Good Faith Exams Are Still Required
IV hydration therapy is medical care. That means every IV treatment must be:
- Based on a valid, individualized order from a Licensed Provider (LP) with prescriptive authority (such as a physician, PA, or NP); and
- Issued after a medical evaluation of the patient.
Orders must be tailored to the patient’s specific needs with a documented medical rationale. Standing orders for elective wellness IVs, where a nurse selects treatments without a direct practitioner-patient relationship, are explicitly prohibited.
Bottom line: A questionnaire or intake form alone is not enough. Patients must be examined by a qualified LP before treatment, whether via telemedicine or in person.
RNs and LPNs Cannot Diagnose or Prescribe
An LPN may only assist with IV therapy under the supervision of an RN or licensed physician who is readily available in person or electronically. It is outside the scope of practice for an RN or LPN to:
- Diagnose patients;
- Select which IV a patient should receive; or
- Order or compound IV formulations.
Compounding and Medication Handling Are Heavily Regulated
- Compounding: Mixing two or more drugs or altering a formulation is only allowed when performed by a licensed pharmacist (or under their supervision). Nurses may not compound IVs.
- Reconstitution: Preparing a medication per FDA-approved instructions from the manufacturer may be allowed but must follow strict guidelines.
- Admixture: Adding medication to IVs must use aseptic techniques and in accordance with safety protocols. The process is typically performed for immediate use.
Clinics must also follow USP <797> sterile compounding standards and source medications from FDA-licensed distributors or 503B compounding pharmacies.
Documentation and Ongoing Monitoring Are Required
Nurses performing IV therapy must:
- Maintain complete patient charts, including medical history, consent forms, and treatment notes;
- Monitor for adverse reactions and have emergency protocols in place;
- Validate nursing competency regularly based on services offered and patient populations served.
What Arizona IV Clinics Should Do Now
Now is the time to take steps to tighten your protocols and ensure proper delegation and licensed supervision. These requirements apply to any IV hydration service regardless of the setting—including mobile units, patients’ homes, and retail-style IV bars.
If you’d like assistance in ensuring that you’re fully compliant, please reach out to us—we’re here to help.