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.
It can get confusing and overwhelming searching for the answer. But don't worry! We’ve got you covered!
Create a free Rupa Health account to see our Lab Ordering Access Page, and get to know your specific rights. 🧪
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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 licensure in all 50 states. These practitioners can apply for multiple state licensures, if desired. However, they will only be able to order labs in the state(s) where they hold licenses.
State-Wide Functional Lab Ordering Restrictions
*NJ, NY, and RI have unique laws when it comes to ordering functional lab tests, so regardless of your degree or credentials, functional medicine lab ordering may be restricted in those 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 need for a National Provider Identifier (NPI) number to order laboratory tests depends on the healthcare provider's credentials and state regulations. Licensed professionals such as physicians, nurse practitioners, and physician assistants typically require an NPI number to order lab tests, as it is essential for billing and administrative processes.
Practitioners without medical licensure, like health coaches or some nutritionists, usually cannot obtain an NPI number and must collaborate with licensed providers to order lab tests. However, some nutritionists and health coaches can still apply for an NPI depending on their specific certifications.
You can read more about NPIs in this article and learn more about what it is and when you need it.
Can Nurses and Physician Assistants (PA) Order Labs?
Nurses and Physician Assistants (PAs) generally have the authority to order laboratory tests, although the extent of this authority can vary by state and specific regulations governing their practice.
Nurse Practitioners (NP)
Nurse Practitioners (NPs) can order lab tests because they have special training to diagnose illnesses, prescribe medicine, and do tests like bloodwork. This is a big part of how they take care of patients, especially in places like clinics. But, whether an NP can order these tests on their own or needs to work with a doctor can change depending on the state they're in. The rules are different everywhere.
Check out our article detailing NP lab ordering rights.
Registered Nurses (RN)
Registered Nurses (RNs), on the other hand, usually can't order tests by themselves. They mainly help take care of patients and help with tests, but the decision to order a lab test is often up to NPs or doctors. Sometimes, in certain places like hospitals, RNs might be allowed to order some tests if there's a special rule or agreement.
Other Nursing Credentials
Certified Registered Nurse Anesthetists (CRNAs), Advanced Practice Registered Nurses (APRNs), Certified Nurse Midwives (CNMs), and Clinical Nurse Specialists (CNSs) are advanced nursing professionals with specialized training and significant clinical expertise. The ability of these practitioners to order laboratory tests generally depends on state regulations, which can vary widely.
In many states, CRNAs, APRNs, CNMs, and CNSs are granted the authority to order labs as part of their scope of practice. States such as California, New York, and Texas have regulations that allow these advanced practice nurses to order and interpret laboratory tests independently or under a collaborative practice agreement.
This authority enables them to provide comprehensive and effective patient care, particularly in diagnosing and managing health conditions. However, it’s important for these practitioners to be familiar with the specific regulations in their state to ensure they practice within the legal scope of their credentials and provide the highest standard of care.
Physician Assistants (PA)
Physician Assistants (PAs) are highly trained medical professionals who work under the supervision of physicians to provide a wide range of healthcare services, including diagnosing and treating illnesses, prescribing medications, and performing procedures.
The ability of PAs to order laboratory tests is generally well-established and is allowed in most states. PAs have the authority to order and interpret lab tests as part of their practice, which is essential for providing comprehensive patient care. This authority is typically granted through state regulations and is often included in their scope of practice, which is defined by state law and the supervising physician's delegation.
States like California, New York, and Texas explicitly allow PAs to order lab tests, though the specifics can vary slightly based on individual state regulations and the agreements in place with supervising physicians. It is important for PAs to be familiar with their state's regulations to ensure they practice within their legal scope and provide effective patient care.
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Other Practitioner Types Who Can Order Labs
Many other professionals can order labs, too. Here are the most common practitioner types:
Naturopathic Doctors (ND)
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 DOs.
NDs who are current with their licensure 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 US Territories: Puerto Rico and U.S. Virgin Islands.
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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).
DCs are allowed to order and interpret labs in all states. (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.
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Nutrition Professionals
There are numerous credentials and certifications available for nutritional professionals, each signifying specialized knowledge and expertise in various aspects of nutrition and dietary science. Here are the most common and what they mean in terms of ordering labs:
Registered Dietitians (RD)/ Licensed Dietitian (LD)/Licensed Dietitian Nutritionist (LDN)
A Registered Dietitian (RD) is a licensed nutrition expert who provides evidence-based dietary advice and interventions to promote health and manage medical conditions. 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 RDs can order functional and integrative lab tests.
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 specific state's regulations to ensure compliance and to leverage their full scope of practice effectively.
Other Nutrition Credentials
Functional Diagnostic Nutrition Practitioners, Nutritional Therapy Practitioners, Certified Nutritionists, and Clinical Nutritionists are all examples of educated and knowledgeable professionals in the field of nutrition.
While these credentials may not always lead to licensure and are often subject to varying levels of regulation, these practitioners play a valuable and impactful role in supporting individuals' health and well-being through their expertise and dedication. Their contributions to the field of nutrition are significant, providing personalized guidance and support to help people achieve their health goals.
Certain labs allow for practitioners with the above credentials to order labs even if they don’t have state licensure. For specifics, check with your states, the individual lab companies, or the easiest option - Rupa’s Lab Ordering Access page, which you can utilize for free in your practitioner portal.
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Licensed Acupuncturists (LAc)/ Doctor of Acupuncture and Oriental Medicine (DOM or DAOM/DACM)
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 lab tests is one of them.
In Colorado and Nevada, LAcs must also have earned the title of Doctor of Oriental Medicine to order diagnostic and functional medicine labs. LAcs 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.
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Pharmacist (PharmD)
Pharmacists are highly trained healthcare professionals who play a large role in patient care, particularly in medication management and therapeutic optimization. The ability of pharmacists to order laboratory tests also varies by state, reflecting the diverse regulatory landscapes across the United States.
In some states, pharmacists are granted the authority to order and interpret laboratory tests as part of their collaborative practice agreements or as part of specific health initiatives. States like California, New Mexico, and North Carolina have more progressive regulations that permit pharmacists to order and interpret lab tests, allowing them to manage chronic conditions more effectively and improve patient outcomes.
However, this authority is not universally granted, and in many states, pharmacists may still need to collaborate with physicians or other healthcare providers to order laboratory tests. Understanding the specific regulations in their state is essential for pharmacists to fully utilize their skills and contribute to patient care within the legal scope of their practice.
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Physical Therapist (PT)
Physical therapists (PTs) are healthcare professionals who specialize in diagnosing and treating musculoskeletal and movement disorders. The ability of physical therapists to order laboratory tests is regulated on a state-by-state basis and is generally more restricted compared to other healthcare providers.
In most states, physical therapists do not have the authority to order laboratory tests independently. However, some states are beginning to recognize the value of allowing PTs to order specific types of lab tests, especially those directly related to their scope of practice, such as tests for inflammation markers or metabolic conditions that may impact physical therapy outcomes.
States like Colorado and California have more progressive regulations that grant limited lab ordering privileges to physical therapists under certain conditions. It remains essential for PTs to understand the specific regulations in their state to practice within their legal scope and ensure comprehensive patient care.
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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 occupational therapists to order laboratory tests is generally limited and varies by state.
In most states, OTs do not have the authority to order laboratory tests independently, as their primary focus is on functional assessments and therapeutic strategies rather than diagnostic testing. However, some states may allow occupational therapists to collaborate with other healthcare providers to recommend or interpret lab tests related to their scope of practice, such as tests for sensory processing disorders or metabolic conditions affecting occupational performance.
It is important for OTs to be aware of the specific regulations in their state to ensure they practice within their legal scope and provide the highest quality of care to their clients.
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Licensed Psychologist
Licensed psychologists are mental health professionals who specialize in diagnosing and treating psychological disorders through various therapeutic techniques. The ability of licensed psychologists to order laboratory tests is generally restricted and varies by state.
In most states, psychologists do not have the authority to order laboratory tests independently, as their primary focus is on psychological assessment and therapy rather than medical diagnostics. However, some states may allow licensed psychologists with specialized training or additional certifications to order certain types of lab tests, particularly those related to neuropsychological conditions or psychophysiological assessments.
Understanding state-specific regulations is important for licensed psychologists to ensure they practice within their legal scope and provide the most effective care for their patients.
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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, the ability of Functional Diagnostic Practitioners to order laboratory tests varies and is generally limited, as they typically do not hold medical licenses.
In most states, FDPs cannot order laboratory tests independently and must collaborate with licensed healthcare providers to obtain lab results necessary for their assessments. Some FDPs may work under the supervision of a licensed practitioner who can order the tests, while others may use Physician Services (see below for detail!).
Understanding the specific regulations and working within their scope of practice is essential for Functional Diagnostic Practitioners to ensure they provide effective and legally compliant care.
Can Health Coaches Order Labs?
Health coaches are professionals who support individuals in achieving their health and wellness goals through guidance, education, and motivational support. The ability of health coaches to order laboratory tests is generally not permitted, as they do not hold medical licenses and their role is primarily focused on behavior change and wellness coaching rather than clinical diagnostics.
Health coaches typically collaborate with licensed healthcare providers to help clients understand and implement recommendations based on lab results, but they do not have the authority to order these tests independently.
It is important for health coaches to be aware of their scope of practice and to work within the regulatory framework of their state to provide effective and legally compliant support to their clients.
Health coaches can also utilize our physician services option - Learn more about this below!
Some Labs Only Require Certifications
Tiny Health and Bristle Health are innovative companies that offer laboratory testing services with flexible ordering options for healthcare practitioners. These labs allow a wide range of practitioners to upload their certifications and order tests without specific restrictions on the type of practitioner.
This inclusive approach means that functional diagnostic practitioners, nutritionists, health coaches, and other certified professionals can utilize these labs to support their clients' health and wellness goals. By removing practitioner type restrictions, Tiny Health and Bristle Health provide a valuable resource for a diverse group of health professionals, enabling them to access and interpret lab results to deliver personalized and effective care.
This flexibility enhances the ability of practitioners to integrate comprehensive diagnostic insights into their practice, promoting better health outcomes for their clients.
Not Able to Order Labs With Your Own License? Learn How to Use Physician Services
At Rupa, our mission is to bring root cause medicine to everyone on the planet. We believe we can do that by making root cause medicine more affordable and accessible. To support that mission, Rupa offers Physician Services, a way for health and wellness professionals to partner with a nationally-licensed physician in their client’s state.
With this partnership, clients are able to access lab testing and the signing physician will order and review their lab results for any critical values. If the client has any questions for the physician, they are available for consultations too.
Add Physician Services to your account in Settings!
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 sign off on your patients’ testing, we can set that up for you through Rupa! Invite your Signing Doctor to your clinic from your Team Members page, and they’ll get an email to join your clinic.
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 functional lab ordering as convenient and easy as possible.
We constantly add live courses and boot camps to help practitioners increase their functional medicine knowledge.
We have a whole magazine dedicated to you, an in-depth reference guide, and an amazing group of Onboarding Managers available to walk you and your patients through everything.
Join a Live Group Demo to see the Rupa platform in action!
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Disclaimer
While we strive to always provide up-to-date information for our readers, it's important to keep in mind that laws and regulations are subject to frequent changes. If you have any questions or uncertainties about your rights, feel free to reach out to the licensing board in your state. They're the best resource to help navigate your scope of practice and any legal considerations when it comes to ordering lab testing.
Have any questions for us? Reach out! We love hearing from you!
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