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

Information current as of October 2026. This article is general information, not legal, medical, or compliance advice, and it isn't a substitute for reviewing your own state's PT practice act with an attorney.

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. Clients ask about all three. The honest answer isn't the same for each one, because they sit in three different regulatory categories, and treating them as interchangeable is where PTs get into trouble. Here's what separates them, and what a PT can do with each one today.

This builds on our earlier piece on what APTA's scope of practice says about prescribing medication generally. The short version: our research found no state that gives PTs independent prescriptive authority. 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) 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." It doesn't describe selecting or directing specific drug therapy.

That 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 second can raise practicing-medicine-without-a-license questions regardless of which drug is involved. That's our reading of where the line likely falls, not a citation to a specific statute, and it's worth confirming with counsel for the states you practice in.

TRT: a hard regulatory wall, not just a scope question

Testosterone is a Schedule III controlled substance under federal law. It's classified alongside other anabolic steroids because of documented abuse potential, and it comes with real prescribing mechanics. Prescriptions are capped at five refills or six months from the date written, whichever comes first (21 CFR 1306.22). Remote prescribing of controlled substances currently relies on a DEA telemedicine flexibility that runs through December 31, 2026 under the fourth temporary extension published in the Federal Register. If it isn't extended again, rules requiring an in-person exam could come back into effect.

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, like fatigue, strength loss, or mood changes affecting a client's participation in their plan of care, and suggest the client discuss it with a physician. Suggesting someone see a physician doesn't require special authority. What a PT shouldn't do is recommend TRT specifically as the treatment, or discuss dosing, protocols, or brands. 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 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 position on the adjacent territory: the PT's 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, such as how it's affecting joint load, gait, or recovery speed. Recommending a specific GLP-1 medication for weight loss is different. That's a prescriber's call, not a PT's, even when they're treating the same client.

The practical version: keep it tied to function. "Your weight is adding load that I think is slowing your knee's recovery, and 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. 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. 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 eligible for legal compounding. That vote went against FDA's own staff, whose briefing document for the meeting recommended that BPC-157 not be added.

None of that makes it legal yet. An advisory committee's recommendation is nonbinding. The FDA still has to complete 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, and that process typically takes 12 to 24 months. As of this writing, no proposed rule has been published. Until a final rule lands, BPC-157 remains outside the 503A/503B compounding pathway, and regulatory attorneys have warned that clinics and pharmacies dispensing it now may be exposed to unapproved-new-drug and misbranding issues under federal law. That's a question for whichever physician or pharmacy handles the compound, and a PT's involvement doesn't change it.

Scope of practice for even discussing it is untested. Recovery peptides are conceptually closer to a PT's clinical territory than TRT or GLP-1s: the pitch is tissue healing tied directly to an injury a PT is already treating. But closer isn't cleared. Our research found no APTA position statement on peptides, no state PT board guidance addressing BPC-157 or similar compounds, and no case law we could identify on where the line falls. Anyone telling you definitively that PTs can or can't discuss it is overstating what's settled.

What this means day to day

Across all three, the pattern holds: education and flagging for a physician are yours; direction and recommendation aren't. 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 and benefit the way APTA's 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
• Sending anything that reads as diagnosis or treatment selection to a physician: TRT and GLP-1s always, and peptides until both the compound and the conversation have clearer legal footing

Peptides in particular are moving fast enough that anything written about them today is a snapshot, not a permanent answer. If your practice is building a workflow around any of these categories, that's a conversation for a healthcare regulatory attorney who can look at your state's practice act.

How Doc Connect fits

Whatever a PT flags, the mechanism is the same. You document what you're seeing in the client's plan of care and submit it through your dashboard for physician review. A physician licensed in the client's state conducts their own evaluation, including any follow-up questions they need answered, and decides whether to prescribe anything, and what. You never prescribe at any point. The physician does, under their own license, after their own independent review. What changes is where that review starts: from your dashboard, tied to the chart you're already keeping, instead of the client starting over somewhere else.

Today that covers non-controlled medications and common supportive therapies within the reviewing physician's scope, like the anti-inflammatories and topicals many plans of care depend on. TRT, GLP-1s, and peptides each carry their own regulatory footing, as the sections above lay out. Each gets evaluated on its own before it's offered, 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 them up with a doctor. Recommending TRT specifically, including dosing or protocol, falls to the prescribing physician, both because testosterone is 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 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 role APTA describes for medication generally. Recommending a specific peptide as treatment is a different and untested question; we found 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's 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.

Disclaimer: This article is general information for physical therapy practices. It is not legal, medical, or compliance advice and does not account for the practice act in your state. Content is current as of October 2026; parts of it, especially the peptide section, describe a fast-moving federal process and may be out of date by the time you read this. Talk to a healthcare regulatory attorney before making clinical workflow or business decisions based on it.

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; eCFR: 21 CFR 1306.22; LegalClarity: Is Testosterone a Controlled Substance?; SingleCare: Is Ozempic a Controlled Substance?; Federal Register: Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications; FDA: Pharmacy Compounding Advisory Committee, 2026 meeting materials; FDA: Briefing Document, Pharmacy Compounding Advisory Committee; ABC News: FDA advisory committee votes to add popular peptide BPC-157 to drug compounding list; RAPS: FDA advisory committee backs two controversial peptides; AJMC: FDA Panel Backs 6 Peptides for Compounding; Holt Law: BPC-157 in 2026: Why Regulatory Limbo Is Not the Same as a Green Light; Buchanan Ingersoll & Rooney: FDA Voted Yes on Six Peptides: Now What?