Lab Test Ordering Rights by State: The Ultimate Guide

Dr. Shawn Greenan, DACM, CFMP®
Lab Test Ordering Rights by State: The Ultimate Guide

One of the most common questions we get at Rupa is: “Can I order functional medicine labs?”

The answer to this question is, it depends. States have different rules, it varies on the professional credentials you have, and each lab has different standards of who can order from them.

Really quickly it can get confusing and overwhelming searching for the answer. But don't worry! We’ve got a cheat sheet to help you know your rights.

When you're ready to start ordering functional medicine labs sign up for Rupa.

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Who Can Order Labs?

MD, DO, DDS, DPM, OD, NP, and PA may order labs in all 50 states. (1) Some states require Nurse practitioners and Physician Assistants to be sponsored by MD or DO. (2)  

Naturopathic Doctors

ND’s scope of practice regulations varies among states and provinces, as do the parameters and restrictions for practitioners located in pre-licensed locations. Naturopathic Doctors receive training in the same biomedical and diagnostic sciences as MDs and DO’s. ND’s who are current with their licensure can order and interpret labs in the following states: AK, AZ, CA, CO, CT, DC, HI, ID, KS, ME, MN, MT, NH, ND, OR, UT, VT, and WA. (3)

Licensed Acupuncturists (LAc)

California, Florida, and New Mexico acupuncturists are granted the status of “primary care provider” and function at a high level of medical practice. Among the many medical privileges granted in these states, using western medical diagnostic tools such as labs test is one of them. In Colorado and Nevada, LAc’s must also have earned the title of Doctor of Oriental Medicine to order diagnostic and functional medicine labs. LAc’s in Arkansas and Mississippi are not considered primary care but can still order and interpret labs.(4) Licensed LAc, DOM, and DACM in all 50 states can utilize our lab requisition service through Rupa Health.

Doctor of Chiropractic (DC)

Chiropractic health care is a recognized profession in all United States jurisdictions and in all Canadian provinces. All states require the applicant for chiropractic licensure to obtain a Doctor of Chiropractic (DC) degree from an approved educational program accredited by the Council on Chiropractic Education (CCE).

DC’s are allowed to order and interpret labs in all states except GA and RI. (1) Although it’s important to note that Rupa Health and many functional labs do not ship tests to NY, NJ, and RI due to laboratory billing regulations.


Registered Dieticians (RD)

Each RD has an individual scope of practice determined by education, training, and credentialing.

In 2014 The Centers for Medicare and Medicaid Services (CMS) announced a final rule that now allows RDs lab ordering privileges as long as they meet the following requirements:

1. The RD must be working under a clinic or hospital.

2. The lab tests ordered are specifically meant to monitor the effectiveness of dietary plans.

Private practice RD’s can order functional and integrative lab tests through certain individual lab companies. (5) All licensed RD’s can also utilize our lab requisition service through Rupa Health.

What if I’m Just Getting Started with Functional Medicine?

Maybe you just found out that you have lab ordering rights or have access to our lab requisition services, but you aren’t comfortable with Functional Medicine Labs. That’s ok too, our goal at Rupa Health is to make FM lab ordering as convenient and easy as possible. We are constantly adding live courses to help practitioners increase their FM knowledge, we have a whole magazine dedicated to you, and we have a group of amazing Onboarding Managers available to walk you and your patients through everything.

Not Currently Licensed to Order Lab work

Live in a state where you don’t have lab ordering rights but are a licensed practitioner. Join our waitlist! Soon you will be able to use our free service to get lab requisitions signed by an ordering doctor through Rupa Health.

What if I have a doctor that can sign requisitions for me?

If you work with a physician or other licensed practitioner who can sign off on your patients’ testing, we can set that up through Rupa!

Here’s how:

1. Have your signing practitioner create an account with us.

2. Message us through the portal or at so we can link your account to theirs.

What if it turns out I can order labs in my state, but it’s not listed?

Please let us know! We’re always looking to improve our knowledge base. If you message us through the portal or via email with an updated reference, we’ll get that lab or state added to our catalog. :)


Although we do our best to narrow down the information for our readers, it’s imperative to note that laws and regulations change often. If you have any specific questions or unsure of certain rights, please contact the licensing board in your state. They will be able to guide you on your scope of practice and any legal pitfalls for ordering testing.  

Have any questions for us? Reach out! We love hearing from you!

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Dr. Shawn Greenan, DACM, CFMP®
Acupuncture Physician Certified Functional Medicine Practitioner®
Order from 20+ labs in 20 seconds (DUTCH, GPL, Genova & More!)
We make ordering quick and painless — and best of all, it's free for practitioners.
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