Can Physical Therapists Recommend TRT, GLP-1s, or Peptides? What Scope of Practice Actually Says

Information current as of September 2026. This is general information, not legal advice, and isn't a substitute for reviewing your own state's PT practice act. This post is not published -pending legal and compliance review.

These three categories come up constantly in Physical Therapy clinics right now: testosterone replacement therapy (TRT), GLP-1 medications like semaglutide and tirzepatide, and recovery peptides like BPC-157. The honest answer isn't the same for each one since they sit in three different regulatory categories. Here's what actually separates them, and what a PT can do with each one today.

No state gives PTs prescriptive authority, full stop, for anything. This post is about the layer underneath that: even short of prescribing, how much can a PT say about each of these three categories before it stops being education and starts being something else?

The throughline: counseling, not prescribing, no matter the category

The American Physical Therapy Association's (APTA) own position on pharmacotherapeutics frames the PT's role in a client's medication picture as counseling — "counseling patients and clients on the need for, and the benefits and risks of, medication, and supplements" - not selecting or directing specific drug therapy.

That single sentence is the filter to run TRT, GLP-1s, and peptides through. Does what you're telling a client sound like general education on risk and benefit, or does it sound like you're the one deciding what they should be on? The latter can raise practicing-medicine-without-a-license questions, regardless of which of the three drugs is involved — this is our own reasoning about where that line likely falls, not a citation to a specific statute, and it's worth having counsel confirm for your states.

TRT: the one with a hard regulatory wall, not just a scope question

Testosterone is a Schedule III controlled substance under federal law. That's not a gray area - it's classified alongside other anabolic steroids specifically because of documented abuse potential, and it comes with real prescribing mechanics: prescriptions are capped at five refills or six months from the write date, whichever comes first (21 CFR 1306.22), and remote prescribing currently depends on a DEA telemedicine flexibility confirmed through December 31, 2026 under the DEA's fourth temporary extension (effective January 1–December 31, 2026, per the Federal Register), which could tighten back to requiring an in-person exam if it isn't extended again.

Beyond the controlled-substance status, TRT sits outside a PT's clinical lane in a way the others don't. It's endocrine management - hypogonadism, delayed puberty, certain cancers, AIDS-related wasting, gender-affirming care - not movement or musculoskeletal function. A PT can absolutely notice something worth flagging (fatigue, strength loss, mood changes affecting a client's participation in their plan of care) and suggest the client discuss it with a physician. That's a referral, and referrals don't require special authority. What a PT shouldn't be doing is recommending TRT specifically as the treatment, or discussing dosing, protocols, or brand preferences — that's a physician's call from evaluation through management, not a PT's to make even informally.

GLP-1s: not controlled, but still outside the PT's information lane

Semaglutide and tirzepatide (Ozempic, Wegovy, Mounjaro, Zepbound) are not DEA-controlled substances, so the legal mechanics are simpler than TRT's. But "legal to discuss" and "within PT scope to recommend" aren't the same question.

APTA has a specific position on this adjacent territory: PTs' role in diet and nutrition is "to screen for and provide information on diet and nutritional issues." Screen and inform - that's the ceiling. Nothing in that position extends to weight-management medication.

A PT is on solid ground when they tie a client's weight to something in the plan of care they're already running - how it's affecting joint load, gait, or recovery speed. Recommending a specific GLP-1 medication for weight loss is different. That's really the job of a weight or nutrition coach, or a metabolic-health provider - not a PT's clinical lane, even when they're treating the same client.

The practical version: keep it tied to function. "Your weight is adding load I think is slowing your knee's recovery, that's worth a conversation with a physician" is defensible PT reasoning. "You should be on Zepbound" isn't yours to say.

Peptides like BPC-157: the regulatory ground is still moving

This is the newest and least settled of the three, on two separate fronts.

The compound's own legal status is unresolved, and is still in motion. BPC-157 has no FDA approval for any human use. In April 2026, the FDA removed it from the agency's "Category 2" safety-flagged list, and on July 23–24, 2026, the FDA's Pharmacy Compounding Advisory Committee went further, narrowly voting (8–6, with one abstention) to recommend BPC-157 for the 503A Bulk Drug Substances List - the list that would make it legally eligible for compounding. That vote notably overrode FDA's own staff scientists, who had recommended against it specifically because there's effectively no human clinical safety data on the compound.

None of that makes it legal yet. A compounding advisory committee's recommendation is nonbinding — the FDA still has to run a full notice-and-comment rulemaking process (a proposed rule, a public comment period, then a final rule) before any pharmacy can legally compound it for a patient, and that process typically takes 12 to 24 months. Until a final rule lands, BPC-157 remains outside the 503A/503B safe harbor, and any clinic or pharmacy dispensing it now is doing so without that legal cover, exposed to unapproved-new-drug and misbranding issues under federal law. That's true independent of who referred the client - it's a question for whichever physician or pharmacy is actually handling the compound, not something a PT's involvement changes.

Scope-of-practice for even discussing it is genuinely untested. Recovery peptides are conceptually closer to a PT's actual clinical territory than TRT or GLP-1s the pitch is tissue healing tied directly to an injury a PT is already treating, which is a more natural extension of "this topical would support what I'm doing" than a hormone or weight-loss conversation is. But closer isn't cleared. There's no APTA position statement on peptides, no state PT board guidance addressing BPC-157 or similar compounds specifically, and no case law testing where the line falls. Anyone telling you definitively that PTs can or can't discuss it is overstating what's actually settled.

What this means day to day

Across all three, the pattern holds: education and referral are yours, direction and recommendation aren't. Concretely, a PT stays on solid ground by:

• Noting what you observe (a client mentions low energy, a plateau, or an injury that isn't healing on the expected timeline)
• Explaining general risk/benefit in the way APTA's own policy describes, without picking a specific drug or dose
• Tying anything you flag to the plan of care you're actually running, not a general wellness recommendation outside it
• Referring to a physician for anything that reads as diagnosis or treatment selection — TRT and GLP-1s always, peptides until the compound and the conversation both have clearer legal footing

The newest of these three - peptides - is moving fast enough that anything written about it today is a snapshot, not a permanent answer. If your practice is building a referral workflow around any of these categories, that's a conversation for a healthcare regulatory attorney who can look at your specific state's practice act.

How Doc Connect closes the gap

Whatever a PT flags for physician review, the mechanism is the same, and it's the actual gap a platform like this exists to close. You document what you're seeing in the client's plan of care and submit it through your dashboard. A physician licensed in that client's state reviews it independently - asks follow-up questions if needed, decides whether to write it, and signs. You never prescribe at any point in that process; a licensed physician does, after their own review, the same way they would in an office visit. What changes is where that review happens: from your dashboard, tied to the chart you're already keeping, instead of sending the client out to find and wait on a physician who's never seen them.

Today that covers non-controlled medications and the common supportive therapies a reviewing physician can sign off on from a chart review - the anti-inflammatories and topicals most plans of care actually depend on. TRT, GLP-1s, and peptides each carry their own regulatory footing, as the sections above lay out, and each gets evaluated on its own before it's opened up rather than folded in as a blanket "we handle everything outside your scope." That's a slower way to grow the list, but it's the one that keeps the audit trail and the physician's signature meaning what they're supposed to mean.

Frequently asked questions

Can a physical therapist recommend TRT to a client?

A PT can flag signs worth a physician's attention and suggest the client bring it up — that's a referral, not a recommendation. Recommending TRT specifically, including dosing or protocol, falls to the prescribing physician, both because it's a Schedule III controlled substance and because hormone management sits outside PT's clinical scope.

Are GLP-1 medications controlled substances?

No. Semaglutide and tirzepatide are not DEA-scheduled. That removes one layer of restriction, but APTA's own position limits PTs to screening and informing on nutrition, not directing medication choices — so the scope question is separate from the controlled-substance question.

Is BPC-157 legal?

It has no FDA approval for human use. An FDA advisory committee recommended it for legal compounding in July 2026, but that recommendation is nonbinding — the FDA still has to complete formal rulemaking, typically a 12-to-24-month process, before any pharmacy can legally compound it. As of this writing, it remains outside the legal compounding pathway.

Can PTs discuss peptides with clients at all?

General education about what a peptide is and its documented risk profile likely falls within the same counseling lane APTA describes for medication generally. Recommending a specific peptide as treatment is a different, untested question - there's no APTA or state board guidance settling it either way.

Does direct access change any of this?

No. Direct access governs whether a client needs a physician referral to see a PT in the first place. It has no bearing on what a PT can prescribe, recommend, or direct once the client is there.

Sources: APTA — Pharmacotherapeutics and Supplements in Physical Therapist Practice,

APTA — Role of the PT and APTA in Diet and Nutrition,

APTA — Physical Therapist's Scope of Practice,

LegalClarity — Is Testosterone a Controlled Substance?, SingleCare — Is Ozempic a Controlled Substance?,

Holt Law — BPC-157 in 2026: Why Regulatory Limbo Is Not the Same as a Green Light,

AJMC — FDA Panel Backs 6 Peptides for Compounding,

AJMC — 5 Things to Know About the FDA's Peptide Reversal.