How do I offer fat banking in my clinic?

Written by Oscar Tellez, founder of Regen Med Academy. Oscar is not a clinician. This post is education for licensed providers and is not medical advice. Last updated October 30, 2026.

To offer fat banking services in your clinic, you put the pieces in place in a set order before the first patient. You confirm who may collect under your state license, you train, you check the labeling of your collection system and you set up with a laboratory. Then you finish your consent, your records, your price and your wording. Banking is preservation, not treatment, and every step below is built around that line.

Is fat banking a fit for my clinic, and who asks about it?

The question can reach you from two sides. A patient reads about fat banking, or hears about it, and brings it to a provider they already know. Or a provider hears about it from a colleague and wonders whether to add it. If you want the plain definition first, read what adipose banking is.

And why do patients ask? They have their own reasons, and you do not supply one. Banking is preservation, not treatment, so there is no medical reason for you to give.

That gives you the first test of fit. If your plan depends on telling patients what the tissue is for, it is not a fit, because nobody may say that.

Then put four plain questions to your own practice:

• Does a provider here hold a license that covers the collection in this state?
• Do we already do office procedures with a sterile setup?
• Can we give every patient a full consult, with time to read and think?
• Can every person on the team describe the service without adding a promise?

Who in my practice may collect the tissue?

Collection is a procedure, so your state decides who may do it. The answer comes from the license each person holds and from the board that issued it.

So before you spend anything, name the person who will collect and check that person’s scope. It is your responsibility to confirm the modality is legal in your state for your license, and you should do that before you book. The authority on your own scope is your licensing board, not us.

Our reading of each state, with its sources and the date we checked, is on the rules by state page. State law in this field changes, sometimes more than once a year, so use that page as a starting point and not as legal advice.

What you may perform is set by your own state license and board. A Certificate of Completion does not extend it. We take the scope question one license at a time in a later post.

What training do I need before I offer fat banking?

You need to be able to do two different jobs. One is the collection itself, which is hands-on clinical work. The other is everything around it: the consent, the labels, the packing, the records and the words.

Is there one rule on how much training you need? We cannot point you to one that covers every state. So ask your board and your carrier what each of them expects, and choose training that covers both jobs.

Our course is called Adipose Collection for Stem Cell Banking. It covers collection, specimen handling, chain of custody, documentation, consent and what you may say to a patient. It does not teach breaking tissue down with enzymes, isolating cells, growing cells or giving any fat-derived cell product to a patient.

The format is private training. You train alone, or with your staff, and one instructor runs the whole session. The theory arrives online before you travel, and the hands-on part is with a consenting patient, under supervision. Every licensed person in the room performs within their own scope.

Training at an instructor’s location starts at $5,000. Training inside your own practice starts at $10,000, with travel and lodging inside the quote. Every engagement is quoted.

You should also hear what a course cannot do. Here is how I put it: “We want to avoid saying that you’re going to come to our one day training and you’re going to learn everything from A to Z. We know that that is impossible.” What you get is enough supervised contact to begin, and ongoing access to our clinicians afterward.

What collection system do I need, and what does its labeling say?

You need a legally marketed, FDA-cleared liposuction system, and you need to use it inside its cleared indications and its labeling.

Start with what FDA says this kind of device is. FDA’s rule at 21 CFR 878.5040 describes a suction lipoplasty system as “a device intended for aesthetic body contouring.” That sentence is about the device type as a whole. It does not tell you what your own system is cleared for, and we do not say that collecting fat for storage is inside or outside any system’s indications.

Then go to your own system. Cleared does not mean approved. FDA says a 510(k) is a submission “to demonstrate that the device to be marketed is as safe and effective, that is, substantially equivalent, to a legally marketed device.”

Each cleared system has its own statement of indications for use, and that statement sets your lines. FDA keeps a public 510(k) database that you can search by device name or by 510(k) number. Find the clearance for the exact system you own, print it and keep it in your folder.

Then send four questions to the company that makes your system, and ask for the answers in writing:

• What is the 510(k) number for this exact system?
• What does its statement of indications for use say, word for word?
• Is collecting a small amount of fat and sending it to a lab for storage inside that statement?
• Which parts are single-use, and what does the labeling say about them?

If the answer to the third question is no, or is unclear, stop and take it to your attorney before you collect from anyone. For collection systems, we are not tied to any vendor, so bring the system you already own.

How do I set up with a laboratory, and what should I ask any lab?

Banking is performed by a third party laboratory. Your practice collects, and a U.S.-based biobanking lab stores. Before you send a first sample, have three things on paper: your agreement with the lab, the lab’s written instructions, and the storage agreement your patients will see.

You choose the lab, and we do not steer you to one. Ask any lab you consider the same questions.

Here are the questions, and each one needs a written answer:

• Are you registered with FDA as a tissue establishment, and what is your registration number?
• What do you do with a sample after it arrives? Please list every step.
• Who signs the storage agreement, and what are its term and its fees?
• What happens to a sample if the patient stops paying, cannot be reached or dies?
• What happens to stored samples if the lab closes or is sold?
• What are your written instructions for labeling, packing and shipping?
• Who do we call when a shipment is late or damaged, and how do you confirm that a sample arrived?
• What do you say about banking in your own marketing, and what do you allow a practice to say?
• Who owns the lab?

On the first question, look the lab up yourself, and search by the lab’s name. FDA has a public query tool for tissue establishment registrations. That same page says registration “does not constitute a determination that an establishment is in compliance with applicable rules and regulations, that the HCT/P is licensed or approved by FDA, or that the HCT/P is appropriately regulated solely under section 361 of the PHS Act.” HCT/P is FDA’s short name for human cells, tissues, and cellular and tissue-based products.

In plain words, registration puts a lab on a list, and it is not approval.

Why ask what the lab does with a sample? Because FDA has written about what is done to fat. Its 2020 guidance on minimal manipulation and homologous use treats processing that breaks adipose tissue down to isolate its cells as generally more than minimal manipulation. It treats using adipose tissue for musculoskeletal conditions such as arthritis or tendonitis as generally not a homologous use.

Mechanical processing avoids enzymatic digestion, but that does not settle the question by itself. Homologous use and the device’s cleared indication still apply. So get the lab’s steps in writing, and have your attorney read them.

And why ask what the lab says in its own marketing? Because if the lab makes a claim about stored tissue and you repeat it, the claim is now yours.

What belongs in the consent and the records?

Expect at least two documents. One is your practice’s consent for the collection procedure. The other is the storage agreement, and you should ask the lab who signs it and who keeps the original.

What should the consent cover? Take this list to your attorney, because it is a starting list and not a form:

• what will be collected, how, and by whom
• the risks of the collection procedure
• that banking is preservation, not treatment
• that nobody has promised any use for the stored tissue
• where the tissue goes, and who stores it
• every cost, including what storage costs over time
• what happens if a sample is lost, damaged or not accepted by the lab

Our course gives you sample consent forms. They are teaching templates, and your own attorney must review any form before you use it with a patient.

Then come the records. For each patient, keep the signed consent, the procedure note, the label details and the chain of custody log. Keep the tracking record, the lab’s notice of receipt and a copy of the storage agreement as well.

What happens on the day of collection?

This is the outline only. Technique belongs in training with a clinician, so we do not print it here, and we do not print doses.

1. The provider confirms who the patient is and confirms the signed consent.
2. The room and the sterile field are set up the way the labeling and your own policies call for.
3. The area is numbed, and the provider collects a small amount of fat with the cleared system.
4. The sample is labeled the way the lab’s written instructions say.
5. The sample is packed and shipped by those same instructions, and each handoff is written down.
6. The patient gets written aftercare for the collection site.
7. The chart is finished, and the lab’s notice of receipt is added when it arrives.

The day ends with a sample in a box and a complete chart. Nothing is processed in your office, and nothing is placed into the patient.

What may I tell a patient about an adipose banking service?

You may tell a patient the facts of the service, and you should tell all of them. A patient who is about to pay cash for a procedure should get a full walk-through, and that takes a full consult.

So what does a good consult cover? It covers what the service is and what it is not. It covers the collection and its risks, the lab and who owns it, the storage agreement, and every cost today and over time. Then it gives the patient time to read, to ask and to go home and think.

What may you not tell a patient? You may not say what stored tissue will do, can do or may do. That holds in any tense, and it holds for every person in your building.

Patients will ask you why they should do it. That is the hardest moment in the consult, and the answer is short. Tell them it is their decision, that you cannot give a medical reason, and that banking is preservation, not treatment.

If a patient asks what FDA has approved, show them. FDA keeps a list of approved cellular and gene therapy products, and no fat-derived product was on it when we checked on October 5, 2026. Check the date on that page yourself before you quote it.

How do I set a price for fat banking?

We will not give you a number. What we can give you is the list of things your price has to carry:

• the provider’s time for the consult and the collection
• room time and staff time
• single-use supplies, and the cost of the system
• shipping
• the lab’s fees, and who bills the patient for storage
• your training, your coverage and your attorney’s review

Then decide how the money moves, and get it in writing. Does the patient pay the lab directly for storage, or does the patient pay you? If a lab offers to pay your practice, or you plan to add your own fee on top of the lab’s, take that plan to your attorney before you agree to anything.

Will the service pay for itself? Nobody can know that for your practice from the outside, so we will not say. Our roadmap for adding a first cash-pay service walks through the questions to ask.

What may I say in marketing?

You may describe the service. The plain description is tissue preservation and biobanking coordination: we collect a small amount of your fat, and a lab stores it. You may say who collects, which lab stores, what it costs and how to book a consult.

What may you not say? Anything that ties the service to a health reason. The FTC’s Health Products Compliance Guidance says, “Advertising must be truthful and not misleading.” It says marketers need “adequate substantiation for all objective product claims” before an ad runs, and it holds them responsible for claims that are “suggested or reasonably implied.”

A headline or a photo can make a claim that your words were careful not to make.

Keep FDA’s name out of your badges, too. FDA says, “Mere registration of an establishment or listing of a drug or device does not denote approval of the establishment, the drug or device.” A lab’s registration, once the lab has confirmed it to you in writing, and a system’s clearance are facts for the consult, and they are not selling points.

None of this is bad news. This is how I say it: “I don’t see compliance as a burden. It’s an advantage. If you have clarity on what you can and cannot say, then you know how to grow.”

Several states have their own advertising rules as well, and our reading is on the rules by state page. For the wider method, see our post on how to market a regenerative service without making a claim.

What order should I do all of this in?

I have a saying for this kind of work: hard now, easy later. The hard part is the paper, and it comes first.

1. Get your board’s answer on who may collect, in writing.
2. Get your carrier’s answer on coverage, in writing.
3. Read the clearance for your collection system.
4. Choose a lab, get its written answers and have your attorney read the agreement.
5. Train, and bring the staff who will handle the labels, the packing and the records.
6. Finish your consent, your records and your price sheet, with your attorney’s review.
7. Write the one-paragraph description of the service that everyone will use.

Only then do you see your first patient.

Let’s say you run a practice with one physician and one nurse practitioner. This is a made-up example. Before either of them collects from a patient, the practice has a folder with seven written answers in it, one for each line above. If one is missing, the practice is not ready.

Frequently asked questions

Can I use a liposuction system I already own?

Maybe. For collection systems we are not tied to any vendor, so you can bring the system you already own to training. First read its clearance, and ask the maker in writing whether your planned use is inside its indications. If the answer is no or unclear, show it to your attorney before you collect from a patient.

Will patients in my market pay cash for this?

Providers ask us this, and we cannot answer it with a number. What we can say is that the consult carries most of the weight. A patient who does not understand a service cannot weigh it, and a rushed consult leaves them guessing. Build a consult that explains the service, the cost and the limits, and then let patients decide.

Do I need my own malpractice coverage for collections?

You are responsible for your own coverage, in training and in your own practice afterward. Ask your carrier whether this collection procedure is included, and get the answer in writing. Talk to us and we will help you work out what to ask your carrier. We will never tell you that you are covered, because only your carrier can say that.

Does offering banking mean I can offer fat-derived cell procedures?

No. Banking is collection and storage, and our banking course teaches nothing past that. On its patient information page, FDA lists “stromal vascular fraction (fat-derived cells)” among what it calls “unapproved products.” RMA does not teach it, and a banking service should never turn into talk about any procedure.

What if a shipment is lost or damaged?

Ask the lab that question before your first patient, and get the answer in writing. Your consent should tell the patient what happens in that case, and your attorney should approve the wording. Your chain of custody log shows where the sample was at each step, so fill it in as the day goes.

Key takeaways

• Confirm who may collect under your state license and your board before you do anything else.
• Train for both jobs: the collection, and the consent, labels, records and words around it.
• Use a legally marketed, FDA-cleared liposuction system inside its cleared indications and labeling. Read the clearance for the system you own, and ask its maker in writing whether collection for storage is inside it.
• Ask any lab for written answers, and remember that FDA registration is not approval.
• Your consent and the storage agreement need your attorney’s review before a patient signs.
• Price from your real costs, tell the patient the whole cost, and take any payment plan with a lab to your attorney.
• Banking is preservation, not treatment, in the consult and in every ad.

RMA disclosure

Regenerative Medicine Academy (RMA) is an education company. We train licensed providers in some of the techniques this post covers. This post is education only. It is not medical, legal, business, tax or financial advice.

Banking is performed by a third party laboratory that you choose, not by RMA.

It is your responsibility to confirm the modality is legal in your state for your license. Do that before you book.

Your next step

Start with your board, because every other step waits on that answer. Then see how we teach the collection and the paperwork on the banking course page. When you are ready, request a date now, and a person reads it and calls you back within one business day. If you would like to start with the rules, get the free FDA course.