Nurse entrepreneurship Other mobile nursing services
Nurse entrepreneurship guide
Other mobile nursing services
Injections, blood draws, wound care and care management all start from the same place as IV therapy: the nurse carries out an order within her scope, and the business answers to its own rules.
Educational summary, last reviewed October 17, 2026. Not legal advice — confirm with the state licensing agency or counsel.
Last reviewed October 17, 2026. 25 findings: 15 provisional, 10 verified. 3 time-sensitive, flagged with a recheck date. How findings are sourced and labelled.
1Injections and compounded GLP-1 drugs
Injections need an order in the states read
ProvisionalIn the states read for this point, the boards require a medical order before medication administration: Mississippi’s Board of Nursing requires a valid order and a completed history and physical before the RN administers in IV hydration settings, and South Dakota’s Board of Nursing guidelines (cited by title; no longer at their published address) require a medical order even for elective services a client requests. Neither is an injection-specific rule. Treat any B12, wellness or GLP-1 injection as needing an order from a prescriber authorized in the client’s state.
Not yet confirmed — check with the state board of nursing.
Corrected 2026-10-18: Scoped to the two states whose documents were read and made Provisional; it had been presented as a national, Verified rule.
Source: Mississippi Board of Nursing: IV hydration position statement (Oct 2025)South Dakota Board of Nursing: elective IV infusion and medication therapy guidelines (no longer at its published address; cited by title)
FDA gave 503B outsourcing facilities until March 19, 2025 for compounding that depended on tirzepatide’s shortage listing. For 503A pharmacies and physicians, FDA’s period ran until February 18, 2025 or the court’s decision on a preliminary injunction; the court denied the injunction on March 5, 2025 (FDA update of March 10, 2025).
Corrected 2026-10-18: Now Verified on FDA’s own page; the earlier “conflict” came from a secondary source that gave semaglutide’s 503B date (May 22, 2025) for tirzepatide.
Source: FDA: clarifies policies for compounders as national GLP-1 supply begins to stabilize
Semaglutide
ProvisionalAfter FDA resolved the semaglutide shortage, 503A discretion ended in April 2025 (treated as ended after the court denied a preliminary injunction on April 24, 2025) and 503B discretion on May 22, 2025.
Not yet confirmed — check with FDA.
Source: FDA: clarifies policies for compounders as national GLP-1 supply begins to stabilizeSheppard Mullin: semaglutide shortage resolution
Enforcement in 2026
ProvisionalFDA announced 30 warning letters to telehealth companies on March 3, 2026 over promotion implying compounded products equal approved drugs, signalled restrictions on APIs for unapproved compounded products, and has proposed keeping semaglutide, tirzepatide and liraglutide off the 503B bulks list; the final decision was pending.
Not yet confirmed — check with FDA.
Time-sensitive. Recheck FDA’s 503B bulks-list decision and new warning letters.
Dosing errors
ProvisionalFDA has received adverse-event reports, some involving hospitalization, linked to dosing errors with compounded injectable semaglutide, such as confusing units and milligrams.
Not yet confirmed — check with FDA.
In practice: Document the dose in both milligrams and units.
Source: Becker’s Hospital Review: FDA warns on compounded GLP-1s
Discipline for working without an order
ProvisionalOhio has increased discipline of med-spa nurses doing IV therapy and injections without a valid provider order or supervision.
Not yet confirmed — check with the state board of nursing.
Source: Dinsmore: Ohio med spa nurses disciplined for practicing beyond scope
2Mobile phlebotomy and CLIA
Under the CLIA definition of a laboratory (42 CFR 493.2), facilities that only collect or prepare specimens, or only serve as a mailing service, and do not perform testing are not laboratories, so collection alone needs no CLIA certificate; Montana’s CLIA agency says the same. Washington and New York run CLIA-exempt state laboratory programs, so their own licensing applies there.
Corrected 2026-10-18: Now cites the federal regulation (42 CFR 493.2) as the primary source and notes the Washington and New York exempt-state programs; a secondary source was removed.
Source: 42 CFR 493.2 (CLIA definitions: laboratory)Montana DPHHS: CLIA
Performing even a finger-stick glucose requires a CLIA certificate (Louisiana Department of Health).
California requires an unlicensed person performing venipuncture or skin puncture for testing to hold state phlebotomy certification (Bus. & Prof. Code §1246); RNs appear in the section as permitted supervisors.
Not yet confirmed — check with the California Department of Public Health (Laboratory Field Services).
Recheck on the official site. Read on a verbatim mirror of the statute; confirm the wording on the official site.
Corrected 2026-10-18: Status changed from Verified to Provisional: the statute was read only on an unofficial mirror.
Other state phlebotomy credentials
ProvisionalWashington certifies medical assistant-phlebotomists; Nevada licenses laboratory assistants; Louisiana requires a phlebotomy license.
Not yet confirmed — check with the state board of nursing.
Source: Washington DOH: medical assistant-phlebotomistClark College: licensure disclosures (state phlebotomy credentials)
New York: collecting stations
VerifiedA New York patient service center or collecting station, fixed or mobile, operates only under a permitted clinical laboratory.
Source: Wadsworth Center: patient service centers and health fairs
New York: 2026 changes
ProvisionalNew York reportedly now allows CLIA-waived testing at collecting stations with a limited service laboratory registration, with revised laboratory director qualifications from January 1, 2027.
Not yet confirmed — check with the state board of nursing.
Time-sensitive. Effective January 1, 2027; recheck Wadsworth Center guidance.
Source: McGuireWoods: New York clinical laboratory changes (Sept 2026)
3Wound care
Conservative sharp debridement “may only be performed by RNs with extensive nursing knowledge and training”; surgical sharp debridement is not within RN scope.
Source: Nebraska DHHS: wound debridement
RNs may perform sharp debridement of necrotic tissue on a physician or APRN order with written agency policy; not within LPN scope (Advisory Opinion #27).
Source: South Carolina Board of Nursing Advisory Opinion #27 (sharp debridement)
Oklahoma and West Virginia
VerifiedOklahoma lets RNs and APRNs do mechanical debridement and LPNs only assist with conservative sharp debridement under direct supervision; West Virginia allows debridement as ordered by a qualified RN under written agency policy.
Source: Oklahoma Board of Nursing: wound debridementWest Virginia RN Board: debridement (2019)
Medicare billing for an RN wound service
ProvisionalUnder 42 CFR 410.26, auxiliary personnel, including independent contractors, may furnish services incident to a practitioner’s service, by default under direct supervision; otherwise Medicare revenue comes through a certified home health agency.
Not yet confirmed — check with CMS.
Recheck on the official site. Read on the LII copy of the regulation; confirm on eCFR.
Corrected 2026-10-18: Status changed from Verified to Provisional: the regulation was read only on an unofficial copy.
Source: 42 CFR 410.26 (LII)
Wound certification is voluntary
ProvisionalNo statute requiring WOCN or WCC certification was found; the credentials are a quality signal.
Not yet confirmed — check with the state board of nursing.
Source: Nebraska DHHS: wound debridement
4Care management, advocacy and privacy
Who bills care management
VerifiedMedicare chronic care management is billed by physicians, NPs, PAs, CNSs and CNMs; RNs furnish it incident to the practitioner under general supervision.
HIPAA and the cash-pay advocate
VerifiedA provider is a HIPAA covered entity only if it sends adopted standard electronic transactions; a cash-only advocate may sit outside HIPAA but is a business associate when it works for a covered entity.
Source: HHS: HIPAA Administrative Simplification and ACA FAQs
Apps and portals
VerifiedThe FTC Health Breach Notification Rule (effective July 29, 2024) covers non-HIPAA personal health record vendors and related entities, including most direct-to-consumer health apps.
Source: FTC: Health Breach Notification Rule amendments (2024)
Washington health data
ProvisionalWashington’s My Health My Data Act requires consent before collecting consumer health data and gives consumers a private right of action.
Not yet confirmed — check with the state board of nursing.
5Gig nursing apps
California
ProvisionalNurses are not exempt from California’s ABC test under AB 5.
Not yet confirmed — check with the California Labor Commissioner or the Employment Development Department.
Source: Hooper Lundy: California AB 5 and health care workers
New York
ProvisionalA 2025 New York law reportedly requires gig platforms to comply with temporary health care services agency rules (Public Health Law article 29-K). The citation was not confirmed.
Not yet confirmed — check with the state board of nursing.
Illinois
ProvisionalIllinois amended its Nurse Agency Licensing Act to ban non-competes and limit fees (HB 4666, 2021–22).
Not yet confirmed — check with the state board of nursing.
Carve-out bills
ProvisionalSince 2022 at least 17 states have seen bills to carve gig nursing apps out of staffing-agency rules; carve-outs advanced in Georgia, Ohio, California, Pennsylvania, Missouri and Wisconsin.
Not yet confirmed — check with the state board of nursing.
Time-sensitive. Check 2026 session outcomes.
Source: Duane Morris / Bloomberg Law: gig nursing worker-status bills (Aug 2026)
Official sources
- Mississippi Board of Nursing: IV hydration position statement (Oct 2025)
- South Dakota Board of Nursing: elective IV infusion and medication therapy guidelines (no longer at its published address; cited by title)
- FDA: clarifies policies for compounders as national GLP-1 supply begins to stabilize
- Sheppard Mullin: semaglutide shortage resolution
- Venable: FDA’s latest GLP-1 crackdown (Mar 2026)
- Becker’s Hospital Review: FDA warns on compounded GLP-1s
- Dinsmore: Ohio med spa nurses disciplined for practicing beyond scope
- 42 CFR 493.2 (CLIA definitions: laboratory)
- Montana DPHHS: CLIA
- Louisiana Department of Health: CLIA FAQ
- Cal. Bus. & Prof. Code §1246 (public.law mirror)
- Washington DOH: medical assistant-phlebotomist
- Clark College: licensure disclosures (state phlebotomy credentials)
- Wadsworth Center: patient service centers and health fairs
- McGuireWoods: New York clinical laboratory changes (Sept 2026)
- Nebraska DHHS: wound debridement
- South Carolina Board of Nursing Advisory Opinion #27 (sharp debridement)
- Oklahoma Board of Nursing: wound debridement
- West Virginia RN Board: debridement (2019)
- 42 CFR 410.26 (LII)
- CMS: chronic care management FAQs
- HHS: HIPAA Administrative Simplification and ACA FAQs
- FTC: Health Breach Notification Rule amendments (2024)
- A&O Shearman: Washington’s My Health My Data Act
- Hooper Lundy: California AB 5 and health care workers
- Nurse.org: gig nursing apps report
- LegiScan: Illinois HB 4666 (2021–22)
- Duane Morris / Bloomberg Law: gig nursing worker-status bills (Aug 2026)
Revision history
| Date | Change |
|---|---|
| 2026-10-17 | First published |
About this guide. Published and maintained by Paloma Health Technologies; Findings are cited to official sources, dated and status-labelled; see the editorial policy. Educational summary, last reviewed October 17, 2026. Not legal advice — confirm with the state licensing agency or counsel.
Questions
Other mobile nursing services: common questions
Can a mobile nurse give compounded GLP-1 injections?
Only under a valid prescriber order, with a product lawfully compounded or FDA-approved. The shortage-based route for mass compounding of semaglutide and tirzepatide closed in 2025.
Does a mobile blood-draw service need a CLIA certificate?
Not if it only collects and ships specimens; any test performed, even a finger-stick glucose, needs one.