THE OKLAHOMA BAR JOURNAL 36 | 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. 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 physicians42 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
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