The Florida Board of Medicine and Board of Osteopathic Medicine have been implementing healthcare-related legislation passed during the 2024 Legislative Session, as well as attending to their ongoing regulatory duties. Recent activities include rulemaking requests and significant changes in licensure procedures.
At a February meeting, the Florida Society of Plastic Surgeons and the Florida Academy of Dermatology petitioned for a rule that would require medical directors of medspas to display their name, specialty certification, and contact information on both the medspa’s website and in the waiting room. The rule would also mandate listing other medspa locations under the same supervision. This proposal comes amid concerns about unqualified personnel performing substandard services at medical spas. After discussion, board members concluded they lacked authority to make this change through rulemaking alone. They agreed instead to send a letter supporting legislative action on this transparency measure.
Another matter before the Board involved a physician’s petition asking if it is within their scope of practice to supervise naturopathic healthcare consultants who discuss alternative treatments with patients. Since Florida eliminated licensure for naturopaths in 1959 and recent attempts to reestablish such licensure have not succeeded, there is no statutory framework for their practice in the state. The Board denied the petition, determining that such activity would constitute unlicensed practice of medicine. Physicians are advised to monitor future board decisions regarding similar situations.
During the same meeting, questions arose about whether physician assistants (PAs) holding an area of critical need (ACN) license may prescribe medication under state law. Section 458.347(4)(e), F.S., allows supervising physicians to delegate prescriptive authority only to fully licensed PAs—a definition clarified by Rule 64B8-30.001(7), F.A.C., which previously did not account for ACN licenses since PAs were only recently added via legislative change in 2024. The PA Council reviewed nearly 30 ACN applications—many from Puerto Rico where PAs lack prescriptive training—and approved them with requirements for additional continuing education and examination on prescribing practices. The Florida Academy of Physician Assistants has asked for further rule development to clarify restrictions on prescriptive authority for ACN license holders; monitoring will continue.
One major outcome from the 2024 session was Senate Bill 7016, known as the Live Healthy bill, which included new provisions affecting physician licensure.
A key element is creation of a Graduate Assistant Physician (GAP) limited license for unmatched medical school graduates who have completed all required exams but have not secured residency placement. Under direct supervision by an approved physician—limited to supervising two GAPs—these graduates may provide healthcare services while seeking residency opportunities. The GAP license is valid for two years with one possible one-year renewal option; no licenses had been issued at time of publication but are expected after Match Day in March 2025.
Senate Bill 7016 also introduced a new pathway for foreign-trained physicians who meet specific criteria, including employment requirements within Florida following licensure. The Board has worked on defining acceptable standards for foreign postgraduate training programs, specifically stating that ACGME-International accredited programs qualify as “substantially similar” to domestic ones; applicants from non-accredited programs can demonstrate equivalency during review.
Florida has joined the Interstate Medical Licensure Compact (IMLC), which streamlines licensing across participating states without changing existing practice acts or disciplinary authority structures within each jurisdiction (https://www.imlcc.org/). Applications began processing under this compact in December 2024.
