Last Updated: March 1, 2026Reviewed by: Andrei Dokukin, MD

Legal Disclaimer

This guide is for informational purposes only and does not constitute legal advice. No state explicitly addresses hirudotherapy in its practice acts. Practitioners must verify current regulations with their state licensing board.

This guide provides a detailed analysis of scope-of-practice considerations for hirudotherapy across US states. Provider authority varies significantly by state, provider type, and practice setting.

State Analysis

State	MD/DO	NP Authority	ND Licensed?	ND Scope for Leeches	Safe Harbor?
California	Yes	Supervised	Yes	Defined scope; leeches not addressed	No
Texas	Yes	Supervised	No	N/A	No
Florida	Yes	Supervised	No (prohibited)	N/A	No
New York	Yes	Collaborative	No	N/A	No
Arizona	Yes	Independent	Yes (NMD)	Broadest US scope; “physician” title; plausible	Yes
Oregon	Yes	Independent	Yes	Broadest North American scope	No
Washington	Yes	Independent	Yes	Broad scope; insurance-eligible	No
Colorado	Yes	Independent	Yes	Moderate scope; interpretation required	Yes
Minnesota	Yes	Full practice	Yes	Moderate scope	Yes
Connecticut	Yes	Independent	Yes	Moderate scope; ND prescribing rights	No

Green-highlighted rows indicate jurisdictions with the broadest naturopathic scope.

Authorization by Practitioner Type

Practitioner	Authorization	Key Conditions
MD/DO	Yes — all 50 states	Broadest scope; no restrictions
NP/APRN	State-dependent	Independent in 26 states + DC
PA	Under supervision	Physician delegation required
RN	Under orders	Physician orders + institutional credentialing
ND/NMD	Uncertain	Licensed in ~24 states; not explicitly addressed
LAc	Uncertain	State-dependent; likely outside scope
DC	No — most states	Scope generally too narrow
C.H.P.	High legal risk	Private credential; safe harbor in ~7 states

Key Observations

No Explicit Prohibitions

No US state explicitly prohibits hirudotherapy when performed by a licensed healthcare provider within their scope of practice.

ND Scope is Most Variable

Naturopathic physician authority ranges from comprehensive (Oregon, Arizona) to nonexistent (unlicensed states). This is the area of greatest legal uncertainty.

Hospital Credentialing is Key

Even in states with clear scope authority, hospital-based practice requires institutional credentialing and privileges — an additional layer of authorization.

Evolving Landscape

NP and PA scope of practice laws are evolving rapidly. Several states have recently adopted full practice authority for NPs, which may expand hirudotherapy access.

Safe Harbor Laws

Health Freedom Statutes

Approximately seven states have enacted “health freedom” or “safe harbor” laws permitting unlicensed individuals to provide complementary and alternative health services.

Written disclosure of non-physician, non-licensed status
Signed informed consent from the client
No claims to diagnose, treat, or cure specific diseases
No prescribing of prescription medications

Untested Application to Leech Therapy

Whether hirudotherapy qualifies for safe harbor protection is an untested legal question. The antibiotic requirement creates direct tension with the prescribing prohibition. Practitioners relying on safe harbor laws should obtain legal counsel before initiating hirudotherapy.

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 explicitly covers hirudotherapy
Complete formal training from an accredited program
Maintain detailed documentation of all treatments

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.

State Scope Guide