MARCH 2026 | 35 THE OKLAHOMA BAR JOURNAL 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. 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-ofpractice 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
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