Physician Voices for Patient Safety

On this page:

About the bill
Impact on patients in DC
Impact of physicians in DC
What can you do?

About the bill

In November 2023, DC Health introduced B25-545, the Health Occupations Revisions General Amendment Act of 2023. This bill is a comprehensive rewrite of the law overseeing medical licensing and regulation in Washington, DC.

Unfortunately, the bill as written would overhaul scope of practice, place allied health professionals in oversight positions of medical licensing, and remove the physician from the center of the care team.

MSDC has long advocated that a physician is the most qualified professional at the head of a care team. Physicians have the most health education and pre-practice experience of any health professional, and thus must be involved in all but the most mundane health care decisions. Allied health professionals are a valuable part of the care team, but their medical education and experience limits their role.

The Medical Society of the District of Columbia (MSDC) is the leading voice for physicians in Washington, DC, committed to uniting physicians to advocate for physician-led health care in Washington, DC that protects patients from harm and increases access to quality care. MSDC is leading a coalition of Washington, DC specialty medical societies to advocate against the Health Occupations Revisions General Amendment Act of 2023.


Impact on patients

As currently written, the bill would weaken patient care by expanding the ability of non-physician professionals to practice medicine beyond their training. DC residents deserve access to proper medical care from professionals with the right knowledge and experience to ensure appropriate diagnosis and treatment.

Impact on physicians

Below is a breakdown of some of the major changes the bill would introduce, click on the title to expand how the bill would change that item.


Board of Medicine

Currently the Board of Medicine is composed of 10 physicians and 4 members of the public. The bill as amended would reduce the number of physicians to 9 and adds 2 physician assistants but keep the four members of the public health.

Advanced Practice Registered Nurses

The concern: The bill would codify that APRNs could independently diagnose, prescribe, and administer medicine.

The details: See the analysis from G2L Law Firm on the APRN provisions

The solutions: Independent Advanced Certified Nurse Practitioners should have a defined scope of practice limited to the following functions:

  • Practice only in the field of certification;
  • Comprehensive physical assessment of patients;
  • Certify to the clerk of the court that an adult has given birth;
  • Certify to the Transportation authority that an individual has special needs for certain health reasons;
  • Complete date of birth and medical information on a birth certificate;
  • Complete a death certificate if medical examiner does not take charge and deceased was under the care of the PN;
  • Establish medical diagnosis of common short-term and chronic stable health problems;
  • File a replacement death certificate;
  • Issue a “do not resuscitate order” in medical emergencies;
  • Order, perform, and interpret laboratory and diagnostic tests;Prescribe drugs and devices under DC controlled substance Schedules II-V with a valid DEA license, and medical marijuana under DC laws;
  • Provide emergency care within the scope of their skills;
  • Refer patients to appropriate licensed physicians or other health care providers;
  • Certify to utility company that a client has a serious illness or the need for life-support equipment;
  • Witness an advanced directive;
  • Sign off on home health/care orders.
Anesthesiologists and applying anesthesia

The concern: As seen below, additional allied health professions are permitted to apply anesthesia. Most concerning is the scope expansion that could permit nurse anesthetists to practice without physician collaboration.

The solution: This bill asks to repeal Section 603 of DC official code ₰3-1206.03, and this action will allow nurse anesthetists to administer anesthesia without an anesthesiologist or other physician's direct collaboration. Language seeking repeal of Section 603 of DC official code ₰3-1206.03 should not be included.

This bill adds Sec. 605a, which contains language that a CRNA may plan and deliver anesthesia, pain management, and related care to patients or clients of all health complexities across the lifespan. Language adding Sec. 605a should be removed from this bill.

Athletic Trainers
The bill repeals law that requires limiting athletic trainers to only providing first aid, opening the door to athletic trainers potentially practicing some form of medicine.

The expands audiologists' scope to include "cerumen management" and "interoperative neurophysiologic monitoring" and permits audiologists to screen for cognitive, depression and vision.


The bill completely rewrites the definition of the practice of "chiropractic". Chiropractors could:

  • Diagnose and treat biomechanical or physiological conditions that compromise neural integrity or organ system function
  • Refer patients for further medical treatment or diagnostic testing
Clinical lab technicians

The bill would not longer have physicians overseeing their work but instead a clinical laboratory director


The bill would expand pharmacists' scope to include:

  • Ordering labs
  • Scheduling and monitoring drug therapy
  • Ordering, interpreting, and performing more tests
Physical Therapists

The bill would permit physical therapists to independently evaluate and treat disability, injury, or disease. PTs may also order imaging as part of their treatment plan.


The concern: The bill expands podiatrists scope of practice to allow:

  • apply anesthesia as part of treatment; and
  • administer vaccines and injections.

The details: See the analysis from G2L Law Firm on the podiatrists' provisions

The solution: This bill amends Paragraph (14) of D.C. Official Code § 3-1201.02(14) to define "Practice of podiatry” to include the administration of local anesthesia, monitored anesthesia care, and conscious sedation. Other scope of practice expansions for podiatry include care of human hand and wrist, and administration of injections, vaccinations, and immunizations. Podiatrists should not be administering monitored anesthesia care. Podiatrists do not have the qualifications and training to manage a patient's airway so this language should be stricken.


Throughout the bill, restrictions on nursing scope of practice are removed or loosened throughout. Specific language outlining what and how nurses can practice is removed and replaced with more vague language giving the Mayor (read DC Health) the ability to dictate scope. This applies to many different nursing types, like APRNs and NPs.

Articles on scope of practice


MSDC and Coalition Request Prior Auth Hearing

May 18, 2022, 11:39 AM by MSDC Staff
The letter signed by numerous national and local associations requests a hearing on B24-655 before the Council's summer recess.

Today, MSDC and a coalition of 17 other organizations requested that the Committee on Health hold a hearing on B24-655 (Prior Authorization Reform Act) before the Council's summer recess.

The bill would align DC with other states in reforming the prior authorization process and adopt common-sense reforms modeled by the American Medical Association and other national healthcare organizations. The bill lays out a minimum amount of time a prescription approval is valid, sets qualifications for payer personnel to make prior auth determinations, prohibits a prior auth for cost purposes, and more. The bill is one of MSDC's highest priorities and we have created an action site on the issue.

The letter (seen below) is joined by national and local healthcare, patient advocacy, and health reform organizations. The content is simple in asking for a hearing as the organizations involved have numerous stories on the impact of prior authorization on their members and patients. MSDC has some examples on its prior auth site.

How can you get involved in this issue?

Let MSDC know you want to get involved via our form

Contact your Councilmembers and tell them to support the bill


May 18, 2022

The Honorable Vincent C. Gray
Chair, Committee on Health
1350 Pennsylvania Ave NW Ste 406
Washington, DC 20004

Dear Chair Gray,

We, the undersigned organizations and practices, request that you hold a hearing on B24-655, the Prior Authorization Reform Amendment Act of 2022, before the Council’s summer recess. This legislation is critical to protecting the health and wellbeing of District residents and joins the District with numerous other states in reforming the onerous prior authorization process.

Prior authorizations routinely negatively impact patient care. The recent American Medical Association physician survey on prior auth showed that 93% of physicians report care delays because of prior authorization. The same survey showed that provider offices spend 13 hours each week (almost two business days) dedicated to prior auth paperwork. These delays impact our residents and patients daily, leading many to wait unnecessarily for their treatments or choose to abandon them altogether. 

Our organizations have stories from patients and providers that can help educate the committee on this issue, but without a hearing on the bill we cannot share this information before the committee. We urge you to schedule a hearing for this bill and give us the chance to share why this important reform is needed now.


Medical Society of the District of Columbia
Aimed Alliance 
Allergy & Asthma Network
The ALS Association
American College of Rheumatology
American Medical Association
Arthritis Foundation
The Association for Clinical Oncology 
Chronic Disease Coalition
DC Society of Addiction Medicine
District of Columbia Primary Care Association
Hemophilia Association of the Capital Area
Hemophilia Federation of America
Lupus and Allied Diseases Association
Multiple Sclerosis Association of America
National Multiple Sclerosis Society
Rheumatism Society of DC
Washington Psychiatric Society

CC: Members of the Committee on Health


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