The California Board of Registered Nursing told its Nurse Practitioner Advisory Committee on Sept. 24 that state law prohibits registered nurses and advanced practice nurses from compounding medications and that common retail and mobile IV-hydration models may be operating outside that legal limit. Executive Officer Loretta Melby said the prohibition is “very, very clear” under state law and urged broad education of nurses, educators and employers.

The warning matters because many clinics and franchises offering so-called “IV therapy” or vitamin drips rely on on-demand mixing of vials into IV bags at the point of care. Melby told the committee that, unless a physician is on-site and compounding or a patient-specific order is prepared in advance by a licensed compounding pharmacy, “that nurse is compounding. It is not covered within that emergent or urgent usage, and they are in violation of their scope of practice.”

The board flagged two legal sources in the discussion: Business and Professions Code 2725.1 (which the board staff cited as forbidding RN compounding in California) and federal/industry standards on sterile compounding maintained by the U.S. Pharmacopeia (USP). Melby said USP and California pharmacy law together define narrow situations when an RN may mix products for an identified patient under urgent or emergent care, and that routine retail IV-hydration services typically do not meet those conditions.

Committee members and staff described how widely available retail IV services have become. “We are the state with the most IV hydration clinics,” Melby told the group; she said the board has received reports of clinics in med spas, chiropractic offices, tanning salons and standalone retail locations where staff draw multiple vials and mix them into IV bags for walk-in customers. The board’s explanation: legally allowable reconstitution or admixing of a manufacturer-labeled product (following the manufacturer’s directions) is different from compounding a new mixture from multiple vials or ingredients.

Board counsel and staff described the enforcement path if a complaint alleges an impermissible compounding practice: the BRN investigates complaints and may pursue disciplinary action against a licensee, and other state agencies such as the California Board of Pharmacy and the Medical Board of California may also take action when their statutory authority applies. Melby said the BRN will prioritize education — outreach to nursing programs, licensees and professional organizations — because many nurses and employers appear not to understand the compounding rules.

Public comment supported the board’s outreach. A caller who identified herself as Mercy Peterson told the committee she supported the board’s effort and said large pharmacy chains have tightened compounding practices.

The committee did not take formal action at the meeting; staff said they will pursue coordinated educational outreach and update the BRN website with clear examples and references to law and USP standards.

Melby and committee members recommended that employers and organizations that run IV-hydration services either 1) use a compounding pharmacy to prepare patient-specific bags in advance, each labeled for a named patient, or 2) have an on-site physician (or other authorized compounder) who compounds and labels the product for a named patient. Absent one of those approaches, Melby said, the business model will need to be restructured to comply with California law.