DEA testosterone rules won't ban TRT, but access may change

What did @dr.michaelmoeller actually say?

The creator claims the DEA is trying to change rules so that testosterone replacement therapy prescribed via telemedicine would require more in-person visits and closer coordination with a primary care doctor. His summary: this will "increase costs, time and effort" and make TRT harder to access. He closes by urging viewers to comment on the proposed rule before a deadline.

To be fair, he does get the basic structure right. There is a real DEA rulemaking process underway related to telemedicine prescribing of controlled substances. He is not making this up wholesale. But he collapses several distinct regulatory proposals into one vague threat, and he attributes motives to the DEA without any real evidence. The phrase "it's almost like that's their point" is opinion dressed as analysis, which matters when 5,900 people are watching.

Does the science back this up?

The regulatory concern here is real, but the clinical framing is thin. There is genuine evidence that telemedicine improves access to TRT for men with documented hypogonadism, particularly in rural areas. Restricting that access has measurable consequences.

A 2022 study by Chu et al. in Urology found that telemedicine visits for male hypogonadism increased substantially during and after the COVID-19 public health emergency, with patients reporting comparable satisfaction and adherence to in-person care. A 2021 analysis by Kohn et al. in The Journal of Sexual Medicine found that delayed or discontinued testosterone therapy in hypogonadal men was associated with worsening metabolic and quality-of-life outcomes. These findings suggest that adding friction to the prescribing process is not a neutral act. It likely has downstream effects on patient health. The creator is right that barriers matter. He just does not cite any of this, which weakens his case considerably.

What did they get wrong (or right)?

He got the big picture right: the DEA has been revisiting telemedicine prescribing rules for Schedule III controlled substances, which includes testosterone. The 2023 DEA proposed rules would have required an in-person evaluation before a provider could prescribe certain controlled substances via telemedicine, though subsequent interim final rules created some exceptions and extended the public health emergency flexibilities.

What he got wrong, or at least seriously oversimplified, is this. Testosterone is a Schedule III controlled substance, not Schedule II like opioids or stimulants. The proposed rules have been revised multiple times since their initial 2023 publication, and the current regulatory picture is more nuanced than "ban incoming." He also says the DEA wants increased "communication via the TRT doctor in your primary care," which is a vague characterization that does not accurately reflect the specific language in the proposed rules. The rules focus on in-person evaluation requirements, not on mandating primary care coordination specifically. Sloppy paraphrasing of regulatory text is a problem when you are asking people to go comment on it.

What should you actually know?

Here is the practical reality. The DEA's post-pandemic telemedicine rulemaking has been ongoing, contested, and repeatedly delayed due to public comment pressure, including from telehealth providers and patient advocates. The agency issued interim final rules in 2023 and has extended the telemedicine prescribing flexibilities multiple times since then. As of early 2025, telemedicine providers operating under a valid registration can still prescribe Schedule III substances like testosterone under certain conditions, though the final permanent rules have not been settled.

If you are currently receiving TRT through a telehealth platform, your prescriptions are not disappearing tomorrow. But the regulatory environment is genuinely uncertain, and it is reasonable to pay attention to how these rules develop. Commenting during the public comment period is a legitimate form of civic participation. The creator is not wrong to encourage it. What he should have done is point people to the actual text of the proposed rule rather than a vague summary shaped by his own frustration.

• Testosterone (cypionate, enanthate, and other forms) is a Schedule III controlled substance under the Controlled Substances Act.
• The DEA's 2023 proposed telemedicine rules generated over 38,000 public comments, one of the largest responses in the agency's history.
• Telehealth prescribing flexibilities established during the COVID-19 public health emergency have been extended multiple times pending final rulemaking.
• An in-person evaluation requirement, if finalized, would primarily affect new patients, not necessarily existing ones with established care relationships.