Compliance

The rule that lets you prescribe controlled substances with no in-person visit ends December 31, 2026. A final replacement is under White House review. Nobody outside the government has read it.

Three new registrations, one more for every patient state, and a platform definition that reaches companies that never write a prescription. This is the 2025 proposal. The final text is not public.

One in-person evaluation, by the prescriber, before a controlled substance is prescribed online. Seven exceptions. Every extension since 2020 borrowed one, and the loan comes due December 31, 2026.

An infusion clinic and an at-home prescription program are two businesses under two sets of rules. One needs a DEA registration at the address. The other rests on a rule that ends December 31, 2026.

Nobody has been convicted for using video. The convictions and admissions describe a business model: capped visits, pay tied to prescriptions, automatic refills, and non-clinicians setting policy.

A questionnaire reviewed later is a legitimate model in some states, a disciplinary offense in others, and a conditional pathway in most. Two states changed the answer in 2026.

The three-color map is a trade group’s advocacy classification, not law. What binds you are chart review percentages, ratios and mileage. One state just wrote aesthetics out of its pathway.

Practice happens where the patient’s body is, not where your clinician sits. Several states now say it in one sentence. It is the rule that decides which states your brand can actually open.

We opened the rules in seventeen states looking for the twelve-month good faith exam. It is not there. The law ties the exam to the order, and the triggers are events.

A board reads your chart to answer four questions: who examined this patient, what they found, what they ordered, and who carried it out. Washington wrote the checklist into a rule.

Both need a practitioner’s order for a federal reason: one is a prescription drug, the other a prescription device. Who examines and who injects is state law, and few states name either.

An outsourced exam is only as good as the license, the entity, the order and the record behind it. Ten questions, each tied to the rule that makes it matter.