How transmen testosterone access advocacy can protect current TRT telemedicine access for all men.

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Nelson Vergel

A new proposed rule may complicate access of TRT products via telemedicine.
Testosterone is a Schedule 3 controlled substance.

Under the Ryan Haight Online Pharmacy Consumer Protection Act of 2008 and Drug Enforcement Administration’s (DEA) implementing regulations, after a patient and a
practitioner have had an in-person medical evaluation, that practitioner may use telehealth to prescribe that patient any prescription for a controlled medication that the practitioner deems
medically necessary. The Ryan Haight Act and DEA’s implementing regulations do not apply to other forms of telemedicine, telehealth, or telepsychiatry that are not otherwise
addressed in the Controlled Substances Act. This proposed rule applies only in limited circumstances when the prescribing practitioner wishes to prescribe controlled medications via the practice of telemedicine and has not otherwise conducted an in-person medical evaluation prior to the issuance of the prescription.

The Drug Enforcement Agency and the Department of Health and Human Services last month announced a proposed rule to loosen some of the in-person prescription requirements once the health emergency ends, in May.

  • Providers could make an initial 30-day prescription through telemedicine, but would then require an in-person visit.
  • The agency is also proposing an option for patients to see a DEA-registered practitioner who could then make a referral to a provider who can continue treatments via telehealth.

Believe it or not, access to gender affirming TRT may become one of the main arguments against the proposed new regulations.

Read here:

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Defy Medical TRT clinic doctor

Nelson Vergel

From ChatGPT:

The proposed rule by the Drug Enforcement Administration, published under docket number DEA-407 and RIN 1117-AB40, concerns the prescribing of controlled substances via telemedicine. Specifically, the rule addresses situations where the practitioner and patient have not had an in-person medical evaluation prior to the telemedicine encounter. The rule proposes several amendments to existing regulations under 21 CFR Parts 1300, 1304, and 1306 to provide greater clarity and flexibility for telemedicine prescribing practices while ensuring the prevention of diversion and abuse of controlled substances. The proposed changes include requirements for telemedicine practitioners to comply with state and federal telemedicine laws, record-keeping and reporting requirements, and use of secure electronic communication methods for telemedicine consultations.


Active Member
This is a huge issue. I think the only reason we haven't heard more outcry from the trans community is the short timeframe of this DEA proposed rule change.

Think about this: if you're a trans man and you're living in a place without many (or any) trans-friendly healthcare providers, what are you supposed to do?

The proposed DEA rule will completely end access to telemedicine HRT in this scenerio. The trans person would need to find a local provider who would be willing to work closely (and with complex process) with a telemedicine provider of HRT.

But many trans people who use telemedicine do it *because* they cannot access HRT locally due to a lack of knowledgable or pro-trans providers. The only workaround would be travel to a potentially far-away provider before initiating telemedicine, a fantasy for many lower or medium income trans people.

This would be a disaster for trans healthcare and I'm surprised we haven't seen more outrage.


Active Member
Collecting some trans community info / postings as I find them.

Here's one from a trans telemedicine company:

"Act now to protect transgender health care access"Plume – Gender-Affirming Hormone Therapy From Anywhere
Act now to protect transgender health care access

Good instagram post from TransLash Media:

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Nelson Vergel

I know many men feel very strong reactions against trans people. But this minority actually may help them.

It comes full circle since Biden as a senator was one of the loudest voices advocating for the Scheduling of testosterone even against the advice of the DEA and CSA group. Now he has a chance to reverse this legislative error that has caused harm


Well-Known Member
What a shame a very small group has more influence in our government than the millions or men and women who use TRT, as well as a large part of our medical community, not to mention the countless scientific support. But I guess we need all the help we can get. So much for the Lincoln's concept of a government of the people, for the people and by the people, huh?

But let's look at reality and see what kind of ignorant emotional believes we are up against in Congress. Here is a quote from then Sen. Joe Biden in 1990, “The illegal use of anabolic steroids is a major drug abuse problem in this country. Steroids are dangerous drugs that threaten the physical and mental health of hundreds of thousands of young people.” Pretty ill-informed even in 1990. How many others in Washington DC have this same attitude even today? Imagine, that same year we started handing opiates out like candy

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Active Member
I'm seeing more discussion now in online trans communities. Here's an article I saw just today:

Unfortunately many of these posts miss the critical reason why this is particularly bad for trans people taking testosterone: if these rules were in place, the trans person would need to find a local provider who is completely okay with their trans therapy OR see their telemedicine provider in person.

I imagine that one of the reasons trans people seek out telemedicine is that they can't find a local provider who is supportive of their therapy.
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Kyle Butler

I know many men feel very strong reactions against trans people. But this minority actually may help them.

Reminds me of an old quote. The enemy of my enemy is my friend.
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