Oklahoma’s Comprehensive Advanced Practice Act and
Specialty Certification Requirements
Laurence V. Hicks, D.C., N.D., D.O., M.D., Nicholas Grable, D.C., and Jed Adamson, N.D., D.N., C.Ac. [Author Contacts below]
Key Words: Oklahoma Chiropractic Practice Act, Oklahoma Revised Code, Non-Diplomate Specialty Certificate and Registration, Injectable Nutrients, Diagnostic Radiological Imaging, Laboratory Testing, Meridian Therapy, Hygienic, Sanitary and Therapeutic Measures, Naturopathy, Homeopathy, Animal Chiropractic Diagnosis and Treatment
Cite As: Hicks LV, Grable N, Adamson J, “Oklahoma’s Comprehensive Advanced Practice Act and Specialty Certification Requirements”, Blue Marble University Medical School, Posted November 29, 2020. https://bluemarbleuniversitymedicalschool.com/2020/11/29/oklahoma-expands-chiropractic-scope-of-practice-to-diagnosis-and-treatment/ Accessed __________[Insert Date Accessed]
It is the author‟s belief that the chiropractic profession should always put the welfare of the patient first, and in doing so, should not limit a properly trained practitioner‟s capacity to treat patients.
In the Great State of Oklahoma, the chiropractic profession has made a key decision to expand the Chiropractic scope of practice and increase their ability to diagnose and treat patients.
Several states have expanded their scope of practice, including Florida, Idaho, New Mexico, and Utah. Oregon has always had a broader scope of practice as compared to most other states, which included minor surgery, obstetrics, proctology, and gynecology. The American ChiropracticAssociation (ACA) and other chiropractic groups are promoting the “Chiropractic Medicare Modernization Act of 2019”, H.R. 3654. This bill will improve title XVIII of the Social SecurityAct to grant Medicare coverage for all physicians‟ services provided by a Doctor of Chiropractic within the scope of their licenses, permitting patients to obtain coverage. 
Early in the chiropractic profession, chiropractic adjustments were also made available to animals.  B.J. Palmer wrote “in the early days of chiropractic, we maintained a veterinarian hospital where we adjusted the vertebral subluxations of sick cows, horses, cats, dogs, etc.”  Chiropractic for animals continued to grow and in 1986 veterinarians and chiropractors formed the American Veterinary Chiropractic Association (AVCA).  Today, specialized training in the assessment and care of spinal joint dysfunction and neuromusculoskeletal disorders in animals, places chiropractic as a leader of conservative treatment of spinal-related disorders. 
In the “Sooner State,” the chiropractic profession made the critical decision to immensely expand their scope of practice, offering several specialized areas to qualified chiropractic physicians. This modification in the scope of practice constituted an advanced capability in delivering Acupuncture and/or Meridian Therapy, Homeopathy, Naturopathy, Injectable Nutrition and Animal Chiropractic diagnosis and treatment.
Oklahoma Chiropractic Practice Act
Under section (A), we learn that “the scope of practice of chiropractic shall include those diagnostic and treatment services and procedures which have been taught by an accredited chiropractic college and have been approved by the Board of Chiropractic Examiners.” 
Scope of Practice
A Doctor of Chiropractic shall be bound by all the provisions of the Oklahoma Public Health Code that apply to them, and shall be qualified to sign the following:
- Death certificates, pursuant to Section 1-317 of Title 63 of the Oklahoma Statutes; and
- All other certificates, including those relating to public health
This would be the same as that which is allowed by a Doctor of Medicine and Surgery or a Doctor of Osteopathic Medicine, and with like effect.
Chiropractic physicians may examine, analyze and diagnose the human body to correct, relieve or prevent diseases and abnormalities by the use of any physical, chemical, electrical, or thermal method. Such diagnostic and treatment services and procedures shall include the following:
- Use or order diagnostic radiological imaging
- Use or order laboratory testing
- Use any method of examination for diagnosis and analysis taught by an accreditedchiropractic college
- Adjust, manipulate and treat the human body by manual, mechanical, chemical,electrical, or natural methods
- Use of physiotherapy
- Use meridian therapy
- Use hygienic, sanitary and therapeutic measures
- Use and administration of Naturopathy
- Use of Homeopathy remedies
- Application of first aid
- Perform all other treatments taught by an accredited chiropractic college.” 
The authors opine that the use of statutory language such as “any other method of examination for diagnosis and analysis taught by an accredited chiropractic college” and “any other treatment taught by an accredited chiropractic college” is designed to promote an expanding scope of practice and is language that may be associated with advanced practice provisions.
This section concludes by stating “nothing in this rule shall permit a Chiropractic Physician to prescribe legend drugs, beyond injectable nutrients as authorized and is currently the law in Title 59 Section 161.12 of the Oklahoma Statutes.” 
Non-Diplomate Specialty Certificate and Registration
Here, under section (a), discussing definitions we are informed that “the term “Non-DiplomateSpecialty‟ means a certificate that is not specifically identified as being a Diplomate that is granted to a chiropractic physician by an institution, specialty council, or specialty board, while„Registry‟ means a structured record of registration information regarding all chiropractic physicians holding themselves out as having a specialty certificate. „Specialty Board‟ means aprofessional, independent entity that provides for competency testing of didactic and clinical skills of applicants and granting of certifications in post-doctoral chiropractic specialty areas upon completing an approved post-doctoral curriculum.”
Also, section (b) provides that “Non-Diplomate Specialty education shall meet the requirements and guidelines established by the institution, specialty council, or specialty board granting thecertificate to the chiropractic physician.”
The above language appears to refer to the advanced practice specialty areas, shortly to be discussed, and the need for discrete specialty certification to ensure public health and safety, requiring registration from the Board.
Acupuncture and/or Meridian Therapy
Under 140:15-1-2, covering Definitions, “the Act indicates that the following words and terms, when used in this Chapter, shall have the following meaning, unless the context plainly indicates otherwise.” Therefore, “Acupuncture and/or Meridian Therapy means a healthcare method used to prevent, diagnose and treat disease by restoring the body‟s balance and harmony consisting ofthe stimulation of various points on or within human body or interruption of the cutaneousintegrity by specific needle insertion or other form of point stimulation.” Acupuncture isOklahoma‟s initial advanced practice specialty to be covered.
Under Subchapter (10), Acupuncture, 140:15-10-1, Registration from the Board, we areinformed that “no chiropractic physician shall represent to the public that he/she is a specialist in the practice of Acupuncture and/or Meridian Therapy unless said chiropractic physician holds a registration issued by the Board stating that the chiropractic physician is proficient in Acupuncture and/or Meridian Therapy. The Board shall maintain a registry listing all chiropractic physicians who are authorized by the Board.
Further 140:15-10-2, Application for registration states each such chiropractic physician shall submit to the Board documentary evidence of satisfactory completion of at least one hundred (100) hours of education in Acupuncture and/or Meridian Therapy. Such education shall be obtained through an educational program, which is subject to or has been approved by the Board and meets the following criteria:
—Is conducted under the auspices of and taught by the postgraduate faculty of a fully accredited chiropractic college or institution, by a school of acupuncture recognized by the National Council of Acupuncture Schools and Colleges or by a school of acupuncture recognized by the Accreditation Commission for Acupuncture and Oriental Medicine.
—Requires completion of a certification examination approved by the Board; and
—Meets other such criteria as the Board deems appropriate.
(b) Upon successful demonstration of these requirements, the Board shall list the chiropractic physician’s name on the registry.”
To reiterate, 140:15-1-2, covering Definitions, states “the Act indicates that the following wordsand terms, when used in this Chapter, shall have the following meaning, unless the context plainly indicates otherwise.” Here, “Homeopathy means a healthcare method used to prevent, diagnose and treat disease by homeopathic methods such as homeopathic medicines, agents,remedies and articles. “Institution” means a school of higher education or its affiliate, regulatedby a state department of education or state department of health occupation or state commission on higher education or a school accredited by an agency recognized by the United StatesDepartment of Education or the Council of Higher Education Accreditation.”  Homeopathy is another advanced practice approach.
Homeopathy was developed in the late 18th century by Samuel Hahnemann, a respected physician and pharmacist in Germany. Hahnemann mass-produced the entire materia medica, diluted toxic medications to reduce risks and came to believe in the notion of “like cures like” and that minute concentrations of a particular toxin might have the capacity cure the very same symptoms it would cause in larger doses, e.g., administering poison ivy extract to treat rashes.
Because the notion of “like cures like‟ appeared similar to the emerging science of inoculation and vaccination, the diluted medications, as a part of homeopathic medicine, gained early notoriety. Hahnemann‟s treatments in their dilute forms were far safer than medications employed in most medical practices during his time, such as bloodletting. 
In discussing the overview of homeopathic regulation, Ullman wrote that it is legal for M.D. and D.O. physicians to practice homeopathy anywhere in the U.S. and points out that the three states of Connecticut, Arizona, and Nevada regulate Homeopathic Medicine through legally approved specialty boards. 
Also, At least 14 states have amended their allopathic and osteopathic statutes to facilitate the practice of nontraditional medicine. 
Ullman contends that Naturopathic Doctors can offer Homeopathic treatments in 22 jurisdictions, including Alaska, Arizona, California, Colorado, Connecticut, Hawaii, Idaho, Kansas, Maine, Maryland, Massachusetts, Minnesota, Montana, New Hampshire, New Mexico, North Dakota, Oregon, Pennsylvania, Rhode Island, Utah, Vermont, Washington, plus
In Subchapter (11), Homeopathy, 140:15-11-1, we cover Registration from the Board. “Only a chiropractic physician who has satisfactorily completed education in homeopathy and has received a certificate in homeopathic medicine from an accredited chiropractic college or institution recognized by the board and upon registration from the Board, may hold himself or herself out to the public as a specialist certified in homeopathic medicine.”
In 140:15-11-2, Application for registration; educational requirements (a) is detailed. “Any chiropractic physician who desires to represent to the public that he/she is a specialist in homeopathy shall make application, on a form prescribed by the Board. Each such chiropractic physician shall submit to the Board documentary evidence of satisfactory completion of education in homeopathic medicine. Such education shall be obtained through an educational program which is subject to or has been approved by the Board. (b) Upon a successful demonstration of these requirements, the Board shall list the chiropractic physician‟s name onthe registry.”
Though provisions for the use of homeopathic remedies have been included in the statutes of some states, such as Idaho and Utah; the Oklahoma Revised Code (ORC) is the first time, that we are aware of, in which a chiropractic practice act has gone so far as to define the legal practice of homeopathy for Chiropractic Physicians, establish educational prerequisites and ensure that certification is made available under the practice act, in a way similar to what we find in Arizona or Nevada for M.D. and D.O. physicians.
In a final iteration of 140:15-1-2, covering Definitions, the Act continues to indicate “that the following words and terms, when used in this Chapter, shall have the following meaning, unless the context plainly indicates otherwise. Thus, “Naturopathy means a healthcare method used toprevent, diagnose and treat disease by naturopathic methods of natural therapeutic modalities that include but are not limited to naturopathic medicines, agents, remedies and articles.”Naturopathy is a third advanced practice method.
Naturopathic practice is regulated in 22 jurisdictions, under various provisions. Of interest, in California the Naturopathic Medicine Committee is regulated under the Osteopathic Board  and in Idaho, Naturopathic Physicians are regulated under the Medical Board. 
Oklahoma‟s regulation of Naturopathy under the chiropractic practice Act is the first of its kindin the modern era. It seems most appropriate, considering naturopathic degrees were, early on, awarded primarily by chiropractic institutions.
According to Robert Mootz, D.C. and Reed Phillips, D.C., Ph.D., “although chiropractic has much in common with other health professions, its philosophical approach distinguishes it from modern medicine. Chiropractic philosophy involves what has been described as a „contextual naturopathic approach‟ to health care.” 
Subchapter (12), under provisions relating to Naturopathy, 140:15-12-1 covers Registration from the Board. “Only a chiropractic physician who has satisfactorily completed education in naturopathy and has received a certificate in naturopathic medicine from an accredited chiropractic college or institution recognized by the board and upon registration from the Board, may hold himself or herself out to the public as a specialist certified in naturopathic medicine.”
Next, 140:15-12-2, Application for registration; educational requirements (a) requires “Any chiropractic physician who desires to represent to the public that he/she is a specialist in naturopathy shall make application, on a form prescribed by the Board. Each such chiropractic physician shall submit to the Board documentary evidence of satisfactory completion of education in naturopathic medicine. Such education shall be obtained through an educational
program, which is subject to or has been approved by the Board. Thereafter, (b) assures that“upon a successful demonstration of these requirements, the Board shall list the chiropracticphysician‟s name on the registry.”
Injectable Vitamins, Minerals or Nutritional Supplements
Chapter 15 of the Oklahoma Chiropractic Practice Act is a review of Special Certificates and Miscellaneous Provisions. Under General provisions 140:15-1-1, the stated purpose of this Chapter is to:
Establish a certification system and standards for the education and training of chiropractic physicians who desire to administer injectable vitamins, minerals or nutritional supplements; and
Establish various requirements and prohibitions related to the practice of chiropractic found by the Board to be in the best interest of the health, safety and welfare of the public.
Injectables constitute a fourth advanced practice process and under Subchapter (5), titled the“Authorization for Injectables,” language relevant to 140:15-5-1 is covered. It states that authorization is derived from the Board. This advanced practice provision declares that “Nochiropractic physician shall administer or cause to be used any injectable vitamins, minerals or nutritional supplements unless said chiropractic physician is authorized by the Board, pronouncing that said chiropractic physician is proficient in the administration and use of suchinjectables.”
Further, we are given to understand that “the Board shall establish an examination to be used bythe Board to determine the proficiency of any chiropractic physician who seeks authorization from the Board. However, any authorization issued before January 1, 1994, shall not require examination. The Board shall maintain a registry listing all chiropractic physicians who areauthorized by the Board” in association with section 140:15-5-2.
Also, in making an application for authorization, specific educational requirements must besatisfied. “Any chiropractic physician who desires to administer vitamins, minerals or nutritionalsupplements by means of injectable procedures shall make application, on a form prescribed by the Board, for authorization for such purpose. Each such chiropractic physician shall submit to the Board documentary evidence of satisfactory completion of at least twenty-four (24) hours of education and training in administration and use of such injectables. Such education and training shall be obtained at an educational program, which has been approved by the Board and meets the following criteria:
—The program is conducted under the auspices of and taught by the post graduate faculty of a chiropractic institution.
—Consist of a minimum of twenty-four (24) hours;
—Requires completion of a certification examination given by a board independent of the entity which taught the course; and
—Meets such other criteria as the Board deems appropriate.”
Section 140:15-5-3 covers Education and training. Approval of education and training in administration of vitamins, minerals, nutritional supplements by means of injectable procedures under the provisions of 140:15-5-1 and 140:15-5-2 is vested solely in the Board. No educational program shall be offered, advertised or marketed for the purpose of certification prior to being approved by the Board.
Regarding continuing education hours, (a) Effective July 1, 2014, each chiropractic physician in the State of Oklahoma who is authorized by the Board to administer and use injectable vitamins, minerals or nutritional supplements must re-register and submit a sworn statement of hours of continuing education completed during the concluding licensing period.
Animal Chiropractic Diagnosis and Treatment
Animal Chiropractic diagnosis and treatment is the fifth and final advanced practice routine allowed under the Oklahoma Revised Code (ORC).
Subchapter 8 is titled “Animal Chiropractic Diagnosis and Treatment. 140:15-8-1 requires a certificate to permit a chiropractor to practice animal chiropractic diagnosis and treatment. Under section (a) we are informed that a chiropractic physician may engage in practice of animal chiropractic diagnosis and treatment if certified to do so by the Board. A licensed chiropractic physician may provide chiropractic treatment to an animal without being certified in animal chiropractic diagnosis and treatment if the animal has been referred to the chiropractic physician by a licensed veterinarian.
Under section (b) „Animal chiropractic diagnosis and treatment‟ means treatment that includes vertebral subluxation complex (VCS) and spinal manipulation of nonhuman vertebrates. Insubsection (2) we learn that “Animal chiropractic diagnosis and treatment” means treatment thatincludes vertebral subluxation complex (VSC) and spinal manipulation of nonhumanvertebrates.” However, “the term „animal chiropractic diagnosis and treatment‟ shall not beconstrued to allow the:
Use of x-rays,
Performing of surgery,
Dispensing or administering of medications, or
Performance of traditional veterinary care.”
Section (c) establishes requirements for training. “The Board is charged by statute to establish educational criteria for certification standards in animal chiropractic diagnosis and treatment. According, the Board states that the following educational criteria will be applied to any licensed chiropractic physician who requests certification in animal chiropractic diagnosis and treatment, The criteria shall include education and training in: (1) Anatomy, including sacropelvic, thoracolumbar, cervical and extremity; (2) Equine and canine adjustments; (3) Topographical laboratory; (4) Chiropractic basis, including history and systems review, subluxation, and vertebral subluxation complex; (5) Veterinary basics, including anatomy as it relates to restraint and positioning, physiology, and pharmacology, metabolic and contagious diseases and lameness; (6) Chiropractic and neurological diagnosis; (7) Radiology and biomechanics; (8) Proficiency in basic technique; (9) Pathology; 48 (10) Podiatry, including lower limb dissection; (11) Chiropractic and veterinary philosophy; (12) Professional ethics and legalities; and (13) Identification of animals.”
Section (d) indicates that “any licensed chiropractic physician requesting certification in animal chiropractic diagnosis and treatment shall have completed no less than 150 hours of education and training education as set forth above.” There are several additional animal chiropractic provisions and requirements enumerated in the practice act.
To summate, ORC provides a very broad advanced practice model for Oklahoma chiropractors. Advanced practice specialty certification is available in Acupuncture and/or Meridian Therapy, Homeopathy, Naturopathy, Injectable Vitamins, Minerals or Nutritional Supplements and Animal Chiropractic diagnosis and Treatment. There is no doubt that considerable education and training time, additional to financial outlay are required to advance skill sets and to satisfy individual advanced practice specialty certification requirements. Furthermore, continuing education (CE) is required are to ensure ongoing skill maintenance, but CE adds to cost. It appears doubtful that any one chiropractic physician would ever obtain specialty certification in all of Oklahoma‟s advanced chiropractic practice arenas.
This report represents the author‟s interpretation of the ORC, as we have tried to better understand and share the scope of practice with the reader. If we have erred in any way in our report, we defer to the understanding of the Oklahoma Board of Chiropractic Examiners and their view of the Oklahoma Chiropractic Practice Act.
 http://www.animalchiropractic.org/animal_chiropractic_history.htm. Accessed October 10, 2019.
 B.J. Palmer, “It is as Simple as That,” Palmer College of Chiropractic, 1944
 Haussler, K. K. (1997). Application of chiropractic principles and techniques to equine practice. In Proc of the Annual Convention of the American Association of Equine Practitioners (Vol. 43, pp. 312-318).
 https://www.ok.gov/chiropracticboard/documents/Oklahoma%20Chiropractic%20Practice% 20Act%20Revised%20August%2025%2C%202019.pdf
 Wanjek, Christopher. What is Homeopathy? • https://www.livescience.com/31977-homeopathy.html. May 13, 2013.
 https://homeopath.az.gov/statute/32-2911, http://nvbhme.org/statutes.html
 Ullman, Dana. M.P.H., C.C.H. Legal Issues in Homeopathic Practice • https://homeopathic.com/legal-issues-in-homeopathic-practice/
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Laurence V. Hicks, Sr., D.O. • 1443 Anny Drive East • Twin Falls, ID 83301
Office: 208-733-4444, Cell: 208-320-4823, e-mail: firstname.lastname@example.org
Nicholas C. Grable, D.C. • 6434 W. Interchange Lane • Boise, ID 83709
Office: 208-322-7755, Cell: 910-987-7233, e-mail: email@example.com
Jed Adamson, N.D. • 206 Martin St suite a, Twin Falls, ID 83301
Office: (208) 735-1166