Who on my staff can draw, spin and inject PRP?

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 November 3, 2026.

Who on your staff can draw, spin and inject PRP is decided by your state, one task and one role at a time. Your state’s practice acts and licensing boards set what each license or role may do. The provider who supervises then decides what to hand off inside those limits. No course, vendor or federal agency can answer it for you, so this post gives you the questions to ask for each role and tells you who answers them.

Why are the draw, the spin and the injection three separate questions?

It is easy to ask this as one question, and that is where the trouble starts. A PRP visit has three hands-on tasks in it. Somebody draws the patient’s blood, somebody runs it through the system, and somebody injects what comes out.

Why does that matter when you plan your PRP staff roles? Each task is a different kind of act. The draw puts a needle in a vein, the spin makes the thing that will be injected, and the injection puts it into a patient’s body. Your state may give each act its own answer, so ask the question three times for every person on your team.

One fact sits under all three tasks. FDA lists these systems as a “platelet and plasma separator for bone graft handling.” 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.

If PRP is new to you, start with our post on what PRP therapy is in plain terms.

Who decides what each person on my staff may do?

Your state decides first. The Federation of State Medical Boards, or FSMB, explains that each state and territory “has formally adopted a Medical Practice Act, which defines the requirements for the practice of medicine within their borders and gives authority to a medical board to enforce the act’s provisions.”

Nursing has a law of its own, called a nurse practice act. The National Council of State Boards of Nursing, or NCSBN, has a tool that points you to the act for your state.

Does FDA decide? No. The federal law on off-label use of a device speaks of “a health care practitioner,” and that section does not say who that is.

FDA’s rule for prescription device labels points the same way. A label can say “Rx only,” or it can carry a longer caution that names a physician or “any other practitioner licensed by the law of the State in which the practitioner practices to use or order the use of the device.” That line hands the question back to your state. So read the label, the instructions and the 510(k) clearance for the exact system you own, and note what they say about the user.

After the state comes the provider who supervises. The law draws the outer line, and that provider decides what to hand off inside it. A supervising provider may always choose to hand off less than the state allows.

What do delegation and supervision mean in plain terms?

Delegation means handing a task to another person on the team while you stay answerable for it. Supervision means watching over that work.

Here is how the boards’ own groups write about them. A 2005 FSMB policy paper defines supervision this way: “To oversee or direct professionally a body of work, directly or indirectly, within specified rules and regulations.” Look at the words “directly or indirectly.” They are the reason you ask whether the supervisor has to be in the room, in the building or on the phone.

Who answers for the work? The same paper says, “Supervisors may be accountable for the actions of practitioners under their supervision.” It adds that the people who are supervised may be accountable for their own actions as well. In plain words, both people can be on the hook.

There is also a limit on what may be handed off at all. NCSBN’s national guidelines for nursing delegation say, “The licensed nurse cannot delegate nursing judgment or any activity that will involve nursing judgment or critical decision making.”

That limit is written for nurses, and it is a useful test for any handoff. Hand off a task only if your state allows it, and keep the decision about the patient with the provider who is licensed to make it.

These papers are guides, and neither one is your state’s law. Who is at fault when a handoff goes wrong is a legal question for your attorney, your board and your carrier.

Who can draw blood for PRP?

Your state answers this one, and the answer may differ from role to role.

Here are the questions to ask about any person who will do the draw.

• Does this state license, certify or register people who draw blood, and does this person hold what the state asks for?
• Is the draw inside this person’s own license, or does a provider have to delegate it and stay close by?
• Does the answer change because this blood goes back into the patient and not to a lab?
• Who labels the tube, and when?

Take the third question seriously. A draw for PRP is the first step of a procedure, and the blood goes back into the same patient later in the visit. Ask your board whether it sees a difference.

What should you ask about a phlebotomist? Ask whether your state regulates phlebotomists at all, and who may give one an order. Then ask whether a draw into a PRP device is inside what this person was trained and hired to do.

Who answers these? Start with the board of the provider who will supervise the draw, and ask which state office, if any, oversees people who draw blood. How much blood to draw is a clinical detail, and it is taught in the course under your instructor’s protocol.

Who may run the spin and prepare the PRP?

The spin looks like the easy job, because a person loads a centrifuge and presses a button. It is also the step where the thing that gets injected is made, and that is why it has a list of its own.

• Does this state see preparing PRP as part of the procedure, to be done by the provider who injects or under that provider’s eye?
• May the spin be handed off, to which role, and with what supervision?
• Who trained this person on this exact system, and where is the record?
• Who moves the PRP into the syringe, and is that step covered by the same answer?
• Who checks the name on the tube against the patient before the syringe changes hands?

The settings are not a staffing question. The spin speed, the time and the handling steps come from your system’s instructions and your instructor’s protocol, and they are taught in the course. Our post on what PRP equipment a clinic needs covers the system itself.

Who can inject PRP?

The injection is the task where the license matters most. It puts the prepared PRP into a patient’s body, and the person who does it has to judge the patient, the site and the approach.

So ask these questions about every person who might hold the syringe.

• Is this injection, at this site, inside this person’s license in this state?
• Does this person need an order, a written protocol or a supervising provider for it?
• Does the supervising provider have to be trained in PRP, and have to be on site?
• Who has to examine the patient and decide on PRP before anyone injects?
• Does the answer change with the area injected, or when ultrasound guidance is used?
• Has this person done this injection with a clinician watching?

The board that issued the license answers the first five. Training answers the last one, and only the last one. What you may perform is set by your own state license and board. A Certificate of Completion does not extend it.

Whoever decides on PRP for a patient should also be the one who can talk with that patient about the evidence. For a knee or a hip, that talk includes the American College of Rheumatology’s 2026 update, which says, “In people with knee and hip OA, we strongly recommend against PRP treatment.” OA is short for osteoarthritis.

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

Can a medical assistant do PRP?

The short answer is: it depends. It depends on your state, on the task and on who is handing the task off.

Start with how the law sees a medical assistant. The American Association of Medical Assistants, or AAMA, says, “Scope of practice laws for medical assistants may vary by state.” It also says, “Medical assistants are not mentioned by name in the laws of some states,” and that those states often class them as “unlicensed personnel.”

Here’s why. Where a person with no license of their own does a clinical task, it is because a licensed provider handed it over. So every question about a medical assistant is really a question about delegation.

• May a provider in this state hand a blood draw to a medical assistant, and what training does the state ask for?
• May a medical assistant run the centrifuge and handle the kit?
• Does this state let a provider hand any injection to a medical assistant, and does that reach a PRP injection?
• Which providers may delegate to a medical assistant: a physician only, or a nurse practitioner or a PA as well?

We will not answer those for your state, and no course should. Ask the board of the provider who delegates. In our own training, people with no license do not inject.

What should I ask about a registered nurse?

A registered nurse holds a license of their own, so these questions go to the board of nursing.

• Is a blood draw for PRP inside RN practice in this state, and on whose order?
• May an RN prepare PRP or inject it on a provider’s order, and does the answer depend on the site?
• Who has to examine the patient before the order is written, and does that provider have to be on site?
• Has the board put out a position statement or a decision tool for new procedures?
• May the RN hand any part of the work to a medical assistant?

The same NCSBN guidelines say “it is the responsibility of all licensed nurses to know what is permitted in their state NPA, rules/regulations, and policies.” In plain words, the nurse has a duty to know the answer too. A nurse who takes on a task because a doctor said it was fine still answers to the board of nursing.

What should I ask about a nurse practitioner or a PA?

A nurse practitioner starts with how the state handles NP practice. The American Association of Nurse Practitioners, or AANP, sorts the states into full practice, reduced practice and restricted practice. In a restricted practice state, AANP says, the law “requires career-long supervision, delegation or team management by another health provider in order for the NP to provide patient care.”

A label like that covers NP practice in general. It says nothing about PRP, so the NP still has questions for the board of nursing.

• Is a PRP injection, at the sites the NP plans to inject, inside NP scope in this state?
• Does the NP’s agreement or protocol with a physician have to name PRP?
• Does that physician have to be trained in PRP?
• May the NP hand the draw or the spin to a nurse or a medical assistant?

Our post on PRP training for nurse practitioners goes further on the NP path.

A PA’s first job is to find the right board. FSMB notes, “In many states, other health care professionals are also licensed and regulated by medical boards in addition to physicians. Examples include PAs and acupuncturists.” The PA then asks the same four questions about whatever agreement the state calls for between a PA and a physician.

What rules follow anyone who handles blood?

One federal rule follows the task and not the license. OSHA’s bloodborne pathogens standard covers employees with what it calls occupational exposure. It defines that as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.”

Drawing blood and handling the tubes fit that line, and the employer makes that call for each job in the practice.

The rule also makes the employer write the roles down. The employer’s plan has to include “A list of all job classifications in which all employees in those job classifications have occupational exposure.” So your PRP roles belong in that plan by job title.

Then there is the timing. Training has to be given “At the time of initial assignment to tasks where occupational exposure may take place.” In plain words, this training comes before a person’s first draw or first spin. Our checklist of what you need to offer PRP injections covers the plan itself.

Here is where this rule stops. OSHA training is there to protect your staff, and it does not make a task legal for a role. That answer still comes from the board.

How do I write PRP staff roles down?

Write a protocol before the first patient, and keep a record at every visit. The protocol says who may do what, and the record shows who did it.

I call this the soil before the seed. The basics come before any injection, and who does what is one of the basics.

Let’s say you run a practice with one physician, one nurse practitioner, one registered nurse and one medical assistant. Three tasks and four people give you twelve boxes to fill, and each box needs four things written in it.

• Whether the state allows this role to do this task, with the source and the date of that answer.
• Who supervises, and how close that person has to be.
• What training this person has had on this task and on this system.
• What your carrier said about this person doing this task.

A box stays empty until you have the answer in writing, and an empty box means that person does not do that task yet. Some boxes in this made-up practice may stay empty for good, and that is fine.

Then build the visit record to match the protocol. It should show who drew, who ran the spin, who injected and who supervised, every time. Go back to the protocol when you hire and when your state changes a rule.

What can staff without a license still learn?

They can learn the workflow, and the workflow is most of the visit.

Somebody books the visit and answers the first questions on the phone. Somebody sets up the room, checks the date on the kit and has the forms ready. Somebody makes the follow-up call. None of those jobs is the draw, the spin or the injection, and each of them can go wrong.

Providers ask us who can attend a training. Anyone legally able to provide the treatment can train with us. Physicians, nurse practitioners, PAs and nurses are examples, and the list is not closed.

Training is private, so you can train alone or bring your team. Every licensed person in the room performs, within their own scope, and the rest of your staff can learn the workflow around them. When the instructor comes to your practice, your team learns in your own rooms with your own tools, and that format starts at $10,000 with travel and lodging inside the quote.

Frequently asked questions

How do I start offering PRP in my clinic if only one person may inject?

Build the service around that one person, and let the boards’ answers decide the rest. Ask whether the draw and the spin may be handed to other staff, and under what supervision. If those answers come back no, the same provider does all three tasks and you plan the schedule around that.

Does a training certificate let my nurse or my assistant inject?

No. A certificate shows that a person trained, and it does not change what that person’s license or role allows. No government office issues a PRP certification that grants the right to inject, because that right comes from the state license and the board. Ours is called a Certificate of Completion, and it does not extend anyone’s scope.

Which board do I ask when my staff hold different licenses?

Ask the board behind each license. A physician’s question goes to a medical or osteopathic board, and FSMB keeps a contact list for the state medical boards. A nurse’s question goes to a board of nursing. For staff with no license, ask the board of the provider who will hand off the task, and keep every reply.

Does the supervising provider have to be in the building?

That depends on your state, the task and the role, and we will not guess at it. Supervision can mean in the room, on site or within reach by phone. Ask the board which one applies to the draw, the spin and the injection, and ask where the rule is written.

Does my malpractice carrier need to know who draws and who spins?

Ask the carrier, and ask in writing. You are responsible for your own coverage. Talk to us and we will help you work out what to ask your carrier. A good place to start is to name each person, each task and each area you plan to inject, and to ask whether the policy reaches all of them.

Key takeaways

• A PRP visit has three hands-on tasks, and the draw, the spin and the injection each get their own answer.
• Your state’s practice acts and boards decide first, and no vendor, course or federal agency decides for them.
• Delegation means handing off a task while you stay answerable for it, and the judgment about the patient is not handed off.
• Every question about a medical assistant is a delegation question, and the board of the provider who delegates answers it.
• OSHA’s bloodborne pathogens rule follows anyone who handles blood, whatever license they hold.
• Write a protocol with a name in every box, and keep a visit record of who did each task.

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. The authority on your own scope is your licensing board, not us.

Your next step

Draw the grid this week, with the three tasks across the top and every name on your staff down the side. Look up your state on our state-by-state rules page, then send each board its questions in writing. When the boxes are filled, request a date now, and a person will read it and call you back within one business day. If you would like to start with the rules, get the free FDA course.