How to Open a Hormone and Menopause Clinic in Texas (2026)

By Tom Kashul, Founder, Moonshot EHR; clinic owner-operator

To open a hormone and menopause clinic in Texas, form a physician-controlled entity such as a professional association or PLLC, because only a Texas-licensed person may practice medicine and only a physician may organize a medical PLLC. NPs and PAs prescribe under written prescriptive authority agreements, one physician may delegate to no more than seven, and a delegated testosterone prescription, refills included, is limited to 90 days without a documented physician consultation. Estradiol and progesterone are not controlled substances; testosterone is Schedule III for women and men alike, so prescribing it needs DEA registration, and FDA's approved testosterone products are approved only for men. Compounded hormones are not FDA-approved and are made by a 503A pharmacy for an identified patient; outsourcing facilities supply pellet office stock under FDA's interim policy for Category 1 substances, which include testosterone and estradiol, so get the facility's basis in writing, and store controlled pellets locked with a biennial inventory. Then run memberships, prescribing, labs and texting in one system; Moonshot EHR is $1,000 per location per month with one prescriber.

What a hormone and menopause clinic sells

What a hormone and menopause practice usually sells:

• Visits: an initial consultation, then follow-ups in person or by video.
• Prescriptions for FDA-approved estradiol, progesterone and testosterone products, sent to a pharmacy.
• Compounded preparations, such as creams or troches, from a pharmacy for an identified patient when the prescriber chooses them.
• Pellet insertions in the clinic.
• Labs at baseline and on a monitoring schedule, and memberships that bundle visits, labs and messaging.

1. Entity and ownership in Texas

Settle ownership first. Diagnosing and treating menopause symptoms and writing hormone prescriptions is practicing medicine, so the business has to leave the licensee, not the investor, in control of clinical decisions.

These statutes are why most Texas cash-pay clinics are owned by a physician, not by the partner who funded them.

Only a person licensed in Texas may practice medicine in Texas. (Occ. Code 155.001)

A physician can be disciplined for aiding the practice of medicine by an unlicensed person or entity. (Occ. Code 164.052(a)(17))

An unlicensed person or entity that indicates it is entitled to practice medicine commits an offense. Read this provision before a company owned by non-physicians puts "medical" or "clinic" in its name or advertising. (Occ. Code 165.156)

Physicians may form a professional association or a professional limited liability company (PLLC). Physicians and physician assistants may form one together, but only a physician may organize it and physicians must control it. (Bus. Orgs. Code 301.012(a), (a-1), (a-4))

A physician assistant in a jointly owned entity may not serve as an officer, may hold only a minority stake that is never equal to or larger than any physician owner's, and may not employ the supervising physician. (Bus. Orgs. Code 301.012(a-2), (a-3), (a-6))

A nonprofit health organization certified by the Texas Medical Board, organized solely by licensees and with licensed, active directors, may employ physicians. (Occ. Code 162.001)

Open questions on this topic: see things to confirm.

Background: the MSO and corporate practice guide.

2. Prescribers: physician, NP and PA rules

Hormone and menopause practices are often NP-led. The physician's agreement decides how many clinicians you can staff and how testosterone refills are scheduled.

The delegation rules decide how many NPs and PAs you can staff, what the paperwork says and how often the physician is involved.

22 TAC Chapter 193, the old standing delegation order chapter, was repealed effective January 9, 2025, so templates that cite it are out of date. Delegation now lives in 22 TAC Chapter 169, physician assistant rules in Chapter 183, advertising in Chapter 164, business organizations in Chapter 174 and telemedicine in Chapter 175. (22 TAC Chapter 169)

An NP or PA may prescribe under delegation only through a written prescriptive authority agreement with adequate supervision. (Occ. Code 157.0512(a))

According to the Texas Medical Board, adequate supervision does not require the physician's constant physical presence. (TMB FAQ on delegation)

A physician may delegate to no more than seven APRNs and PAs, or seven full-time equivalents, with exceptions for medically underserved populations and facility-based hospital practice. (Occ. Code 157.0512(c), (d))

The agreement must at minimum be signed and dated and list license numbers, practice settings, delegated drug categories, a consultation and referral plan, an emergency plan, a communication process, alternate physicians and a quality assurance plan. (Occ. Code 157.0512(e))

The agreement sets how many charts the physician reviews, and the two must hold a documented meeting at least monthly. The circulating figure of a 10 percent chart review and an on-site visit every 10 business days comes from a 2007 bill draft, not current law. (Occ. Code 157.0512(e)(9), (f); 22 TAC 222.5(c)(9), (d))

The agreement is reviewed, dated and signed every year, kept for two years after it ends, and produced to the board by the third business day after a request. (22 TAC 222.5(h), (k))

The physician registers each delegation with the Texas Medical Board within 30 days (name, license, start date and locations) and reports a termination within 30 days. (22 TAC 169.5)

An APRN also needs prescriptive authority approval and an authorization number from the Texas Board of Nursing. (22 TAC Chapter 222)

Since September 1, 2025, agreements for elective IV therapy count toward the seven-person cap, and the underserved exception does not apply to them. (HB 3749; Occ. Code 172.051(d))

A Texas physician may delegate a medical act to a qualified, properly trained person under the physician's supervision when a reasonable and prudent physician would find it within sound medical judgment; the physician stays responsible, and the Medical Board may decide whether an act can be safely delegated. (Occ. Code 157.001)

Open questions on this topic: see things to confirm.

3. Testosterone for women and men: DEA, Schedule III, PMP, refills

Estradiol and progesterone are not controlled substances. Testosterone is, whether it is prescribed to a woman or a man, so a clinic that prescribes it to anyone is a controlled substance practice for those prescriptions, and testosterone pellets held in the office are controlled stock.

Testosterone is a Schedule III controlled substance because it is an anabolic steroid. (21 CFR 1308.13(f))

DEA requires a separate registration for each principal place of business where controlled substances are dispensed. (21 CFR 1301.12)

Each prescriber registers with DEA individually. (21 CFR 1301.11(a))

A Schedule III or IV prescription may not be refilled more than six months after it was written or more than five times without a new prescription. (21 CFR 1306.22(a))

The federal anabolic steroid definition excludes estrogens, progestins, corticosteroids and DHEA, and estradiol, progesterone and DHEA are not listed in the schedules. (21 CFR 1300.01; 21 CFR part 1308)

Controlled substances a clinic holds, including testosterone pellets, are stored in a securely locked, substantially constructed cabinet. (21 CFR 1301.75(b))

A registrant takes an initial inventory on the day it first holds controlled substances and a new one at least every two years. (21 CFR 1304.11(b), (c))

A practitioner who regularly administers controlled substances and charges patients for them, as a clinic billing for pellet insertions does, keeps records of what was administered, to whom and when, for at least two years. (21 CFR 1304.03(b), (d); 1304.04(a); 1304.22(c))

Texas adds its own rules on top of the federal ones:

Texas allows anabolic steroids to be prescribed only for a valid medical purpose, and bodybuilding or muscle enhancement in a healthy person is expressly not one. (HSC 481.071(b), (c))

A federal DEA registration is required to prescribe, possess or dispense controlled substances in Texas. The separate Texas DPS controlled substance registration was repealed effective September 1, 2016. (HSC 481.061)

Checking the Texas Prescription Monitoring Program is mandatory only before prescribing opioids, benzodiazepines, barbiturates or carisoprodol. For testosterone it is permitted, not required; many clinics check anyway as a written policy. (HSC 481.0764(a), (b), (d))

Texas law carries the same Schedule III and IV refill limit as federal law. (HSC 481.074(g))

When an NP or PA prescribes a Schedule III, IV or V drug under delegation, the prescription including refills may not cover more than 90 days; going past that requires a documented consultation with the delegating physician. Schedule II delegation is limited to hospital and hospice settings. This is the rule that shapes an NP-staffed clinic's refill calendar. (Occ. Code 157.0511(b); 22 TAC 222.8(b), (c))

The Texas Medical Board says controlled substance prescriptions must be sent electronically, with limited exceptions, and that NPs and PAs consult the delegating physician for controlled substance refills after the first 90-day supply. (TMB, prescribing and supervision)

Telemedicine

Menopause visits and hormone follow-ups fit video well; keep the first visit and any remote start of testosterone inside these rules.

A valid telemedicine prescription requires an established practitioner and patient relationship and compliance with the Medical Practice Act and Health and Safety Code Chapters 481 and 483. Only chronic pain carries an extra telemedicine-specific condition. (22 TAC 175.3(a))

The relationship can come from a preexisting relationship, call coverage, or a synchronous audio and video visit (or qualifying store-and-forward). The practitioner gives follow-up guidance and, with consent, sends records to the patient's primary care physician within 72 hours. (Occ. Code 111.005)

Telemedicine must follow Chapter 111 and the Medical Practice Act, including the delegation rules and the complaint-notice posting requirement. (22 TAC 175.2)

DEA's Fourth Temporary Extension, published December 31, 2025, lets an audio and video telemedicine visit start a Schedule II through V prescription without a prior in-person visit through December 31, 2026, unless extended or replaced. Re-check before you rely on it. (90 FR 61301)

Open questions on this topic: see things to confirm.

4. Sourcing: FDA-approved hormones, compounded preparations and pellets

Hormone clinics choose, prescription by prescription, between FDA-approved products and compounded preparations such as creams, troches, capsules and pellets. Compounded preparations are not FDA-approved, and a 503A pharmacy makes them for an identified patient on a prescription. Office stock is narrower than many operators assume, especially for pellets. This section sets out the rules for each choice, not which one suits a patient.

FDA says compounded drugs are not FDA-approved and that FDA does not review their safety, effectiveness or quality before they are marketed. (FDA, compounding questions and answers)

A 503A compounding pharmacy is exempt from the new-drug rules only when it compounds for an identified patient on a valid prescription. (21 U.S.C. 353a(a))

A 503A pharmacy may compound only with bulk substances that have a USP or NF monograph, are components of FDA-approved drugs, or are on FDA's 503A bulks list, each with a certificate of analysis from an FDA-registered manufacturer. (FDA 503A bulks page; 21 U.S.C. 353a(b)(1)(A))

Under FDA's guidance, a 503A pharmacy may not ship office stock without patient-specific prescriptions; a 503B outsourcing facility may. (FDA, Prescription Requirement Under Section 503A)

By statute, a 503B outsourcing facility compounds from a bulk substance on FDA's 503B bulks list or for a drug on FDA's shortage list. While FDA builds that list, its interim policy says it does not intend to act against an outsourcing facility compounding from a Category 1 substance, one under evaluation, when the policy's conditions are met. (21 U.S.C. 353b(a)(2); FDA interim 503B bulks policy, January 2025)

FDA's 503B categories list places testosterone, testosterone cypionate, enanthate and propionate, estradiol, estradiol cypionate, estriol and progesterone in Category 1, under evaluation. Testosterone and estradiol are not on the five-substance 503B bulks list itself. (FDA 503B nominated bulk substances, updated March 21, 2025)

Testopel, a testosterone pellet for implantation, is approved for males with primary or hypogonadotropic hypogonadism and for delayed puberty in selected males. No FDA-approved estradiol pellet or implant was found. (openFDA drug label and approval data)

FDA says no FDA-approved drug contains estriol, so estriol products on the market are compounded. (FDA, menopause)

FDA says its approved testosterone products are approved only for men who lack or have low testosterone with an associated medical condition, so prescribing testosterone to a woman is an unapproved use of an approved drug. (FDA, testosterone information)

FDA says a prescriber generally may prescribe an approved drug for an unapproved use when it is medically appropriate for the patient, and that FDA has not found the drug safe and effective for that use. (FDA, unapproved use of approved drugs)

Each prescription estrogen product must be dispensed with a patient package insert covering contraindications, serious risks and side effects. (21 CFR 310.515)

On November 10, 2025, FDA announced it would work with manufacturers to remove references to cardiovascular disease, breast cancer and probable dementia from the boxed warnings on menopausal hormone therapy labels, keeping the endometrial cancer boxed warning on systemic estrogen-alone products. (FDA press announcement, November 10, 2025)

On February 12, 2026, FDA approved the first of those label changes, for six menopausal hormone therapy products. Read the current label of each product you prescribe rather than an older one. (FDA press announcement, February 12, 2026)

In Texas, office stock and take-home dispensing are where state and federal rules diverge.

The State Board of Pharmacy says Texas law allows office-use distribution of compounded preparations, but "such action may not be allowed by federal law", and non-compounded drugs cannot be dispensed for office use. (TSBP Rules FAQ, February 2025)

A Class A, C or E pharmacy may supply a reasonable quantity of non-sterile compounded preparations for office use under a written agreement, for administration in the clinic only, never for dispensing or resale. (22 TAC 291.131)

A physician may supply any drug, remedy or clinical supply necessary for a patient's immediate needs. That permission is not a license to run a pharmacy. (Occ. Code 158.001)

Open questions on this topic: see things to confirm.

5. Labs and blood draws

Hormone care runs on labs: a baseline before treatment and monitoring on the prescriber's schedule. Most new clinics draw in the clinic or route patients to a patient service center and send every test to a reference lab.

Collecting and preparing specimens, with all testing sent to an outside lab, does not make a clinic a laboratory under CLIA. (42 CFR 493.2)

Any test performed on site, including a waived test, requires a CLIA certificate. (42 CFR 493.3(a))

A lab that runs only waived tests files a certificate of waiver for each location. (42 CFR 493.35(a))

This research found no Texas license an office lab must hold beyond CLIA; that absence is on the confirm list.

Open questions on this topic: see things to confirm.

6. Patient texting and reminders

Text is how a hormone clinic talks to patients: visit reminders, lab-draw reminders, refill and renewal nudges. Clinic texting rules are federal, and the business number must be registered before carriers will deliver at volume.

Marketing texts need prior express written consent, health care messages from HIPAA covered entities have their own carve-out, and a reply of "stop", "quit", "end", "revoke", "opt out", "cancel" or "unsubscribe" revokes consent by itself. (47 CFR 64.1200)

The Campaign Registry charges $4.50 per brand ($4.00 for a sole proprietor), $41.50 for a standard vet and $101.50 for an enhanced vet, and $10 a month per Marketing, Mixed, Customer Care or Account campaign ($1.50 Low Volume Mixed, $2.00 Sole Proprietor). Vendors add their own fees. (TCR fees and pricing, August 13, 2026)

HIPAA's minimum necessary standard applies to what you put in a message. (45 CFR 164.502(b))

A practical rule, not a quoted regulation: keep diagnoses and drug names out of reminders.

Open questions on this topic: see things to confirm.

7. Getting paid: processors, underwriting, memberships

Processors commonly treat hormone clinics like TRT clinics. The reasons operators hear most:

• Recurring card-not-present charges for memberships.
• Testosterone, a controlled substance, in the product mix.
• Compounded preparations and pellets, which some processors will not touch.

Processors commonly ask for licenses, DEA registrations, the pharmacy partners and their 503A or 503B status, any LegitScript certification, supervision agreements, a written refund policy and prior processing history. Reserves on new accounts are common. Have the package ready before you apply.

Common structures:

• Monthly membership: follow-ups, scheduled labs and messaging, with medication billed separately.
• Pellet programs priced per insertion, or as a membership that includes a set number of insertions a year.
• Quarterly or yearly prepaid plans, with written terms for early exits.
• A la carte consultations and labs, often the on-ramp to a membership.

Put cancellation and refund terms in a signed agreement at enrollment, and say plainly what happens to a prepaid insertion the patient does not use.

Physicians and practitioners, including nurse practitioners and physician assistants, may opt out of Medicare and treat Medicare patients under private contracts. An opt-out or contract that does not meet the rules is void. (42 CFR 405.400, 405.405)

The first two-year opt-out period starts on the date the affidavit is signed if it is filed within 10 days after the first private contract. It renews by default; cancelling takes written notice to each Medicare contractor at least 30 days before the period ends. (42 CFR 405.410(c), 405.445(a))

The private contract is signed by both parties before services, not during urgent or emergency care, and says the patient pays in full, Medicare limits do not apply, no claim will be filed, Medicare and Medigap will not pay, and the dates of the opt-out period. A new contract is signed for each two-year period. (42 CFR 405.415)

For months after December 31, 2025, a direct primary care arrangement does not stop HSA contributions if it covers only primary care for a fixed fee of no more than $150 a month ($300 for more than one person). Prescription drugs other than vaccines are excluded, and an arrangement that includes other services does not qualify, whatever the member uses. (IRS Notice 2026-5)

Open questions on this topic: see things to confirm.

8. Texas filings, taxes and fees

What a new Texas clinic files and pays in its first year.

Open questions on this topic: see things to confirm.

9. Advertising rules

Hormone marketing often leans on the words bioidentical and natural and on symptom-relief stories. Every claim an ad makes needs substantiation under the rules below, and a compounded preparation must not be presented as FDA-approved.

Texas holds the physician responsible for what the clinic's marketing says.

Ads may not be false, deceptive or misleading. Testimonials need a credentials disclaimer and a compensation disclosure, models must be identified, and medical directorship or supervision must be disclosed at non-primary locations run under protocols. (22 TAC 164.3)

The physician is responsible for all of the practice's advertising, must have a patient's consent before the patient's photos appear in an ad, and must keep copies of ads for two years. (22 TAC 164.2)

The FTC's Consumer Reviews and Testimonials Rule, effective October 21, 2024, bans fake reviews and undisclosed insider reviews. (16 CFR Part 465)

Under the FTC Endorsement Guides, claims in an endorsement need substantiation, and when the endorser's result is not typical you disclose the results people can generally expect. (16 CFR 255.2)

FTC health products guidance requires competent and reliable scientific evidence for health benefit claims, and for most such claims that generally means randomized, controlled human clinical testing. (FTC Health Products Compliance Guidance)

10. The software stack and what it costs

You need these pieces whichever vendor you choose. The right column is what Moonshot EHR includes and charges.

At list price that is 1 prescriber: $1,000; 2 prescribers: $1,200; 3 prescribers: $1,400 per location per month, before the optional packages and your processor's fees.

11. A 30-item opening checklist

1. Decide who owns the practice; if a non-physician is investing, take the structure to health care counsel first.
2. Form the practice entity with the Secretary of State.
3. File an assumed name if you market under a different brand.
4. Get an EIN, a business bank account and bookkeeping before the first charge.
5. Register for state business taxes, including a sales tax permit if you sell taxable products, and calendar the annual filings.
6. Sign a supervising physician agreement with a physician who will do the work.
7. Sign a written prescriptive authority agreement for each NP and PA.
8. Register each delegation with the medical board.In Texas, register each delegation with the Medical Board within 30 days.
9. Confirm each APRN's prescriptive authority.Texas APRNs need Board of Nursing prescriptive authority approval and an authorization number.
10. Calendar the required supervision meetings and chart reviews and keep minutes.
11. Carry malpractice coverage for every prescriber.
12. Register each prescriber with DEA, and add a registration for each location that holds or dispenses testosterone, including pellets.
13. Complete EPCS identity proofing for every prescriber.
14. Write a testosterone refill and renewal policy within the Schedule III limits, and decide in writing whether you check the PMP.Texas limits a delegated Schedule III prescription, refills included, to 90 days without documented physician consultation. The PMP check is optional for testosterone.
15. Decide which FDA-approved products and which compounded preparations you will offer, and how the prescriber documents the choice.
16. Choose pharmacies and confirm each one's license and 503A or 503B status in writing.
17. Settle pellet sourcing in writing: FDA-approved pellets, or compounded pellets prescribed for an identified patient, and confirm any office-stock plan before you rely on it.Testosterone and estradiol are in FDA's 503B Category 1, under evaluation; no estradiol pellet is FDA-approved.
18. Set up locked storage, a receiving log and counts for testosterone stock, including pellets.
19. Confirm in writing who may perform pellet insertions under your delegation.Texas lets a physician delegate a medical act to a properly trained person under supervision; pellet-specific limits are on the confirm list.
20. Open a reference lab account and set up draws or patient service center routing.
21. Get a CLIA certificate before running any test on site.
22. Build baseline and monitoring panels so ordering is one click.
23. Register the texting brand and campaign for your clinic number.
24. Add texting consent to intake, with marketing consent as a separate choice.
25. Write reminder templates with no diagnosis or drug name.
26. Apply for a merchant account with the underwriting package ready.
27. Publish membership and pellet plans with signed cancellation and refund terms.
28. Configure appointment types, intake, hormone and pellet consents, memberships, e-prescribing and lab ordering.
29. Have the physician review every ad, substantiate every claim, collect photo consent and keep copies.
30. Work the confirm list below, then run a test patient from booking to first follow-up.

12. Things to confirm before you open

Questions this guide could not settle from a primary source, each with who can answer it. Ask in writing and keep the answers.

• Confirm with Texas health care counsel whether a management services organization (MSO) fits your plan, where a non-physician company provides non-clinical services to the physician-owned practice for a fair-market-value fee. No Texas statute, Medical Board rule or Medical Board FAQ found for this guide expressly approves it, and the status of 2023 HB 2982 is unconfirmed.
• Confirm with the Board of Nursing and your counsel whether a nurse practitioner may own a Texas practice entity; the statute is silent.
• Confirm with the Texas Medical Board that Occ. Code 157.0511 and 157.0512, HSC 481.074 and 481.0764, and 22 TAC Chapters 169 and 183 read as cited here after the 2025 session; this guide used statute and rule mirrors, not the official sites.
• Confirm with the State Board of Pharmacy and the Medical Board before you plan take-home testosterone dispensing. HSC 481.074(g) lets a practitioner dispense a Schedule III drug to the patient, but how that fits the physician-dispensing limits in Occ. Code Chapter 158 is unresolved.
• Confirm with the Texas Medical Board how large an immediate-needs supply may be under Occ. Code 158.001; no primary source found for this guide gives a number.
• Confirm with the State Board of Pharmacy and the Medical Board whether the rural physician-dispensing exception in Occ. Code 158.003 applies to your location at all. It is written for dangerous drugs, has population and distance conditions, and should not be read as permission to dispense testosterone.
• Confirm with the State Board of Pharmacy the current text of 22 TAC 291.133, the sterile office-use rule, reportedly amended in February 2026.
• Confirm with the Texas Medical Board whether in-office IV drips at your clinic fall under Occ. Code Chapter 172, which turns on whether the clinic counts as a physician's office.
• Confirm with the Texas Medical Board that no facility registration applies to a hormone clinic; none was found.
• Confirm with the Texas Health and Human Services Commission, which handles CLIA applications for CMS in Texas, the current form and whether any state license applies to an office lab; none was found.
• Confirm with the Texas Comptroller how sales tax applies to prescription drugs the clinic dispenses and to the services and memberships it sells.
• Confirm the Form 206 (PLLC) filing fee with the Secretary of State.
• Confirm with the State Board of Pharmacy the exemptions in Occ. Code 560.004 before you use an out-of-state pharmacy that ships to Texas patients without a Class E license.
• Confirm with the Texas Medical Board and the Board of Nursing who may perform a subcutaneous hormone pellet insertion under delegation, and under what supervision and training.
• Confirm with the outsourcing facility, in writing, that each pellet it ships as office stock is compounded under FDA's interim Category 1 policy or another lawful basis, and that the product is not essentially a copy of an approved drug.
• Confirm with FDA whether the estrogen patient package insert rule in 21 CFR 310.515 applies to compounded estrogen preparations.
• Confirm with FDA and your compounding pharmacy the bulk substance basis for estriol before you prescribe it, since no FDA-approved drug contains it.
• Confirm with DEA whether inserting a testosterone pellet from clinic stock for a fee is administering or dispensing for recordkeeping, and how each pellet used must be logged.
• Confirm with Texas health care counsel whether calling a compounded product bioidentical or natural in your ads raises a misleading-advertising issue under 22 TAC 164.3 or FTC rules.
• Confirm with the State Board of Pharmacy and the Medical Board whether the clinic may keep compounded creams or troches to hand to patients, beyond in-clinic administration under a written agreement.
• Confirm with the State Board of Pharmacy the exemptions in Occ. Code 560.004 before you use an out-of-state pharmacy that ships to Texas patients without a Class E license.
• Confirm with the Texas Medical Board and the Board of Nursing who may perform a subcutaneous hormone pellet insertion under delegation, and under what supervision and training.
• Confirm with the outsourcing facility, in writing, that each pellet it ships as office stock is compounded under FDA's interim Category 1 policy or another lawful basis, and that the product is not essentially a copy of an approved drug.
• Confirm with FDA whether the estrogen patient package insert rule in 21 CFR 310.515 applies to compounded estrogen preparations.
• Confirm with FDA and your compounding pharmacy the bulk substance basis for estriol before you prescribe it, since no FDA-approved drug contains it.
• Confirm with DEA whether inserting a testosterone pellet from clinic stock for a fee is administering or dispensing for recordkeeping, and how each pellet used must be logged.
• Confirm with Texas health care counsel whether calling a compounded product bioidentical or natural in your ads raises a misleading-advertising issue under 22 TAC 164.3 or FTC rules.
• Confirm with the State Board of Pharmacy and the Medical Board whether the clinic may keep compounded creams or troches to hand to patients, beyond in-clinic administration under a written agreement.
• Confirm with DEA whether the telemedicine flexibilities were extended past December 31, 2026 or replaced by a special registration rule before you build a remote-start model.
• Confirm with your counsel how the FCC treats appointment-reminder texts from a covered entity to wireless numbers.
• Confirm with your texting vendor how long brand and campaign review take and what each submission needs, such as privacy policy and terms URLs.
• Confirm with your processor, in writing, which of your products and services they accept, including any controlled substances and compounded preparations, and what reserve they hold and for how long. No card-brand rule found for these guides names a clinic type.
• Confirm with your Medicare Administrative Contractor the current opt-out affidavit form and filing address before you see a Medicare patient under a private contract.

Related

• All Texas opening guides
• How to Open a Functional Medicine Clinic in Texas (2026)
• How to Open a GLP-1 Weight Loss Clinic in Texas (2026)
• How to Open a Longevity Clinic in Texas (2026)
• How to Open a TRT Clinic in Texas (2026)
• What software a TRT clinic needs
• 503A vs 503B compounding
• Does Moonshot EHR track controlled substance inventory?
• Does Moonshot EHR do e-prescribing and EPCS?
• Does Moonshot EHR have intake forms and e-signed consents?
• Does Moonshot EHR do membership billing?
• Moonshot EHR pricing

This guide is operating information, not legal advice. Confirm the current rules with the Texas Medical Board, the Board of Nursing, the State Board of Pharmacy and your counsel before you open. Each statement above is tied to the source beside it as read on the date shown; statutes and rules change, and some sources are statute mirrors, not the official text. Moonshot prices are current as of October 19, 2026.