THE OKLAHOMA BAR JOURNAL 34 | 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. 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 PRACTICAL STEPS FOR COUNSEL For lawyers advising health care providers or employers, Oklahoma’s regulatory framework requires a layered analysis: 1) Identify the provider’s licensure type and experience status 2) Determine whether statutory independence applies 3) Review applicable board rules and guidance 4) Evaluate facility bylaws, employment contracts and delegation agreements 5) Consider federal program and payor requirements 6) 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.
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