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


You're Not Dreaming - Prior Auth Reform Passes the DC Council

Nov 7, 2023, 15:19 PM by MSDC Staff
The Council passed MSDC-supported comprehensive prior authorization reform legislation for the first time ever.


November 7, 2023, is a day DC physicians have wanted to see for a long time. That is because today prior authorization reform has passed the DC Council.

B25-124, the Prior Authorization Reform Amendment Act, passed via the Council's consent agenda at its legislative meeting. With the second vote to pass, the bill is considered passed by the Council and will now go to the Mayor for her signature.

This bill is not perfect and it will not solve every prior auth issue in the District. But when it goes into effect, it will allow DC to join 40 other states who have passed some restrictions on prior authorization.

MSDC thanks Councilmember Brooke Pinto and the other council members who introduced and supported the bill. We also thank MedChi DC, other DC physician organizations, the American Medical Association, DC Hospital Association, DC Primary Care Association, DC Behavioral Health Association, and other healthcare organizations that helped advocate for this legislation.

The bill will now go to the Mayor who will hopefully sign the bill. Once she signs it - or it goes into effect without her signature - the bill will go through a Congressional review period. After that, the legislation can go into effect. We anticipate this will be in the early spring of 2024.

Our advocacy work is not yet done. The legislation applies immediately to private insurers but must be funded to apply to Medicaid. MSDC and partners will continue to push for funding for the bill in the DC budget. MSDC will also seek technical corrections and updates in future bills to adapt to the changing healthcare environment and address if/when insurers avoid the bill's requirements.

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