---
title: "Cash-Pay Services A Clinic Can Offer Outside Insurance | RMA"
description: "An overview of cash-pay medical procedures for clinics, each with its FDA status: PRP, toxins and fillers, plasma gel, adipose banking and donor products."
url: "https://regenmedacademy.com/cash-pay-services-outside-insurance/"
---

# What cash-pay services can a clinic offer outside insurance?

- [Oscar Tellez](https://regenmedacademy.com/oscar-tellez/)
- November 5, 2026

![Cash-pay services: a closed green folio, a pen and a stack of blank cards on a stone counter in sunlight](https://regenmedacademy.com/wp-content/uploads/2026/10/cash-pay-services-outside-insurance.webp)

*Written by [Oscar Tellez](https://regenmedacademy.com/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 November 5, 2026.*

A clinic can offer several kinds of cash-pay medical procedures outside insurance, and each kind has its own FDA status. Toxins and dermal fillers are approved products that can be used on their labels, while PRP injections and plasma gel are off-label uses. Adipose banking is a storage service, and donor products such as exosomes and Wharton’s jelly are subjects to learn about, not services to offer. Which of these you may perform is set by your own state license and board.

## What does “outside insurance” mean for a clinic?

It means two things at once. The patient’s health plan does not cover the service, and the patient pays the practice directly. People search for services like these as cash based services for a medical practice, or as non-insurance medical services for clinics. Both names point to the same idea.

It does not have to mean the practice has left insurance. Can you offer a non-covered service while you stay in network, and how do you keep the two apart? That is a question for your payer contracts, your biller and your attorney, and this post does not answer it.

It also does not mean the service sits outside the rules, because insurance is only one set of rules. FDA still decides what a product is approved or cleared for. The FTC’s rules still cover what an ad may claim, and your board still decides what your license covers.

So the useful way to sort cash-pay services is by status, not by price. That is how the rest of this post is laid out.

## What do approved, cleared and off-label mean?

You need three words before you can sort anything, and a sales sheet can mix them up.

Approved is the first word. FDA says “[new drugs and biological products for people must be FDA approved before they are marketed, offered for sale, or shipped in interstate commerce](https://www.fda.gov/consumers/consumer-updates/it-really-fda-approved).” An approval is for a named product and a named use, and some devices, such as dermal fillers, are approved as well.

Cleared is the second word, and it belongs to many medical devices. FDA explains it this way: “[A 510(k) is a premarket submission made to FDA to demonstrate that the device to be marketed is as safe and effective, that is, substantially equivalent, to a legally marketed device](https://www.fda.gov/medical-devices/premarket-submissions-selecting-and-preparing-correct-submission/premarket-notification-510k).” In plain words, a cleared device was compared to a device already on the market, for a stated use.

Off-label is the third word. FDA wrote its definition about drugs: “[Unapproved use of an approved drug is often called ‘off-label’ use](https://www.fda.gov/patients/learn-about-expanded-access-and-other-treatment-options/understanding-unapproved-use-approved-drugs-label).” For devices, [federal law on the practice of medicine](https://www.law.cornell.edu/uscode/text/21/396) leaves a provider free to use “any legally marketed device” for a patient inside a real provider-patient relationship. What a clinic may say about that use in an ad is a separate question.

What about “FDA registered”? It is not an approval of anything. FDA’s page on what “FDA approved” means says that registering an establishment or listing a device “does not denote approval.”

Learning these words is not busywork. 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.”

Free mini course

The FDA rules behind this field, in a short, self-paced course. It costs nothing.

[Get the free FDA course](https://regenmedacademy.com/fda-legal-foundations-of-regenerative-medicine/#free-course)

## What is the status of regenerative injections such as PRP?

PRP is short for platelet-rich plasma, and it is prepared in the office from the patient’s own blood. The status question is really about the device that prepares it.

FDA lists those devices under one definition: “[Preparation of autologous platelet rich plasma from a small sample of peripheral blood for mixing with bone graft to improve handling characteristics](https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfPCD/classification.cfm?ID=ORG).” Autologous is a long word for a plain idea, which is that the material comes from the patient’s own body.

In plain words, the devices that prepare PRP are FDA cleared for use with bone graft material. Injecting PRP into joints, tendons, ligaments, skin or scalp is an off-label use. Read the clearance for the exact system you own, because that document is where your own status starts.

There is also no approved PRP product. FDA keeps a live [list of approved cellular and gene therapy products](https://www.fda.gov/vaccines-blood-biologics/cellular-gene-therapy-products/approved-cellular-and-gene-therapy-products), and no PRP product was on it when we checked on October 5, 2026.

Status and evidence are two separate things, and you need to know both. The American College of Rheumatology’s 2026 update says, “[In people with knee and hip OA, we strongly recommend against PRP treatment](https://assets.contentstack.io/v3/assets/bltee37abb6b278ab2c/bltb3d12c34020da842/oa-guideline-summary-2026.pdf).” OA is short for osteoarthritis.

That line speaks to two joints, and it is not a statement about every use of PRP. For any other use, ask what has been published, and be ready to tell a patient where the evidence stops.

Our posts on [what PRP is](https://regenmedacademy.com/what-is-prp-therapy/) and on [whether PRP is FDA approved](https://regenmedacademy.com/is-prp-fda-approved/) go further into both.

## What is the status of aesthetic injectables?

This group holds the approved products, which makes its status the shortest one to state. There are two kinds of product in it.

Dermal fillers are the first kind. FDA’s page on [dermal fillers](https://www.fda.gov/medical-devices/aesthetic-cosmetic-devices/dermal-fillers-soft-tissue-fillers) calls them “medical device implants approved by the FDA,” and it lists what they are approved for. The list includes moderate to severe facial wrinkles and skin folds, and added volume in the lips, cheeks, chin and back of the hand.

Toxins are the second kind. Botulinum toxin products are FDA-approved prescription drugs, and each product’s approved uses are printed on its own label. You can read any current label on [DailyMed](https://dailymed.nlm.nih.gov/dailymed/about-dailymed.cfm), which calls itself “the official provider of FDA drug label information.”

On-label means your use matches the label. When it does not match, the use is off-label, and that includes uses in sexual health. Say the word plainly in the consult and in the consent form.

Two more points come with this group. Use only FDA-approved toxin products that you bought from authorized sources. And take FDA’s own line to providers seriously: “Do not inject dermal fillers if you do not have the appropriate training or experience.”

Who may inject is a state scope question, and the answer can change with the state and with the license. What you may perform is set by your own state license and board. A Certificate of Completion does not extend it. Our post on [who can draw, spin and inject PRP](https://regenmedacademy.com/who-can-draw-spin-and-inject-prp/) shows how to work through a question like that with your board.

## Where does plasma gel fit?

Plasma gel sits between the last two groups, and that is where the confusion starts. It is made from the patient’s own plasma, and in aesthetics it goes by the name bio-filler.

Is it a dermal filler in FDA’s sense? No. Plasma gel is not an FDA-approved dermal filler, and its use is off-label. It is made from plasma, and the devices that prepare PRP are cleared for use with bone graft material.

So keep the words straight when you describe it. Do not call it an approved filler, and do not let a brochure say that for you. Your consent form, your web page and your front desk should all say the same two things, which are what it is made from and that its use is off-label. Our post on [what regenerative aesthetics means](https://regenmedacademy.com/what-is-regenerative-aesthetics/) covers the wider group.

## Is adipose banking a medical service or a storage service?

Adipose banking is a storage service. Adipose simply means fat, and banking means a patient’s own fat tissue is collected and then kept at a laboratory. The house line is short, and a patient should hear it the first time the subject comes up: banking is preservation, not treatment.

Your part as the provider is the collection. You collect the tissue with a legally marketed, FDA-cleared liposuction system, inside its cleared indications and labeling. Then you handle the specimen, document the chain of custody, and send it to a U.S.-based biobanking laboratory.

The banking itself is performed by a third party laboratory that you choose. It is not performed by your clinic, and it is not performed by us.

What may you say to a patient about it? You may describe the collection, the storage and the paperwork. You may not say what stored tissue will do, or may do, at some later date. Our posts on [what adipose banking is](https://regenmedacademy.com/what-is-adipose-banking/) and on [how to offer fat banking in a clinic](https://regenmedacademy.com/how-to-offer-fat-banking-in-a-clinic/) cover the details.

Fat tissue also falls under FDA’s tissue rules, and they are a longer conversation. Our post on [the 351 and 361 rules](https://regenmedacademy.com/351-vs-361-hctp-rules/) explains where FDA draws those lines.

## Which areas are for education only?

Donor products are for education only. That group includes exosomes and Wharton’s jelly. Neither one is a service a clinic can just add.

Start with exosomes. FDA’s public safety notification from December 6, 2019 says, “[There are currently no FDA-approved exosome products](https://www.fda.gov/vaccines-blood-biologics/safety-availability-biologics/public-safety-notification-exosome-products).” It says exosomes “used to treat diseases and conditions in humans are regulated as drugs and biological products” and are “subject to premarket review and approval requirements.”

Wharton’s jelly is the gelatinous connective tissue of the umbilical cord, and it is a donor product. No Wharton’s jelly product is FDA approved. FDA names both Wharton’s jelly and exosomes among the products being marketed without approval. It also says it “[has repeatedly notified manufacturers, clinics, and health care practitioners of the need for Investigational New Drug applications (INDs) to legally administer these products](https://www.fda.gov/vaccines-blood-biologics/consumers-biologics/important-patient-and-consumer-information-about-regenerative-medicine-therapies).”

Why learn about them at all, then? A rep may sit in your office one day, or a patient may ask you about them. You will want to know the status before that day comes.

Here is what I tell providers about that visit: “If you ask a vendor for the certificate of analysis and they don’t want to give it, or they don’t have it, that’s your answer. Run away.”

That advice is for donor products only, since PRP and fat prepared in your own room have no such certificate. The exosome vendor checklist we use is the work of [Dr. Carla Mazzeo](https://regenmedacademy.com/dr-carla-mazzeo/), PhD, who is on our science faculty.

Our posts on [whether exosome products are legal in a clinic](https://regenmedacademy.com/are-exosome-products-legal-in-my-clinic/) and on [what Wharton’s jelly is](https://regenmedacademy.com/what-is-whartons-jelly/) go deeper.

## What does this overview leave out?

It leaves out a lot, on purpose. Hormone, weight loss and IV services each carry their own rules, and they are not covered here.

It also leaves out the insurance side. How a non-covered service lives beside your insurance work is a contract and billing question, and this post only names it. The same goes for how the practice is owned and set up, which belongs with your attorney.

## What should I ask about any new cash-pay service?

The same short list of questions fits every service in this post, and any new one a rep brings you next year. I have one line for this: “Define the terms, ask the questions, and do it right.”

- What is the service, in one plain sentence that a patient would understand?
- What is the FDA status of the product or the device, and for which use?
- Is the way you plan to use it on-label or off-label?
- Has your board confirmed that your license covers it in your state?
- What will your consent form say about status, about what is known and about what is not known?
- Can you describe it in your marketing without a claim about what it will do?
- What has your malpractice carrier told you in writing?
- What paper can the seller show you, such as a clearance, a label or a certificate of analysis?
- Who will train you, and will you work on a consenting patient under supervision?

If you cannot answer one of these yet, finding the answer is your next task.

## How do I choose among these cash-pay services?

An overview tells you what exists, but it cannot tell you what fits. For that you need to look at your own patients, your own license, your room and your team.

We wrote a separate post on [which regenerative service to add first](https://regenmedacademy.com/which-regenerative-service-to-add-first/), and it gives you five questions to put to each service. It also explains why we will not rank these services by income. Nobody outside your practice can know that number.

Once you have picked one, the steps come in a set order. Our [roadmap for adding a cash-pay procedure](https://regenmedacademy.com/how-to-add-cash-pay-procedures-to-a-medical-practice/) walks through them, from the scope check to the first patients.

## Which of these services does Regen Med Academy teach?

We teach some of them. Regen Med Academy sells education and nothing else. We do not sell a device or a biologic, and we are not tied to any vendor.

Our hands-on courses cover PRP for [musculoskeletal injuries](https://regenmedacademy.com/musculoskeletal-courses/), PRP for aesthetics and hair loss, and bio-fillers with plasma gel. They also cover adipose and MFAT tissue harvesting, and Adipose Collection for Stem Cell Banking.

Our [sexual health courses](https://regenmedacademy.com/sexual-health-courses/) teach PRP, toxins and fillers used off-label. Toxin training by itself is available on request.

The exosome and Wharton’s jelly courses are online, they are education only, and they are open as a wait list. You can [see all courses](https://regenmedacademy.com/our-courses/) on one page.

All hands-on training is private. The price starts at $5,000 when you come to an instructor’s location, and at $10,000 when the instructor comes to you, with travel and lodging inside the quote. Every engagement is quoted, and you leave with a Certificate of Completion, which is not a license.

## Frequently asked questions

### Are cash-pay services still regulated if no insurance company is involved?

Yes. Insurance is only one set of rules, and the others stay in place. FDA still sets the status of the product or the device, and the FTC’s [guidance on health claims](https://www.ftc.gov/business-guidance/resources/health-products-compliance-guidance) still says advertising “must be truthful and not misleading.” Your state board still sets your scope, and your consent duties to the patient stay the same.

### Where can I check the FDA status of a product myself?

You can check most of it on FDA’s own pages. For a device, read its clearance and its product classification, and for a drug such as a toxin, read the current label on DailyMed. For a cell or tissue product, look at FDA’s list of approved cellular and gene therapy products. If a seller’s sheet says something different, ask the seller to show you the document.

### Are all cash-pay services cosmetic?

No. Aesthetic injectables are one group, but PRP for a tendon and adipose banking are not cosmetic services. What the groups in this post share is that the patient pays the practice directly. Sort them by FDA status and by your own scope, and use our [rules by state page](https://regenmedacademy.com/regenerative-medicine-laws-by-state/) as a starting point for the state side.

### Can I learn one of these services in a day or a weekend?

Providers ask us this before they book, and the answer is no. A day or a weekend does not make a specialist. A course gives you enough supervised contact to begin, and people to call afterward. After that we tell providers to start slowly, with staff, family and friends. Ask your board whether it has its own rules about family members and employees as patients.

### Do I have to tell a patient that a use is off-label?

Our own rule is to say “off-label” plainly, in the consult and in the consent form, every time it applies. What your state requires in a consent form is a legal question, so have your own attorney review the form. Either way, the patient should hear the status from you first.

### Does Regen Med Academy offer CME credit for these courses?

No. We do not offer CME, credit hours or accreditation of any kind. You receive a Certificate of Completion, which says that you trained with us and does not extend your scope of practice. If you need credit this year, take a credit course for that.

## Key takeaways

- “Outside insurance” means the plan does not cover the service and the patient pays. It does not mean outside the rules.
- Learn three words first: approved, cleared and off-label. “Registered” is not an approval.
- Approved toxins and dermal fillers can be used on their labels, and any other use of them is off-label.
- The devices that prepare PRP are cleared for use with bone graft material, so injecting PRP is off-label. Plasma gel is off-label too.
- Adipose banking is a storage service. Banking is preservation, not treatment.
- Exosomes and Wharton’s jelly are subjects to learn about, because no product of either kind is FDA approved.
- Put the same nine questions to every new service, and take scope to your board.

## 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.

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

## Your next step

Pick the one or two services on this page that match the patients you already see, and write down the status of each in your own words. Then read [which regenerative service to add first](https://regenmedacademy.com/which-regenerative-service-to-add-first/) to choose between them. If you want the rules laid out from the start, [get the free FDA course](https://regenmedacademy.com/fda-legal-foundations-of-regenerative-medicine/). When you have picked a service and want to train, [request a date now](https://regenmedacademy.com/contact/).

The course that goes with this post

## PRP training

Every PRP course in one place, from the first draw to aesthetics and sexual health, private and hands on.

[See the course](https://regenmedacademy.com/prp-training/)

[Request a date now](https://regenmedacademy.com/contact/?course=prp)

[Or see all courses](https://regenmedacademy.com/our-courses/)

[PrevPrevious351 or 361: which rule covers the product in my clinic?](https://regenmedacademy.com/351-vs-361-hctp-rules/)

[NextWho can collect adipose tissue for banking?Next](https://regenmedacademy.com/who-can-collect-adipose-tissue-for-banking/)

#### Table of Contents

Prefer our take? Star us in Google.

## More from the blog

[Nov 6, 2026By Oscar Tellez ### Who can collect adipose tissue for banking? Read Written by Oscar Tellez, founder of Regen Med Academy. Oscar is not a clinician. This post is education…](https://regenmedacademy.com/who-can-collect-adipose-tissue-for-banking/)[Nov 4, 2026By Oscar Tellez ### 351 or 361: which rule covers the product in my clinic? Read Written by Oscar Tellez, founder of Regen Med Academy. Oscar is not a clinician. This post is education…](https://regenmedacademy.com/351-vs-361-hctp-rules/)[Nov 3, 2026By Oscar Tellez ### Who on my staff can draw, spin and inject PRP? Read Written by Oscar Tellez, founder of Regen Med Academy. Oscar is not a clinician. This post is education…](https://regenmedacademy.com/who-can-draw-spin-and-inject-prp/)

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