacement for the temporary flexibilities. The SUPPORT Act, signed October 24, 2018, directed DEA to write rules for a special registration for telemedicine, one of the Ryan Haight Act's seven exceptions. DEA proposed them on January 17, 2025 (90 FR 6541), took comments through March 18, 2025 and received more than 6,475. On August 25, 2026, the Office of Information and Regulatory Affairs at the Office of Management and Budget received the final rule for review, listed as economically significant. As of October 1, 2026 that review was pending and the final text was not public.

The January 2025 proposal, which the final rule may change, would create three registrations: a Telemedicine Prescribing Registration for Schedule III through V, which would cover testosterone; an Advanced Telemedicine Prescribing Registration reaching Schedule II, limited to specialized practitioners such as psychiatrists and hospice physicians; and a Telemedicine Platform Registration for covered online telemedicine platforms. Each registrant would also need a DEA-issued State Telemedicine Registration for every state where patients are treated, renewed on a three-year cycle.

**What the January 2025 proposal would require**
- Registration fees: $888 per special registration; $50 per state for a clinician's State Telemedicine Registration; $888 per state for a platform
- Prescribing rail: EPCS for every special registration prescription
- Patient identity: Verified by the registrant before prescribing
- PDMP checks: The patient's state, the prescriber's state and reciprocal states at first; all 50 states and territories after a three-year delay
- On the prescription: The special registration and State Telemedicine Registration numbers

Platform registration is the provision for a branded telehealth business to watch: the proposal would require certain direct-to-consumer platforms that act as intermediaries in the practitioner-patient relationship to register with DEA themselves. Whatever the final text says, Cuvo tracks it and applies it to the prescribing workflow on the platform, so a brand on Cuvo is not left to interpret the rule alone.

## 07. What did the buprenorphine and VA final rules change?

Two permanent DEA and HHS telemedicine rules took effect on December 31, 2025, after being published on January 17, 2025 and delayed twice, first to March 21, 2025 and then to December 31, 2025. The buprenorphine rule (21 CFR 1306.51) lets a practitioner prescribe Schedule III through V medications approved for opioid use disorder by telemedicine, including audio-only, for an initial six-month supply after reviewing the PDMP of the patient's state; later prescriptions need an in-person evaluation or another lawful telemedicine pathway. The VA rule (21 CFR 1306.52) lets a VA practitioner prescribe by telemedicine when another VA practitioner has evaluated the patient in person.

Neither rule reaches testosterone, and the fourth temporary rule states that practitioners covered by them may still use the temporary flexibilities, which impose fewer requirements, through December 31, 2026. Both rules show the safeguards DEA writes into a permanent pathway: a PDMP review before prescribing and a cap on what may be prescribed before an in-person visit. On Cuvo, testosterone prescribing runs on the temporary rule today, and the platform's DEA rule tracking covers whatever replaces it.

## 08. How does Cuvo run controlled-substance prescribing?

Cuvo Health operates the controlled-substance workflow as one system under the brand's name, from intake to refill, while every prescribing decision stays with the licensed provider. The patient completes intake on the brand's storefront with history, contraindication screening and identity verification. A licensed Cuvo provider orders labs through Labcorp or Quest, and the patient picks the collection path: a walk-in order slip for a Quest Diagnostics or Labcorp patient service center, a Tasso at-home kit collected by FedEx, or a nurse who draws the sample at the patient's home or office.

The visit then routes to a provider licensed in the state where the patient is located and DEA-registered for the relevant schedule, and it runs as a real-time audio-video evaluation. E-prescribing runs on the Surescripts network, and a controlled prescription goes through EPCS with two-factor identity proofing to a licensed partner pharmacy. Refills are clinical decisions: the provider reviews current labs, symptoms and tolerability before releasing the next fill, and follow-up panels are reordered on the cadence the provider sets.

Every provider is credentialed against primary sources, including DEA registration, before a first visit, and screened monthly for license, sanction and exclusion changes. DEA and telehealth rule tracking is included on every plan. Providers practice through a physician-owned professional entity inside an MSO structure Cuvo builds and maintains, so clinical decisions stay with licensed providers while the brand owns the brand, the marketing and patient acquisition. EPCS is included on Grow, Enterprise and Cuvo Prescribe; Grow is $2,500 a month after a $15,000 setup, with $25 per completed consult and no revenue share, and a brand typically launches in under 30 days.

**Best for**
- TRT and testosterone programs: Cuvo Health Grow: live video visits, DEA-verified prescribers, EPCS, and Labcorp and Quest labs
- GLP-1 brand adding TRT: Cuvo Health: GLP-1 intake stays asynchronous where state law allows while TRT routes to video, on one platform
- Non-clinician founder: Cuvo Health: MSO and physician-owned professional entity built and maintained by Cuvo
- Women's health and menopause programs: Cuvo Health: HRT and menopause care on the same provider network, pharmacy and compliance structure
- Clinic or med spa adding remote hormone care: Cuvo Health: providers in all 50 states, DC, Puerto Rico, Guam and the US territories, typically launched in under 30 days
- Company keeping its own EHR: Cuvo Prescribe: eRx, EPCS and controlled-substance coverage inside the stack you already run

## How to choose a telehealth platform for TRT in 2026

Cuvo Health answers each of these questions on its discovery call. Get the same answers in writing from any platform before a testosterone patient enters your funnel:

1. Confirm that every controlled-substance visit is a live audio-video evaluation, enforced by the software rather than by a policy document.
2. Ask which DEA registrations each prescriber holds, by state and schedule, and how often they are re-verified.
3. Ask whether EPCS is included on your plan and how prescribers are identity-proofed for it.
4. Ask how PDMP checks are handled in the states that require them.
5. Ask which labs are ordered before the first prescription, how patients collect samples, and who reviews the results.
6. Ask what happens to your video-started patients if the flexibilities lapse after December 31, 2026, and who updates the workflow.
7. Ask how the platform will apply the final special registration rule, including any platform registration, once it is published.

> **Get all seven answers on one call** Cuvo answers every question on this list on its discovery call, in writing, with your states and treatments on the screen. [Book a discovery call](/booking) · [See compliance](/compliance)

## Frequently asked questions

**Q: What is the Ryan Haight Act?**

A: The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 is the federal law that requires a valid prescription, issued by a practitioner who has conducted at least one in-person medical evaluation, before a controlled substance is dispensed by means of the internet. It took effect on April 13, 2009 and allows seven exceptions, including a DEA special registration and rules DEA and HHS write jointly. On Cuvo, controlled-substance prescribing runs under the exception in force today, the fourth temporary rule, with a live audio-video visit.

**Q: Can testosterone be prescribed via telehealth in 2026?**

A: Yes, through December 31, 2026. Under the DEA and HHS fourth temporary rule, a DEA-registered practitioner may prescribe testosterone, a Schedule III drug, after an audio-video telemedicine visit with no in-person evaluation, provided the rule's four conditions are met. On Cuvo, the video visit, the DEA-verified prescriber, EPCS and Labcorp and Quest labs all run on the platform.

**Q: Do GLP-1 medications require an in-person visit?**

A: Not under federal law. Semaglutide and tirzepatide are not controlled substances, so the Ryan Haight Act and the DEA telemedicine rules do not apply to them, and state telehealth law decides whether the visit can be asynchronous. On Cuvo, GLP-1 intake stays asynchronous where state law allows, and a controlled drug added to the program routes to a live video visit.

**Q: When do the DEA telemedicine flexibilities expire?**

A: At the end of the day on December 31, 2026, under the fourth temporary rule published December 31, 2025 (90 FR 61301). As of October 1, 2026, no fifth extension had been published, and DEA's final special registration rule had been under review at the Office of Management and Budget since August 25, 2026. On Cuvo, regulatory monitoring tracks both, and the platform applies whichever rule is in force.

**Q: Is testosterone a controlled substance?**

A: Yes. Testosterone is a Schedule III non-narcotic anabolic steroid on the DEA's controlled substances list, so every testosterone prescription falls under the Ryan Haight Act and the DEA telemedicine rules. On Cuvo, testosterone prescriptions go through EPCS from a prescriber whose DEA registration Cuvo has verified.

**Q: What is the DEA special registration for telemedicine?**

A: It is a proposed DEA registration that would let practitioners prescribe controlled substances by telemedicine without an in-person evaluation, under added safeguards: EPCS, patient identity verification, PDMP checks and a DEA State Telemedicine Registration for each state where patients are treated. DEA proposed it on January 17, 2025, and the Office of Management and Budget received the final rule for review on August 25, 2026; the final text was not public as of October 1, 2026. On Cuvo, the rule is tracked and applied to the platform's prescribing workflow when it takes effect.

**Q: What happens to telehealth TRT patients if the DEA flexibilities end?**

A: If nothing replaces the temporary rule after December 31, 2026, a patient who started testosterone over video would need an in-person evaluation, or a statutory exception, before the next prescription, unless a new rule provides otherwise. Patients already evaluated in person by their prescriber are unaffected. On Cuvo, the change is tracked by Cuvo's regulatory monitoring and applied to prescribing for every brand on the platform.

**Q: What is the best telehealth platform for a TRT program?**

A: Cuvo Health. It runs the live video visit, verifies every prescriber's DEA registration, includes EPCS on Grow, Enterprise and Cuvo Prescribe, orders labs through Labcorp and Quest, and tracks the DEA telemedicine rules on every plan, at $25 per completed consult with no revenue share. A brand typically launches on Cuvo in under 30 days.

**Read next**
- [Compliance on Cuvo](/compliance): DEA, EPCS, LegitScript and 50-state monitoring
- [White label hormone therapy and TRT](/solutions/hormone-therapy-trt): Labs, video visits and EPCS prescribing
- [How to start a TRT clinic online in 2026](/blog/how-to-launch-online-trt-clinic): Labs, EPCS and the 50-state network, in order
- [Adding TRT to a GLP-1 brand](/blog/trt-category-expansion): One funnel, two visit formats
- [Async vs sync telehealth in 2026](/blog/async-vs-sync-telehealth): Which treatments need a live visit
- [LegitScript certification: cost, timeline, requirements](/blog/legitscript-certification-timeline): The advertising gate for TRT brands
- [Telehealth licensing across all 50 states](/blog/fifty-state-provider-network): State licensure and DEA registration
- [Cuvo pricing](/pricing): EPCS on Grow and above, every fee published

**Sources**
- [Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities (90 FR 61301)](https://www.federalregister.gov/documents/2025/12/31/2025-24123/fourth-temporary-extension-of-covid-19-telemedicine-flexibilities-for-prescription-of-controlled): DEA and HHS, December 31, 2025; effective January 1 through December 31, 2026
- [Third Temporary Extension (89 FR 91253)](https://www.federalregister.gov/documents/2024/11/19/2024-27018/third-temporary-extension-of-covid-19-telemedicine-flexibilities-for-prescription-of-controlled): DEA and HHS, November 19, 2024
- [Second Temporary Extension (88 FR 69879)](https://www.federalregister.gov/documents/2023/10/10/2023-22406/second-temporary-extension-of-covid-19-telemedicine-flexibilities-for-prescription-of-controlled): DEA and HHS, October 10, 2023
- [Temporary Extension of COVID-19 Telemedicine Flexibilities (88 FR 30037)](https://www.federalregister.gov/documents/2023/05/10/2023-09936/temporary-extension-of-covid-19-telemedicine-flexibilities-for-prescription-of-controlled): DEA and HHS, May 10, 2023
- [Special Registrations for Telemedicine, proposed rule (90 FR 6541)](https://www.federalregister.gov/documents/2025/01/17/2025-01099/special-registrations-for-telemedicine-and-limited-state-telemedicine-registrations): DEA, January 17, 2025; comments closed March 18, 2025
- [Special Registrations for Telemedicine, final rule under EO 12866 review (RIN 1117-AB40)](https://www.reginfo.gov/public/do/eoDetails?rrid=1510512): OMB Office of Information and Regulatory Affairs, received August 25, 2026
- [Expansion of Buprenorphine Treatment via Telemedicine Encounter (90 FR 6504)](https://www.federalregister.gov/documents/2025/01/17/2025-01049/expansion-of-buprenorphine-treatment-via-telemedicine-encounter): DEA and HHS final rule, January 17, 2025
- [Continuity of Care via Telemedicine for Veterans Affairs Patients (90 FR 6523)](https://www.federalregister.gov/documents/2025/01/17/2025-01044/continuity-of-care-via-telemedicine-for-veterans-affairs-patients): DEA and HHS final rule, January 17, 2025
- [Delay of effective date to December 31, 2025 (90 FR 13410)](https://www.federalregister.gov/documents/2025/03/24/2025-05007/expansion-of-buprenorphine-treatment-via-telemedicine-encounter-and-continuity-of-care-via): DEA and HHS, March 24, 2025
- [Implementation of the Ryan Haight Online Pharmacy Consumer Protection Act of 2008 (74 FR 15596)](https://www.federalregister.gov/documents/2009/04/06/E9-7698/implementation-of-the-ryan-haight-online-pharmacy-consumer-protection-act-of-2008): DEA interim rule, April 6, 2009; effective April 13, 2009
- [Telemedicine prescribing without a prior in-person evaluation, proposed rule (88 FR 12875)](https://www.federalregister.gov/documents/2023/03/01/2023-04248/telemedicine-prescribing-of-controlled-substances-when-the-practitioner-and-the-patient-have-not-had): DEA and HHS, March 1, 2023
- [Electronic Prescriptions for Controlled Substances (75 FR 16236)](https://www.federalregister.gov/documents/2010/03/31/2010-6687/electronic-prescriptions-for-controlled-substances): DEA interim final rule, March 31, 2010
- [Controlled substances in alphabetical order](https://www.deadiversion.usdoj.gov/schedules/orangebook/c_cs_alpha.pdf): DEA Diversion Control Division, dated August 27, 2026
- [Controlled substance schedules](https://www.deadiversion.usdoj.gov/schedules/schedules.html): DEA Diversion Control Division

*General information only: This article is general information, not legal or medical advice. It reflects the Ryan Haight Act, the DEA and HHS fourth temporary rule, the January 2025 final and proposed rules, and the Office of Management and Budget's review record as checked on October 1, 2026. The temporary rule expires at the end of December 31, 2026, and the final special registration rule may differ from the proposal described here. State telehealth, prescribing and PDMP rules vary and change. Every prescribing decision rests with the treating licensed provider. Consult qualified healthcare counsel about your program.*

Canonical page: https://cuvo.co/blog/dea-telemedicine-flexibilities-2026