Scope of Practice



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.

Certain professional decisions critical to high quality patient care should always be the ultimate responsibility of the physician practicing in a health plan...

MSDC Policy Manual, 285.008 Physician Decision-Making

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 would reduce the number of physicians to 6 and adds 2 physician assistants, 1 chiropractor, 1 podiatrist, and an acupuncturist.

Advanced Practice Registered Nurses

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

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. DCSA does not want to repeal Section 603 of DC official code ₰3-1206.03.

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. DCSA wants to remove Sec. 605a 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
  • Use x-rays and diagnostic imaging to diagnose skeletal disorders
Clinical lab technicians

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


The bill would completely blur the line between optometrists and ophthalmologists by:

  • Permitting prescribing antibiotics, antihistamines, non-steroidal anti-inflammatories, glaucoma medicine, and analgesics included in Schedules III through V controlled substances as well as Schedule II controlled.
  • Allow them to diagnose, treat, and manage open-angle glaucoma
  • Apply for a DEA license

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 drastically expands podiatrists scope of practice to allow:

  • diagnosis, treatment, and care of all structures and tissues around the foot and ankle;
  • care for all tissue below the knee;
  • care for soft tissue in the wrist and hand area;
  • apply anesthesia as part of treatment; and
  • administer vaccines and injections.

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.

What can you do?

  1. Sign our physician letter opposing the scope of practice changes in the bill.
  2. Share this information with your specialty society and have them contact Robert Hay with questions or concerns.
  3. Reach out to Councilmembers and tell them why you object to this bill.


Articles on scope of practice


Learn About Our New Strategic Vision

Jul 12, 2023, 10:04 AM by Susanne Bathgate, MD
MSDC just approved a new strategic plan and vision. What does this mean for you and your practice?



At our June Board of Directors meeting, the MSDC Board approved a new strategic vision for the Society. I am writing to share why this matters to you and your practice, and show some highlights of this plan.

First, let's talk about the process. This plan came through serious thought and consideration of the direction of the Society. To help focus the conversation, MSDC hired Global Navigators to facilitate conversations and provide an outside perspective. Global Navigators interviewed the Board and Executive Vice President, and held a half-day retreat one weekend to have some honest discussion. Two Board meetings included long conversations about the strategic plan and various drafts.

Second, let's discuss what is in our strategic plan. The plan includes (a) a mission statement, (b) a vision statement, (c) our core values, (d) a new diversity, equity, inclusion, and belonging statement, and (e) our objectives and goals to implement them.

Mission Statement

To ensure physician and patient well-being in the District of Columbia through the promotion of high-quality accessible care in a changing healthcare environment. 

Our mission is clear: your Society will work every day for you and your patients. We want the District to be a model of high-quality and accessible care even while recognizing that we face a rapidly changing world.

Vision Statement

To make the District of Columbia the nation’s model for patient care and physician practice.

The vision statement is the brief summary of our strategic vision, and we include it on every letter and written testimony we create. As you can see, we want to make DC a model across the country for how we care for patients and protect physicians practice, regardless of the type.

Core Values


Our values go beyond scientific knowledge. The Society values and promotes sound medicine (like we have since 1817), but also medicine that treats people with equity and compassion. As we will see in the DEIB statement, we recognize that past medical and Society practices may have downplayed these elements, but we now recognize that quality, equity, and compassion are essential to the practice of medicine and the mission of the Society.

Our Commitment to Diversity, Equity, Inclusion, and Belonging

MSDC respects, welcomes, and celebrates all people and their diverse identities. We recognize the negative impact of health inequity across all facets of society. We are committed to working toward elimination of bias and healthcare disparities wherever they exist with the goal of ensuring that everyone belongs.

Our communities will flourish when we mutually celebrate and champion our unique strengths and diverse backgrounds.

This is MSDC's first equity statement, and we wanted to incorporate "belonging" to our DEI statement. We recognize that inequality has negatively impacted society and patient care, and your Society will work to eliminate bias and disparities. Not recognize or highlight, but eliminate. Our statement acknowledges that differences and diversity are a strength and we celebrate them in your Society's work.

Objectives and Goals

Objective 1: Become the Best Resource for Physicians Practicing in DC

  • Build greater awareness of MSDC among individual physicians and physician groups
  • Introduce MSDC to physicians new to the District of Columbia
  • Engage medical students, residents, fellows, and early-career physicians with mentorship and support
  • Engage licensed allied health professionals

Objective 2: Strengthen advocacy and outreach

  • Ensure MSDC provides a home where physicians in DC belong
  • Advance Diversity, Equity, Inclusion, and Belonging within medicine in DC
  • Build on existing relationships that further expand MSDC’s voice for physicians and patients
  • Extend outreach efforts by building new partnerships with key stakeholders

Objective 3: Ensure MSDC’s long-term Growth

  • Build member and partner value to ensure long-term commitment to MSDC
  • Increase the number of engaged members
  • Introduce a sound business plan that reflects MSDC’s long-term strategy
  • Optimize existing and explore new revenue streams

These are the three pillars on which our work and implementation of our plan will rest. The Society will execute our vision in three areas. First, your Society will provide resources to support physicians practicing in DC, no matter what type of practice, including engaging with all parts of your practice. Second, MSDC will grow what has consistently been our highest-rated member benefit, advocacy on behalf of the profession. Finally, we will continue to position the Society for sustained growth in the future despite uncertainty in the world around us.

That's our plan. How can you help or get involved? Sign-up to join one of our member groups or reach out to me via We plan on this being a living document, guiding our work for the years to come.