Initiation Criteria
Who qualifies, on what labs, and what has to be ruled out first — approved by your director.
HRT / TRT
Find a Medical Director for HRT and TRT Programs
Hormone programs carry lab work, controlled-substance considerations and long-term follow-up. Direction here is ongoing clinical oversight, not a signature at setup.
Medical Director Oversight
What a Director Actually Signs Off for HRT / TRT
Each of these is a decision your director owns, in writing, before it happens in your clinic.
Controlled Substances
Testosterone prescribing requires the right registration. We map what applies to your clinic and state.
Monitoring Cadence
Follow-up labs and reviews on a schedule that is recorded, not remembered.
Scope Limits
Written referral criteria so complex cases leave your clinic rather than lingering in it.
What We Set Up
Everything Behind a Compliant Hormone Therapy Program
Hormone therapy needs baseline labs, monitoring intervals and clear stop rules — plus the credentials that testosterone prescribing requires.
Standing orders for hormone initiation and monitoring
Baseline and interval lab panels defined per protocol
DEA and controlled-substance requirements mapped for your state
Titration, monitoring and discontinuation rules
Consent, risk discussion and documentation templates
Referral criteria for cases outside your scope
Supply
Where the Product Comes From
FAQ
Questions About HRT / TRT
Still not sure? Twenty minutes on the phone answers what a page can't.
Do I Need a DEA Registration for TRT?
Testosterone is a controlled substance, so a registration is generally required for the prescriber. We confirm what your state and category need before you launch.
Can a Nurse Practitioner Run the Program?
In many states, under delegation and supervision terms set out in standing orders. Those terms are state-specific and we draft them.
What Labs Are Required?
Your protocols define baseline and interval panels. They are written with your director rather than copied from a forum.
How Often Does Monitoring Actually Need to Happen?
On an interval set in your protocol, not left to patient-reported symptoms — follow-up labs and reviews are scheduled and recorded, so a gap in monitoring is visible rather than assumed away.
What If a Patient Needs Care Outside Hormone Therapy?
Your protocol sets referral criteria for anything outside scope, so complex cases leave the clinic on a defined pathway rather than lingering under a program not built to handle them.
Who Is Allowed to Own a Hormone Therapy Business?
Can a non-physician own an HRT or TRT clinic? Not the clinical entity. Hormone programs involve labs, prescribing and in some cases controlled substances — squarely the practice of medicine in every state that applies the doctrine.
That is what the corporate practice of medicine doctrine decides — and it is the single rule that shapes how your business is built. Most states hold that medical judgment belongs to licensed clinicians, so a non-physician or a general corporation may not own or control an entity that practices medicine. The MSO model is the answer the industry settled on.
The Rule
CPOM — Corporate Practice of Medicine
A doctrine in state law, not a company or a service. The professional entity — the PC — must be owned by a licensed physician, and control counts as much as ownership: who hires the clinicians, who sets the fees, who decides what gets treated.
Only a licensed physician may own the professional entity in most states
Control counts too — hiring clinicians, setting fees, directing treatment
Fee-splitting rules limit how the MSO can be paid
Enforcement is by medical boards, attorneys general, insurers and acquirers
The Structure
MSO — Management Services Organization
The company that provides everything a Hormone Therapy clinic needs that is not the practice of medicine, under a written management services agreement with the PC. You can own the MSO outright, whatever your license.
Owned by you, whatever your license — no physician equity required
Holds the brand, lease, staff, systems, supply and marketing
Paid a fair-market management fee, never a cut of clinical revenue
Takes no part in diagnosis, treatment or any clinical decision
How the two meet: a physician-owned PC employs the clinical team and holds the medical decisions; your MSO holds the brand, the lease, the staff, the systems and the supply; a fair-market management fee moves between them; and the line is drawn in writing where your state says it must be. Testosterone scheduling makes the line especially worth drawing carefully here.
Watch
Where the Money Actually Goes
What This Covers
How money actually moves through a PC/MSO structure — patient revenue landing in the PC, the fixed management transfer to the MSO, MedGrid's retainer, and physician compensation — the same CPOM flow of funds covered on this page, walked through step by step.
This isn't just how we recommend running the accounts. In a state that enforces corporate practice of medicine, this exact flow is required to keep a PC structure compliant: revenue lands in the PC first, the MSO is paid a fixed, fair-market amount rather than a share of medical revenue, MedGrid is paid a fixed retainer by the MSO, and the accounts stay separate.
It's also why MedGrid only builds on a PC — never a PLLC — in every state we work in. A PLLC lets revenue flow straight into a member's account with no equivalent separation, which is exactly the structure this flow of funds is built to avoid. Why that distinction matters.
Getting It WrongMistake 01 Mistake 02 Mistake 03 Mistake 04
Four Ways Hormone Therapy Clinics Get Structured Badly
These are the arrangements we most often find in place when a clinic comes to us, usually built in good faith, on advice from someone who had not read the state's rules.
An LLC That Should Be a PC
The clinical entity was formed as a plain LLC owned by a non-physician. In a strict state that is the whole problem, and it usually surfaces at diligence or renewal.
A Director on a Handshake
A physician agreed to "be the medical director" with no management agreement, no delegation document and no standing orders. There is nothing to show a board.
A Fee That Looks Like a Split
The MSO takes a percentage of clinical revenue. Many states read that as fee-splitting regardless of what the contract calls it.
Protocols From a Course
Treatment protocols copied from a training weekend, never adapted to this state or signed by the director who is supposed to own them.
General information about how these structures work, not legal advice for your clinic. Your director and your counsel confirm the specifics before you treat.
Other Modalities We Cover
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Adding Hormone Therapy to Your Menu?
Twenty minutes tells you what direction costs in your state, what has to be on file before the first patient, and how fast you can start.