THE OKLAHOMA BAR JOURNAL 32 | MARCH 2026 Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff. Health Law Independent Practice, Supervision and Scope: A Legal Guide for PAs and APRNs in Oklahoma By Fareshteh H. Hamidi 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
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