MARCH 2026 | 37 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. 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. 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. 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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