IV Therapy in MedSpas: Who Can Legally Administer It in New York, New Jersey, and Pennsylvania?
Intravenous (IV) hydration therapy has become a popular offering in MedSpas, but before adding it to your menu of services, it is critical to understand who can legally administer IV treatments. The rules vary by state – and misunderstanding them can expose your practice to liability or professional discipline.
New York
In New York, IV therapy is definitively considered a medical procedure.
The State Board for Nursing allows Registered Nurses (RNs) and Licensed Practical Nurses (LPNs) to perform IV therapy only if they have completed formal IV training and demonstrated clinical competency. LPNs must work under supervision – typically from an RN, nurse practitioner, or physician, and the supervising clinician must be available to personally intervene to ensure timely and appropriate care to the patient receiving IV Therapy from the LPN.
By contrast, Medical Assistants (MAs) are not licensed in New York and may not insert or remove IVs, administer fluids, or give injections of any kind. Even for certified medical assistants, performing IV therapy would exceed the scope of their permissible tasks.
New Jersey
New Jersey limits IV therapy to specific licensed professionals: physicians, registered nurses, physician assistants, and qualified licensed practical nurses. LPNs must have specialized IV certification recognized by the New Jersey Board of Nursing. Unlicensed MAs may support patient care through administrative or non-invasive functions, but they cannot start or administer IVs, even under direct physician supervision.
Pennsylvania
In Pennsylvania, LPNs may provide IV therapy only when they have the necessary skills and training, and when acting under the supervision of a licensed health care provider such as a physician, nurse practitioner, or Physician Assistant. Depending on the circumstances, a clinician can be physically present to supervise an LPN administer IV therapy or supervise by way of electronic communication.
The Pennsylvania Board of Medicine is currently in the process of developing guidance as to whether unlicensed assistants can take part in IV hydration therapy, but it has indicated that it will rely on other states’ policies when issuing new guidance – suggesting restrictions similar to those articulated in the Oregon Medical Board’s October 3, 2024 Statement of Philosophy, available here, and the Joint State Regarding IV Therapy Clinics and Medical Spas from the Vermon Office of Professional Regulation and Boards of Medical Practice, Nursing, Osteopathic Medicine, and Pharmacy, available here.
Key Takeaway for MedSpa Owners
Across New York, New Jersey and Pennsylvania, IV hydration therapy is considered a clinical medical service, not a cosmetic procedure. It must be performed by licensed personnel who are properly trained and supervised. Unlicensed medical assistants may help with setup, documentation, or patient comfort, but may not insert IVs or administer fluids under the applicable law.
Before launching IV hydration services, MedSpa owners should review staffing and supervision models to ensure compliance. Our firm regularly assists MedSpas and licensed professionals with scope-of-practice reviews, delegation policies, and compliance planning.
If you are expanding your services to include IV therapy, please contact Evan Sampson, Counsel within the firm’s Health Care Practice Group, at esampson@postschell.com or 856.301.2561 for tailored legal guidance.
Disclaimer: This post does not offer specific legal advice, nor does it create an attorney-client relationship. You should not reach any legal conclusions based on the information contained in this post without first seeking the advice of counsel.
About the Author
Evan M. Sampson is Counsel in the firm’s Health Care Practice Group, where he advises health care providers and organizations on a broad range of regulatory, transactional, and litigation matters.