1. What does Florida add on top of federal prescribing rules?
Three things that change the day-to-day, and two that change who may do it.
| Rule | Statute | Applies to | What it does to the workflow |
|---|---|---|---|
| PDMP consultation before prescribing | § 893.055(8) | Schedule II–V for any patient aged 16 or over; not Schedule V non-opioids or hospice | A check and a record on every testosterone or phentermine script. Skip it and the maximum is a three-day supply, documented. First violation is a citation, then discipline |
| No Schedule II by telehealth | § 456.47(2)(c) | Schedule II only, with four exceptions | Testosterone (III) and phentermine (IV) are not barred by Florida. Federal rules still govern the in-person question |
| Evaluation in place of a physical exam | § 456.47(2)(b) | All telehealth | An evaluation sufficient to diagnose and treat has to be in the record; the standard of care is the in-person one |
| Two CE hours on controlled substances | § 456.0301(1) | Every Florida-licensed DEA registrant | A two-hour course at each renewal; confirmation submitted with the biennial renewal |
| E-prescribing is mandatory | § 456.42(3) | Any prescriber who maintains an electronic health record system | Prescriptions may only be transmitted electronically, since licence renewal or 1 July 2021; eight narrow exceptions, including hospice and a documented price-comparison benefit |
| APRN autonomy is primary care only | § 464.0123 | Nurse practitioners | Hormone and weight work happens under a protocol with a supervising physician, kept on site |
| APRN Schedule II seven-day cap | § 464.012(6)(a) | APRNs prescribing Schedule II | No effect on testosterone or phentermine; matters only if a programme uses Schedule II stimulants |
Everything else — DEA registration, EPCS, the telemedicine in-person question, compounding, advertising certification, payment processing — is federal or contractual and is the same in Miami as in Dallas. Those are in section 6. The rest of this page is the Florida layer.
The rules on ownership and supervision that sit underneath all of this are in who can own a med spa in Florida; the overview is the five Florida rules.
2. Do I have to check the PDMP for every testosterone prescription?
Yes. Before every one, for every patient aged 16 or over.
Section § 893.055(8) requires a prescriber or dispenser, or a designee of either, to consult the programme — Florida calls it E-FORCSE — to review the patient’s controlled-substance dispensing history before prescribing or dispensing a controlled substance. The exceptions are narrow: Schedule V non-opioid drugs, patients admitted to hospice, and periods when the department declares the system non-operational or it cannot be reached because of a technological or electrical failure.
If the check is not made, the prescriber may not prescribe or dispense more than a three-day supply and must document the reason. A first violation draws a non-disciplinary citation; subsequent ones are disciplinary.
Two workflow consequences. First, a designee may run the check, so a medical assistant can do it — but the record should then show who consulted and when, because the duty sits with the prescriber. Second, this applies to testosterone (Schedule III) and to phentermine (Schedule IV), which many weight programmes still use alongside a GLP-1. It does not apply to semaglutide or tirzepatide, which are not controlled.
3. Can a Florida med spa prescribe testosterone by telehealth?
Florida law does not stop it. Federal law decides whether a prior in-person evaluation is required.
Florida’s telehealth statute bars a telehealth provider from prescribing a controlled substance listed in Schedule II, with four exceptions — treatment of a psychiatric disorder, inpatient treatment at a licensed hospital, a patient receiving hospice services, and a resident of a nursing home (§ 456.47(2)(c)). Testosterone is Schedule III and phentermine is Schedule IV; neither is caught.
The same section sets the standard: a telehealth provider practises within their scope and to the prevailing standard for in-person care (§ 456.47(2)(a)), and need not perform a physical examination where they conduct a patient evaluation sufficient to diagnose and treat (§ 456.47(2)(b)). That evaluation is the thing the chart has to show.
What Florida leaves alone, federal law does not. The Ryan Haight Act and the DEA’s telemedicine flexibilities govern whether a controlled substance may be prescribed without a prior in-person evaluation, and the current flexibility runs to 31 December 2026 — see EPCS and telehealth testosterone in 2026. A provider licensed in another state treating Florida patients by telehealth also needs Florida’s out-of-state telehealth registration under the same section.
4. What can a nurse practitioner prescribe in Florida?
Under a protocol, any drug — including controlled substances once the coursework is on file — with a seven-day cap on Schedule II that does not touch hormone or weight-loss work.
An APRN performs the functions in § 464.012 within the framework of an established protocol maintained at the practice site, under physician supervision. That includes prescribing, dispensing, administering or ordering any drug; prescribing a controlled substance requires the graduate-level coursework the statute specifies. A Schedule II prescription is limited to a seven-day supply, except psychiatric medications prescribed by psychiatric nurses (§ 464.012(6)(a)).
Autonomous practice does not enter into it. Florida’s autonomous registration under § 464.0123 reaches only primary care — family medicine, general pediatrics, general internal medicine — so an APRN prescribing testosterone or a GLP-1 at a med spa is a protocol APRN whatever their registration says. The supervising physician files notice of the protocol with the Board of Medicine within 30 days (§ 458.348(1)), and the PDMP duty applies to the APRN exactly as it does to the physician.
5. What training does Florida require to prescribe controlled substances?
Two hours per renewal, from a named kind of provider, with proof filed.
Section § 456.0301(1)(a) requires every person registered with the DEA and authorised to prescribe controlled substances to complete a two-hour continuing-education course on prescribing controlled substances at each subsequent renewal, offered by a statewide professional association of physicians in Florida accredited for AMA PRA Category 1 credit. Confirmation of completion is submitted with the biennial licence renewal (§ 456.0301(1)(b)).
That is on top of the federal one-time eight hours on treating and managing patients with opioid or other substance use disorders that DEA registrants have had to attest to since 2023. The two are different courses with different providers; clinics that hire a prescriber mid-cycle should check both are current before the first script.
6. What stays federal?
Most of it. Florida is a thin layer on a thick federal one.
DEA registration, currently $888 for three years, and the EPCS requirements of 21 CFR 1311 — identity proofing, two-factor signing, the audited application — are federal and are covered in choosing an EMR with EPCS. The in-person-evaluation question for telehealth is federal, above. Compounded GLP-1s and peptides are governed by the federal 503A and 503B rules and by the FDA’s 2026 narrowing of both, which no state has widened: the 2026 compounding squeeze. Advertising prescription treatments online runs into certification requirements that gate ad spend regardless of state: what LegitScript certification costs. And standard card processors prohibit prescription drug sales in their terms and enforce it retroactively, which is a contract problem, not a Florida one: why processors shut down GLP-1 and TRT clinics.
One Florida-specific non-rule worth stating: Florida does not levy sales tax on cosmetic or medical procedures the way Kentucky does. Retail product sold across the desk is taxable like any other tangible good.
7. What has to be in the chart for a Florida prescription?
Four fields the state can ask for by name, plus the two every board asks for.
The PDMP consultation — who ran it, when, before the script (§ 893.055(8)). The evaluation sufficient to diagnose and treat, in person or by telehealth (§ 456.47(2)(b)). For an APRN script, the protocol it was written under and the supervising physician (§ 464.012(3)). The prescriber’s controlled-substance CE, current at the last renewal (§ 456.0301). And the prescription itself, sent electronically: a Florida prescriber who keeps an electronic record may only e-prescribe (§ 456.42(3)), so a paper script from an EHR-using clinic needs one of the statute’s eight exceptions written down next to it.
Then the two that are not Florida law but are what a complaint turns on: the consent for that treatment on that date, and — for anything injected in the clinic — product, dose and lot per administration. The refill cadence that a weight programme lives on is a scheduling problem as much as a charting one; GLP-1 clinic management software covers what has to sit on one calendar.
What changes at a med spa the day it starts prescribing — oversight, payments, certification, charting, e-prescribing — is the national version of this page: adding weight loss or hormones to a med spa.
8. Frequently asked questions
Does the Florida PDMP rule apply to GLP-1s?
No. Semaglutide and tirzepatide are not controlled substances. § 893.055(8) applies to Schedule II–V, which in a wellness clinic means testosterone and phentermine.
Do I have to check the PDMP for phentermine?
Yes. Phentermine is Schedule IV, the patient is almost always over 16, and none of the exceptions apply.
Can a medical assistant run the PDMP check?
The statute allows a designee of the prescriber to consult the system. The duty stays with the prescriber, so the record should show who consulted and when.
Can I prescribe testosterone by telehealth in Florida?
Florida bars only Schedule II by telehealth (§ 456.47(2)(c)); testosterone is Schedule III. Whether a prior in-person evaluation is required is a federal question — see EPCS and telehealth testosterone in 2026.
What happens if the PDMP check was missed?
No more than a three-day supply may be prescribed or dispensed, the reason must be documented, and a first violation draws a non-disciplinary citation under § 893.055(8).
Does Florida require electronic prescribing?
Yes, for any prescriber who maintains a system of electronic health records: since licence renewal or 1 July 2021, whichever came first, such prescriptions may only be transmitted electronically (§ 456.42(3)). The exceptions include a hardship waiver, technical impossibility, hospice and nursing-home patients, and a documented benefit from comparing pharmacy prices.
Does Florida require a separate state controlled-substance licence?
Florida’s requirements sit on the professional licence — the PDMP duty and the two-hour CE — rather than a separate state registration. Confirm the current position with the Department of Health before relying on it; roughly half of states do require one.