One of the most common questions we get at Rupa is: “Can I order functional medicine labs?”
The ability to order functional medicine labs depends on various factors, including state regulations, your professional credentials, and specific lab requirements. Each lab has different standards regarding which professionals can order tests, and state laws also govern this ability.
The easiest way to see which labs you can order is to create a free Rupa Health account to see our Lab Ordering Access Page and learn more about which labs you may be eligible to order! 🧪
The easiest way to explore which labs you may be eligible to order is to create a free Rupa Health account to access our Lab Ordering Access Page, which provides helpful guidance based on your credentials and location. Please consult your state's licensing board or a legal professional for confirmation of your specific eligibility.
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Who Can Order Labs in All 50 States?
Certain practitioners, such as Medical Doctors (MD), Osteopathic Doctors (DO), Dentists (DDS/DMD), Podiatrists (DPM), and Optometrists (OD), are able to apply for professional licensure in all 50 states. These practitioners can apply for multiple state licensures if desired. However, the ability to order labs depends not only on holding a license but also on state-specific regulations that govern each profession’s scope of practice.
State-Wide Functional Lab Ordering Restrictions
*NJ, NY, and RI have unique laws that may restrict the ordering of various types of laboratory tests, including functional medicine labs. These restrictions can apply to practitioners regardless of their degree or credentials. It is important to verify lab ordering eligibility by consulting state-specific regulations before attempting to order tests in these states
Click Here to see which labs and tests may be affected in NJ. NY, and RI.
Is an NPI Number Required to Order Labs?
The requirement for a National Provider Identifier (NPI) number to order laboratory tests depends on both the healthcare provider’s credentials and state regulations. Licensed professionals, such as physicians, nurse practitioners, and physician assistants, typically require an NPI number for lab ordering, billing, and administrative purposes. However, the need for an NPI can vary based on state rules and the type of healthcare service being provided.
Some practitioners, such as nutritionists, health coaches, or other non-licensed professionals, usually cannot obtain an NPI number and generally cannot order labs independently. However, in certain cases, these practitioners may be able to order labs if certified in specific fields or working in collaboration with licensed providers.
You can read more about NPI numbers in this article and learn more about what they are and when you need one.
*Please note: Lab ordering regulations vary by state and profession, and this information is intended for general guidance only. Always consult your state’s licensing board or a legal professional to ensure compliance with specific state laws regarding lab ordering and NPI requirements.
Can Nurses and Physician Assistants (PA) Order Labs?
Nurses and Physician Assistants (PAs) may have the authority to order laboratory tests, but the extent of this authority varies depending on their credentials, state regulations, and the specific scope of practice laws governing their profession.
Nurse Practitioners (NP)
Nurse Practitioners (NPs) can order lab tests based on their state's scope of practice regulations. Depending on the state's classification—whether it allows full, reduced, or restricted practice—NPs may need to collaborate with or work under the supervision of a physician.
Check out our article about which labs NPs may be able to order.
Registered Nurses (RN)
Registered Nurses (RNs) typically cannot order lab tests independently. Their role usually involves assisting in patient care and facilitating testing based on orders from NPs or physicians. However, in certain healthcare settings, such as hospitals, RNs may be permitted to order specific tests if allowed by state laws, institutional policies, or under standing orders or collaborative agreements.
Other Nursing Credentials
Certified Registered Nurse Anesthetists (CRNAs), Advanced Practice Registered Nurses (APRNs), Certified Nurse Midwives (CNMs), and Clinical Nurse Specialists (CNSs) have advanced training and clinical expertise. In many states, these practitioners are granted the authority to order labs within their specific scope of practice.
States such as California, New York, and Texas allow these advanced practice nurses to order and interpret laboratory tests either independently or under a collaborative agreement with a physician. However, the rules governing their scope of practice and lab ordering authority vary widely between states, so it’s essential that they are familiar with their local regulations.
*Please note that It’s critical that these professionals regularly consult their state’s nursing board or regulatory body to ensure they are practicing within their legal scope and maintaining the highest standard of care.
Physician Assistants (PA)
Physician Assistants (PAs) are highly trained medical professionals who work under the supervision of physicians. They are authorized to order labs as part of their scope of practice, though the level of independence they have in doing so varies by state.
Some states allow PAs more autonomy in ordering and interpreting lab tests, while others require close collaboration with a supervising physician. PAs must stay informed about their state's specific regulations and their supervising physician's delegation agreements to ensure they are practicing within their legal scope and providing effective patient care.
*Please note that the ability to order lab tests varies by state, profession, and setting. Practitioners should always consult their state’s regulatory body or their institution’s policies to ensure compliance with the current laws and standards.
Other Practitioner Types Who Can Order Labs
Several other healthcare professionals may have the ability to order labs, depending on their licensure, certification, and the regulations of the state in which they practice. Below are some of the most common practitioner types who may be able to order laboratory tests.
Naturopathic Doctors (ND)
NDs can order labs in states where they are licensed. However, in pre-licensed states—where naturopathic medicine is not yet formally regulated—the ability to order or interpret labs may be restricted or prohibited. In these states, NDs may need to collaborate with licensed medical providers, such as MDs or DOs, to order labs and deliver care.
Naturopathic Doctors receive training in biomedical and diagnostic sciences similar to that of MDs and DOs, although the scope of training and clinical hours may differ. NDs are trained to order and interpret laboratory tests as part of their diagnostic process in states where they are licensed.
Licensed NDs can order and interpret labs in the following states: AK, AZ, CA, CO, CT, DC, HI, ID, KS, MA, MD, ME, MN, MT, NH, ND, OR, RI, UT, VT, WA, WI, and in the US Territories: Puerto Rico and the U.S. Virgin Islands. However, lab ordering regulations may vary by state, so it’s important for NDs to be familiar with the specific laws governing their scope of practice.
*Please note that while NDs are authorized to order labs in many licensed states, the specific scope of this authority varies and is subject to change. NDs should regularly review their state's naturopathic practice laws to ensure compliance with current regulations.
Doctor of Chiropractic (DC)
Chiropractic healthcare is a recognized profession in all U.S. states and Canadian provinces. All states require applicants for chiropractic licensure to obtain a Doctor of Chiropractic (DC) degree from an educational program accredited by the Council on Chiropractic Education (CCE).
However, the scope of practice for DCs, including the ability to order and interpret labs, varies by state. In some states, DCs may be able to order labs independently, while in others, their ability to do so may be restricted or require collaboration with a licensed medical provider.
Chiropractors should verify the specific regulations governing lab ordering in their state to ensure compliance with the legal scope of practice.
*Please note that lab ordering regulations for chiropractors vary by state, and chiropractors should consult their state’s chiropractic board or regulatory body to ensure they are practicing within their legal scope. It is essential to regularly check for updates to state regulations regarding lab ordering.
Nutrition Professionals
There are numerous credentials and certifications available for nutrition professionals, each signifying specialized knowledge in various aspects of nutrition and dietary science. Lab ordering authority for these professionals varies based on their specific credentials, state regulations, and collaboration with licensed healthcare providers.
Registered Dietitians (RD)/ Licensed Dietitian (LD)/Licensed Dietitian Nutritionist (LDN)
Registered Dietitians (RDs) are licensed nutrition experts who provide evidence-based dietary advice and interventions to promote health and manage medical conditions. In 2014, the Centers for Medicare and Medicaid Services (CMS) issued a final rule allowing RDs working in clinics or hospitals to order labs when monitoring dietary plans.
In private practice, RDs’ ability to order labs, including functional labs, varies by state. Some states allow RDs to order labs directly, while others may require collaboration with a licensed medical provider or specific agreements with lab companies.
Certified Nutrition Specialist (CNS)
Practitioners with the Certified Nutrition Specialist (CNS) credential are highly trained professionals recognized for their expertise in nutrition science and clinical practice. The requirements for gaining certification include a Master’s Degree and passing the board exam given by the Board for Certification of Nutrition Specialists℠ (BCNS℠).
The ability of CNS credential holders to order laboratory tests varies by state due to differing regulations. In some states, CNS practitioners have the authority to order labs independently, which is critical for conducting comprehensive nutritional assessments and developing personalized treatment plans.
States such as California, New York, and Washington have more favorable regulations that allow CNS practitioners to order laboratory tests. However, this is not uniformly the case across the United States, and in some states, CNS practitioners may need to collaborate with other healthcare providers to order lab tests.
It is essential for CNS practitioners to be well-versed in their state's regulations and any updates to ensure compliance and to leverage their full scope of practice effectively.
Other Nutrition Credentials
Practitioners with credentials such as Functional Diagnostic Nutrition Practitioners (FDPs), Nutritional Therapy Practitioners, Certified Nutritionists, and Clinical Nutritionists play a valuable role in supporting individuals' health and well-being through their expertise and dedication..
However, they cannot order labs independently as they do not hold medical licensure. In most cases, they must collaborate with licensed healthcare providers to order tests.
These practitioners often collaborate with licensed providers to order lab tests, ensuring they stay within their legal scope of practice. Rupa's Physician Services may also provide a way for them to support clients while maintaining compliance. It is essential to check your state's regulations and the policies of individual labs to determine lab ordering eligibility.
*Please note that the ability of nutrition professionals to order labs varies by state and credential. Nutrition professionals should consult their state’s regulatory body or legal counsel to ensure they are operating within their legal scope of practice.
Licensed Acupuncturists (LAc)/ Doctor of Acupuncture and Oriental Medicine (DOM or DAOM/DACM)
The ability of licensed acupuncturists (LAc), Doctors of Acupuncture and Oriental Medicine (DOM), and Doctors of Acupuncture and Chinese Medicine (DACM) to order labs varies by state. While some states allow these practitioners to order and interpret labs independently, others may require collaboration with licensed medical providers or have more restrictive regulations. Practitioners should verify their lab ordering rights based on their state’s laws.
In states like California, Florida, and New Mexico, licensed acupuncturists (LAcs) are granted the status of 'primary care provider' and can perform a variety of medical functions, including the use of Western medical diagnostic tools such as lab tests. This designation allows these practitioners to order labs as part of their scope of practice, providing a broader range of patient care services.
In states like Colorado and Nevada, acupuncturists must earn the title of Doctor of Oriental Medicine (DOM) to be authorized to order diagnostic and functional medicine labs. This additional credential expands their ability to provide diagnostic care, including lab ordering, under certain state regulations.
In Arkansas and Mississippi, LAcs are not recognized as primary care providers, but they may still be able to order and interpret certain lab tests depending on their specific credentials and any collaboration agreements with other licensed providers.
*Please note that the ability to order labs varies by state and by credential for acupuncturists. Practitioners should consult their state’s regulatory board or legal counsel to ensure they are operating within their legal scope of practice.
Pharmacist (PharmD)
Pharmacists (PharmDs) are highly trained healthcare professionals who play a critical role in patient care, particularly in medication management and therapeutic optimization. The ability of pharmacists to order laboratory tests varies by state, often depending on collaborative practice agreements with physicians or as part of specific public health initiatives. These variations reflect the diverse regulatory landscapes across the United States.
In some states, pharmacists can order and interpret laboratory tests as part of their collaborative practice agreements (CPAs) with physicians. These agreements allow pharmacists to expand their role in patient care by managing chronic conditions and monitoring lab results.
States like California, New Mexico, and North Carolina have more progressive regulations that allow pharmacists to order and interpret lab tests, particularly for managing chronic conditions such as diabetes or hypertension. In these states, pharmacists can contribute more effectively to patient outcomes by integrating lab data into therapeutic decisions.
However, this authority is not universally granted, and in many states, pharmacists may have limited or no ability to order laboratory tests independently. In these states, pharmacists typically need to collaborate with physicians or other licensed healthcare providers to access lab results. Understanding the specific regulations in their state is essential for pharmacists to ensure they practice within their legal scope and optimize patient care.
*Please note that the ability to order and interpret laboratory tests varies significantly by state and is often dependent on collaborative practice agreements or specific health initiatives. Pharmacists should consult their state pharmacy board or legal counsel to ensure compliance with local regulations.
Physical Therapist (PT)
Physical therapists (PTs) are healthcare professionals specializing in diagnosing and treating musculoskeletal and movement disorders. The authority of PTs to order laboratory tests is generally more restricted than that of other healthcare providers and is regulated on a state-by-state basis.
In most states, physical therapists do not have the authority to independently order laboratory tests. However, some states are starting to recognize the value of allowing PTs to order specific lab tests related to their scope of practice, such as inflammation markers, vitamin D levels, or metabolic tests that may influence physical therapy treatment plans and outcomes..
States like Colorado and California have more progressive regulations that grant limited lab-ordering privileges to physical therapists under certain conditions, particularly for lab tests that are directly related to the musculoskeletal or metabolic needs of the patient. Other states may be exploring similar regulations as the role of PTs continues to evolve.
Because lab-ordering rights for PTs vary widely, it is essential for physical therapists to stay informed about the specific regulations in their state to ensure they are practicing within their legal scope and providing comprehensive care.
*Please note that the ability of physical therapists to order laboratory tests is regulated by state law and is generally limited. PTs should consult their state’s physical therapy board or legal counsel to ensure they are practicing within their legal scope.
Occupational Therapists (OT)
Occupational therapists (OTs) are skilled healthcare professionals who help individuals achieve independence and improve their ability to perform daily activities through therapeutic interventions. The ability of OTs to order laboratory tests is generally limited, as their primary focus is on functional assessments and therapeutic strategies rather than diagnostic testing.
In most states, OTs do not have the authority to order laboratory tests independently. However, some states may allow OTs to collaborate with licensed healthcare providers to recommend or interpret lab tests related to their scope of practice, particularly for conditions like sensory processing disorders or metabolic issues that impact occupational performance.
It is important for OTs to be familiar with the specific regulations in their state, as the ability to collaborate on lab tests and the scope of practice can vary significantly. Understanding these regulations ensures OTs practice within their legal scope and continue to provide high-quality, compliant care to their clients.
*Please note that the ability of occupational therapists to recommend or collaborate on lab tests is regulated by state law and is typically limited. OTs should consult their state’s occupational therapy board or legal counsel to ensure they are practicing within their legal scope of practice.
Licensed Psychologist
Licensed psychologists are mental health professionals specializing in diagnosing and treating psychological disorders through various therapeutic techniques. The ability of licensed psychologists to order laboratory tests is generally restricted, as their primary focus is on psychological assessment and therapy rather than medical diagnostics.
In most states, psychologists do not have the authority to order laboratory tests independently. However, in certain states, psychologists with specialized training or additional certifications may be allowed to order specific lab tests related to neuropsychological conditions or psychophysiological assessments, provided that these tests align with their scope of practice.
It is essential for licensed psychologists to be familiar with state-specific regulations governing lab-ordering authority. This ensures they practice within their legal scope and provide the most effective, compliant care for their patients.
*Please note that the ability of licensed psychologists to order laboratory tests is regulated by state law and is generally limited to specific cases involving specialized training or certifications. Psychologists should consult their state’s psychology board or legal counsel to ensure they are practicing within their legal scope
Functional Diagnostic Practitioner (FDP)
Functional Diagnostic Practitioners (FDPs) are trained to use a holistic approach to identify underlying causes of health issues through various diagnostic tools and techniques. However, since FDPs typically do not hold medical licenses, their ability to order laboratory tests is generally limited and regulated by state laws.
In most states, FDPs cannot order laboratory tests independently. They must collaborate with licensed healthcare providers to access lab results necessary for their assessments. Some FDPs may work under the supervision of a licensed practitioner who can order tests on their behalf, while others may utilize services such as Physician Services (explained below) to facilitate lab ordering within their scope of practice.
It is critical for FDPs to understand the specific regulations in their state and to work strictly within their legal scope of practice. By collaborating with licensed providers or using approved lab requisition services, FDPs can provide effective and legally compliant care.
*Please note that Functional Diagnostic Practitioners do not typically hold medical licenses and must collaborate with licensed healthcare providers to order and interpret laboratory tests. FDPs should consult their state’s regulations and work with legal counsel or licensed professionals to ensure they are practicing within their legal scope.
Can Health Coaches Order Labs?
Health coaches are professionals who help individuals achieve their health and wellness goals through guidance, education, and motivational support. However, health coaches do not have the authority to order laboratory tests independently, as they do not hold medical licenses, and their role is focused on behavior change and wellness coaching rather than clinical diagnostics.
Health coaches typically collaborate with licensed healthcare providers to help clients interpret and implement lab-based recommendations. These collaborations enable health coaches to support their clients within the scope of wellness coaching, while the licensed provider orders and interprets the necessary lab tests.
It is vital for health coaches to be fully aware of their scope of practice and to adhere to the regulatory framework in their state. Operating within these boundaries ensures that they provide effective and legally compliant support to their clients without engaging in activities reserved for licensed healthcare professionals
Health coaches can also utilize our physician services option, which allows them to work with licensed providers who can order and interpret lab tests. This ensures that lab testing is handled in a compliant manner while allowing health coaches to stay within their scope of practice. Learn more about this below!
*Please note that health coaches are not licensed to order laboratory tests independently. Any lab-related recommendations should be made in collaboration with a licensed healthcare provider, and health coaches should consult their state’s regulations to ensure they are practicing within their legal scope.
Some Labs Only Require Certifications
Tiny Health and Bristle Health are innovative companies offering laboratory testing services with flexible ordering options for healthcare practitioners.
This inclusive approach means that certified professionals, such as functional diagnostic practitioners, nutritionists, and health coaches, may be able to use these labs to support their clients' health and wellness goals. However, it’s important to check each lab’s policies and state-specific regulations to ensure compliance with legal and regulatory requirements.
By offering flexible practitioner-type requirements, Tiny Health and Bristle Health provide a valuable resource for a broad range of health professionals. However, even with this flexibility, practitioners should ensure they are complying with both lab-specific policies and state regulations when ordering and interpreting lab results.
Practitioners using these labs should hold appropriate certifications, but it’s essential to remember that certification does not substitute for licensure in states that require licensed providers to order labs. Practitioners must be aware of their legal scope of practice and ensure they are operating within the boundaries set by state and local laws.
*Please note that while certain labs may offer more flexible lab-ordering options for certified professionals, practitioners are still required to follow state-specific regulations regarding lab testing. Always verify your eligibility to order and interpret tests based on both lab policies and state law.
Not Able to Order Labs With Your Own License? Learn How to Use Physician Services
At Rupa, our mission is to make root cause medicine more accessible and affordable for everyone. To help achieve this, Rupa offers Physician Services, which allows health and wellness professionals who do not hold a medical license to partner with a nationally-licensed physician in their client’s state.
Through this partnership, clients can access lab testing in a compliant manner, as the licensed physician orders the tests and reviews the results for any critical values. This ensures that health and wellness professionals who are not licensed to order labs can still offer lab-based insights within their legal scope of practice.
If the client has any questions regarding their lab results, the signing physician is available for consultations to provide medical guidance. This ensures that clients receive expert advice while allowing wellness professionals to focus on their role in supporting overall health and wellness.
Using Physician Services ensures that all lab testing is conducted in compliance with state and federal laws, while allowing wellness professionals to offer comprehensive care without overstepping legal or ethical boundaries.
*Please note that health and wellness professionals who are not licensed to order laboratory tests independently must work with a licensed physician through services like Physician Services to ensure legal compliance. Always verify your scope of practice and applicable laws in your state.
What if I Have a Doctor That Can Sign Requisitions For Me?
If you’re working with a physician or other licensed practitioner who can legally sign off on your clients' lab testing, Rupa can help facilitate that process. The signing physician will be the one responsible for ordering and reviewing the lab tests, ensuring compliance with all state and licensing regulations.
Invite your Signing Doctor to your clinic from your Team Members page, and they’ll receive an email to join, enabling them to sign requisitions and ensure all lab testing is done in compliance with legal and medical standards.
*Please note that the physician or licensed practitioner must hold the appropriate legal authority to order and sign lab requisitions. Always verify that the signing practitioner complies with your state’s regulations to ensure all lab testing is conducted within the legal scope of practice.
What If I’m Just Getting Started With Functional Medicine?
If you're just getting started with functional medicine and have recently gained lab ordering rights or access to our lab requisition services, but you're not yet comfortable with Functional Medicine Labs, that's perfectly fine. At Rupa Health, our goal is to make functional lab ordering as convenient and accessible as possible while ensuring you remain compliant with your scope of practice.
We offer live courses and boot camps designed to help practitioners increase their knowledge of functional medicine labs. These resources aim to empower you with the confidence and skills needed to integrate lab testing into your practice effectively and compliantly.
We also offer a comprehensive magazine dedicated to functional medicine practitioners, an in-depth reference guide, and a team of knowledgeable Onboarding Managers ready to walk you and your patients through the lab ordering process, ensuring everything is handled smoothly and compliantly.
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Disclaimer
This information is provided for educational purposes only and should not be considered legal advice. Laws and regulations regarding lab ordering vary by state and are subject to change. For the most accurate and up-to-date guidance, consult your state’s licensing board or a qualified legal professional.
Have any questions for us? Reach out! We love hearing from you!
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