Most of the telehealth regulation conversation in 2026 has been about GLP-1 oversight. Quietly, underneath that, the actual legal infrastructure — who's licensed where, and what a provider can prescribe without ever seeing you in person — has kept shifting too. None of it made headlines the way the secret shopper study did. All of it affects whether the provider you're about to sign up with is even allowed to treat you.
Here's what's actually changed in 2026, and what's still unsettled.
The DEA flexibility got extended again — but it's still temporary
Since the COVID-19 public health emergency, the DEA has allowed telehealth providers to prescribe many controlled substances without a prior in-person visit. That flexibility was supposed to end more than once. It didn't. On December 31, 2025, the DEA and HHS issued a fourth temporary extension, pushing the deadline to December 31, 2026, while the agency continues working on a permanent framework called Special Registration for telemedicine prescribing.
One narrower piece did become permanent in 2025: DEA-registered providers can now prescribe certain Schedule III–V addiction treatment medications, including FDA-approved options for opioid use disorder, via telemedicine without an in-person visit — as long as they check the state's prescription drug monitoring program first. Everything broader than that remains a temporary rule that gets renewed, not a settled policy.
What this means practically
If a provider's model depends on prescribing a controlled substance purely through telehealth, that model is currently legal — but it's legal because of a rule that's been extended four times, not because Congress passed something permanent. Providers who've built real compliance infrastructure treat this as temporary. The ones worth avoiding treat it as guaranteed.
Michigan just left the interstate licensure compact
The Interstate Medical Licensure Compact (IMLC) is the main tool that lets a physician licensed in one state get expedited licensure in others — it's what makes it feasible for a telehealth company to legally treat patients nationwide instead of one state at a time. As of 2025, the compact covered 41 states, including recent additions like Texas and California.
Michigan is now moving the other direction. The state repealed its IMLC participation on March 28, 2025, starting a 12-month withdrawal process that takes effect March 28, 2026 absent further legislative action. It's a reminder that compact membership isn't permanent infrastructure — it's a policy choice that can be reversed, and a provider licensed to treat Michigan patients today may not be able to next year without a separate license.
"Fill out a form" still isn't a legal prescription in most states
This is the rule that matters most for anyone evaluating a telehealth GLP-1, TRT, or hair loss provider: most states do not consider an online questionnaire alone sufficient to establish a real patient-provider relationship, which is generally required before a prescription can be written. Some states go further and require an actual exam — though many explicitly allow that exam to happen over video rather than in person.
In practice, this is exactly the gap the 2026 secret shopper study on GLP-1 telehealth sites found being skipped. A questionnaire that approves everyone who fills it out, with no clinician review behind it, isn't just a quality issue — in a meaningful number of states, it's arguably not a legally adequate basis for the prescription that follows.
New this year: the APRN Compact
A newer interstate compact for Advanced Practice Registered Nurses launched in early 2026 and already links roughly a dozen states. Since nurse practitioners write a large share of telehealth prescriptions, this compact matters as much as the physician-focused IMLC — and it's early enough that coverage is still uneven state to state.
What to actually check before signing up
You generally can't verify a provider's specific state licensure yourself in a few minutes, but you can look for signals that a platform takes this seriously:
- Does the intake ask where you're physically located, not just your billing address? Telehealth law follows the patient's location during the visit, not the provider's.
- Is there any synchronous component — video or live phone — anywhere in the process, or is it purely an asynchronous form?
- Does the platform mention licensure or compact membership anywhere in its about page or terms? Providers with nothing to hide usually say so.
The practice of medicine occurs where the patient is located at the time telehealth technologies are used — not where the provider happens to be sitting.
Providers built around real licensure infrastructure
Both providers below maintain multi-state licensure and build a synchronous or reviewed intake step into their process rather than relying on a form alone.
Providers we've verified maintain broad state licensure
Sesame operates across weight loss, men's health, and women's health with providers licensed across a wide footprint of states, and includes a live consultation step rather than a form-only intake.
See Sesame Care's coverage → Paid linkEden's direct intake pathway includes clinician review rather than automated approval. As with any compounded medication provider, confirm the specific pharmacy licensure for your state before enrolling.
See Eden Health's program → Paid linkThe bottom line
None of this is settled law. The DEA flexibility is renewed, not permanent. Compact membership can be repealed, as Michigan just showed. And the baseline rule — that a questionnaire alone usually isn't enough to establish a prescribing relationship — is exactly the standard the 2026 secret shopper study found being routinely ignored. The providers worth trusting are the ones whose intake process would hold up even if regulators started checking.