There has been a lot of confusion lately as to whether Paramedics can administer IVs at doctors’ offices, clinics or MedSpas. While these professionals are trained to administer IVs during emergency transport, they are not allowed to administer IVs in most other situations.
The statutes and rules pertaining to paramedics and scope of practice fall under Chapter 401, Medical Telecommunications and Transportation, Florida Statutes, and Chapter 64J-1, Emergency Medical Services, Florida Administrative Code.
Based on definitions and the text of the statutes and rules, although a paramedic is trained to administer IVs, they can only do so during the course of emergency services and transportation and at public health care programs. Further, a paramedic’s services must be rendered under a medical director’s supervision, as the term medical director is defined under Section 401.23, Florida Statues. Under this statute, a medical director “is a physician employed or contracted by a “licensee” and who provides medical supervision, including appropriate quality assurance but not including administrative and managerial functions, for daily operations and training pursuant to this part.” Section 401.23(15). Pursuant to statutes, a “licensee” means any basic life support service, advanced life support service, or air ambulance service licensed pursuant to this part.” Section 401.023(13).
There has been a bit of confusion in the health care industry and even among attorneys as to whether a paramedic can administer IVs for a private or non-public health care program or entity. I believe part of the confusion derives from Section 458.348, Formal Supervisory Relationships, Standing Orders, and Established Protocols, Florida Statutes. Specifically, Section 458.348(1)(a) provides that there must be a written protocol and notice to the Board of Medicine when a physician (MD) enters into a supervisory relationship with a paramedic licensed pursuant to Section 401.27, Florida Statutes. Because Section 458.348 references Section 401.27, Chapter 401 must be read in its entirety to determine the scope of practice afforded to a paramedic. Chapter 401 simply does not provide that a paramedic can provide services to private entities.
As long as the paramedic is providing services during the course of emergency services and transportation or is providing services for health and wellness to prevent illness or injury at a public health program (usually a state or county program) the paramedic is practicing within his/her scope of practice. Once a paramedic delivers services outside of Chapter 401, that is, for a private entity, even if self-owned, that would be considered practicing outside a paramedic’s scope of practice. Thus, based on the statutory language, the Department of Health is likely to find that a paramedic providing IV administration services outside of Chapter 401, that is, at private entities like doctors’ offices, clinics and Medspas, to be practicing beyond the scope of his/her license.
The above also applies to EMTs.