In 2025, Oklahoma enacted legislation expanding the autonomy of experienced mid-level health care providers, including advanced practice registered nurses (APRNs) and physician assistants (PAs).[1] [2] These changes modify long-standing physician supervision rules once required for all mid-level providers, including those with many years of experience, and allow certain mid-level providers to practice with less physician oversight once they have met statutory experience requirements. These reforms reflect broader national efforts to improve health care access and workforce shortages across the state. Considering Oklahoma’s physician-to-patient ratio is a whopping “39% worse than the national average,” and the state ranks “nearly last in total physician supply,” it is no surprise that all but two Oklahoma counties are designated as health care professional shortage areas, meaning there are too few doctors to provide basic care.[3] That is where mid-level providers make the biggest impact. “The number of employed PAs in the U.S. is expected to grow by 39,300 or 31.3% between 2019 and 2029 ... [t]his growth rate is well above the average rate of labor growth in the healthcare industry,” as described by the Journal of Market Access & Health Policy.[4] The authors go on to assert that by comparison, the projected growth rate for U.S. physician and surgeon positions over the same time period is 3.6%, with a projected 27,300 new physician/surgeon positions over that time.[5]

In an effort to tilt Oklahoma’s provider shortage statistics in the other direction and recognize the training and experience of the state’s mid-level providers, the Legislature enacted new laws to that effect last year. Under House Bill 2298, which was codified on Nov. 1, 2025, APRNs who complete 6,240 hours of supervised clinical practice may apply for independent prescriptive authority to prescribe Schedule III to V drugs.[6] Until that hours requirement is met and approved by the Oklahoma Board of Nursing, an APRN must continue to practice under a physician supervision agreement.[7] Similarly, House Bill 2584, also codified in 2025, reduces supervision requirements for PAs by permitting experienced PAs to practice without a formal supervising physician, as long as they meet statutory criteria and maintain appropriate collaborative relationships and professional liability coverage of a minimum amount of $1 million per occurrence and $3 million in the aggregate per year.[8] These liability minimums are also standard amounts for physicians (and now, APRNS with independent prescriptive authority) to carry in Oklahoma. The statutory expansion also includes prescriptive authority for PAs to prescribe Schedule III to V drugs without a physician supervision agreement.

Although these laws expand autonomy, supervision requirements remain highly dependent on the practice setting. Hospitals and health systems often impose their own credentialing, privileging and oversight rules that may exceed statutory minimums. Clinics may require written collaboration or supervision agreements as a condition of employment or payor participation. Additionally, certain regulatory frameworks – such as osteopathic supervision rules – continue to require documentation, chart review and occasional physician involvement for mid-level providers who have not qualified for independent practice.[9]

Medical spas present a separate and more restrictive regulatory environment. Even where mid-level providers otherwise qualify for independent practice, Oklahoma law and medical board guidance require physician involvement in procedure-based medical spa services. This includes establishing the physician-patient relationship (which mid-level providers can only do with physician supervision), delegating services within the mid-level provider’s scope and maintaining oversight of cosmetic and aesthetic procedures.[10] [11]

As these changes take effect, attorneys advising health care providers, employers and stakeholders must understand how the updated statutes interact with facility policies, board rules and setting-specific supervision requirements.

HISTORICAL FRAMEWORK OF PA AND APRN SUPERVISION IN OKLAHOMA

For decades, Oklahoma regulated PAs and APRNs through statutes that required physician supervision or collaboration as a condition of their practice. These requirements could be found in Title 59 and were enforced through separate licensing boards. Although the two professions were regulated under different acts, both were subject to physician-centered oversight models that limited independent clinical and prescribing authority.[12] While national standards for both professions evolved toward greater independence, Oklahoma law continued to treat physician oversight as a core patient-safety mechanism. Between the two professions, statutory changes occurred slowly and unevenly.[13]

APRN REGULATION AND LEGISLATIVE HISTORY

APRNs are licensed under the Oklahoma Nursing Practice Act and include certified nurse practitioners, certified registered nurse anesthetists, certified nurse-midwives and clinical nurse specialists.[14] Initially, the act authorized advanced nursing practice but conditioned any prescriptive authority on a formal supervisory relationship with a physician. The supervising physician’s role was defined in statute and Board of Nursing rules, and APRNs could not prescribe independently under Oklahoma law.

Between the 1990s and early 2020s, legislative amendments affecting APRNs primarily addressed the scope of delegated prescriptive authority and controlled substance limitations and requirements for physician supervision agreements related to prescribing. These amendments expanded certain practice functions but did not eliminate the requirement that APRNs maintain physician involvement as a condition of prescribing. As a result, APRNs remained legally dependent on physician supervision even where their clinical practice authority had otherwise expanded.[15] During this period, Oklahoma APRN advocates focused on statutory recognition of advanced licensure, alignment with national practice advancements and access to care –particularly in rural and underserved areas. Despite repeated legislative proposals, reform efforts stalled due to concerns raised by physician organizations and regulators regarding patient safety and accountability.[16]

PA REGULATION AND LEGISLATIVE HISTORY

The first PA class, consisting of four Navy hospital corpsmen, graduated from Duke University’s PA program on Oct. 6, 1967.[17] The PA concept was lauded early on and gained federal acceptance and backing as early as the 1970s as a creative solution to physician shortages.[18] Oklahoma law historically required PAs to practice pursuant to written supervision agreements that identified a supervising physician, specified authorized practice locations and listed the medical acts delegated to the PA.[19] Unlike APRNs, whose authority is derived from their nursing license, PA authority was explicitly derivative of physician delegation. Oklahoma statutes also addressed physician availability, chart review and limits on prescriptive authority.[20] Although amendments over time allowed increased flexibility, particularly in rural or underserved settings, the supervision requirement remained a central feature of PA regulation.[21]

PA advocates emphasized that the delegation-based model created administrative burdens, limited mobility between practice settings and failed to acknowledge modern PA education and certification standards. Unlike APRN advocacy, PA reform efforts generally focused on replacing rigid supervision requirements with more flexible collaboration standards.

COVID-19 EMERGENCY MEASURES

The COVID-19 crisis prompted temporary regulatory changes to address acute health care workforce shortages.[22] These measures allowed APRNs and PAs to practice with reduced physician involvement in defined circumstances and provided real-world evidence that they could exercise expanded autonomy without immediate adverse patient safety issues. Although these emergency measures were temporary, they later influenced legislative discussions by providing practical examples of alternative regulatory models.[23]

THE 2025 LEGISLATIVE REFORMS

Ultimately, in 2025, the Oklahoma Legislature enacted significant statutory reforms affecting both APRNs and PAs. Rather than adopting blanket independence, the Legislature chose experience-based autonomy models tied to documented clinical practice hours and continued board oversight.

APRNS – HOUSE BILL 2298

As recently as 2024, Gov. Stitt vetoed Senate Bill 458, which “would have allowed providers like nurse practitioners to independently prescribe certain drugs [Schedule III to V drugs, which include things like anabolic steroids, Ambien and Xanax],” saying “these professionals shouldn’t have this power.”[24] Nevertheless, state lawmakers voted to override the governor’s veto, thus forging the path toward today’s version of the Oklahoma Nursing Practice Act.[25] House Bill 2298 amended the Nursing Practice Act, most notably in Okla. Stat. tit. 59 §567.4c, to authorize independent prescriptive authority for APRNs who complete at least 6,240 hours of supervised clinical practice that includes prescribing.[26] Eligibility is determined by the Oklahoma Board of Nursing, which retains authority to establish rules governing documentation, application procedures and ongoing compliance. APRNs who qualify are no longer required to maintain a supervising physician relationship for prescribing up to a 30-day supply of Schedule III to V drugs, though they remain subject to nursing board discipline and applicable scope-of-practice limitations.

For attorneys advising APRNs or health care employers, House Bill 2298 creates a clear statutory distinction between APRNs with independent prescriptive authority and those who remain subject to supervision requirements.

PAS – HOUSE BILL 2584

Just as he did with the similar APRN-focused bill in 2024, Oklahoma’s governor vetoed House Bill 2584, a bill designed to give PAs the flexibility they sought.[27] Once again, state lawmakers banded together to override the governor’s veto. “The passage of this law allows PAs to do what PAs do best, take care of patients,” said Jeff Burke, PA-C, president of the Oklahoma Academy of Physician Associates.[28] House Bill 2584 amended 59 O.S. §519.6 to allow PAs with at least 6,240 hours of postgraduate clinical experience to practice without a supervising physician agreement in place.[29] The statute removes the previous prohibition against unsupervised PA practice and, in Subsection (D), expands prescriptive authority for qualifying PAs.[30]

The law directs the Oklahoma State Board of Medical Licensure and Supervision to verify eligibility and maintain a list of PAs authorized to practice independently.[31] PAs who do not meet the experience threshold remain subject to supervision requirements under existing statutory and regulatory provisions. From a compliance perspective, the statute creates two distinct regulatory categories for PAs with differing supervision and prescribing obligations. For instance, PAs engaged in a PA-physician supervision agreement may prescribe Schedule II drugs when their supervising physician is authorized to prescribe Schedule II drugs, while independent PAs cannot prescribe Schedule II drugs.[32]

LEGAL SIGNIFICANCE

Taken together, these reforms mark a shift away from universal physician supervision toward profession-specific regulation based on licensure, experience and board oversight. The Legislature preserved regulatory accountability by retaining licensing board authority while allowing greater autonomy for experienced providers.[33]

For attorneys advising health care practitioners, employers or regulators, the current statutory framework requires careful attention to experience thresholds, board recognition status and compliance obligations under the Nursing Practice Act and Physician Assistant Act updates.

SUPERVISION AND SCOPE OF PRACTICE ACROSS SETTINGS: OKLAHOMA’S REGULATORY PATCHWORK

Despite recent statutory reforms, Oklahoma law does not create a uniform supervision or scope-of-practice framework for PAs and APRNs. Instead, legal requirements vary based on licensure type, experience-based independence, practice setting and overlaying regulatory authority, including licensing boards, health care facilities and federal programs. The result is a regulatory patchwork in which the same provider may lawfully perform an act in one setting but not another.

OFFICE-BASED PRACTICES AND CLINICS

In office-based settings, supervision requirements are governed primarily by Title 59. APRNs who have obtained independent prescriptive authority under the Nursing Practice Act may prescribe and practice without a supervising physician.[34] That authority is conditioned on completion of the statutory clinical experience requirement and formal recognition by the Oklahoma Board of Nursing.[35] APRNs who have not obtained independent prescriptive authority remain subject to physician supervision for prescribing and must comply with collaborative practice requirements established by statute and board rules.

PAs who meet the experience threshold established by statute may practice without physician supervision.[36] For PAs who do not meet that threshold, Oklahoma law continues to require a written supervision agreement identifying the supervising physician, delegated medical acts and oversight responsibilities.

HOSPITALS AND HEALTH SYSTEMS

Hospitals add an additional layer of legally enforceable regulation that operates independently of licensure statutes. Oklahoma law does not require hospitals to grant privileges or clinical authority coextensive with a PA’s or an APRN’s statutory scope of practice. Instead, hospitals retain authority to regulate practice through medical staff bylaws, credentialing standards and privileging decisions.[37] As a result, a PA or an APRN who may lawfully practice independently under Oklahoma statutes may still be required by hospital policy to obtain a physician co-signature for orders, limit performance of procedures or practice under physician oversight as a condition of privileges. These requirements arise from hospital governance authority and accreditation standards rather than from the Physician Assistant Act itself.[38]

MEDICAL SPAS AND AESTHETIC PRACTICES

Despite being termed “medical spas,” only 37% of such facilities in the U.S. were owned by physicians as of 2022.[39] Further, 70% of medical spas lack any affiliation with a physician practice.[40] Medical spas present heightened regulatory risk because many aesthetic services constitute the practice of medicine under Oklahoma law. Okla. Stat. tit 59 §492 defines the practice of medicine broadly, and the Oklahoma State Board of Medical Licensure and Supervision has historically treated procedures – such as injectable treatments, laser therapies and use of energy-based devices – as medical acts when performed on human tissue.[41] For these reasons, the American Medical Association issued guidance stating that states should enact medical spa safety laws that:

• Ensure a supervising physician is present at the site, can immediately respond in person as needed and is trained in the indications for and performance of any cosmetic medical procedure performed
• Require a supervising physician to perform initial patient assessments, develop a written treatment plan for each patient and obtain patient consent if the procedure is being done by a nonphysician
• Obligate any nonphysicians to wear badges that clearly identify their licensure and communicate that they are not physicians[42]

Negative stories of local medical spa clients claiming disfigurement by microneedling, laser and Botox treatments stem from unsupervised estheticians – not APRNs or PAs – performing procedures classified as medical in nature.[43] Nevertheless, medical spa owners are sensitive to the heightened scrutiny of regulators who look for active supervision from physicians.

In Oklahoma, baseline authority for PAs in medical spa settings depends on whether the PA is practicing independently or performing services pursuant to lawful physician delegation.[44] The push for physician, and specifically licensed dermatologist, presence in these settings will likely warrant more physician oversight here than in other settings.[45] APRNs may perform aesthetic procedures only if the procedures fall within advanced nursing practice as defined by statute and Board of Nursing rules. Like physicians, APRNs are legally permitted to administer Botox, fillers, lasers, peels, microneedling, Ultherapy, Kybella and CoolSculpting.[46] In enforcement actions, regulators have focused less on formal supervision documents and more on whether the physician is actively supervising the clinic.[47]

RURAL CLINICS AND UNDERSERVED SETTINGS

Oklahoma statutes do not create a separate scope-of-practice scheme based solely on rural or underserved geography. However, experience-based autonomy under House Bill 2298 and House Bill 2584 has particular relevance in rural clinics, where physician availability may be limited.[48] A TU doctoral nursing program alumna opened up a family practice in Skiatook that serves 600 patients. After news of the passage of House Bill 2298, she told a local network that not having prescriptive authority as an APRN in rural Oklahoma would not work long term.[49]

APRNs and PAs who qualify for independent practice may lawfully operate without physician supervision under state law, but they remain subject to licensing board jurisdiction, controlled substance laws and federal program requirements. Rural health clinics and federally qualified health centers, for example, are subject to federal supervision and Medicare/Medicaid billing requirements beyond those found in Title 59.

CONCLUSION

Oklahoma’s regulation of PAs and APRNs combines statutory reforms, board governance and facility policies, creating a patchwork that varies by licensure, experience and practice setting. House bills 2298 and 2584 provide pathways for mid-level providers to practice or prescribe independently, aiding in Oklahoma’s health care provider shortage. Still, supervision requirements, scope limitations and federal rules continue to apply. Attorneys advising providers or employers must consider these intersecting authorities to ensure compliance and reduce risk.

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PRACTICAL STEPS FOR COUNSEL

For lawyers advising health care providers or employers, Oklahoma’s regulatory framework requires a layered analysis:

• Identify the provider’s licensure type and experience status
• Determine whether statutory independence applies
• Review applicable board rules and guidance
• Evaluate facility bylaws, employment contracts and delegation agreements
• Consider federal program and payor requirements
• Assess risk based on the actual practice setting, not just the statute

The result is a regulatory environment in which “independent practice” under state law does not always translate into independent practice in fact.

COMPARISON CHART: SUPERVISION AND SCOPE BY SETTING

Setting	PAs (Independent Status)	PAs (Supervised Status)	APRNs (Independent Prescriptive Authority)	APRNs (Supervised)	Primary Legal Authority
Office-Based Clinics	No physician supervision required	Written supervision agreement required	No supervising physician required for prescribing Schedule III to V drugs	Physician supervision required for prescribing	Okla. Stat. tit. 59, §§519.6 and 567.4c
Hospitals	Subject to bylaws and privileging	Subject to bylaws and supervision	Subject to bylaws and privileging	Subject to bylaws and supervision	Hospital bylaws; accreditation standards
Medical Spas	Only within scope and lawful delegation or independence	Physician delegation required	Limited to advanced nursing scope	Physician involvement often required	Okla. Stat. tit. 59, §§492, 519.6 and 567.4c; medical board guidance for supervising physicians
Rural Clinics	Independent practice if statutory criteria met	Written supervision agreement required	Independent prescribing if criteria met	Supervision required	Okla. Stat. tit. 59, §§519.6 and 567.4c
Controlled Substances	May prescribe Schedule III to V drugs as authorized per statute and Drug Enforcement Administration law	May prescribe up to Schedule II drugs as authorized per delegation	Authorized per statute and Okla. Admin. Code	Authorized with supervision	Okla. Stat. tit. 59, §§519.6, and 567.4c; Okla. Admin. Code §435:15-11-1 and §485:10-16-5

 

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ABOUT THE AUTHOR

Fareshteh H. Hamidi is an attorney in Steptoe & Johnson PLLC’s Oklahoma City office, where she litigates business, commercial and insurance defense matters. She is a proud 2019 graduate of the TU College of Law.

 

 

 

 

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ENDNOTES

[1] 2025 Okla. Sess. Laws ch. ___ (H.B. 2298).

[2] 2025 Okla. Sess. Laws ch. ___ (H.B. 2584).

[3] “Oklahoma Physician Shortage Facts,” Cicerio Institute, https://bit.ly/4boIWPC (last visited Dec. 15, 2025).

[4] B. Walia, et al., “Increased Reliance on Physician Assistants: An Access-Quality Tradeoff?” J Mark Access Health Policy. (Jan. 24, 2022).

[5] Id.

[6] Okla. Stat. tit. 59, §§567.1-567.20 (Oklahoma Nursing Practice Act), as amended (2025).

[7] Okla. Board of Nursing, Rules of the Oklahoma Board of Nursing; Okla. Admin. Code §§485:10-15-1 et seq. (2025).

[8] Okla. Stat. tit. 59, §§519.1-519.26 (Physician Assistant Act), as amended (2025).

[9] Oklahoma State Board of Osteopathic Examiners, Rules Governing Supervision of Physician Assistants and Advanced Practice Providers; Okla. Admin. Code §§510:10-13-1, et seq.

[10] Oklahoma Medical Board, Guidelines for the Operation of Medical Spas (rev. Jan. 18, 2024).

[11] Oklahoma State Board of Osteopathic Examiners, Policy for Osteopathic Medical Spas (rev. Sept. 18, 2025).

[12] Okla. Stat. tit. 59, §§567-567.20; Okla. Stat. tit. 59, §§519.1-519.15 (2024).

[13] National Council of State Boards of Nursing, APRN Consensus Model for APRN Regulation: Licensure, Accreditation, Certification & Education (2008), https://bit.ly/3NIv4pH.

[14] Okla. Stat. tit. 59, §567.3a (2024).

[15] Okla. Stat. tit. 59, §567.3a (2024) (conditioning prescriptive authority on physician supervision).

[16] Oklahoma State Medical Association, Scope of Practice Policy Statements, https://bit.ly/4qOinbg (last visited Dec. 15, 2025).

[17] “History of AAPA & the PA Profession, American Academy of Physician Assistants,” www.aapa.org/about/history (last visited Dec. 15, 2025).

[18] Id.

[19] Okla. Stat. tit. 59, §519.2 (2024).

[20] Id.

[21] Okla. Stat. tit 59, §§519.2, 519.6 (2023).

[22] Executive Order No. 2020-07, State of Oklahoma (March 24, 2020), https://bit.ly/3OdUdIQ.

[23] “State responses to COVID-19: Potential benefits of continuing full practice authority for primary care nurse practitioners,” 70 Nursing Outlook 28, 28-35 (2021), published online Aug. 7, 2021.

[24] “Oklahoma governor vetoes bill that would allow nurses to prescribe without supervision,” Oklahoma Voice (April 2, 2024).

[25] “Nurse Practitioners Gain Prescriptive Independence After Governor’s Veto Override in OK,” Nurse.org, https://bit.ly/4bM4JB9 (last visited Dec. 15, 2025).

[26] H.B. 2298, 59th Leg., 1st Sess. (Okla. 2025) (enrolled), https://bit.ly/3ZHgQYF.

[27] Oklahoma Enacts Legislation Significantly Modernizing PA Practice, American Academy of Physician Assistants, https://bit.ly/4qRikvA (last visited Dec. 15, 2025).

[28] Id.

[29] H.B. 2584, 59th Leg., 1st Sess. (Okla. 2025) (enrolled), https://bit.ly/49QzzXK.

[30] Okla. Stat. tit. 59, §519.6 (2025).

[31] Oklahoma State Board of Medical Licensure & Supervision, Physician Assistant Practice Information, www.okmedicalboard.org/physician_assistants (last visited Dec. 15, 2025).

[32] Okla. Stat. tit. 59, §519.6(D)-(E).

[33] Okla. Bd. of Nursing, HB 2298 – Independent Prescriptive Authority for APRNs (FAQ) (June 9, 2025), https://bit.ly/4q8QDNp.

[34] Okla. Stat. tit. 59, §567.4c.

[35] Id.; supra note 33.

[36] Okla. Stat. tit. 59, §519.6 (2025).

[37] Okla. Stat. tit. 63, §1-707b.

[38] See generally 42 C.F.R. §482.12.

[39] J. Eichinger et al., “Trends in Medical Spa Statistics and Patient Safety,” 50 Dermatologic Surg. 216 (February 2024).

[40] Id.

[41] Okla. Stat. tit. 59, §492.

[42] J. Lubell, “Who's on site for care at ‘medical spas’? Not usually a physician,” American Medical Association, (Oct. 6, 2025).

[43] J. Wolfe, “In Oklahoma, laws haven’t kept up with trendy medical spa treatments,” The Frontier (Aug. 5, 2024).

[44] Okla. Stat. tit. 59, §519.6 (2025).

[45] Lubell, supra note 42.

[46] D. Holt, “A State-by-State Guide for Medspa Regulations,” Holt Law, https://bit.ly/3NUJUta (last visited Dec. 15, 2025).

[47] See, e.g., Oklahoma Board of Medical Licensure & Supervision, disciplinary authority under Okla. Stat. tit. 59, §503.

[48] B. Roddy, “How does Oklahoma’s new law for nurse practitioners compare to other states?” News On 6 (June 2, 2025).

[49] Id.