Yes: a nurse practitioner, physician assistant or physician can open a cash-pay telemedicine hormone practice in Texas, but Texas is one of the more structured states to do it in. The gating items are a delegating or supervising physician for NPs and PAs (Texas has no independent practice for either), a strong corporate-practice-of-medicine doctrine that controls who owns the clinical entity, a full Texas license for anyone treating Texas patients, and a telemedicine framework under Occupations Code Chapter 111 that allows video-first care without a prior in-person exam. This is a 2026 planning summary, not legal advice; confirm every point with the Texas Board of Nursing, Texas Medical Board, Texas Physician Assistant Board and counsel, because rules change.
Texas practice authority: who can run and own a telemedicine hormone practice
Nurse practitioners in Texas
Texas is a restricted practice state for APRNs: there is no full practice authority and no transition-to-practice pathway to independence, and every medical act an NP performs, including prescribing, is delegated by a physician under Occupations Code Chapter 157. Full-practice bills filed in the 2025 session did not pass, as far as public records show; the next regular session is 2027.
The working document is the prescriptive authority agreement (PAA): written and signed, listing practice settings, the drug categories that may or may not be prescribed, consultation, referral and emergency plans, and a quality-assurance plan with chart review and meetings at least monthly. It is reviewed and re-signed at least annually, the delegating physician registers the delegation with the Texas Medical Board, and the APRN needs a Texas APRN license plus a prescriptive authorization number from the Board of Nursing. A physician may generally delegate to no more than seven full-time-equivalent APRNs and PAs combined (facility-based and medically underserved exceptions apply), so confirm a prospective collaborator has room.
For a hormone practice the key detail is controlled substances. Under a PAA an NP may prescribe Schedule III through V drugs, which covers testosterone, subject to limits commonly summarized as a 90-day supply with physician consultation documented before further refills; Schedule II is limited to hospital and hospice settings. Read the current 22 TAC Chapter 222 with your collaborator.
Physician assistants in Texas
PAs are licensed by the Texas Physician Assistant Board and practice under a supervising physician with an active, unrestricted Texas license who has notified the Medical Board of the relationship. Prescribing is delegated through the same PAA mechanism, with the same seven-FTE ceiling, Schedule III through V outpatient scope, monthly meetings and annual review. Texas does give PAs something NPs do not get: the Business Organizations Code allows physicians and physician assistants to jointly own a professional entity, commonly read as permitting a PA minority stake in a physician-owned practice. Whether that fits a clinic you intend to run day to day is a question for counsel.
Physicians and the corporate practice of medicine
Texas enforces the corporate practice of medicine doctrine firmly: in general only a physician may own the entity that delivers medical services, employ physicians to practice medicine, or collect the fees medicine generates. A physician starting a cash-pay hormone clinic typically forms a professional association (Business Organizations Code Chapter 302) or a PLLC (Chapter 304) and owns it outright. Non-physician partners, investors and spouses sit in a separate management services organization (MSO) that supplies marketing, technology, billing and staff under a fair-market-value management agreement.
So who may own the practice?
A physician may own it outright. A PA may generally co-own with a physician. For an NP the honest answer is that Texas law is unsettled: many NP-owned clinics operate as a nursing practice contracting with a delegating physician, which commonly cited guidance calls neither expressly permitted nor prohibited, while others use a physician-owned clinical entity plus an NP-owned MSO. Have a Texas health-care attorney set the model in writing before you file anything.
Texas telehealth rules for a remote hormone practice
Licensure and patient location. Texas treats the patient’s location as the place of practice. A physician treating a patient in Texas needs a full Texas medical license; the Medical Board’s out-of-state telemedicine license is narrow, and the 2025 bill that would have created a telehealth registration for out-of-state practitioners did not advance. The Interstate Medical Licensure Compact can shorten the path for physicians licensed elsewhere. The Nurse Licensure Compact covers the RN license only; an APRN still needs a Texas APRN license and prescriptive authorization.
Establishing the relationship. Occupations Code Section 111.005 lets a practitioner establish a valid practitioner-patient relationship through synchronous audio-video, through store-and-forward combined with the patient’s clinical information or synchronous audio, or through other technology meeting the standard of care. No in-person exam is required first. The standard of care is the same as in person, follow-up guidance is required, and if the patient consents and has a primary care physician you must send that physician a report within 72 hours. Telemedicine informed consent and a notice on how to file a complaint with the Medical Board are required; the Board’s telemedicine rules now sit in 22 TAC Chapter 175.
Controlled substances and registrations. Testosterone is Schedule III, so each prescriber needs a DEA registration tied to a Texas address. Texas eliminated its separate Department of Public Safety controlled-substance registration effective September 1, 2016, and did not replace it. Federal telemedicine rules for controlled substances have been extended and revised repeatedly, so confirm the current federal position on in-person evaluation before prescribing. Texas mandates a prescription monitoring program (PMP Aware) check before prescribing opioids, benzodiazepines, barbiturates or carisoprodol; testosterone is not on that list as commonly read, but checking it for every controlled prescription is sound practice. Texas also generally requires electronic prescribing of controlled substances, so an EHR with certified EPCS is a baseline.
See the full 12-week program →
Entity options, registered agent and Texas taxes
Physicians choose between a professional association and a PLLC, both filed with the Texas Secretary of State; a PLLC may be formed only by professionals licensed to provide the entity’s service, which is why the ownership question comes first. A PA co-owning with a physician uses the physician’s entity; an NP nursing practice generally files a PLLC or LLC; any MSO is an ordinary LLC. Every Texas entity needs a registered agent with a physical Texas street address.
Texas has no personal income tax. The state-level cost is the franchise tax, a margin tax filed by May 15 each year. For reports due in 2026 and 2027 the no-tax-due threshold is $2.65 million in annualized revenue, so a new practice typically owes nothing in year one, though the Public Information Report is still filed; above the threshold the rate is generally 0.75 percent of margin. Treat these as typical figures to confirm with a Texas CPA.
Labs and pharmacy in Texas
Texas is generally listed among the states that permit direct-access laboratory testing, and the national laboratories run direct-to-consumer programs there; individual labs set their own policies, so confirm with the one you use. In a cash-pay hormone model the clinic orders the panel under its own lab account, the patient walks into a nearby draw site, and results flow back into the EHR.
The pharmacy detail that trips new practices up is nonresident licensing. A compounding pharmacy outside Texas that ships to Texas patients must hold a Texas State Board of Pharmacy nonresident license: Class E for non-sterile preparations and Class E-S for sterile preparations, which includes injectable testosterone. Ask any pharmacy for its Texas license number and class before routing the first prescription, and keep a Texas-based 503A compounder as a backup.
Texas at a glance
| Item | Texas (confirm with the board or counsel) |
|---|---|
| NP practice authority | Restricted; physician delegation under a PAA; Schedule III–V; no independent practice as of 2026 |
| PA model | Supervising physician registered with the Medical Board; PAA for prescribing; physician-PA co-ownership recognized |
| Corporate practice of medicine | Strong; physician-owned PA or PLLC; MSO for non-clinical ownership |
| Telehealth registration | None; full Texas license required; IMLC for physicians; NLC covers RN only |
| In-person exam before prescribing | Not required by statute; federal controlled-substance rules still apply |
| State controlled-substance registration | None since September 1, 2016; DEA registration only |
| PDMP check | Mandatory for opioids, benzodiazepines, barbiturates, carisoprodol; recommended for all controlled prescriptions |
| Direct-to-consumer labs | Generally permitted; lab policies govern |
| State tax | No personal income tax; franchise tax with $2.65M no-tax-due threshold for 2026–2027 reports |
The 12-week Clinic In A Box map applied to Texas
Clinic In A Box™ is a private, 1-on-1, done-with-you 12-week build led by an operator-mentor who runs active telemedicine clinics in the US, Colombia and Australia. The Texas items land in the weeks shown.
- Weeks 1–4, Foundation. Niche and patient avatar; ownership model (physician-owned entity, PA co-ownership, NP nursing practice or MSO) settled with counsel; entity filed and registered agent named; Texas license confirmed and any multi-state pathway started; delegating or supervising physician identified, PAA drafted and Medical Board registration queued; DEA registration and NPI; HIPAA framework, BAAs, and an EHR with EPCS and Texas consent language.
- Weeks 5–8, Operations. Intake and telemedicine consent built to Chapter 111; the 72-hour PCP-report workflow; monthly QA meeting and chart-review cadence calendared; lab account opened and Texas draw sites mapped; compounding pharmacies vetted by Texas license class; Schedule III refill-consultation step built into prescribing; cash-pay service menu, subscription option and payment processing live.
- Weeks 9–12, Launch. Patient acquisition for Texas metros and rural counties (Google Business where eligible, referrals, organic search); soft launch and first patients seen; revenue and retention tracking; a 90-day roadmap including the franchise-tax calendar and the annual PAA review.
By week 12 the practice has a compliant Texas entity, a registered delegation, a configured EHR, lab and pharmacy relationships, a priced service menu and its first patients. Read the telemedicine hormone clinic compliance guide for the national layer under these Texas rules, and how to start a telemedicine hormone clinic for the full sequence. Texas NPs can start with the nurse practitioner practice startup program page; physicians should read the physician telemedicine practice launch program page. The investment is $10,000 for two hours a week of direct work plus messaging between sessions; details are on the Clinic In A Box™ program page.
Frequently asked questions
Can a nurse practitioner open a telemedicine hormone clinic in Texas without a physician?
No. Texas requires physician delegation for prescribing and other medical acts, documented in a prescriptive authority agreement registered with the Texas Medical Board. An NP can build and operate the business, but a delegating physician, monthly quality-assurance meetings and an annual agreement review are part of the model; whether the NP owns the clinical entity directly or uses an MSO is a question for Texas counsel.
Does Texas require an in-person visit before prescribing testosterone by telemedicine?
Texas statute does not require an in-person exam when care is delivered by audio-video or store-and-forward technology and the standard of care is met. Testosterone is a federally controlled Schedule III drug, so federal telemedicine prescribing rules also apply and have changed several times; confirm the current federal position and the Medical Board’s Chapter 175 rules before prescribing.
Do I need a Texas controlled-substance registration in addition to my DEA number?
Not as of 2026. Texas eliminated the Department of Public Safety controlled-substance registration effective September 1, 2016, and did not replace it. You need a DEA registration tied to your Texas practice address, the relevant Texas license and, for NPs and PAs, a registered delegation. Confirm with the Texas State Board of Pharmacy.
Can I treat Texas patients from another state?
Only with a full Texas license and, for NPs and PAs, a Texas delegation. Texas has no general telehealth registration for out-of-state practitioners, and the Medical Board’s limited out-of-state telemedicine license does not cover ongoing treatment. Physicians licensed elsewhere can use the Interstate Medical Licensure Compact; APRNs apply to the Texas Board of Nursing directly.
Request your free info session
The next step is a free 30-minute info session covering your credential, your Texas licensing and delegation situation, your timeline and whether this is the right vehicle. Either way you leave with a clearer picture of what to do next. Call 844-734-2112 or use the form below.