How to Open a TRT Clinic in Texas (2026)

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

To open a TRT 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. Each prescriber needs a federal DEA registration, with a separate registration for each place where controlled substances are dispensed. Nurse practitioners and PAs prescribe testosterone only under a written prescriptive authority agreement, and each delegated Schedule III prescription, refills included, is limited to 90 days unless the physician is consulted and that is documented. Prescribe FDA-approved testosterone cypionate or enanthate to a pharmacy, and confirm with the pharmacy board before planning office stock or take-home dispensing. Draw blood and send every test to a reference lab; collection alone needs no CLIA certificate for the clinic. Register your texting brand and get written consent before any marketing text. Expect processors to underwrite you closely. Then run memberships, prescribing, labs and texting in one system; Moonshot EHR is $1,000 per location per month with one prescriber.

What a TRT clinic sells

• Visits: an initial consultation, then follow-up visits in person or by telemedicine.
• Labs: a baseline panel before treatment and monitoring panels on a schedule the prescriber sets.
• Testosterone cypionate or enanthate, prescribed to a pharmacy for self-injection at home or administered in the clinic.
• Memberships that bundle visits, labs and messaging access into a recurring charge, with medication either included or billed separately.

1. Entity and ownership in Texas

Settle ownership first, because it decides who signs every agreement after it. Diagnosing low testosterone and writing the prescription 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

After the first visit, most TRT visits are follow-ups: a lab review, a dose conversation, a refill. That makes the NP or PA the economic center of the clinic and the physician's agreement the thing it rests on.

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))

Open questions on this topic: see things to confirm.

3. Testosterone: DEA, Schedule III, PMP, refills, telemedicine

Testosterone is a controlled substance, so every TRT clinic is a controlled substance practice. That drives DEA registration, e-prescribing, refill policy and how processors see you.

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))

Telemedicine

Telemedicine works well for TRT follow-ups and lab reviews; keep the first visit and any remote 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: FDA-approved vs compounded, office stock, dispensing

Testosterone cypionate and enanthate are commercially manufactured, FDA-approved products, so a TRT clinic rarely needs compounded testosterone. Most clinics prescribe to a pharmacy for self-injection at home; some inject in the clinic, which is where office stock rules matter.

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))

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)

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.

If you add GLP-1 weight loss later

The GLP-1 compounding picture changed when the shortages ended, and processors and pharmacies 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 and blood draws

TRT runs on labs: a baseline panel before the first prescription and monitoring panels 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 TRT clinic talks to patients: lab-draw reminders, refill nudges, confirmations. 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 TRT as higher risk, for reasons unrelated to how well you run the clinic. The ones operators hear most:

• Recurring card-not-present charges for memberships and programs, which processors associate with disputes.
• A controlled substance in the product mix.
• Compounded products, if the clinic sells any, which some processors will not touch.

Processors commonly ask for licenses, DEA registrations, the pharmacy partner and its 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.

Memberships turn a visit business into a predictable one. Common structures:

• Monthly: follow-up visits, scheduled labs and messaging, with medication billed separately.
• All-in monthly: the same plus medication, simpler to bill but tied to drug cost.
• Quarterly or yearly prepaid, at a lower effective rate, with written terms for early exits.
• A la carte visits and labs, often the on-ramp to a membership.

Put cancellation and refund terms in a signed agreement at enrollment; it is what a processor reads when a patient disputes a charge.

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

TRT marketing leans on transformation stories, which is exactly what the state and FTC rules watch.

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)

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 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.
13. Add a DEA registration for each location that dispenses controlled substances.
14. Complete EPCS identity proofing for every prescriber.
15. Write a refill and renewal policy within the Schedule III limits.Texas limits a delegated Schedule III prescription, refills included, to 90 days without documented physician consultation.
16. Decide, in writing, whether you check the PMP for every patient.
17. Choose pharmacies for patient-specific prescriptions.
18. If you inject in the clinic, settle office-use sourcing in writing and confirm it with the pharmacy board.
19. If you hold controlled stock, set up locked storage, a receiving log and counts.
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 plans with signed cancellation and refund terms.
28. Configure appointment types, intake, consents, memberships, e-prescribing and lab ordering.
29. Have the physician review every ad, collect photo consent and keep copies.
30. Work the confirm list below, then run a test patient from booking to refill.

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 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, whether they accept testosterone and any compounded products and what reserve they hold and for how long. No card-brand rule found for this guide names TRT.

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 Longevity Clinic in Texas (2026)
• What software a TRT clinic needs
• 503A vs 503B compounding
• Does Moonshot EHR do e-prescribing and EPCS?
• Does Moonshot EHR track controlled substance inventory?
• 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.