Kansas health regulators have issued a warning to IV therapy providers, medical spas, and hydration clinics across the state. The joint statement from the Kansas State Board of Healing Arts (KSBHA) and the Kansas Board of Pharmacy (KSBOP) underscores longstanding medical spa compliance principles that AmSpa has advocated for years, including the need for proper examinations, appropriate supervision, valid prescriptions, and lawful delegation.

The joint statement reiterates that “IV therapy is a medical practice requiring licensed professionals.”

Retail IV therapy clinics offer pre-selected IV “cocktails” that mix a combination of saline, vitamins, minerals, amino acids and sometimes prescription medications. The therapy are marketed to alleviate the symptoms of dehydration, migraines, hangovers, nausea, and to support athletic recovery, appetite regulation and inflammation support, among others.

Regulators say they have received complaints about “out-of-scope practices, delegation of medical treatments to unqualified individuals, unauthorized compounding and administration of prescription medications and other drugs, and the unlicensed practice of the healing arts and pharmacy.”

Prescriptive Authority

In the statement, regulators say the person with “prescriptive authority” is required to evaluate and diagnose the patient before making treatment recommendations. A prescription or order for medication is required before the prescriptive authority orders the IV therapy.

“Offering and providing IV therapy indisputably constitutes the practice of healing arts,” the regulators said in their statement. “Only a person with prescriptive authority may diagnose a patient, assess the patient’s symptoms, and make the decision to provide medication, by injection or otherwise, to a patient.”

The person with prescriptive authority must establish a direct relationship with the patient. It's not enough to have a supervising prescriber “on staff” or “available.” 

Standing Orders

Self Prescribing

Drug Compounding

Additionally, adding substances to IV saline counts as drug compounding. Only physicians and pharmacists are authorized under the law to compound drugs. PAs, APRNs, RNs, LPNs, cosmetologists, estheticians, and unlicensed persons are legally prohibited from mixing additives with IV saline. RNs may compound only under the direct supervision and orders from a physician.