Establishing A Mobile IV Therapy Clinic in Florida
Recently, I’ve received several inquiries from doctors, nurses and healthcare entrepreneurs who are considering opening mobile intravenous therapy clinics throughout Florida but have some legal concerns. In the past, there weren’t many Florida laws enacted to significantly regulate IV therapy clinics whether mobile or not and not much has changed over the years. Florida doesn’t have corporate practice of medicine limitations which is attractive for many of these individuals.
What is Intravenous Therapy?
The administration of intravenous (“IV”) therapy is defined as the therapeutic infusion and/or injection of substances (i.e. supplements, vitamins and minerals) through the venous peripheral system, consisting of activity which includes observing, initiating, monitoring, discontinuing, maintaining, regulating, adjusting, documenting, planning, interviewing and evaluating. It involves the administration of medication through a needle or catheter. It is believed by some that delivering medication directly into the bloodstream can help to quickly manage a patient’s pain or symptoms. In addition to treating illnesses, IV therapy proponents claim that it may also increase athletic performance, reduce jet lag, build immunity or help with dehydration by using vitamins and minerals. According to several practitioners, IV therapy should be customized for each patient’s needs to maximize results.
What is a Mobile IV Therapy Clinic?
A license issued by the Agency for Healthcare Administration (“Agency”) is required to operate a clinic in Florida. Each clinic location must be licensed separately regardless of whether the clinic is operated under the same business name or management as another clinic. In Florida, a clinic is an entity where health care services are provided to individuals and which tenders charges for reimbursement for those services, including a mobile clinic and a portable equipment provider. A mobile clinic means a movable or detached self-contained health care unit within or from which direct health care services are provided to individuals. Each mobile clinic must obtain a separate healthcare clinic license and must provide to the Agency, at least quarterly, its projected street location to enable the agency to locate and inspect the clinic.
Additionally, a home infusion therapy provider must be licensed as a home health agency or nurse registry. Nurse registries can refer nurses to patients to provide home infusion therapy. “Home infusion therapy provider” means an organization that employs, contracts with, or refers a licensed professional who has received advanced training and experience in intravenous infusion therapy and who administers infusion therapy to a patient in the patient’s home or place of residence. “Home infusion therapy” means the administration of intravenous pharmacological or nutritional products to a patient in his or her home.
A healthcare professional licensed as an acupuncturist, medical doctor, osteopathic doctor, nurse, midwife, speech pathologist, occupational therapist, physical therapist and others, whether or not incorporated, are exempt from the licensure requirements of Florida Statute 400.464 if they are acting alone within the scope of his or her professional license to provide care to patients in their homes.
The application for a healthcare clinic license must include information pertaining to the name, residence and business address, phone number, social security number and license number of the medical or clinic director of the licensed medical providers employed or under contract with the clinic.
Who Can Provide IV Therapy?
Most Florida licensed medical doctors, osteopathic doctors, dentists, registered nurses, medical assistants, and licensed practical nurses may provide iv therapy to patients if they possess the appropriate certifications and training. Several of these practitioners must complete a required 30-hour IV certification course. Regardless of who you hire to provide IV therapy they should have several years of experience with administering IVs.
1. Emergency Medical Technicians and Paramedics
Some have inquired about the appropriateness of hiring an emergency medical technician (“EMT”) or a paramedic to administer IV therapy to the clinic’s patients. Florida law makes a clear distinction between what types of services an EMT and paramedic may provide. An EMT is defined as a person who is certified by the Department of Health to perform “basic life support”. A paramedic is defined as someone who is certified by the DOH to provide basic and advanced life support. Paramedics hold a certificate of successful completion in “advanced cardiac life support” from the American Heart Association (“AHA”) or its equivalent, whereas EMTs are only required to hold a current AHA cardiopulmonary resuscitation course card. This distinction between basic and advanced life support is important. Florida law states that Advanced life support means assessment or treatment by an appropriately qualified individual to use techniques such as endotracheal intubation, the administration of drugs or intravenous fluids, cardiac monitoring and cardiac defibrillation. Basic life support means the assessment or treatment by a person qualified to use techniques as described in the EMT-Basic National Standard Curriculum or the National EMS Education Standards of the USDOT, which includes the administration of oxygen and other techniques. The DOH has taken action against several IV clinics, which were identified as posing a potential health threat to Florida’s residents and visitors. DOH investigators have issued several cease and desist notices to paramedics and EMTs for operating outside their scope of practice for practicing medicine without the proper license.
2. Medical Assistants
Medical Assistants involved in the performance of IV therapy must receive training and certification in IV procedures. All IV therapy provided by a medical assistant must be done under direct supervision of a practitioner who is trained and has experience in the administration, potential side effect and complications related to IV therapy. If services are provided in an office setting (or mobile clinic) the experienced practitioner should always present in the office whenever a medical assistant is providing IV therapy to a patient. In a Florida Board of Medicine case, the Board held that medical assistants may lawfully perform IV infusion therapy as long as it is performed under the direct supervision and responsibility of a Florida licensed physician that is always present in the office whenever a medical assistant is providing the therapy to a patient.
3. Licensed Practical Nurses
Aspects of IV therapy may be outside the scope of practice of a licensed practical nurse (“LPN”) unless under the direct supervision of the registered professional nurse or physician and which shall not be performed or initiated by the LPN without direct supervision include the following:
- Initiation of blood and blood products;
- Initiation or administration of cancer chemotherapy;
- Initiation of plasma expanders;
- Initiation or administration of investigational drugs;
- Mixing IV solution;
- IV pushes, except heparin flushes and saline flushes.
With the exception of those aspects of IV therapy deemed outside the scope of practice of the LPN, and subject to the approval of the institution at which the LPN is employed, any LPN who meets the competency knowledge requirements is authorized to administer intravenous therapy under the direction of a registered professional nurse. “Under the direction of a registered professional nurse” means that the registered professional nurse has delegated IV therapy functions to a qualified LPN. The registered professional nurse does not in all instances have to be on the premises in order for the licensed practical nurse to perform the delegated functions. Direct supervision means on the premises and immediately physically available. Only license practical nurses that have met the education and competency requirement in state nursing rules can provide infusion therapy.
Who Pays for IV Therapy?
The overwhelming majority of mobile IV therapy patients will be self-pay. Medicare, Medicaid and commercial payors typically won’t cover the costs for these treatments. However, I have seen reports where commercial payors may utilize specific per diem codes to pay certain infusion providers for services, supplies and equipment. Medicare has limited coverage for home infused drugs under the Part B and Part D benefit when it is medically justified.
As a medical provider you must anticipate that medical emergencies may emerge even during the most routine situations. Providers should have adequate insurance coverage for claims arising out of injury to or death of a patient and damage to the property of others resulting from any cause for which the owner of the mobile IV clinic would be liable. In lieu of malpractice insurance, a provider may furnish a certificate of self-insurance as evidence that the provider has established adequate self-insurance to cover these types of risks.
Because IV injection involves direct access into the patient’s circulatory system, sterile equipment and sterile technique must be used to avoid the introduction of any pathogens into a patient’s bloodstream. The practitioner must inspect vials for signs of contamination such as particulate matter, cloudiness, or inappropriate color. The practitioner must use a sterile alcohol wipe to cleanse the top of the vial and withdraw the fluid form the vial using a sterile needle and a sterile syringe. Practitioners must follow Universal Precautions, as described by the Occupational Safety and Health Standards (“OSHA”). To ensure safe and proper administration of infusion drugs you should consider providing some of the following services:
- Patient Assessment
- Drug interaction monitoring
- Patient education
- Patient monitoring
- Car planning
- Maintenance of storage, preparation, dispensing and quality control of all infusion medications and equipment.
I would advise against treating individuals under the influence of alcohol, suffering from congestive heart failure, history of aneurysms, kidney or renal disease and high blood pressure. Patients should also be 18 or older and valid written consent forms should be signed by every patient.
You must have a medical director who is employed or contracted by the clinic licensee and who provides medical supervision, including appropriate quality assurance but not including administrative and managerial functions, for daily operations and training. Additionally, a health care practitioner may not serve as the clinic director if the services provided at the clinic are beyond the scope of that practitioner’s license.
It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice, it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please contact me using the contact information listed above.
All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.
sasha ikramelahaiJune 23, 2019 at 5:20 am
So can. Emt open an iv mobile infusion business?
AmandaOctober 30, 2019 at 8:26 am
I am confused as well I am a registered medical assistant trained in emergency medicine and iv’s can I open one?
Jamaal R. Jones, Esq.October 31, 2019 at 12:10 am
It may be possible for you to obtain the license(s) necessary to open your own mobile IV therapy practice but as a registered medical assistant you may need direct supervision and depending on your training you might not be permitted to perform the IV therapy yourself, unlike a registered nurse or medical doctor.
sasha ikramelahaiJune 23, 2019 at 5:21 am
Can a Emt open a iv infusion center
BurgosNovember 9, 2019 at 1:53 pm
I am looking to start my own business as well. I am however looking for a partner. I am a Family Nurse Practitioner. If you’re interested in possible starting it together- contact me and maybe we can use Jones as our lawyer email@example.com
Flobrenne Joseph-SpauldingApril 12, 2020 at 9:11 pm
Hi, I’m looking to partner up with a practitioner to open a IV hydration clinic. I would love to talk to you more about this.
Brenda RamirezMay 30, 2020 at 11:10 pm
What part of Florida are you in?
Faith BakerDecember 18, 2019 at 7:50 pm
Can a nurse Practitiner be the medical director/clinical director?
Jamaal R. Jones, Esq.December 18, 2019 at 8:38 pm
By statutory definition in section 400.9905(5), F.S., a medical director is a health care practitioner that holds an active and unencumbered Florida physician’s license in accordance with chapters 458 (medical physician), 459 (osteopathic physician), 460 (chiropractic physician) or 461 (podiatric physician), F.S.
Christina BennettMarch 20, 2021 at 9:41 pm
Now that statue 464 gives qualifying Primary care NPs autonomous practice, would that not allow autonomous NPs the ability to be medical/clinical directors for IV therapy?
Jamaal R. Jones, Esq.March 21, 2021 at 2:15 pm
You would have to look at the definition of “Medical Director” under Florida Statute 400.9905(5) to find the answer to that question.
JamesApril 27, 2020 at 11:41 am
Your distinction between Paramedics and EMT’s needs to be reviewed. All properly certified Paramedics including both the EMT-P designation from the state and the NRP certification from the National Registry have a scope of practice that qualifies them to initiate IV therapy, administer pharmacological interventions, and monitor patients for therapeutic response.
EMTs cannot, Paramedics can.
Jamaal R. Jones, Esq.April 27, 2020 at 4:44 pm
The information that I’ve included about Paramedics and EMTs is taken directly from Florida DOH Press Release. In fact, I stated that Paramedics have a advanced life support training that allows them to administer intravenous fluids.
Further, as I state in all of the blog posts that I author “All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.”
LisaApril 30, 2020 at 2:19 am
Jamal: out of curiosity, are you saying RNs can prescribe and administer infusions without a provider (MD, DO, PA, NP) order?
RussDecember 10, 2021 at 5:00 am
If the infusion is vitamins and saline, I don’t see why not. I don’t think they are going to be able to call the pharmacy and order Vancomycin or other IV administered drugs. (not a lawyer)
LEEMay 17, 2022 at 9:43 pm
I read that Paramedics can only work under medical direction for emergency services. They can’t provide Infusions for a private clinic. All this information is provided I believe under the Florida Department of Health. So, Paramedics would be in violation if performing outside of FDOH statues. This is unfair but they make the rules.
AlexisJune 23, 2020 at 4:02 pm
I am a registered nurse and I am looking to open a mobile IV hydration business. I have a physician who has agreed to partner with me. I want to make the business an LLC. My question is does the physician have to be a part business owner to be covered by my business insurance I obtain? If he is my medical director but not a business owner, would the business insurance still cover him from liability or would he have to be covered separately?
CynthiaJune 29, 2020 at 4:41 am
I’m a physician assistant looking into opening a mobile infusion business. Am I allowed to provide the IVs or can I get an RN to do them? Does she need a special certification?
I’m assuming I still need a medical supervisor . Does he have to be co-owner?
MirandaAugust 27, 2020 at 5:01 pm
Hi I’m Looking to start Mobile IV and looking to partner up with A practitioner in the Tampa FL area. I have been doing IVs for a while now and wanting to branch out on my own contact me if interested 🙂 firstname.lastname@example.org
Ola ThomasFebruary 7, 2022 at 4:16 am
I am a registered nurse interested to start iv dehydration clinic and looking for someone to partner. I lived in orlando
Rose JonkaFebruary 13, 2022 at 5:00 pm
Hi looking to partner with someone if only you was in Port st Lucie
Beth S.April 19, 2022 at 3:50 am
I am in PSL ,just found this do u still need a partner ?
McCaelaJune 18, 2022 at 1:06 am
I am just north in Satellite Beach. Are you a practitioner? I am an RN and am interested in finding a partner.
MallissaSeptember 22, 2022 at 1:49 pm
I’m an LPN who’s also located in Orlando. I’m looking to partner up to start an IV hydration clinic. Please let me know if you’re interested in teaming up. You may reach me at “MALLISSAFAUSTIN@yahoo.com”
Cynthia RemySeptember 24, 2020 at 7:06 pm
Hi So I am a license Nurse Practitioner so I wanted to know if I was able to start a mobile IV hydration service?
Jamaal R. Jones, Esq.September 24, 2020 at 7:31 pm
Yes you can so long as it’s structured appropriately.
Anna Marie Di SantiDecember 13, 2020 at 8:10 pm
I am an RN. Do the clients need a presciption for the IV solution in order for me to deliver it? If so then do they need a brief history and physical from an MD or NP to get the prescription? Please advise.
RhondaJanuary 12, 2021 at 8:33 pm
I’m a Registered Nurse in NYS and would like to relocate and partner up to open a business. Anyone interested reach out at email@example.com
Christie KennedyFebruary 3, 2021 at 12:39 am
Does a Nurse Practitioner with autonomous practice need a collaborative MD to run their own mobile or office IV hydration business?
Jamaal R. Jones, Esq.February 3, 2021 at 1:40 pm
According to Florida Statute 464.0123: An advanced practice registered nurse who is registered under this section may:
1. Engage in autonomous practice only in primary care practice, including family medicine, general pediatrics, and general internal medicine, as defined by board rule.
3. Perform the general functions of an advanced practice registered nurse under s. 464.012(3) related to primary care.
Based on my reading of the Statute above, it would appear that an APRN would need a Medical Director Agreement to provide IV Therapy Services since it doesn’t fall under one of the permitted practice areas for autonomous practice.
EveMarch 24, 2021 at 12:54 pm
I didn’t see anything mentioning Respiratory Therapist. Why not?
Las Vegas Mobile IV TherapyApril 3, 2021 at 5:55 pm
It is so important to know and follow the applicable state and federal laws that apply to the IV therapy industry. Thanks for posting this. Maybe i will do the same for my state. You are a good influence on the industry!
Jamaal R. Jones, Esq.April 5, 2021 at 2:07 pm
Thank you! I’m happy that you found some value in the post.
JheanelleMay 11, 2021 at 2:27 am
On ACHA’s website do I obtain license for home health agency or nurse registry. Also, is this the very first step?
Marin Mobile IV TherapyMay 23, 2021 at 3:44 am
Thank you for providing this thorough article on the benefits of iv infusions. We just opened up our own practice in Marin, CA, and are currently hiring RN nurses to provide services to our clients in their homes.
Yoe EstevezJune 29, 2021 at 8:40 pm
Please I’m a Registered Nurse in Florida. I will like to operate a home IV therapy business. Please advise on steps and requirements needed.
Jamaal R. Jones, Esq.June 30, 2021 at 12:43 pm
Yoe, this blog posts lists many of the requirements. If you’d like to schedule a paid consultation or hire my firm to assist you with setting up your IV therapy business please call or email me directly. Thank you.
richard eckertJuly 18, 2021 at 1:47 am
Hi Jamal! Could you kindly contact me directly so as to discuss the terms/cost of your assistance in setting up my IVT biz in Miami? firstname.lastname@example.org
Jamaal R. Jones, Esq.July 19, 2021 at 1:39 pm
Thank you for your interest in our services. Please call my office at your convenience to discuss our pricing.
TommySeptember 30, 2021 at 5:42 pm
Good day Mr. Jones. what are the steps to follow to open a mobile IV clinic in FL? I am a paramedic with a LLC already opened and have an MD standing by, thanks
Indira PonceOctober 4, 2021 at 6:19 pm
Can an autonomous Nurse Practitioner be the medical director of an IV mobile hydration business in Florida ?
Jamaal R. Jones, Esq.October 5, 2021 at 12:25 pm
“Medical director” means a physician who is employed or under contract with a clinic and who maintains a full and unencumbered physician license in accordance with chapter 458, chapter 459, chapter 460, or chapter 461. However, if the clinic does not provide services pursuant to the respective physician practices acts listed in this subsection, it may appoint a Florida-licensed health care practitioner who does not provide services pursuant to the respective physician practices acts listed in this subsection to serve as a clinic director who is responsible for the clinic’s activities. A health care practitioner may not serve as the clinic director if the services provided at the clinic are beyond the scope of that practitioner’s license, except that a licensee specified in s. 456.053(3)(b) who provides only services authorized pursuant to s. 456.053(3)(b) may serve as clinic director of an entity providing services as specified in s. 456.053(3)(b).
Fabiola BaptisteOctober 6, 2021 at 6:13 pm
Can a nurse practitioner with a family practice clinic add IV hydration to the practice without a medical director? I do have a collaborative physician buy will be autonomous soon.
Jorge VazquezJanuary 31, 2022 at 2:50 pm
I am a RN for the state of Florida and I have a Serenity day spa in New Smyrna, Fl. I would like to know if I am aloud to give iv hydration therapy to my clients. And what are the rules or permits that I need? You can email me at email@example.com
Jamaal R. Jones, Esq.January 31, 2022 at 3:00 pm
Thank you for your comment Mr. Vazquez. I’d be happy to answer any questions that you may have during a paid consultation. Please feel free to to contact our office to schedule a consultation at your earliest convenience. Thank you.
ArielFebruary 17, 2022 at 7:41 pm
Nurse Practitioner looking for partner for IV therapy in Florida. Ariel9313@gmail.com
Robin GApril 16, 2022 at 8:17 pm
Where in Florida are you? I’m an RN
AlyaOctober 4, 2022 at 9:19 pm
Hi! I am a pharmacist looking to get into IV business. Please contact if any interest
Amber RNApril 10, 2022 at 11:03 pm
Hello, thank you so much for educating us all on the IV Hydration ViVe situation. I was wondering, I have a family member in California that holds an active chiropractic physician license, But she be able to be my medical Director here in Florida it’s a business has been around here?
Crystal FLOWERSApril 26, 2022 at 1:59 pm
Can Phlebotomist do iv
Jamaal R. Jones, Esq.April 26, 2022 at 2:11 pm
You would have to contact the Department of Health to determine whether phlebotomists can start an IV in an IV Therapy Clinic. I have not come across any rules that whether a phlebotomist is permitted or prohibited from starting an IV in an IV Therapy Clinic. If you do reach out to the Dept. of Health feel free to share any updates in the comment section.
ChrizziApril 27, 2022 at 3:00 pm
This was an amazing read! I learned so much! Thank you! I will be saving it💕
Jamaal R. Jones, Esq.April 27, 2022 at 4:50 pm
Your welcome! Please share with your friends.
RyanAugust 11, 2022 at 1:10 pm
If you are already licensed to perform IVs in a clinic / mobile setting and have all appropriate business licenses etc, are there any regulations for performing them in a booth at an outdoor festival?
Thanks for the info!
Jamaal R. Jones, Esq.August 11, 2022 at 3:27 pm
Feel free to call our office to schedule a consultation to discuss this further….305-877-5054
Lori LenhartNovember 16, 2022 at 2:07 am
Can a licensed salon or hair salon offer IV therapy from a contractor or mobile IV therapy service? Or do we need to hold a Medispa business license or some other license to have this offered in our salon if it’s coming from a mobile IV therapy business?
Nicole PaizDecember 22, 2022 at 3:40 pm
Can a registered dental hygienist, in the state of Florida, perform IV infusions? We have degrees and licensures, as well as license for local anesthetic injections (much more than a medical assistant). You would think so… i’ m unsure..?
Jamaal R. Jones, Esq.December 22, 2022 at 3:50 pm
Hi Nicole. It’s not clear at this time whether it is within the scope of practice for a Dental Hygienist to perform IV Infusions. I haven’t come across any information that expressly prohibits or allows a Dental Hygienist to perform IV Infusions. The Florida Board of Dentistry might be able to provide some guidance.