GLP-1 telehealth operations in Texas
Texas is the second-largest compounded GLP-1 market and has been a center for both compounded medication innovation and aggressive Medical Board enforcement. The Texas Medical Board (TMB) has issued multiple disciplinary actions against telehealth GLP-1 prescribers in 2025-2026.
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Texas is the second-largest compounded GLP-1 market and has been a center for both compounded medication innovation and aggressive Medical Board enforcement. The Texas Medical Board (TMB) has issued multiple disciplinary actions against telehealth GLP-1 prescribers in 2025-2026.
Operating rules in Texas
Corporate Practice of Medicine posture: Strict. Good faith exam format: Synchronous audio-visual is required for the initial prescription of compounded medications via telehealth in Texas. The TMB has explicitly disqualified async-only GFE for higher-risk prescribing. In-person follow-up: No universal in-person requirement for compounded GLP-1, but the TMB expects ongoing documented clinical decision-making, not refill-only authorizations. Pharmacy licensure: 503A pharmacies shipping to Texas patients require a Texas State Board of Pharmacy nonresident pharmacy license. 503B outsourcing facilities require separate registration. Nurse practitioner authority: APRNs in Texas require a delegation agreement (prescriptive authority agreement) with a delegating physician for Schedule II-V controlled substances and most prescribing. The agreement must be on file with the Texas Medical Board. Controlled-substance scheduling: Compounded semaglutide is non-scheduled, but Texas has heightened reporting requirements for sterile injectable compounding. Schedule II-V prescribing requires DEA registration and TX-specific controlled substance registration (DPS).
Statutes and rules cited
Tex. Occ. Code §§157.001-157.060 — Physician delegation to APRNs: Establishes the prescriptive authority agreement framework between Texas APRNs and delegating physicians — foundational for NP-staffed GLP-1 programs. Tex. Admin. Code §174.5 — TMB Telemedicine Rule: The Texas Medical Board's telemedicine practice standards, including requirements for an established practitioner-patient relationship before prescribing. Tex. Occ. Code §164.0521 — Texas CPOM prohibition: Prohibits the corporate practice of medicine in Texas — the underlying statute requiring PC-MSO structure for non-physician investors in clinical operations. Tex. Pharmacy Act §551.001 et seq. — Texas State Board of Pharmacy authority: Establishes pharmacy licensure and compounding regulations enforced by the Texas State Board of Pharmacy.