The TRT Telehealth Industry
Overview of the Online Testosterone Marketplace
Evidence grade 3 of 5, Mixed. Read how the Atlas grades evidence.
The written rationale for this grade is still being prepared.
- FDA
- Testosterone is a Schedule III controlled substance; prescribing regulated by DEA and state boards
Reference only. Not medical advice.
What can go wrong
Exogenous testosterone suppresses the hypothalamic-pituitary-gonadal axis and can impair fertility, cause polycythemia (elevated hematocrit), and produce cardiovascular and prostate-monitoring concerns. The central market-level risk documented in reporting is structural: a recurring-revenue model that financially rewards prescribing and continued refills.
This is something to take to a clinician. The Atlas can tell you what is known about the trt telehealth industry in general. It cannot tell you what is happening in your body, and the difference matters most for exactly the symptoms that bring people to this page.
The online testosterone-replacement-therapy (TRT) market was transformed by COVID-19 telemedicine deregulation, which temporarily waived the DEA's in-person evaluation requirement for prescribing controlled substances. A 2023 study identified 223 online TRT clinics; STAT News (November 2025) reported an estimated 325+ new multi-location clinics with an online presence opening since early 2024. The dominant business model is a recurring subscription combining monthly fees, marked-up medication, and monitoring services. Reporting and peer-reviewed work have raised concern that this model creates a financial incentive to prescribe.
How COVID deregulation turned testosterone into a subscription.
What people take it for
These are the reasons people give for taking it. They are not effects it has been shown to have.
How it is supposed to work
Telehealth TRT platforms connect a consumer to a remote clinician, order labs, and (where criteria are stated to be met) prescribe testosterone or off-label alternatives such as enclomiphene, fulfilled by a partner or compounding pharmacy. Revenue recurs monthly so long as the prescription continues.
The incentive the marketing skips
Because revenue recurs monthly, continued prescribing is the financial default. A mystery-shopper study by urologist Justin Dubin and colleagues (published in JAMA Internal Medicine in 2023; data collected 2022) found that 6 of 7 online TRT clinics offered to prescribe testosterone to a standardized 34-year-old patient who reported low energy and low libido but had normal total and free testosterone and stated a desire for future fertility, guidelines advise against testosterone in this scenario, since exogenous testosterone suppresses spermatogenesis.
Safety in detail
TRT involves significant physiological effects and requires evaluation and ongoing monitoring by a qualified physician. Self-administration without medical oversight carries documented health risks including polycythemia, infertility, and cardiovascular concerns.
What it does to fertility
Exogenous testosterone suppresses LH/FSH and spermatogenesis and can cause infertility; guidelines advise against starting TRT in men seeking fertility. The Dubin mystery-shopper finding centers on platforms offering to prescribe despite this contraindication in a patient with normal testosterone who wanted future fertility.
What has to be monitored
The bloodwork this needs, and the reason it belongs with a clinician rather than a website.
- Total and free testosterone
- Hematocrit/hemoglobin
- PSA (age-appropriate)
- Estradiol
- Lipids and metabolic panel
What people get wrong
Nothing recorded here yet. There is almost certainly something people get wrong about this one, and the blank space means we have not written it down, not that the record is clean.
Who profits, and who pushes back
Justin Dubin, MD
In a mystery-shopper study (JAMA Internal Medicine, 2023), 6 of 7 online TRT clinics offered to prescribe testosterone to a patient with normal testosterone who stated he wanted future fertility, guidelines advise against testosterone in this scenario.
Platforms profit from recurring monthly subscriptions, medication markup (KFF: ~50x over Medicare ASP), and monitoring fees. Compounding pharmacies, lab partners, and franchise pellet companies capture additional margin.
Set against the alternatives
Compared with conventional urology or endocrinology care, telehealth TRT compresses access to days and removes the in-person exam, which COVID-era waivers made legally possible for a Schedule III drug. The structural difference is incentive alignment: a recurring subscription that bundles the visit, marked-up medication, and monitoring earns revenue only while the prescription continues, which reporting and peer-reviewed work argue can bias toward initiating and maintaining therapy. Against enclomiphene-first competitors, injectable-TRT platforms offer the FDA-approved drug class but suppress fertility, whereas enclomiphene preserves spermatogenesis at the cost of being off-label. Against in-person clinics, telehealth wins on convenience and price transparency but is weaker on longitudinal monitoring and diagnostic rigor.
| Model | What is prescribed | Revenue driver | Key concern |
|---|---|---|---|
| Subscription TRT | Injectable / topical testosterone | Recurring fee + marked-up drug | Incentive to prescribe / continue |
| Enclomiphene-first | Off-label SERM | Monthly subscription | Off-label, not FDA-approved |
| Compounding-pharmacy model | Compounded testosterone / hCG | Bundled fulfillment | Variable oversight and quality |
| Traditional in-person | Testosterone after exam | Insurance / visit-based | Slower access, more gatekeeping |
What we do not know
- Does the subscription model measurably increase inappropriate or over-prescribing of testosterone?
- What monitoring cadence is actually achieved by online clinics versus guideline recommendations?
- How will the post-waiver DEA framework (expiry currently set for December 2026) reshape access?
- Are off-label enclomiphene prescriptions adequately disclosed and counseled to patients?
- What are the long-term cardiovascular and fertility outcomes of telehealth-initiated TRT cohorts?
What could change
Permanent telehealth rulesFinal DEA/HHS controlled-substance prescribing framework after waiver expiryEnclomiphene growthFertility-sparing off-label SERM marketed as a TRT alternativeAt-home diagnosticsMail-in and point-of-care labs tightening or loosening the prescribing funnelRegulatory scrutinyHeightened attention to incentive-driven prescribing and advertising claimsGLP-1 cross-sellTRT platforms layering weight-loss and metabolic offerings onto subscriptions
At a glance
- 2023 clinic count
- 223 online TRT clinics (peer-reviewed study)
- New clinics since 2024
- 325+ (STAT News, Nov 2025)
- Telemedicine waiver expiry
- Currently set to expire December 2026
- Markup (KFF 2024)
- ~50x ($1.55/mg vs $0.027/mg Medicare ASP)
What this entry does not yet cover
What follows is unfinished work on our side, not a finding about The TRT Telehealth Industry. A short entry is not a safe entry.
- Cost and market. We have not documented what it sells for or who sells it.
- Supply chain. We have not mapped where it is made.
- Who uses it. We have not documented the user groups.
- Children and teenagers. We have not checked what is known about younger people.
Sources
No sources recorded for this entry yet. Nothing on this page can be checked against a citation until that changes, so treat it as a summary awaiting its evidence.