The Georgia Composite Medical Board (“GCMB”) has released significant updates following its June 4, 2026, meeting regarding its controversial IV Hydration/Therapy Position Statement. These developments provide important clarification about the Board’s positions statement, offers some reassurances, and also provides an important warning to physicians, APRNs, PAs, and healthcare business owners who have been concerned about the Position Statement’s impact.
June 5, 2026: GCMB Releases Public Clarification
One day after its June 4 meeting, the GCMB published a public statement addressing widespread concerns raised by healthcare professionals across Georgia.
According to the Board, the IV Hydration/Therapy Position Statement was not intended to create new law or policy. Instead, the Board stated that the Position Statement was issued to explain the Board’s longstanding interpretation of existing Georgia laws and regulations governing physician supervision, delegation, and collaboration with Advanced Practice Providers (“APPs”).
The Board emphasized several key points:
- It recognizes and values the contributions of APPs throughout Georgia.
- It is not directing physicians or APPs to close their practices.
- It is not terminating existing protocol agreements.
- Physicians and APPs who currently maintain active protocols may continue practicing under those agreements.
- Moving forward, when approving protocol agreements or considering enforcement, the Board makes a commitment to closely examine the relationship between the physician and the APP with the purpose of ensuring independent medical judgment and a truly collaborative relationship between the physician and the APP.
The Board also announced plans to continue discussions with stakeholders and collaborate with other regulatory agencies, including the Georgia Board of Nursing and Georgia Board of Pharmacy, as the issue evolves.
June 5, 2026: Email Sent to Georgia Physicians
The same day, the Board reportedly distributed its public statement to licensed Georgia physicians along with a companion document addressing what it characterized as misinformation circulating within the healthcare community.
In the email communication, the Board attempted to reassure physicians that:
- Contractual arrangements between physicians and APRNs or PAs do not automatically violate Georgia law.
- Physicians should not terminate otherwise compliant protocol agreements solely because of the Position Statement.
- Lawful professional collaboration remains permissible.
This clarification appears to address concerns that many physicians were considering ending protocol relationships out of fear that the Position Statement immediately rendered some existing contractual arrangements unlawful.
June 5, 2026: Board Releases “Misinformation” Document
The Board’s companion document provides additional insight into its position and enforcement priorities.
The Board asserts that its interpretation of the law is not new and has been its position since approximately 2008. The Board characterizes the Position Statement as a restatement of an existing interpretation rather than a policy change.
The Board also disclosed new data regarding protocol approvals:
- Approximately 7,300 protocols have been submitted through the Board’s new online protocol system.
- Approximately 519 protocols have been denied since the Board transitioned to the new online system.
- More than 27,000 active APRN protocols remain in effect statewide.
The Board reiterated that moving forward, when approving protocol agreements or considering enforcement, the Board makes a commitment to closely examine the relationship between the physician and the APP with the purpose of ensuring independent medical judgment and a truly collaborative relationship between the physician and the APP. The Board also reiterates that it is not advising any practice to close, and it is not terminating any currently active protocol agreements.
Looking Back: The May 7 Position Statement
The controversy began on May 7, 2026, when the Georgia Composite Medical Board issued its IV Hydration/Therapy Position Statement addressing physician supervision, APRN delegation, and IV therapy business models. There, the Board reiterates that Georgia law restricts the economic relationship between the APRN & the delegating physician by making it unlawful for a physician to be an employee of an APRN if the physician is required to supervise the employing APRN. However, for the first time in published document, the Board took the position that the term “employee” includes a physician receiving compensation of any kind, monetary or non-monetary, from an APRN or an APRN-owned company in exchange for serving as the supervising or delegating physician. The Board also states that if the APRN is paying the physician through a third-party physician-matching company, the Board will view this arrangement as prohibited where, in substance, the APRN is directly or indirectly compensating the delegating physician through the third-party arrangement.
The Position Statement generated significant concern throughout Georgia’s healthcare community because many APRNs, physicians, and APRN-owned businesses operate under business models that could potentially be affected by the Board’s interpretation. In response to those concerns, the Board issued a Public Notice on May 26 acknowledging the widespread questions raised by the Position Statement and indicating that further discussion and clarification would occur at its June 4 meeting. Since then, the Georgia Composite Medical Board has taken steps to gather additional information and provide further guidance regarding the Position Statement’s impact (as discussed above).
What Has Changed?
The June 5 clarifications do not withdraw or reverse the Board’s underlying concerns regarding physician supervision arrangements, APRN-delegating physician relationships, or certain third-party physician matching models. However, the Board has now made several important points clear:
- The Position Statement was not intended to create new law.
- Existing approved protocols remain in effect and will not be terminated.
- APRNs should not close their practices or stop practicing.
- Physicians should not automatically terminate compliant protocol agreements solely due to having a contractual relationship with the APRN.
- The Board’s primary concern remains meaningful physician involvement and independent medical judgment.
- Additional discussions among regulators and stakeholders are expected.
What Questions Remain?
Despite these clarifications, important questions remain unanswered, including:
- What specific compensation arrangements will the Board consider impermissible?
- How will the Board define “indirect compensation”?
- What level of physician involvement will satisfy the Board’s expectations?
- How will the Board evaluate relationships involving management companies and physician-matching services?
- Will the Board issue formal guidance or rulemaking in the future?
For now, healthcare professionals should understand that while the Board has attempted to calm concerns about immediate disruption, it has also reaffirmed its intent to closely scrutinize physician-APP relationships that appear to lack genuine collaboration or meaningful physician oversight.
Bottom Line
The June 5 updates provide some reassurance for Georgia physicians, APRNs, and PAs. The GCMB has made clear that it is not ordering practices to close, terminating protocols, or announcing a new regulatory framework. At the same time, the Board continues to signal that physician supervision arrangements, particularly those involving compensation for supervisory relationships, will remain an area of heightened scrutiny.
Healthcare professionals operating APP-driven practices should continue monitoring developments as discussions between the GCMB, Georgia Board of Nursing, and other stakeholders continue in the coming months. In addition, it would be very prudent for APRNs and physicians to closely examine their current arrangements to ensure compliance and proper documentation.
If you are a healthcare professional whose protocol agreement has been denied or are facing enforcement action regarding these issues, please use this link to request a consultation with the firm.
You can find the Board’s documents here: