Michael Behan

Response to HB 1321 As an owner of Prime IV Hydration & Wellness, which we opened in January 2024, I appreciate the effort HB 1321 makes to define the scope of practice in elective IV therapy settings. When launching our business, my partner and I spent significant time contacting multiple New Hampshire state departments seeking clear regulatory guidance. Ultimately, we retained healthcare counsel and learned that the statutory framework lacked specificity in this area. For that reason, I am encouraged to see this bill introduced. However, in my view, the bill does not go far enough in clearly defining scope of practice—particularly regarding qualified personnel. Our clinical team includes an Advanced EMT (AEMT), paramedics, and Registered Nurses. Through direct operational experience, we have found our EMS professionals to be exceptionally skilled in IV placement. Initially, I believed we would need to staff exclusively with RNs. After further research, I came to understand that AEMTs and paramedics are required to establish IV access in high-pressure, unpredictable field environments—often in moving ambulances en route to hospitals. By comparison, an elective IV clinic provides a calm, controlled, and stable setting. Having observed both EMS personnel and nurses in our clinic, I have been impressed by the technical proficiency and experience EMS professionals bring to patient care. Their expertise has strengthened our overall clinical standards and contributed to an exceptionally safe environment for our clients. Our medical malpractice carrier has also raised no concerns regarding this staffing model. At a minimum, I respectfully recommend that AEMTs and paramedics be explicitly included among qualified providers under the bill. While I do not have experience employing LPNs or LVNs with IV certification in this setting, I can speak directly to the competence and safety record of EMS professionals in our practice. Our most experienced clinician is an AEMT who also serves with a New Hampshire fire department. He places IVs safely and competently in both emergency and elective settings. He is a dedicated professional who supports his family through his work and takes great pride in his role. It would be unfortunate if regulatory language inadvertently limited opportunities for highly trained EMS professionals who demonstrably enhance patient safety. HB 1321 is a positive and necessary step. With thoughtful revisions to clearly include AEMTs and paramedics within the defined scope, the bill can more fully protect both patients and providers while reflecting the realities of modern clinical practice. Sincerely Yours, Michael Behan, Owner Preventive Healthcare of New England, LLC dba Prime IV of Salem, NH