Guidance for Holistic Nutrition Professionals and Unlicensed Providers

Laboratory testing is an important tool in assessing health status, identifying imbalances, and monitoring client progress. In New York State, however, strict legal frameworks determine who may order clinical laboratory tests. Understanding these regulations is essential for holistic nutrition professionals and other unlicensed providers to practice ethically and legally, in compliance with state law.

Licensed Practitioners Authorized to Order Laboratory Tests

In New York, only certain licensed healthcare practitioners are legally authorized to order laboratory tests. These include:

• Physicians (MDs and DOs)
• Physician Assistants (PAs)
• Nurse Practitioners (NPs)
• Certified Nurse-Midwives (CNMs)
• Dentists
• Podiatrists

All test orders must fall within the practitioner’s licensed Scope of Practice and relate directly to patient diagnosis or treatment. Remember, holistic nutrition professionals are not licensed in any state, nor do we diagnose, treat, cure, prevent, prescribe, heal, or manage any disease state in our clients.

What This Means for Holistic Nutrition Professionals

Holistic Nutrition Professionals and other unlicensed practitioners in New York may not legally order laboratory tests. This includes blood work, urine testing, saliva testing, stool testing, genetic testing, or any clinical diagnostic panel processed by a licensed laboratory.

However, Holistic Nutrition Professionals may:

• educate clients about available laboratory tests
• discuss the purpose, general concepts, and lifestyle relevance of lab markers
• recommend that a client consult with a licensed provider to obtain appropriate testing
• collaborate with licensed practitioners who can legally order tests
• review results with clients for educational and wellness purposes, provided no medical diagnosis or treatment plan is rendered

They may not:

• sign or submit lab requisitions
• represent themselves as authorized ordering providers
• diagnose medical conditions
• provide medical treatment plans based on laboratory results

Maintaining this distinction protects both the practitioner and the client.

Scope of Practice and Legal Boundaries

New York law strictly ties laboratory ordering authority to professional licensure. Ordering tests outside one’s legal scope may be interpreted as the unauthorized practice of medicine.

For Holistic Nutrition Professionals, best practice is to operate within a wellness, educational, and lifestyle support framework, while referring all diagnostic authority to licensed providers.

Direct Access Testing in New York

New York is one of the most restrictive states regarding direct-to-consumer laboratory testing. Clinical laboratories may not perform tests without an order from a licensed New York practitioner. Limited exceptions exist only for FDA-approved over-the-counter tests under New York Public Health Law §576-b. These exceptions do not include most routine or diagnostic laboratory panels used in integrative or functional nutrition practice.

Out-of-State Providers and Telehealth

Orders from out-of-state practitioners are generally not accepted by New York laboratories unless the provider is licensed in New York. There is no broad reciprocity that allows out-of-state providers to order tests for New York patients routinely.

For holistic practitioners, this reinforces the importance of building relationships with New York licensed ordering providers or referring your client to a licensed provider.

Best Practice for Holistic Nutrition Professionals

To remain compliant, holistic nutrition practitioners in New York should:

• establish referral networks with licensed practitioners
• use clear informed consent and disclosure language with clients
• emphasize education, prevention, and lifestyle-based wellness strategies
• position laboratory data as supportive wellness information, not diagnostic authority

This collaborative model protects public safety while allowing holistic professionals to play a vital role in their clients’ preventive care and support lifestyle strategies.