Who Can Legally Order Lab Tests in Georgia? Licensed Scope, DTC Rules, and Compliance

In Georgia, laboratory testing isn’t only a diagnostic tool but also a critical part of public health oversight and clinical decision-making. Determining who may legally order tests requires careful attention to both state and federal regulations.

Recent changes, including Georgia's shift from separate state lab licensure to CLIA certification, have further highlighted the need for providers and institutions to align with the correct framework. Authority to order a lab test depends on professional licensure, scope of practice, and whether the ordering is performed directly or through a collaborative model.

This guide provides a breakdown of Georgia’s lab ordering rules. It explains which providers have independent ordering authority, how direct-to-consumer (DTC) labs operate under physician oversight, and the compliance measures necessary to reduce legal or billing risks.

Legal foundations of lab ordering in Georgia

Laboratory law in Georgia is shaped by state statutes and federal regulations.

Overview of regulatory authority and statutory framework

Georgia Code 0.C.G.A. Title 31, Chapter 22 defines the legal foundation for clinical laboratories. Administrative oversight is carried out by the Department of Community Health's Healthcare Facility Regulation Division (DCH/HFRD). Georgia recognizes federal laboratory oversight through CLIA.

CLIA certification and the post-licensure framework

All laboratories operating in Georgia must hold an appropriate CLIA certificate. Georgia law now ties operation to certification rather than a separate state license. State rules governing laboratory practice (including specimen handling, reporting, and records) remain in effect under Ga. Comp. R. & Regs. 111-8-10.

Lab ordering authority by provider type

Who can order a lab test in Georgia depends entirely on professional licensure and statutory scope.

Fully licensed providers

The following licensed professionals may order laboratory tests:

• Physicians (MD, DO) — full ordering authority.
• Dentists (DDS, DMD) — may order labs relevant to oral-systemic health.
• Optometrists (OD) — authority centers on ocular disease within optometry scope.
• Podiatrists (DPM) — may order labs for foot and ankle conditions within podiatry scope.

Advanced practice providers may order under physician collaboration/supervision:

• Nurse Practitioners (APRNs) — ordering under a Nurse Protocol Agreement with delegated medical acts (diagnostic studies may be included).
• Physician Assistants (PAs) — may order and initiate medical treatment or diagnostic studies as authorized by the supervising physician.

Important scope clarifications:

• Chiropractors (DCs) may evaluate and refer patients, but Georgia authorities indicate they generally cannot order blood work; chiropractors are also prohibited from performing venipuncture.
• Licensed acupuncturists practice under the Acupuncture Act and related rules and don’t have independent authority to order clinical laboratory tests; collaboration with a physician is required when labs are involved.
• Pharmacists may order and administer certain FDA‑cleared home‑use tests and interpret results in CLIA‑waived or certified settings.
• Registered Dietitians/Certified Nutrition Specialists don’t have independent authority to order labs under Georgia statute; access may occur via institutional policy or physician‑directed protocols.

Telemedicine encounters don’t change scope. If a provider may order in person, they may order virtually, provided documentation requirements are met.

Direct-to-consumer (DTC) testing models and limitations

Georgia has stricter rules for direct patient access to lab testing compared to many other states.

DTC testing laws and policy restrictions

Direct Access Testing (DAT) isn’t generally permitted in Georgia. A clinical laboratory may examine human specimens only when requested by a licensed physician, dentist, or other person authorized by law, and results are reported to that requester. Even when companies sell self-collection kits, Georgia orders are placed under a credentialed provider.

How DTC labs operate legally in Georgia

DTC platforms comply by retaining physicians to authorize requisitions. To operate legally, labs are required to hold the appropriate CLIA certificate, use HIPAA-compliant systems, verify identity, and provide appropriate disclaimers.

Professional and legal considerations for partnering with DTC platforms

Providers should evaluate physician agreements, documentation, and informed consent workflows, and compliance with CLIA, HIPAA, and FTC rules. Unauthorized NPI use or interpretation outside licensure can trigger board action.

Lab oversight, delegation, and documentation requirements

Laboratory ordering also involves obligations for record retention, supervision, and privacy.

Specimen collection stations and CLIA requirements

Physician offices performing tests only for their own patients may operate under a CLIA waiver. If a location only collects specimens and forwards them to another lab, it may qualify as a specimen collection station. Such stations are required to meet CLIA registration requirements and maintain appropriate documentation and staff training.

Clinical documentation, retention, and privacy

Laboratories must maintain records as required by state rule and CLIA. Georgia specifies minimum retention periods. Patients have a federal right to access their lab reports within 30 days.

Delegated services and use of laboratory consultants

Unlicensed providers may assist only through documented delegation or under a physician-services model. Orders and results are directed to an authorized person.

Point-of-care testing supervision requirements

Waived testing still requires oversight. Directors and supervisors are responsible for ensuring quality systems and, where applicable, proficiency testing.

Oversight, enforcement, and incident reporting in Georgia

Laboratory activity is subject to both state and federal monitoring.

Oversight agencies and regulatory domains

• OSHA Bloodborne Pathogens (worker safety).
• CMS/CLIA (quality and certification).
• Georgia DCH/HFRD (facility oversight).

Mandatory reporting requirements for labs

Labs must notify DCH within 24 hours when serious incidents occur, such as transfusion-related fatalities, patient harm linked to testing, or facility service interruptions.

Consequences of regulatory non-compliance

Penalties can include loss of certification/Medicare participation (CLIA), state administrative action, and potential professional discipline.

Frequently asked questions (FAQs)

Can health coaches legally order functional labs in Georgia?

No. Health coaches and other non-licensed professionals cannot order labs independently.

Are physician offices exempt from lab licensure?

Yes, if the office tests only for internal diagnosis and treatment, though CLIA registration may still apply.

Do chiropractors and acupuncturists have lab ordering rights?

Yes, but only within the boundaries of their licensed scope of practice.

Can pharmacists or dietitians order labs independently?

Pharmacists may order under collaborative agreements. Dietitians may have limited authority in institutional or collaborative contexts.

How does Georgia differ from other states on Direct Access Testing (DAT)?

Georgia prohibits direct patient ordering of labs, requiring physician oversight, unlike many states that allow partial DAT access.

Key takeaways

• Georgia law ties laboratory ordering authority directly to licensure and professional scope.
• Physicians, dentists, optometrists, and podiatrists have broad ordering rights.
• Nurse practitioners and physician assistants may order under collaborative agreements.
• Chiropractors, acupuncturists, pharmacists, and dietitians have conditional authority based on scope or agreements.
• Direct Access Testing isn’t permitted in Georgia; all labs must be ordered through a credentialed provider.
• Non-compliance can lead to federal penalties, state enforcement, and professional liability.

Disclaimer:

This article is for educational purposes only and does not provide legal, medical, or compliance advice. Providers should consult Georgia statutes, CLIA regulations, and professional licensing boards before developing lab ordering policies.