California has enacted a significant change to its controlled substance reporting framework under Assembly Bill 82 (AB 82). Effective January 1, 2026, prescriptions for testosterone and mifepristone are no longer reportable to the state’s Prescription Drug Monitoring Program (PDMP), known as CURES (Controlled Substances Utilization Review and Evaluation System).

For clinics prescribing hormone therapy, men’s health services, reproductive medicine, or related treatments, this change materially affects compliance workflows and risk management.

This is not a repeal of CURES. It is a targeted reporting carve-out with operational consequences.

Below is what you need to know.

What AB 82 Actually Does

Under AB 82:

• Prescriptions and dispensations of testosterone may no longer be reported to CURES.
• Prescriptions and dispensations of mifepristone may no longer be reported to CURES.
• The California DOJ must remove previously reported records of these medications from the CURES database no later than January 1, 2027.

All other controlled substance reporting, recordkeeping, registration, and storage requirements remain fully intact.

Testosterone remains a Schedule III controlled substance under federal law. What changed is California’s state-level reporting requirement to its PDMP database. DEA audits remain possible.

Why This Matters for TRT Clinics, Med Spas, and Physicians

For practices operating in:

• Testosterone Replacement Therapy (TRT)
• Men’s health and wellness
• Longevity and hormone optimization
• Reproductive medicine
• Aesthetic or integrative clinics offering hormone services

This change directly affects:

• PDMP querying expectations
• Reporting software integrations
• Pharmacy compliance
• Internal audit procedures
• Risk exposure analysis

Previously, testosterone prescriptions were visible in CURES reports when prescribers reviewed a patient’s controlled substance history. That will no longer be the case.

This creates both:

• Reduced data visibility in PDMP reviews
• Heightened responsibility for internal prescribing oversight

What This Does NOT Do

AB 82 does not:

• Declassify testosterone as a controlled substance
• Eliminate DEA requirements
• Remove federal reporting obligations
• Authorize non-compliant prescribing
• Change supervision rules for NPs or PAs
• Modify corporate practice of medicine restrictions
• REMS requirements (for mifepristone)

If you store and prescribe testosterone or mifepristone, you are still subject to:

• DEA oversight
• Medical Board scrutiny
• Scope-of-practice limits
• Standard of care requirements
• Recordkeeping rules
• Telehealth regulations

The exception from CURES reporting should not be interpreted as a relaxation of enforcement risk.

Risk Analysis: What Changes Operationally

1. PDMP Review Gaps

Because testosterone prescriptions will not appear in CURES, physicians reviewing PDMP reports will not see a complete hormone prescribing picture through that system.

Practices should consider:

• Whether to implement enhanced internal chart review processes
• Whether to adjust intake questionnaires
• Whether to update patient attestation forms

2. Multi-Provider Coordination

Without PDMP reporting visibility, practices should ensure they:

• Ask patients directly about outside hormone prescriptions
• Document cross-provider prescribing disclosures
• Clarify refill and monitoring protocols

3. Software & Reporting Systems

Many EHRs auto-report controlled substances to CURES.

You should confirm:

• Your EHR vendor has updated reporting protocols
• Testosterone is no longer being auto-submitted
• Internal compliance teams understand the reporting change

Over-reporting can be as problematic as under-reporting.

Strategic Takeaway for Clinics

AB 82 reflects a broader policy trend toward tightening control over how sensitive prescription data is stored and accessed.

For compliant clinics, this is not a loophole.

It is a signal that:

• Documentation matters more than database reporting.
• Internal compliance systems must be stronger.
• PDMP review is no longer a substitute for proper intake screening.

Well-run practices will treat this as an opportunity to refine systems, not relax them.