Frequently Asked Questions: FDA Regulatory Status of Interventional Pain Treatments
This FAQ addresses the regulatory status of common interventional pain treatments, with particular emphasis on platelet-rich plasma (PRP), stem cell therapies, and other regenerative medicine approaches.
Platelet-Rich Plasma (PRP)
Q: Is PRP FDA-approved for pain management?
No, PRP is not FDA-approved for interventional pain treatments. PRP falls under the FDA's Center for Biologics Evaluation and Research (CBER) jurisdiction and is exempt from the traditional FDA regulatory pathway under 21 CFR 1271.
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Most PRP preparation systems have 510(k) clearance only for producing platelet-rich preparations intended to be mixed with bone graft materials to enhance handling properties in orthopedic practices.
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Any use of PRP for intradiscal, epidural, facet joint, or sacroiliac joint injections is considered off-label use.
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Q: What are my responsibilities when using PRP off-label?
When using PRP off-label, clinicians must "be well informed about the product, to base its use on firm scientific rationale and on sound medical evidence, and to maintain records of the product's use and effects".
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All regenerative therapies must follow applicable FDA regulations.
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Q: Are there any special regulatory concerns with activated PRP?
The language in 21 CFR 1271 has raised some regulatory concern regarding activated PRP, though the FDA has not attempted to regulate it to date.
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Clinicians using activated PRP should remain informed about potential regulatory developments.
Q: What is the current evidence level for PRP in lumbar spine applications?
According to the 2025 ASIPP guidelines, intradiscal PRP injections have Level III (fair) evidence with a moderate consensus-based recommendation. Epidural PRP injections also have Level III evidence, while facet joint and sacroiliac joint PRP injections have Level IV (limited) evidence.
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Q: Are stem cell therapies FDA-approved for pain management or musculoskeletal conditions?
No. The only FDA-approved stem cell products are derived from umbilical cord blood and are used to treat certain cancers and disorders of the hematopoietic system, such as leukemias, lymphomas, and sickle cell disease.
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The FDA has not approved stem cell products to treat any other diseases or conditions, such as osteoarthritis, chronic pain, or aging.
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Recently, an MSC therapy was approved for pediatric graft-vs.-host disease, marking the first MSC therapy approved by the U.S. FDA—but this is not for pain or musculoskeletal indications.
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Q: What about bone marrow aspirate concentrate (BMAC)?
BMAC is considered to meet criteria for minimal manipulation and homologous use under FDA regulations, potentially qualifying for the same surgical exemption.
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The 2020 ASIPP position statement provides strong evidence that BMAC preparation involves minimal manipulation and moderate evidence for homologous utility for various musculoskeletal and spinal conditions.
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However, if the FDA does not accept BMAC as homologous, it would require an Investigational New Drug (IND) classification with FDA (351) cellular drug approval for use.
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Q: What is the evidence level for stem cell therapies in lumbar spine applications?
According to the 2025 ASIPP guidelines, intradiscal injections of mesenchymal stem cells (MSCs) have Level III (fair) evidence with a moderate consensus-based recommendation.
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For knee osteoarthritis, the evidence is highest with Level II evidence based on systematic reviews and randomized controlled trials.
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Q: Are adipose-derived stem cells (stromal vascular fraction) FDA-approved?
No. Stromal vascular fraction (SVF) products are not FDA-approved, and the risks and efficacy are largely uncharacterized.
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These products have skirted FDA regulation by claiming to be of low risk based on autologous use and minimal manipulation, but the FDA has issued warning letters to clinics utilizing SVF products, citing violations such as lack of a valid biologics license and deviations from current good manufacturing practice.
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FDA Warnings About Stem Cell Clinics
Q: Has the FDA issued warnings about stem cell clinics?
Yes. The FDA has issued multiple warnings that stem cell products for joint diseases, sports injuries, chronic pain, and other indications have not been proven safe or effective.
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The FDA cautions that patients are vulnerable to the marketing of stem-cell treatments that are not supported by adequate study, are illegal, and may be harmful.
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The FDA's Office of Criminal Investigations has worked with federal agencies to prosecute those who have manufactured, sold, and utilized stem-cell products without FDA approval.
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Q: Have there been documented harms from unapproved stem cell products?
Yes. A 2021 CDC/FDA investigation documented bacterial infections in 20 patients who received umbilical cord blood-derived products marketed as stem cell treatments.
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Of unopened, undistributed products sampled for testing, 65% (22 of 34 vials) were contaminated with at least 1 of 16 bacterial species, mostly enteric organisms including E. coli and Enterobacter cloacae.
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All but one patient required hospitalization.
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Q: How many stem cell clinics are operating in the United States?
As of March 2021, 1,480 U.S. businesses operating 2,754 clinics were found selling purported stem cell treatments—more than four times as many businesses as were identified 5 years earlier.
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These clinics are selling stem cell products that are not FDA-approved and lack convincing evidence of safety and efficacy.
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Q: What is the FDA's current enforcement stance?
The FDA offered a grace period for "stem cell clinics" until November 2020 to come into compliance by obtaining Investigational New Drug applications and working to secure premarket approval of their products.
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The FDA needs to enforce adherence to their outlined standards to protect patients.
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Q: Are corticosteroids FDA-approved for pain management?
Yes, corticosteroids are FDA-approved for numerous conditions including rheumatic disorders (rheumatoid arthritis, osteoarthritis, acute gouty arthritis, bursitis, tenosynovitis, epicondylitis), inflammatory conditions, allergic states, and many other indications.
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Intra-articular corticosteroid injections use FDA-approved medications for approved indications including osteoarthritis and rheumatoid arthritis.
Q: What about epidural steroid injections?
Epidural steroid injections typically represent off-label use of FDA-approved medications (corticosteroids and local anesthetics). While the drugs themselves are FDA-approved, their epidural administration for specific spine pain indications may not have formal FDA approval for that route or indication.
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Q: Are there FDA warnings about corticosteroid injections?
Yes, the FDA has warned that injection of corticosteroids into the epidural space may result in rare but serious adverse effects, including loss of vision, stroke, paralysis, and death.
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These rare complications may be associated with particulate steroids, with no adverse outcomes reported when nonparticulate steroids were used.
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Q: What is the FDA approval status of spinal cord stimulation?
Spinal cord stimulation (SCS) is FDA-approved for chronic pain and was initially introduced to market in 1967.
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Dorsal root ganglion (DRG) stimulation received FDA approval in 2016 with specific mandated training requirements—physicians must complete both didactic and hands-on training before offering this therapy.
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Q: What's the difference between FDA-cleared and FDA-approved devices?
Medical devices can enter the market through multiple FDA pathways: 510(k) clearance (demonstrating substantial equivalence to existing devices) or premarket approval (PMA) requiring more rigorous safety and efficacy data. Many neuromodulation devices are FDA-cleared rather than approved, representing a lower evidentiary threshold.
Intrathecal Drug Delivery
Q: Which medications are FDA-approved for intrathecal pain management?
Only morphine and ziconotide are FDA-approved analgesics for long-term intrathecal infusion.
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Ziconotide is a selective N-type voltage-gated calcium channel blocker approved for intrathecal use in uncontrolled cancer pain.
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Q: What about birth tissue products (umbilical cord, placental membranes, amniotic fluid)?
Birth tissue products are subject to different regulatory pathways depending on their processing and intended use.
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The FDA has determined the need for varying degrees of regulation for these products for safety and efficacy.
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The regulatory landscape for these products is frequently updated and federally enforced, so clinicians must stay informed to remain within FDA purview.
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Q: Is radiofrequency ablation FDA-approved?
Radiofrequency ablation procedures (conventional, thermal, water-cooled) use devices that may be FDA-cleared but are applied to various anatomical targets without specific FDA approval for each indication.
Q: Are there any recommendations against radiofrequency ablation?
Yes, recent guidelines strongly recommend against facet joint radiofrequency ablation for chronic spine pain. A 2025 BMJ guideline issued strong recommendations against joint radiofrequency ablation with or without joint targeted injection for chronic axial spine pain.
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These reflect evidence-based practice recommendations rather than FDA warnings.
FDA approval status varies significantly by device, drug, and indication rather than by procedure type
Off-label use is common and legal when clinicians meet their responsibilities for informed use based on scientific rationale and sound medical evidence
Stem cell products for pain and musculoskeletal conditions are NOT FDA-approved—the only approved stem cell products are for hematologic malignancies
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PRP devices are FDA-cleared only for bone graft applications—all other uses are off-label
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Recent guidelines recommend against many interventional procedures for chronic spine pain despite their regulatory status
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Clinicians must stay informed about evolving FDA regulations, particularly for regenerative therapies, and should be aware of documented harms from unapproved products
1.
The American Society of Pain and Neuroscience (ASPN) Evidence-Based Clinical Guideline of Interventional Treatments for Low Back Pain.
Journal of Pain Research. 2022. Sayed D, Grider J, Strand N, et al.Guideline
2.
Comprehensive Evidence-Based Guidelines for Regenerative Therapies in the Management of Chronic Low Back Pain: 2025 Update From the American Society of Interventional Pain Physicians (ASIPP).
Pain Physician. 2025. Manchikanti L, Navani R, Navani A, et al.
3.
Investigation of Bacterial Infections Among Patients Treated With Umbilical Cord Blood–Derived Products Marketed as Stem Cell Therapies.
JAMA Network Open. 2021. Hartnett KP, Powell KM, Rankin D, et al.
4.
Mesenchymal Stromal Cell Therapy: Progress to Date and Future Outlook.
Molecular Therapy : The Journal of the American Society of Gene Therapy. 2025. Lu W, Allickson J.New
5.
Bone Marrow Concentrate (BMC) Therapy in Musculoskeletal Disorders: Evidence-Based Policy Position Statement of American Society of Interventional Pain Physicians (ASIPP).
Pain Physician. 2020. Manchikanti L, Centeno CJ, Atluri S, et al.
6.
Intraocular Stem Cell Therapy - 2016.
American Academy of Ophthalmology. 2016. Guideline
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Intraocular Stem Cell Therapy.
American Academy of Ophthalmology (2016). 2016. Guideline
8.
The American Stem Cell Sell in 2021: U.S. Businesses Selling Unlicensed and Unproven Stem Cell Interventions.
Cell Stem Cell. 2021. Turner L.
9.
Governmental Regulations and Increasing Food and Drug Administration Oversight of Regenerative Medicine Products: What's New in 2020?.
Arthroscopy : The Journal of Arthroscopic & Related Surgery : Official Publication of the Arthroscopy Association of North America and the International Arthroscopy Association. 2020. Fang WH, Vangsness CT.
10.
Regenerative Medicine: Pharmacological Considerations and Clinical Role in Pain Management.
Current Pain and Headache Reports. 2022. Kaye AD, Edinoff AN, Rosen YE, et al.
11.
"Platelet-Rich Plasma" Epidural Injection an Emerging Strategy in Lumbar Disc Herniation: A Randomized Controlled Trial.
BMC Musculoskeletal Disorders. 2023. Wongjarupong A, Pairuchvej S, Laohapornsvan P, et al.
12.
The Efficacy of Platelet-Rich Plasma on Tendon and Ligament Healing: A Systematic Review and Meta-Analysis With Bias Assessment.
The American Journal of Sports Medicine. 2018. Chen X, Jones IA, Park C, Vangsness CT.
13.
Platelet-Rich Plasma: Fundamentals and Clinical Applications.
Arthroscopy : The Journal of Arthroscopic & Related Surgery : Official Publication of the Arthroscopy Association of North America and the International Arthroscopy Association. 2021. Sheean AJ, Anz AW, Bradley JP.
14.
Platelet-Rich Therapies for Musculoskeletal Soft Tissue Injuries.
The Cochrane Database of Systematic Reviews. 2014. Moraes VY, Lenza M, Tamaoki MJ, Faloppa F, Belloti JC.
15.
Do Regenerative Medicine Therapies Provide Long-Term Relief in Chronic Low Back Pain: A Systematic Review and Metaanalysis.
Pain Physician. 2018. Sanapati J, Manchikanti L, Atluri S, et al.
16.
Efficacy of Intradiscal Injection of Platelet-Rich Plasma in the Treatment of Discogenic Low Back Pain: A Single-Arm Meta-Analysis.
Medicine. 2023. Peng B, Xu B, Wu W, et al.