IDENTIFYING SOMEONE TO ADMINISTER INFUSION

In California

State-level regulations are a critical factor in determining access to treatment and shaping advocacy efforts. These policies can either support patients or limit their ability to receive necessary care. Read on to learn more about the regulatory landscape in California and how advocacy is affected.

See more California-specific topics:

Non-medical SUD facilities

  • Staff-assisted administration of infusion and injection medications is not permitted. Clients who are unable to self-administer their injection or infusion medication would require placement in a SUD facility with medical staff.

    Source:

    • Licensing and Certification Division and Department of Health Care Services on July 13, 2023.

  • “I understand that staff are not permitted to administer injection and infusion medications for patients. 

    Have you considered allowing patients to self-administer their medications? Most people with bleeding disorders, like [patient’s name] are able to self-administer with no medical oversight and minimal accommodations. And per CA state regulations, patients are permitted to self-administer infusion and injection medications in non-medical SUD facilities.

    If your facility does not currently have established policies and procedures for self-administration, we’d be happy to share some sample language of self-administration policies for you to consider. Self-administration is a great way for individuals who are trained to maintain access to their medications in the absence of staff who are able to administer them. 

    [Patient’s name]'s bleeding disorder treatment team is an excellent resource and is ready to partner with you to help ensure that you are comfortable with the plan of care. They can provide information on how to supervise an IV infusion or injection, as well as discuss the very reasonable accommodations [patient’s name] would need to self-administer on their own. The bleeding disorder treatment team can provide ongoing support for you and your team to ensure everything goes smoothly and safely.

    If you are not comfortable permitting [patient’s name] to self-infuse, have you considered bringing in an external provider to provide this service?

    Just so you’re aware, under the CA Code of Regulations, if a non-medical SUD program does not have staff available to administer routine physical health medications, such as infusion or injection medications, the facility is allowed to arrange for an external provider to administer the patient’s medication. [Patient’s name] has a specialized care team at [his/her/their] bleeding disorder treatment team) and this team would be more than happy to work with you to provide this service for [patient’s name] during their stay at your facility or can help identify a provider in your area.

    If you are not comfortable permitting self-infusion or external providers to administer infusions at your facility, do you have any recommendations for other facilities that might be open to helping us? 

  • Send the following to the facility:

Medi-Cal members

  • The Behavioral Health Plan (BHP) may authorize and arrange for a contracted provider or another entity to deliver medical and health medical services. The most reliable way to obtain current information about a county’s provider network is to contact the county BHP directly.

    Source:

    • Medi-Cal Behavioral Health – Policy Division, California Department of Health Care Services via email on July 9, 2025.

  • Talking Points for Facilities When a Patient Requires Infusion or Injection Support

    "[Insert patient name] will require someone to administer [his/her/their] bleeding disorder medication during [his/her/their] stay at your facility. Maintaining the patient’s established treatment protocol is essential to ensuring bleeding disorder stability and significantly reduces the risk that mental health or substance use disorder treatment will be interrupted by a bleeding episode."

    Step 1: Assess internal capacity
     "Do you have someone on staff who is qualified to administer an [infusion/injection]?"

    Step 2: Explore in-system options
     "If not, is there a provider from a medical unit within your healthcare system who might be able to administer the medication?"

    Step 3: Explore external provider options
     "If no one within your facility or health system is available, would your facility permit an external provider to administer the medication onsite?"

    "Do you currently have any contracts with:

    • A home infusion or visiting nurse agency?

    • A specialty pharmacy with staff trained to administer infusions or injections?"

    Step 4: One-time/one-off administration option
     "If you do not have an existing contract, would you permit one of the following to administer the medication at your facility on a one-time basis? We would be happy to help develop a single-use case agreement, if needed:

    • A staff member from our Hemophilia Treatment Center (HTC)

    • A home infusion nurse

    • A visiting nurse

    • A trained professional from a specialty pharmacy"

    Step 5: Consider family/caregiver support
     "Would your facility permit a trained family member or legal guardian—approved by the bleeding disorder treatment team—to administer the infusion or injection onsite?"

    Final note on standard of care
     "Asking a person to discontinue their bleeding disorder treatment in order to receive mental health or substance use disorder care would represent a violation of the standard of care. We are committed to working with you to find a safe and appropriate solution."

  • Send the following to the facility:

PHFs and MHRCs

  • Medication and treatment shall be administered only by licensed medical or licensed nursing personnel on staff. If the facility does not have staff licensed, available, and comfortable with administering the medication, they cannot admit the individual. External providers are not permitted to administer medications in the facility.

    Sources:

    • For PHFs, use the script below and add: “Just so you’re aware, we have confirmed with the Licensing and Certification Division of the Department of Health Care Services that  infusions and injection medications for non-behavioral health indications can be administered by licensed medical or nursing personnel on your staff. If a staff member’s license permits them to administer injections or infusions, they are permitted to do so. Do you have someone on staff who is qualified to administer these medications? 
      If you have staff who are licensed but do not feel comfortable, [patient’s name] bleeding disorder treatment team is more than happy to provide training to staff on how to administer these medications. They are very easy to learn. We teach community members to administer these medications all the time.”

    • For MHRCs, use the script below and add: “Just so you’re aware, infusion and injection medications for non-behavioral health indications, can be administered by licensed medical or nursing personnel, per California Code of Regulations (CCR), Title 9 Section 785.13, Nursing Service-Administration of Medication and Treatment. We’ve verified this with the Licensing and Certification Division of the Department of Health Care Services.

      If you have staff who are licensed but do not feel comfortable, [patient’s name] bleeding disorder treatment team is more than happy to provide training to staff on how to administer these medications. They are very easy to learn. We teach community members to administer these medications all the time. “

    Talking Points for Facilities When a Patient Requires Infusion or Injection Support

    "[Insert patient name] will require someone to administer [his/her/their] bleeding disorder medication during [his/her/their] stay at your facility. Maintaining the patient’s established treatment protocol is essential to ensuring bleeding disorder stability and significantly reduces the risk that mental health or substance use disorder treatment will be interrupted by a bleeding episode."

    Step 1: Assess internal capacity
     "Do you have someone on staff who is qualified to administer an [infusion/injection]?"

    Step 2: Explore in-system options
     "If not, is there a provider from a medical unit within your healthcare system who might be able to administer the medication?"

    Step 3: Explore external provider options
     "If no one within your facility or health system is available, would your facility permit an external provider to administer the medication onsite?"

    "Do you currently have any contracts with:

    • A home infusion or visiting nurse agency?

    • A specialty pharmacy with staff trained to administer infusions or injections?"

    Step 4: One-time/one-off administration option
     "If you do not have an existing contract, would you permit one of the following to administer the medication at your facility on a one-time basis? We would be happy to help develop a single-use case agreement, if needed:

    • A staff member from our Hemophilia Treatment Center (HTC)

    • A home infusion nurse

    • A visiting nurse

    • A trained professional from a specialty pharmacy"

    Step 5: Consider family/caregiver support
     "Would your facility permit a trained family member or legal guardian—approved by the bleeding disorder treatment team—to administer the infusion or injection onsite?"

    Final note on standard of care
     "Asking a person to discontinue their bleeding disorder treatment in order to receive mental health or substance use disorder care would represent a violation of the standard of care. We are committed to working with you to find a safe and appropriate solution."

  • Send the following to the facility:

    • Sample single use case agreement: This document provides facilities with sample language that could be incorporated into a contract with an external provider for services related to a specific patient.

    • Add the following:

      “Just so you’re aware, we have confirmed with the Licensing and Certification Division of the Department of Health Care Services that infusions and injection medications for non-behavioral health indications can be administered by licensed medical or nursing personnel on your staff. If a staff member’s license permits them to administer injections or infusions, they are permitted to do so. Do you have someone on staff who is qualified to administer these medications? 


      If you have staff who are licensed but do not feel comfortable, [patient’s name] bleeding disorder treatment team is more than happy to provide training to staff on how to administer these medications. They are very easy to learn. We teach community members to administer these medications all the time.”