The Georgia Composite Medical Board’s IV Hydration/Therapy Position Statement

IV Hydration in Georgia: What the Composite Medical Board’s 2026 Position Statement Means for Clinics and Clinicians

A clinical and regulatory roadmap for compliant IV therapy practice in Georgia.

Yoon Hang Kim, MD, MPH

Board-Certified in Preventive Medicine | Integrative & Functional Medicine Physician

www.directintegrativecare.com

IV hydration and “drip bar” services have become a fixture of the wellness economy. They are marketed on social media as quick fixes for fatigue, hangovers, immune support, athletic recovery, and skin health. In Georgia, however, regulators have drawn a firm line. On May 7, 2026, the Georgia Composite Medical Board issued an IV Hydration/Therapy Position Statement that makes one principle unambiguous: IV therapy is the practice of medicine and must be structured accordingly.

The position statement is more than a policy reminder. It clarifies how delegating physicians, advanced practice registered nurses (APRNs), physician assistants (PAs), and registered nurses (RNs) must work together to deliver IV therapy lawfully in Georgia—whether in a brick-and-mortar clinic, a walk-in setting, or a mobile hydration service. For physicians, APRNs, PAs, and entrepreneurs operating in this space, the statement is essential reading.

IV Therapy Is Not a Menu

The Board’s most consequential clarification is also its simplest. A patient cannot walk into a clinic, select an IV “package” from a printed menu, and receive fluids, vitamins, or medications without an individualized clinical assessment. Before any IV hydration, nutrient therapy, or medication is administered, there must be:

• A valid individualized order or prescription

• A completed history and physical

• An assessment by a physician, APRN, or PA acting within legal scope and authority

Standing orders are not an acceptable substitute for individualized clinical judgment. “Menu-based” treatment without individualized assessment is not a recognized workaround—it is a compliance risk.

This expectation applies regardless of the setting. The Board explicitly acknowledges that IV hydration may be offered in nontraditional environments, including walk-in clinics, mobile hydration services, and drip bars. But the setting does not relax the medical standard. RNs and LPNs may administer IV therapy when a proper clinical framework is in place, but they may not be the only licensed health care professionals evaluating and treating patients. Nursing scope of practice does not include independently diagnosing, identifying medical problems, or developing medical treatment plans.

APRNs and the Delegating Physician: A Real Relationship, Not a Contract Title

For APRNs working in or operating IV hydration practices, the Board requires a compliant relationship with a delegating physician. The relationship must satisfy several conditions:

• The APRN is fully licensed by the Georgia Board of Nursing

• The APRN’s specialty area is comparable to the physician’s specialty area

• The services delegated are services the physician regularly performs in the physician’s own practice

• A compliant nurse protocol agreement is in place

• The delegating physician is available for immediate consultation, or a qualified substitute is designated

Critically, the delegating physician retains ongoing oversight responsibilities. The physician must document direct on-site observation of the APRN’s practice at least annually, conduct quarterly medical record reviews, and ensure that delegated medical acts match the APRN’s training, certification, and competence. Ultimate responsibility for the clinical appropriateness, supervision, documentation, and legal compliance of delegated acts remains with the delegating physician.

The Compensation Problem: Employment and “Collaborating Physician” Services

One of the most important parts of the position statement addresses how delegating physicians may—and may not—be compensated.

Georgia law restricts arrangements in which a physician is employed by an APRN whom the physician is required to supervise. The Board does not interpret “employment” narrowly. It is not limited to W-2 employment. The Board generally views compensation of any kind from an APRN or an APRN-owned company to a delegating physician as prohibited when the compensation is in exchange for serving as the required supervising or delegating physician.

This interpretation has direct implications for the growing market of third-party “collaborating physician” services. The Board’s position is clear: routing payment through a matching, staffing, or management company does not automatically solve the supervision problem. If an APRN pays a third party to obtain a delegating physician and the physician is compensated through that arrangement, the Board may view the structure as an indirect payment from the APRN to the physician. The Board emphasizes substance over form. The label on the contract and the entity structure are not determinative; the practical effect of the relationship is.

For physicians considering delegating arrangements, and for APRNs considering “plug-and-play” collaborating physician platforms, this is the most important takeaway in the statement.

Physician Assistants and Supervising Physicians

Georgia maintains a separate but equally rigorous framework for PAs. A PA working in an IV hydration setting must have:

• An active Georgia PA license

• A Board-approved supervising physician

• A Board-approved job description signed by the supervising physician and the PA

The job description must describe the medical acts the PA may perform, and those acts must remain within the supervising physician’s own scope of practice. A supervising physician is responsible for the medical acts performed by the PA.

A supervising physician need not be in the same building as the PA at all times, provided the task is within the approved job description and immediate consultation is available. For tasks outside the approved job description, however, the supervising physician must be physically present and directly supervising.

When properly authorized, a PA may issue prescription drug orders, order or initiate medical treatment or diagnostic studies, and prescribe medical devices, dangerous drugs, and Schedule III–V controlled substances. PAs with controlled-substance prescribing authority must register with the DEA and the Georgia PDMP as required.

A PA may serve as an evaluator, medical provider, and prescriber in an IV hydration clinic only when these requirements are met and when IV therapy is within the supervising physician’s normal scope of practice.

Nursing Administration of IV Therapy

RNs may administer IV hydration and IV therapy when there is a valid individualized order and an appropriate clinical framework. LPNs may participate only under the supervision of an RN, physician, NP, or PA.

Businesses are expected to maintain written policies and procedures covering IV hydration administration, nutrient therapies, medications, emergency interventions, infection control, and applicable pharmacy standards (including USP 797 where relevant). These are not optional administrative formalities; they are part of the clinical infrastructure the Board expects.

Transparency for the Public

The position statement also imposes a public disclosure obligation. Licensees must clearly inform the public of the APRN’s delegating physician or the PA’s supervising physician, including how that physician may be contacted. This information should be posted in a way that allows unrestricted public access. Patients have a right to know who is medically responsible for their care.

The Bottom Line for Georgia Operators

The Board’s position statement should be read by anyone delivering, supervising, or contemplating an IV hydration service in Georgia. The unifying principle is that IV therapy is medicine. It requires:

• Individualized clinical assessment, not menu selection

• Lawful ordering authority by a physician, APRN, or PA acting within scope

• Genuine and properly compensated supervisory relationships

• Documented oversight of APRNs and PAs by their delegating or supervising physicians

• Trained nursing administration within scope

• Written policies for safety, emergencies, and pharmacy compliance

• Transparent public disclosure of physician responsibility

Clinics that have been structured around RN/LPN-only evaluation, generic standing orders, menu-based treatment, or “paper” physician supervision arrangements should review their operations against the Board’s statement. So should APRNs and PAs whose delegating or supervising physician relationships are mediated through third-party platforms.

The trajectory of regulation in this space is consistent across states: as IV therapy has become more visible, regulators have insisted that it be delivered within a real medical framework. Georgia has now joined that direction in clear terms.

At www.directintegrativecare.com, we believe that integrative and functional medicine succeeds in the long term only when it is delivered with the same clinical rigor as any other medical practice. The Georgia Composite Medical Board’s position statement is consistent with that view. For physicians, APRNs, and PAs building integrative practices in Georgia, the path forward is straightforward: structure the practice as medicine, not as retail.

Source: Georgia Composite Medical Board, IV Hydration/Therapy Position Statement, May 7, 2026.

About Dr. Kim

Dr. Yoon Hang “John” Kim is a board-certified physician with more than 20 years of experience in preventive, integrative, and functional medicine. He completed fellowship training in integrative medicine at the University of Arizona under Dr. Andrew Weil as an Osher Fellow and holds additional certifications in preventive medicine, medical acupuncture (UCLA), and integrative and holistic medicine.

Dr. Kim specializes in low-dose naltrexone (LDN) therapy, autoimmune disease, chronic pain, integrative oncology, fibromyalgia, chronic fatigue syndrome (CFS), mast cell activation syndrome (MCAS), and mold toxicity / chronic inflammatory response syndrome (CIRS). He is the author of three books and more than twenty articles, and founder of the LDN Support Group, an international patient and clinician community.

Professional: www.yoonhangkim.com

Clinical: — www.directintegrativecare.com