With IV hydration therapy clinics rapidly gaining popularity across the country, Wisconsin regulators are stepping in to clarify who can legally assess, prescribe, mix, and administer these treatments. In a new Joint Advisory Opinion issued June 25, 2025, six Wisconsin boards—including the Medical, Nursing, Pharmacy, and Cosmetology Boards—have released comprehensive guidance for healthcare professionals offering or working at IV therapy businesses.
This statement aims to address the confusion surrounding legal requirements and scopes of practice in these clinics, many of which operate in a walk-in or “retail” setting. Here’s what Wisconsin practitioners need to know before offering IV hydration services.
IV Therapy Is the Practice of Medicine
According to the Advisory Opinion, IV hydration therapy constitutes the practice of medicine and surgery under Wisconsin law. That means:
- A licensed physician, physician assistant (PA), or advanced practice nurse prescriber (APNP) must assess and diagnose each patient.
- Offering pre-selected IV “cocktails” with prescription ingredients (such as vitamins, amino acids, or medications) is not a cosmetic service—it is medical treatment.
- RNs and LPNs cannot independently determine which IV treatment a patient should receive or prescribe medications.
Patient Assessment Must Be Done by a Qualified Practitioner
Before a patient receives an IV treatment, a licensed provider (MD, PA, or APNP) must perform a proper medical assessment. While telehealth may be used, the advisory strongly recommends in-person evaluations, emphasizing that:
- A simple questionnaire is not sufficient.
- The evaluation must include a history and physical examination.
- The treating practitioner must obtain informed consent and create a complete medical record.
- Standing orders outside of a practitioner-patient relationship for individualized assessment, diagnosis, and treatment may violate standards of minimal competence.
Nurses may assist with delegated parts of the exam, but they cannot make the diagnosis or treatment recommendation on their own.
IV Additives Must Be Compounded Under Strict Legal Requirements
When vitamins, minerals, amino acids, or medications are added to IV bags, that constitutes compounding: an activity regulated under both state and federal law.
- Only a licensed pharmacist or physician may legally perform sterile compounding.
- Prescription drugs (including saline and additives) must be purchased and stored by qualified licensees only. RNs and LPNs may not maintain or control prescription drug inventory without proper authorization.
- Fluids and additives must be purchased from FDA licensed manufacturers, distributors licensed in the state where they are being purchased, or from compounding pharmacies designated and licensed as 503B compounding facilities.
- Clinics must comply with USP <797> standards for sterility, labeling, and timing, even when using the “immediate use” exemption.
Administration and Monitoring
Once the IV bag is prepared and prescribed, a licensed nurse (RN or LPN) may administer the IV. However:
- Only RNs may perform the nursing assessment during administration, including monitoring vital signs and patient reactions.
- LPNs may assist, but they cannot independently monitor or assess patients during treatment.
- All observations and actions must be thoroughly documented.
What Does This Mean for Your Practice?
If your IV hydration business operates in Wisconsin, or you’re a practitioner working at one, here’s what to do now:
- Review your business model: Ensure a licensed MD, PA, or APNP is involved in every patient assessment and treatment decision.
- Audit your staffing: Unlicensed personnel and RNs may not legally diagnose or prescribe IVs. Confirm that all roles align with Wisconsin licensing laws.
- Update your protocols: From informed consent to compounding practices, make sure your processes meet USP <797> standards and Wisconsin statutes.
- Secure proper licensure: Prescription medications must be purchased, stored, and handled in accordance with Pharmacy Examining Board rules.
Final Thoughts
This joint advisory is a strong reminder that IV hydration clinics are not simply wellness or beauty businesses, but are also providing medical care, and are subject to strict regulatory oversight. Wisconsin’s regulators have made clear that patient safety, proper delegation, and licensure are non-negotiable.
If you are unsure whether your IV hydration practice complies with Wisconsin law, Lengea Law is here to help.