How to Open a Longevity Clinic in Texas (2026)

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

To open a longevity clinic in Texas, form a physician-controlled entity such as a professional association or PLLC for the medical side, because diagnosing, prescribing and IV therapy are medical acts and only a physician may organize a medical PLLC. NPs and PAs work under written prescriptive authority agreements, and elective IV therapy agreements count toward the seven-agreement limit. Prescribing testosterone makes the clinic a controlled substance practice that needs DEA registration. Before a peptide or NAD product goes on the menu, confirm its federal status with the pharmacy: a 503A pharmacy may compound only from eligible bulk substances, several peptides often sold for longevity are in none of FDA's bulk substance categories, and FDA's advisory committee reviewed seven of them in July 2026. Register any DEXA device with the Department of State Health Services within 30 days of first use, and confirm who may operate it. Then run memberships, diagnostics, prescribing and texting in one system; Moonshot EHR is $1,000 per location per month with one prescriber, with DEXA sync included.

What a longevity clinic sells

A longevity clinic is usually a membership business with a medical core. What patients pay for:

• Memberships: annual or monthly plans with long visits, scheduled lab panels and messaging access.
• Diagnostics: expanded lab panels, body composition and DEXA scans, and testing sent to outside labs.
• Prescriptions where a clinician finds them indicated, such as hormone therapy, sent to a pharmacy or administered in the clinic.
• In-clinic services such as IV therapy and injections, each under the medical rules below.
• Supplements and other retail products sold from the office.

1. Entity and ownership in Texas

A longevity clinic mixes things anyone may sell, such as supplements and coaching, with things only a licensee may do, such as diagnosing, prescribing and IV therapy. The medical side decides the ownership structure; the retail side does not change it.

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

Longevity clinics run on long scheduled visits and lab reviews, often with an NP or PA as the main clinician under a physician's agreement. IV therapy agreements count toward the physician's limit.

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))

Elective IV therapy means an IV procedure a patient seeks for temporary discomfort or temporary wellness that is not given in a physician's office, a licensed health facility, a licensed mental hospital or a state hospital. (Occ. Code 172.001 (HB 3749))

The Texas Medical Board says elective IV hydration must be ordered by a physician, or by a PA or APRN under adequate physician supervision, and administered by a licensed professional nurse or a higher-level licensee. (TMB FAQ, who can do IV hydration)

The enrolled text of HB 3749 sets no pre-treatment exam, emergency protocol, adverse event, signage or recordkeeping requirement of its own; ask the board whether its rules add any. (HB 3749 enrolled text)

Open questions on this topic: see things to confirm.

3. Testosterone and other controlled substances: DEA, PMP, refills, telemedicine

Many longevity clinics prescribe testosterone to some patients, which makes them controlled substance practices for those prescriptions. If yours will prescribe no controlled substance, this section is the reason you can skip DEA.

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))

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

Lab reviews and follow-ups fit video well; keep first visits and any controlled substance start 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: peptides, NAD, compounded drugs and office stock

Peptides, NAD and similar injectables are where a longevity clinic carries the most regulatory risk. A 503A pharmacy may compound from a bulk substance only if it meets the federal criteria, and several peptides often sold for longevity, such as BPC-157 and TB-500, sit in none of FDA's bulk substance categories, with an FDA advisory committee reviewing them in 2026. This guide describes the rules, not whether any of these products works; check each product's status with your pharmacy before it goes on a menu.

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))

While FDA builds the 503A bulks list, it does not intend to act against compounding with Category 1 substances that meet its conditions. Category 3 substances are outside that policy, and FDA does not intend to categorize substances nominated on or after January 7, 2025. (FDA 503A bulks page)

FDA lists AOD-9604, BPC-157, CJC-1295, epitalon, melanotan II, thymosin alpha-1 and TB-500 as substances whose nominations were withdrawn. They are not in Category 1, so FDA's interim enforcement policy does not cover them. (FDA, bulk substances that may present significant safety risks)

Ipamorelin acetate and GHRP-6 are in Category 2, the significant safety risk category, for 503B outsourcing facilities. (FDA, bulk substances that may present significant safety risks)

FDA's Pharmacy Compounding Advisory Committee met on July 23 and 24, 2026 on BPC-157, KPV, TB-500, MOTS-c, emideltide, epitalon and Semax. Committee votes are not binding, and FDA makes its own determination afterward. (FDA advisory committee briefing, July 2026)

NAD and NADH are on FDA's 503A Category 1 list, under evaluation, while beta-NAD disodium salt trihydrate is in Category 3, so the exact form a pharmacy uses matters. (FDA 503A categories list, May 14, 2026)

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)

FDA's consumer alert says stem cell and exosome products generally require FDA approval, that the approved stem cell products it names are cord blood derived blood-forming stem cells, and that no exosome product is approved. Check FDA's list of approved cellular and gene therapy products for anything approved since. (FDA consumer alert on stem cells and exosomes, 2024)

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)

Texas allows an investigational adult stem cell treatment only for a patient with a listed severe chronic disease or terminal illness, when the treatment is in a clinical trial, with signed informed consent, given by a physician under an institutional review board at a licensed hospital, ambulatory surgical center or medical school. (HSC 1003.053 to 1003.055)

Open questions on this topic: see things to confirm.

If you add GLP-1 weight loss

Many longevity clinics add weight loss programs. The GLP-1 compounding picture changed when the shortages ended, and pharmacies and processors ask about these dates.

FDA has declared the GLP-1 shortages resolved: tirzepatide on December 19, 2024 (enforcement discretion ended February 18, 2025 for 503A and March 19, 2025 for 503B) and semaglutide on February 21, 2025 (April 22, 2025 for 503A and May 22, 2025 for 503B). Neither is on the 503B bulks list. (FDA GLP-1 compounding policy page)

5. Labs, DEXA and diagnostics

Longevity clinics sell diagnostics: broader lab panels, body composition and often a DEXA scan. Blood draws follow the same CLIA rules as any clinic; an x-ray based DEXA device brings its own Texas registration and operator rules.

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 longevity 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 look at a longevity clinic's product mix more than its name. What raises the risk rating:

• High-ticket recurring memberships charged card-not-present.
• Testosterone or another controlled substance in the mix.
• Compounded peptides and injectables, which some processors exclude outright.

Processors commonly ask for licenses, any DEA registrations, the pharmacy partners and their 503A or 503B status, a list of every product and service you sell, 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:

• Annual membership, prepaid or in installments, covering visits, scheduled labs, a DEXA scan cadence and messaging.
• Monthly membership with diagnostics and treatments billed separately.
• Prepaid packages of scans, IV sessions or injections.
• A la carte assessment, often the on-ramp to a membership.

Put cancellation and refund terms in a signed agreement at enrollment, and say what happens to prepaid scans or sessions 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

Longevity marketing makes claims about aging, energy and lifespan. Every such claim in an ad needs substantiation under the rules below.

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)

A supplement label with a structure or function statement must carry FDA's disclaimer that the statement has not been evaluated and the product is not intended to diagnose, treat, cure or prevent any disease, and the marketer notifies FDA within 30 days of first marketing. (21 CFR 101.93(a), (c))

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. Decide in writing whether the clinic will prescribe testosterone or any other controlled substance; if it will, register each prescriber and dispensing location with DEA and complete EPCS identity proofing.Texas limits a delegated Schedule III to V prescription, refills included, to 90 days without documented physician consultation.
13. For every peptide, NAD product or other compounded preparation, get the pharmacy's written statement of the bulk substance's federal status before it goes on the menu.
14. Choose pharmacies and confirm each one's license and 503A or 503B status in writing.
15. If you administer in the clinic, settle office-use sourcing in writing and confirm it with the pharmacy board.
16. If you offer IV therapy, map each requirement of the Texas elective IV therapy law to a written procedure.Texas Occ. Code Chapter 172 applies to elective IV therapy given outside a physician's office or licensed facility.
17. Count IV therapy agreements toward the physician's delegation limit.
18. Open a reference lab account and set up draws or patient service center routing.
19. Get a CLIA certificate before running any test on site.
20. Build your lab panels so ordering is one click.
21. Register any DEXA or other x-ray device with the state before first use.Texas requires DSHS registration of a radiation machine within 30 days after use begins.
22. Confirm in writing who may operate the DEXA device.22 TAC 186.41 lists who may perform bone densitometry in Texas.
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 memberships with signed cancellation and refund terms, and decide whether you will see Medicare patients and on what terms.Seeing Medicare patients cash-pay requires a Medicare opt-out and a signed private contract.
28. Have the physician review every ad, substantiate every claim, collect photo consent and keep copies.
29. Configure appointment types, intake, consents, memberships, packages, e-prescribing, lab ordering and DEXA sync.
30. Work the confirm list below, then run a test patient from booking to first lab review.

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 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 FDA whether a final determination or updated category list followed the July 2026 advisory committee meeting on BPC-157, TB-500 and the other peptides reviewed.
• Confirm with the State Board of Pharmacy whether a Texas pharmacy may compound a peptide that is on no 503A list or category and has no USP monograph, and how the board treats it on inspection.
• Confirm with the Texas Medical Board whether its rules add an exam, emergency protocol, adverse event procedure, posting of the delegating physician's name, or recordkeeping duty for elective IV therapy.
• Confirm with the Department of State Health Services Radiation Control the registration form, fee and timeline for a DEXA device used only for body composition.
• Confirm with the Texas Medical Board that 22 TAC 186.41 is the complete rule on who may operate your DEXA device, including any non-certified technician registration elsewhere in Chapter 186.
• Confirm with the Texas Medical Board whether any rule governs a physician selling supplements or retail products from the office or an online dispensary, including disclosure of a financial interest; the old Chapter 190 rules are repealed and no replacement was found.
• Confirm with FDA or your counsel whether a clinic that sells a supplement under its own label is the firm that files the 21 CFR 101.93 notification and meets the supplement manufacturing rules.
• Confirm with Texas health care counsel whether your clinic counts as a physician's office under Occ. Code 172.001, which decides whether the elective IV therapy law applies.
• 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 FDA whether a final determination or updated category list followed the July 2026 advisory committee meeting on BPC-157, TB-500 and the other peptides reviewed.
• Confirm with the State Board of Pharmacy whether a Texas pharmacy may compound a peptide that is on no 503A list or category and has no USP monograph, and how the board treats it on inspection.
• Confirm with the Texas Medical Board whether its rules add an exam, emergency protocol, adverse event procedure, posting of the delegating physician's name, or recordkeeping duty for elective IV therapy.
• Confirm with the Department of State Health Services Radiation Control the registration form, fee and timeline for a DEXA device used only for body composition.
• Confirm with the Texas Medical Board that 22 TAC 186.41 is the complete rule on who may operate your DEXA device, including any non-certified technician registration elsewhere in Chapter 186.
• Confirm with the Texas Medical Board whether any rule governs a physician selling supplements or retail products from the office or an online dispensary, including disclosure of a financial interest; the old Chapter 190 rules are repealed and no replacement was found.
• Confirm with FDA or your counsel whether a clinic that sells a supplement under its own label is the firm that files the 21 CFR 101.93 notification and meets the supplement manufacturing rules.
• Confirm with Texas health care counsel whether your clinic counts as a physician's office under Occ. Code 172.001, which decides whether the elective IV therapy law applies.
• 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 Hormone and Menopause Clinic in Texas (2026)
• How to Open a TRT Clinic in Texas (2026)
• Does Moonshot EHR integrate with DEXA body composition scanners?
• Does Moonshot EHR do membership billing?
• Does Moonshot EHR sell prepaid packages and bundles?
• Does Moonshot EHR track medication inventory?
• 503A vs 503B compounding
• 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.