Scope of Practice
Which healthcare providers can perform hirudotherapy and under what authority
Legal Disclaimer
Hirudotherapy authorization derives from existing healthcare licensing frameworks — no separate "hirudotherapy license" exists in any US state. Understanding scope of practice is critical for legal compliance, institutional credentialing, and malpractice protection.
Scope Summary by Provider Type
| Practitioner | Authorization | Key Conditions |
|---|---|---|
| MD/DO (Physician) | Yes — all 50 states | No restrictions; broadest scope |
| NP/APRN | Yes — state-dependent | Independent in 26 states + DC; supervision required elsewhere |
| PA | Yes — under supervision | Physician delegation agreement required |
| RN | Yes — under orders | Physician orders; institutional credentialing |
| ND/NMD | Uncertain — state-dependent | Licensed in ~24 states; no state explicitly addresses leeches |
| LAc (Acupuncturist) | Uncertain | State-dependent; likely outside standard scope |
| DC (Chiropractor) | No — in most states | Scope generally too narrow |
| C.H.P. (unlicensed) | High legal risk | Private credential; safe harbor laws in ~7 states |
Provider Categories
Physicians (MD/DO)
Authorized in all 50 states and DC. Physicians hold the broadest scope of practice. No state prohibits physicians from performing leech therapy. Physicians may use any FDA-cleared medical device within the practice of medicine, including for off-label indications.
Nurse Practitioners (NP)
State-dependent. Full independent practice in 26 states + DC (2025). NPs with full practice authority can independently evaluate patients, order treatments, and prescribe medications. In the remaining states, collaborative agreements or physician supervision is required.
Physician Assistants (PA)
Authorized under physician supervision in all 50 states. PAs practice medicine under physician supervision. PAs frequently participate in postoperative leech therapy under standing surgical orders in hospital settings.
Registered Nurses (RN)
Primary applicators in hospital settings under physician orders. RNs perform the majority of direct leech applications in hospitals. Institutional credentialing typically requires completion of a facility-specific training module.
Naturopathic Physician (ND) Scope
Complex Scope-of-Practice Landscape
Licensed in approximately 24 states + DC. No state explicitly addresses hirudotherapy. The core question is whether leech therapy falls within statutory categories such as “natural therapies,” “physical medicine,” or “naturopathic modalities.”
Broadest Scope
Oregon: Broadest in North America. Arizona: NDs referred to as “physicians” in state law. Washington: Insurance-eligible, broad prescribing.
Moderate Scope
Colorado, Connecticut, Minnesota: Licensed with moderate scope; interpretation required. Board advisory opinion recommended.
No ND Licensure
Florida, South Carolina, Tennessee, Texas, New York: Do not license NDs. Practicing under an ND credential constitutes unauthorized practice.
State-by-State Summary (Selected Jurisdictions)
| State | MD/DO | NP Authority | ND Licensed? | Safe Harbor? |
|---|---|---|---|---|
| California | Yes | Supervised | Yes | No |
| Texas | Yes | Supervised | No | No |
| Florida | Yes | Supervised | No (prohibited) | No |
| New York | Yes | Collaborative | No | No |
| Arizona | Yes | Independent | Yes (NMD) | Yes |
| Oregon | Yes | Independent | Yes | No |
| Washington | Yes | Independent | Yes | No |
| Colorado | Yes | Independent | Yes | Yes |
| Minnesota | Yes | Full practice | Yes | Yes |
| Connecticut | Yes | Independent | Yes | No |
Safe Harbor Laws
Health Freedom Statutes
At least seven states have enacted “health freedom” or “safe harbor” laws permitting unlicensed individuals to provide complementary and alternative medicine services. These statutes typically require written disclosure, signed consent, no claims to diagnose or treat, and no prescribing.
Whether leech therapy qualifies for safe harbor protection is an untested legal question. The antibiotic requirement creates particular tension with prescribing prohibitions. Practitioners relying on safe harbor laws should obtain legal counsel.
C.H.P. Credential & Scope
Certified Hirudotherapy Practitioner
The C.H.P. designation is a private credential, not a state-issued license. In most states, performing leech therapy without an underlying healthcare license constitutes unauthorized practice of medicine.
Key Recommendations
Before Starting Practice
- Verify your state's current scope-of-practice statutes
- Contact your state licensing board for written guidance
- Consult a healthcare attorney
- Obtain malpractice insurance that covers hirudotherapy
- Complete formal training (Academy of Hirudotherapy or equivalent)
ASH Position
ASH advocates for the development of standardized, state-recognized credentialing pathways. Until such frameworks exist, ASH recommends that hirudotherapy be performed by or under the supervision of licensed healthcare providers within their existing scope of practice.