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BlogLabsLab Test Ordering Access by State: The Ultimate Guide
With the 21st Century Cures Act now requiring laboratory results to be released directly to patients in real time, providers face greater responsibility to understand who’s legally permitted to order and access laboratory tests. This is more than an administrative detail, as it directly affects patient safety, compliance with federal and state rules, billing practices, and the communication of sensitive findings.
Laboratory access and ordering authority aren’t standardized across the United States. Instead, they are shaped by overlapping frameworks that include federal regulations such as CLIA and HIPAA, state-specific statutes, professional credential requirements, and institutional policies.
For healthcare providers, navigating this system is crucial to maintaining compliance and ensuring patient care is safeguarded. Knowing which credentials are recognized in each state, how the scope of practice aligns with laboratory regulations, and what operational policies apply within a given setting can help reduce compliance risks and ensure timely, accurate communication with patients.
This article outlines the key regulations and credential considerations, explains how rules differ by state, and offers practical approaches for integrating laboratory testing into clinical workflows in ways that support both regulatory standards and patient-centered care.
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Laboratory ordering rights in the United States are shaped by federal laws, but many details are determined at the state level.
CLIA, HIPAA, and the 21st Century Cures Act
The Clinical Laboratory Improvement Amendments (CLIA) set nationwide standards for laboratory operations. Under CLIA, results may only be released to authorized individuals, with each state defining who qualifies for that role. The Health Insurance Portability and Accountability Act (HIPAA) ensures that patients can access their finalized results, usually through the provider who ordered the test. The 21st Century Cures Act expanded access by requiring real-time release of electronic health information, including laboratory reports, unless a valid exception applies.
Information blocking, exceptions, and EHR access
The Cures Act restricts practices that delay or block patient access to their information. Exceptions apply in specific situations, such as when release may cause harm, when privacy protections are required, or when state laws address the consent of minors.
For providers, this can create a balance between following federal mandates and using clinical judgment in sensitive cases. Electronic health record (EHR) systems are central to this process, as they must enable automatic release while also accommodating valid exceptions and proxy access requirements.
Lab ordering authority by credential
Both professional credentialing and state-specific regulations determine laboratory ordering authority in the United States. Knowing these boundaries is important for avoiding compliance risks and ensuring safe, coordinated care.
Physicians (MD, DO)
Physicians are generally permitted to order laboratory tests in all states. Participation in programs such as the Interstate Medical Licensure Compact (IMLC) may also extend their ability to practice across multiple states.
Nurse practitioners (NP) and physician assistants (PA)
The scope for NPs and PAs varies by state. In full-practice states, NPs may order tests independently, while in restricted states, physician collaboration or supervision may be required. PAs typically work under written protocols or delegated authority, which outline their ability to order labs.
Naturopathic doctors (ND)
Naturopathic doctors may order laboratory tests in states where their licensure is recognized, such as Oregon, Washington, Arizona, Vermont, and others. In states without licensure, they typically need to collaborate with physicians or other licensed providers.
Chiropractors (DC)
The chiropractic scope of practice is highly variable. Some states permit ordering of certain diagnostic tests, while others limit or prohibit this authority, particularly for specialty or advanced testing.
Nutrition providers (RD, CNS, CN)
Registered Dietitians (RDs) may have the authority to order specific tests in institutional or CMS-regulated settings. Certified Nutrition Specialists (CNS) may have limited authority in certain states, such as California and Washington. Non-licensed nutrition providers (such as health coaches) don’t have independent ordering rights and must collaborate with licensed providers.
Acupuncturists and doctors of Oriental medicine (LAc, DOM, DACM)
In states such as California, New Mexico, and Florida, acupuncturists may have limited authority to order labs, often within the framework of primary care provisions. In other states, ordering rights may be limited or require collaboration with a physician.
Pharmacists (PharmD)
Pharmacists may order specific labs under collaborative practice agreements (CPAs) in states such as California and New Mexico. This is typically associated with chronic disease management or medication monitoring.
Allied health professionals (physical therapists, occupational therapists, psychologists)
Most allied health professionals don’t have the independent authority to order labs. In institutional settings, they may contribute within team-based workflows where delegated authority or standing orders are in place.
Laboratory ordering and access across states
While federal laws establish the overall framework for laboratory regulation, the details of who can order and access tests are determined at the state level. Some states take a more restrictive approach, limiting which professionals are authorized to order specific tests, including specialty or functional panels. Others allow broader participation among licensed providers, particularly within team-based models of care.
Patient privacy adds another layer of complexity. In many jurisdictions, minors may hold independent rights to the results of certain tests, especially in areas such as reproductive or behavioral health. This means practices must ensure that their electronic health record systems and communication processes are designed to protect confidentiality while meeting legal requirements.
Telehealth further underscores the importance of state rules. When a provider and patient are located in different states, the laws of the patient’s state generally apply. This often requires the provider to hold a license in that state, and in some cases, laboratories may also need to be registered locally. Interstate licensure compacts can make cross-state practice more efficient, but they don’t override state-specific regulations.
Facility operations, licensing, and institutional protocols
Operational requirements extend beyond providers to the facilities and staff involved in laboratory testing. In some hospitals and health systems, ordering rights are sometimes extended to additional providers through bylaws or delegation agreements, with details shaped by state oversight and institutional policy.
Laboratory personnel are generally expected to meet training, certification, and regulatory standards. In certain states, phlebotomists are required to hold state-issued licenses, and in all cases, compliance with CLIA and occupational safety guidelines is an important part of laboratory operations. Mobile phlebotomy services may also be subject to state registration or licensure, and changes in ownership or location can affect those requirements.
Physician office laboratories are typically regulated under CLIA, though some states add their own requirements, such as licensure for moderate- or high-complexity labs or participation in evaluation programs. Reviewing state and institutional policies helps reduce compliance risk and ensures laboratories operate within the appropriate framework.
Frequently asked questions (FAQs)
Which non-physician providers are authorized to order labs across multiple states?
Nurse practitioners and physician assistants may order laboratory tests in most states, although rules vary. Multistate authority depends on practice models and whether the provider participates in compacts, such as the IMLC.
Can nutrition professionals, such as CNS or RD, order specialty or functional labs?
RDs may order specific tests in institutional settings, and CNS credentials carry authority in certain states. However, access to functional and specialty labs often depends on collaboration with licensed physicians.
What types of lab results are considered sensitive?
Examples include HIV, reproductive health, sexually transmitted infection (STI) results, and certain genetic tests. Some states require oral communication for these results, and others restrict proxy access when minors are involved.
How do collaborative practice agreements (CPAs) affect pharmacists’ ability to order labs?
Pharmacists in states that allow CPAs may order labs tied to medication monitoring or chronic care management. Authority is defined by the agreement and limited to the conditions it covers.
Can providers order labs for patients who live in a different state?
Yes, but only if they are licensed in the patient’s state at the time of care. Lab orders are governed by the patient’s location, not the provider’s. In some cases, laboratories are also required to hold state licensure.
Key takeaways
Lab test ordering rights in the U.S. depend on a mix of state law, federal regulations, and provider credentials, meaning authority isn’t uniform nationwide.
Physicians (MD/DO) have full ordering authority everywhere, whereas NPs, PAs, and pharmacists may require collaboration agreements or face restrictions depending on state regulations.
Other providers, such as nutritionists, naturopathic doctors, chiropractors, and acupuncturists, often face limited or conditional authority and must align with local licensing laws.
Some states are highly restrictive, limiting access to specialty or functional testing, while others are more flexible and allow broader provider participation.
Compliance involves more than meeting the legal scope of practice. It also includes the proper setup of electronic health records, alignment of laboratory result release processes, accurate documentation, and billing practices that comply with current regulations.
Providers should regularly review state-specific updates and institutional policies to ensure that lab ordering for patients is lawful, safe, and transparent.
Ready to start delivering better patient care?
Join 100,000 healthcare providers who rely on Fullscript to dispense top-quality supplements and labs to their patients.
The information in this article is intended for healthcare practitioners for educational purposes only, and is not a substitute for informed medical, legal, or financial advice. Practitioners should rely on their own professional training and judgement, and consult appropriate legal, financial, or clinical experts when necessary.
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