Can a Certified Registered Nurse Anesthetist (CRNA) in Oklahoma perform radiofrequency ablation, peripheral nerve blocks, or epidural steroid injections to treat pain?

Plain-English summary

Two Oklahoma legislators (Senator Dave Rader and Representative Gerrid Kendrix) asked Attorney General Gentner Drummond three questions about what pain-management procedures a Certified Registered Nurse Anesthetist (CRNA) is allowed to perform in Oklahoma.

The answers, in order:

1. The Pain Management Act applies only to "chronic" pain, as defined in the statute. "Chronic pain" under 59 O.S. § 650 means a pain state that is "subacute, persistent and intractable." The opinion says the Act’s restrictions do not extend to all forms of pain management.

2. CRNAs cannot perform radiofrequency ablation (RFA) for any kind of pain. RFA is a procedure that uses radio waves to heat and destroy nerve tissue. The AG read the Nursing Act's authorization for CRNAs to "administer anesthesia" not to extend to a procedure designed to cause permanent nerve damage. The Pain Management Act independently classifies nerve ablation for chronic pain as the practice of medicine reserved for licensed allopathic or osteopathic physicians. Together, this means RFA is off-limits for CRNAs whether the targeted pain is "chronic" under the statute or not.

3. CRNAs CAN perform peripheral nerve blocks and lumbar intra-laminar epidural steroid injections to treat pain. The opinion describes these as medication-delivery techniques with temporary, reversible effects that fit CRNAs’ anesthesia authority. But the Pain Management Act adds a special wrinkle: when a CRNA performs these specific procedures, the CRNA must do so "when requested to do so" by, and "under the supervision of," an Oklahoma-licensed allopathic or osteopathic physician. Footnote 7 says these procedures are the only part of CRNA practice that still requires physician supervision, despite the Nursing Act’s general collaboration rule.

The opinion explicitly preserves the Oklahoma Board of Nursing's regulatory authority and does not address clinical standards of care.

What this means for you

If you are a CRNA practicing in Oklahoma

You can continue to perform peripheral nerve blocks and lumbar intra-laminar epidural steroid injections. For these procedures specifically, you need a physician's request and you must work under the physician's supervision (not just the looser "collaboration" you have for general anesthesia practice).

You cannot perform RFA under the statutory scope analyzed here. The opinion does not assess disciplinary, criminal, or civil consequences for an individual case.

If your facility's protocols list RFA as a CRNA-permitted procedure, raise the issue with your medical director and credentialing committee. You should not be doing it.

If you are an allopathic or osteopathic physician (MD/DO) in pain management

For RFA: this remains within your scope. CRNAs cannot do it. Make sure your practice's referral and supervision protocols reflect that.

For peripheral nerve blocks and lumbar epidural steroid injections by CRNAs: when you request a CRNA to perform one of these, you are signing on to "supervise" the procedure under the Pain Management Act. The opinion notes that the Pain Management Act has not been updated since 2010, while the Nursing Act now requires only "collaboration" between physicians and CRNAs. The "supervision" requirement here is a vestige of pre-2020 law, and the AG flags it as an "incongruity," but you must comply with it as written.

The opinion requires the physician’s request and supervision for those named procedures. It does not prescribe a particular form of documentation for the request.

If you are a hospital credentialing officer or ambulatory surgery center administrator

Update your CRNA privileges:

• RFA: not permitted for CRNAs.
• Peripheral nerve blocks and lumbar intra-laminar epidural steroid injections: permitted for CRNAs only when (a) requested by an Oklahoma-licensed allopathic or osteopathic physician and (b) performed under that physician's supervision.
• Other anesthesia-related activities: continue to follow the Nursing Act's collaboration framework under 59 O.S. § 567.3a(10).

Review CRNA privileges against the opinion’s distinction between RFA and the two named medication-delivery procedures.

If you are an Oklahoma Board of Nursing official

This opinion confirms your existing authority to regulate professional conduct, set standards through rulemaking, and enforce the Nursing Act. The AG explicitly preserved that authority. Footnote 1 reserves regulation and enforcement to the appropriate licensing authorities, provided their rules and actions conform to governing statutes.

If you are a patient receiving pain treatment

• If a CRNA is administering a peripheral nerve block or an epidural steroid injection, that is permitted in Oklahoma when an MD or DO has requested it and is supervising.
• If a CRNA is offering you radiofrequency ablation, that is not permitted under Oklahoma law per this AG opinion. Ask for a physician.

This opinion does not change any clinical standard of care. It is about who is legally allowed to perform the procedure, not whether the procedure is appropriate for your condition.

If you are an Oklahoma legislator

The opinion identifies a discrepancy between the Pain Management Act (§ 650, last amended 2010, requiring physician "supervision") and the Nursing Act (§ 567.3a, amended 2020 to require only "collaboration"). The opinion applies the specific supervision requirement in § 650(D) despite that mismatch. It does not analyze any proposed statutory amendment.

Common questions

Q: What is "chronic pain" under the Pain Management Act?
A: 59 O.S. § 650(B) defines chronic pain as "a pain state which is subacute, persistent and intractable." The opinion applies that statutory definition; it does not adopt a separate clinical definition.

Q: What is radiofrequency ablation?
A: A procedure that uses radio waves to heat and destroy a small area of nerve tissue, stopping the nerve from sending pain signals. The opinion contrasts RFA’s deliberate nerve damage with anesthesia’s temporary, reversible effects.

Q: Why does the AG say CRNAs can do nerve blocks and epidural steroid injections but not RFA? A: The AG drew the line at procedures that intentionally damage tissue. Peripheral nerve blocks and epidural steroid injections deliver medication that produces temporary, reversible effects. They are anesthesia-related. RFA deliberately damages nerves with potentially permanent consequences. The AG treated that as the practice of medicine, not anesthesia.

Q: Can a CRNA perform a peripheral nerve block without a physician's request? A: Not under the Pain Management Act for the specific procedures listed in § 650(D). The Act requires both physician request and physician supervision for peripheral nerve blocks and lumbar intra-laminar epidural steroid injections.

Q: Does this affect general anesthesia for surgery?
A: No. CRNAs continue to administer general anesthesia in collaboration with a physician under 59 O.S. § 567.3a(10). The opinion is specifically about pain management procedures.

Q: What if my pain is "acute" rather than "chronic"?
A: The Pain Management Act's restrictions on interventional pain management apply only to chronic pain. The opinion says RFA falls outside CRNAs’ Nursing Act scope even when the Pain Management Act’s chronic-pain restriction does not apply.

Q: Does this opinion overrule the Board of Nursing's rules?
A: No. The opinion expressly preserves the Board of Nursing's authority to regulate professional conduct through rulemaking, "provided that such rules and enforcement actions are consistent with the governing statutes."

Background and statutory framework

The Nursing Practice Act categorizes Advanced Practice Registered Nurses (APRNs) into types, including Certified Registered Nurse Anesthetists (CRNAs). 59 O.S. § 567.3a(10) defines a CRNA as an APRN authorized to administer anesthesia in collaboration with a physician where "timely on-site consultation" with the physician is available. With additional training, a CRNA may "order, select, obtain, and administer" certain drugs, devices, and medical gases for "preanesthetic preparation and evaluation; anesthesia induction, maintenance and emergence; and postanesthesia care."

The Oklahoma Interventional Pain Management and Treatment Act (Pain Management Act), 59 O.S. § 650, makes it unlawful for anyone other than an Oklahoma-licensed allopathic or osteopathic physician to practice "interventional pain management." The Act defines that practice as "the practice of medicine devoted to the diagnosis and treatment of chronic pain," with chronic pain defined as a pain state that is "subacute, persistent and intractable." Subsection (D) provides a narrow exception: the Act does not forbid CRNAs from administering "lumbar intra-laminar epidural steroid injections and peripheral nerve blocks" when requested to do so by, and under the supervision of, a licensed physician.

The opinion reads the two statutes "as a harmonious whole," following Stricklen v. Multiple Injury Tr. Fund, 2024 OK 1, ¶ 20, 542 P.3d at 868. The opinion distinguishes the following activities:

• General anesthesia: CRNAs in collaboration with a physician (Nursing Act).
• Peripheral nerve blocks and lumbar intra-laminar epidural steroid injections: CRNAs under physician supervision and on physician request (Pain Management Act § 650(D)).
• RFA: outside CRNAs’ statutory scope; the Pain Management Act treats nerve ablation for chronic pain as physician practice.
• Other interventional pain management for chronic pain: the Act reserves it to Oklahoma-licensed allopathic or osteopathic physicians, subject to its stated CRNA exception.

The opinion notes a discrepancy between the Pain Management Act's "supervision" requirement (frozen since 2010) and the Nursing Act's modernized "collaboration" framework (post-2020), and acknowledges the supervision requirement is "a vestige of the pre-2020 requirement." Under standard statutory interpretation rules, the more specific and particular Pain Management Act controls in its narrow domain, even if its terminology is dated.

Citations and references

Statutes:

• 59 O.S. § 650 (Oklahoma Interventional Pain Management and Treatment Act)
• 59 O.S. §§ 567.1 to 567.31 (Oklahoma Nursing Practice Act)
• 59 O.S. § 567.3a (APRN definitions and scope)

Cases:

• Hall v. Galmor, 2018 OK 59, 427 P.3d 1052 (plain-meaning interpretation)
• Stricklen v. Multiple Injury Tr. Fund, 2024 OK 1, 542 P.3d 858 (in pari materia)

Prior AG opinions:

• 2024 OK AG 14 (CRNA-physician collaboration framework after 2020 amendments)
• 2012 OK AG 21 (physician supervision of CRNAs)

Source

• Landing page: https://oklahoma.gov/oag/opinions/ag-opinions/2026/6.html
• Original PDF: https://oklahoma.gov/content/dam/ok/en/oag/opinions/ag-opinions/2026/A.G.%20Opinion%202026-6.pdf

Original opinion text

GENTNER DRUMMOND
ATTORNEY GENERAL
ATTORNEY GENERAL OPINION
2026-6

The Honorable Dave Rader
April 23, 2026
Oklahoma Senate, District 39
State Capitol, Room 233
2300 N. Lincoln Blvd.
Oklahoma City, OK 73105

The Honorable Gerrid Kendrix
Oklahoma House of Representatives, District 52
State Capitol, Room 204
2300 N. Lincoln Blvd.
Oklahoma City, OK 73105

Dear Senator Rader and Representative Kendrix:

This office has received your requests for an Attorney General Opinion in which you ask, in effect, the following questions:

1. Does the Oklahoma Interventional Pain Management and Treatment Act (the
  “Pain Management Act”), 59 O.S.2021, § 650, apply only to the treatment of
  “chronic” pain?

2. If the answer to question no. 1 is “yes,” is it a violation of the Pain Management
  Act for a licensed Certified Registered Nurse Anesthetist (“CRNA”) to
  perform radiofrequency ablation (“RFA”) to treat “acute” pain or “acute
  exacerbation” of chronic pain?

3. Does the Pain Management Act authorize a licensed CRNA to perform
  peripheral nerve blocks or epidural steroid injections to treat pain? If so,
  would the Oklahoma Nursing Practice Act (the “Nursing Act”), 59 O.S.2021
  & Supp.2025, §§ 567.1 – 567.31, nevertheless prohibit the CRNA from
  performing such treatments?

                                            I.
                                         SUMMARY

The Pain Management Act and the Nursing Act must be read together to determine a CRNA’s scope of practice as it relates to pain management. First, the Pain Management Act applies only to

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the diagnosis and treatment of “chronic pain,” as defined therein. Its restrictions do not extend to all forms of pain management. Additionally, CRNAs are not authorized to perform RFA procedures to treat pain under either statute. RFA procedures fall outside CRNAs’ scope of practice authorized under the Nursing Act, and, under the Pain Management Act, RFA procedures are deemed to be the practice of medicine that can be performed only by a licensed allopathic or osteopathic physician. By contrast, peripheral nerve blocks and epidural steroid injections fall within CRNAs’ scope of practice and therefore CRNAs may perform these procedures, subject to the limitations imposed by the Nursing Act and Pain Management Act.

II.
BACKGROUND

Your questions concern a CRNA’s scope of practice under Oklahoma law, specifically the Nursing Act and the Pain Management Act. 1

First, the Nursing Act categorizes and describes the various types of Advanced Practice Registered Nurses (“APRNs”) authorized to practice in the State. See 59 O.S.Supp.2025, § 567.3a(5). The CRNA is one such APRN. See id. § 567.3a(10). Through its definitions section, the Nursing Act defines what a CRNA is and sets out his or her statutory scope of practice. In short, a CRNA is an APRN who maintains appropriate certification and is authorized to administer anesthesia. Id. With additional training, a CRNA may also “order, select, obtain, and administer” certain drugs, devices, and medical gases when engaged in specific anesthesia-related activities, namely “preanesthetic preparation and evaluation; anesthesia induction, maintenance and emergence; and postanesthesia care.” Id. § 567.3a(10)(b). A CRNA may practice only “in collaboration with” a physician 2 where “timely on-site consultation” with the physician is available. Id. § 567.3a(10)(a), (b). The nature of this “collaboration” is defined by statute: it refers to “an agreement between [the physician who is] performing . . . or directly involved with the procedure and the [CRNA] working jointly toward a common goal providing services for the same patient.” Id. § 567.3a(10)(h). 3 A full discussion of this relationship between physician and CRNA can be found in Attorney General Opinion 2024-

14. See 2024 OK AG 14, ¶¶ 6-12.

     1
        Nothing in this Opinion should be interpreted to limit the authority of the Oklahoma Board of Nursing
    

    (“OBN”) or other appropriate licensing authorities to regulate professional conduct, establish standards of practice through rulemaking, or enforce applicable statutory and regulatory requirements, provided that such rules and enforcement actions are consistent with the governing statutes. Additionally, this Opinion does not purport to establish clinical standards of care or regulate the manner in which medical procedures are performed. It addresses only whether the applicable statutes permit CRNAs to perform the identified procedures under the circumstances described.

     2
      This Opinion uses the term physician simply as a convenient shorthand for the medical professionals with
    

    whom a CRNA may collaborate under the Nursing Act, which include Oklahoma-licensed allopathic and osteopathic physicians, podiatric physicians, and dentists. 59 O.S.Supp.2025, § 567.3a(10)(a)(2).
    3
    The Nursing Act does not include specific requirements as to the contents of this collaboration agreement.
    See 2024 OK AG 14, ¶ 8. Rather, it requires only that the terms of the agreement be formulated jointly between the physician and CRNA and that the agreement cover the “anesthesia plan” for the patient. See 59 O.S.Supp.2025, § 567.3a(10)(h). Similarly, OBN rules provide no guidance as to the parameters of a CRNA-physician collaboration agreement.

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Second, the Pain Management Act imposes restrictions on the performance of certain interventional pain management procedures, including limitations applicable to CRNAs. See 59 O.S.2021, § 650. In essence, the Pain Management Act makes it unlawful for any person to practice interventional pain management, as the statute defines it, except for Oklahoma-licensed allopathic or osteopathic physicians. Id. § 650(C). However, the Pain Management Act also explicitly provides that it “shall not be construed to forbid” pain management care by CRNAs in limited, and specifically identified, circumstances discussed below. Id. § 650(D). Understanding the interplay between the Pain Management Act and the Nursing Act is essential to determining the proper scope of a CRNA’s practice for the procedures referenced in your questions.

III.
DISCUSSION

In interpreting the effect of a statute, this office is guided first by the plain meaning of the words chosen by the Legislature. Hall v. Galmor, 2018 OK 59, ¶ 45, 427 P.3d 1052, 1070-71. Where the meaning is clear, no further interpretation is needed. Id. However, where a subject matter is covered by two or more statutory schemes, the separate statutes are considered “as part of a coherent system, since different statutes on the same subject are generally to be viewed as in pari materia and must be construed as a harmonious whole.” Stricklen v. Multiple Injury Tr. Fund, 2024 OK 1, ¶ 20, 542 P.3d 858, 868 (internal quotation marks omitted).

1. The Pain Management Act applies only to the treatment of “chronic” pain.

Your first question is answered by the plain language of the Pain Management Act. The Pain Management Act prohibits the practice of “interventional pain management” by anyone other than a licensed physician. 59 O.S.2021, § 650(C); see also 2012 OK AG 21, fn. 2. The Pain Management Act defines “interventional pain management” as the “practice of medicine devoted to the diagnosis and treatment of chronic pain,” which is further defined as a “pain state which is subacute, persistent and intractable.” 59 O.S.2021, § 650(B) (emphasis added). Taken together, the Legislature drafted the Pain Management Act to apply only to the treatment of chronic pain, as defined therein, 4 and to allow only licensed physicians to use certain techniques to treat chronic pain. However, whether a particular patient’s condition constitutes “chronic pain” as defined by the Pain Management Act is ultimately a factual determination dependent on the specific clinical circumstances.

2. Neither the Nursing Act nor the Pain Management Act permit CRNAs to perform
   radiofrequency ablation to treat “acute” pain or “acute exacerbation” of chronic
   pain.

While your second question focuses on the Pain Management Act, its answer requires a broader look at a CRNA’s scope of practice established by the Nursing Act. In essence, you ask under what

4
This definition of “chronic pain” may extend beyond the common industry standard. Specifically, “subacute” pain—which is included in the Pain Management Act’s definition of “chronic” pain—is defined in at least one medical dictionary as being “[b]etween acute and chronic; denoting the course of a disease of moderate duration or severity.” Subacute, STEDMANS MEDICAL DICTIONARY (27th ed. 2000). However, for the purposes of construing the Pain Management Act, this office is bound to follow the statutory definition. See 25 O.S.2021, § 2.

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circumstances a CRNA may perform RFA procedures. As explained in more detail below, the answer is that a CRNA may not perform RFA procedures at all, because such procedures fall outside a CRNA’s authorized scope of practice under the Nursing Act and are not otherwise permitted by the Pain Management Act.

Under the Nursing Act, the practice of nursing includes, among other things, the “execution of the medical regime including the administration of medications and treatments prescribed by any person authorized by state law to so prescribe.” 59 O.S.Supp.2025, § 567.3a(2). In addition to those functions, a CRNA, in collaboration with a physician, may administer anesthesia, and, with additional training, order, select, obtain, and administer certain drugs, devices, and gases in connection with pre- and post-operative anesthesia. Id. § 567.3a(10)(b).

Anesthesia is not defined in the Nursing Act, but the term is commonly used for both the “loss of sensation” and for “an agent that produces anesthesia: anesthetic.” Anesthesia, MERRIAM- WEBSTER.COM, https://www.merriam-webster.com/dictionary/anesthesia (last visited Apr. 21, 2026). An anesthetic is more specifically defined as “[a] compound that reversibly depresses neuronal function, which produces loss of ability to perceive pain and/or other sensations.” Anesthetic, STEDMAN’S MEDICAL DICTIONARY (27th ed. 2000). RFA is not the administration of anesthesia accompanying a medical procedure; it is the medical procedure itself, which aims to cause long-term alteration, or controlled damage, to the body. For example, the Cleveland Clinic describes the RFA procedure as follows:

Radiofrequency ablation (RFA), also called radiofrequency neurotomy, uses radio waves to create a current that heats a small area of nerve tissue. The heat destroys that area of the nerve, stopping it from sending pain signals to your brain. RFA can provide lasting relief for people with chronic pain, especially in the lower back, neck and arthritic joints.

Radiofrequency Ablation for Pain Management, CLEVELAND CLINIC, https://my.clevelandclinic.org/health/treatments/17411-radiofrequency-ablation (last visited Apr. 21, 2026); see also Radiofrequency Ablation for Back and Neck Pain, HOSP. FOR SPECIAL SURGERY, https://www.hss.edu/health-library/conditions-and-treatments/radiofrequency-ablation (last visited Apr. 21, 2026).

Although the purpose of anesthesia and RFA may seem similar, the two are distinct in practice. Where an anesthetic temporarily “turns off” nerves with the expectation that they return to full function, RFA procedures deliberately damage those nerves to disrupt pain signals to the brain. While controlled nerve damage is the intended purpose of RFA procedures, it is a negative side- effect or risk associated with anesthesia. See Anesthesia, CLEVELAND CLINIC, https://my.clevelandclinic.org/health/treatments/15286-anesthesia (last visited Apr. 21, 2026). In plain terms, a procedure that by design damages or destroys human tissue—for any reason—is not considered anesthesia and is therefore outside a CRNA’s scope of practice authorized by the Nursing Act.

This conclusion aligns with the Pain Management Act, which classifies nerve ablation to treat chronic pain as the practice of medicine, which may be performed only by a licensed allopathic or

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osteopathic physician. 59 O.S.2021, § 650(B). There is no reason to believe that RFA is something less than the practice of medicine if used to treat acute pain or the acute exacerbation of chronic pain. And to that point, RFA is generally not even recognized as a treatment for acute pain. As noted above, RFA procedures risk long-term consequences of destroying nerve tissue, making them more appropriate to treat chronic pain. See, e.g., Long-lasting pain relief with radiofrequency ablation, MAYO CLINIC, https://www.mayoclinichealthsystem.org/hometown-health/speaking-of- health/radiofrequency-ablation-pain-relief (last visited Apr. 21, 2026) (“To qualify [for an RFA procedure], patients need to have had chronic pain for more than six months and haven’t found relief with conservative measures like medications, physical therapy or chiropractic care.”). Thus, like the Nursing Act, the Pain Management Act does not permit CRNAs to perform RFA procedures.

To the extent the Pain Management Act references CRNAs at all, it is in subsection (D), which cautions that “[n]othing in [the Pain Management Act] shall be construed to forbid the administration of lumbar intra-laminar epidural steroid injections and peripheral nerve blocks by a [CRNA] when requested to do so” by, and under the supervision of, a licensed physician. 59 O.S.2021, § 650(D). This provision suggests that, in passing the Pain Management Act, the Legislature was aware that CRNAs play a role in pain management and it did not intend for the Pain Management Act to curtail CRNAs’ established scope of practice. And by expressly listing only peripheral nerve blocks and lumbar intra-laminar epidural steroid injections, the Legislature limited CRNA participation in interventional pain management to only these procedures.

In summary, nothing in the Nursing Act authorizes CRNAs to perform RFA procedures, and such procedures are regulated as interventional pain management under the Pain Management Act. Accordingly, CRNAs do not have statutory authorization to perform them.

3. A licensed CRNA may perform peripheral nerve blocks or epidural steroid injections
   to treat pain, subject to the limitations of the Nursing Act and Pain Management Act.

Next, you ask, in essence, whether CRNAs are statutorily permitted to perform either peripheral nerve blocks or lumbar intra-laminar epidural steroid injections for the treatment of pain. As outlined above, the Nursing Act provides that a CRNA may administer anesthesia in collaboration with a physician. 59 O.S.Supp.2025, § 567.3a(10). Peripheral nerve blocks are widely recognized as techniques of regional anesthesia, 5 and epidural injections similarly involve the administration of anesthetic or anti-inflammatory agents 6 in the epidural space for temporary relief of back pain.

5
See, e.g., Our Anesthetic Techniques, HOSP. FOR SPECIAL SURGERY,
https://www.hss.edu/departments/anesthesiology/our-anesthetic-techniques (last visited Apr. 21, 2026). “A peripheral nerve block involves injecting a local anesthetic (sometimes with a steroid) near a specific nerve or group of nerves outside the brain and spinal cord. These nerves control sensation and movement in the limbs, face, and other parts of the body.” Precision Pain Relief: How Peripheral Nerve Blocks Help Treat Targeted Nerve Pain, COLUMBUS REG’L HEALTHCARE SYS., https://crhealthcare.org/treatments/peripheral-nerve-block/ (last visited Apr. 21, 2026).

6
“A steroid injection delivers corticosteroid medication directly to an inflamed area, often alongside a small amount of anesthetic.” Nerve Blocks and Steroid Injections: What’s the Difference?, SOUTHERN PAIN CLINIC, https://southernpainclinic.com/blog/nerve-blocks-and-steroid-injections-whats-the-difference/ (last visited Apr. 21, 2026). “A lumbar epidural steroid injection (lumbar ESI) is an injection of anti-inflammatory medicine—a steroid or corticosteroid—into the epidural space around the spinal nerves in your low back.” Lumbar Epidural Steroid Injection,

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The Nursing Act therefore permits the administration of both by a CRNA as long as they are conducted in collaboration with a physician.

If there were any question of whether the Nursing Act permits CRNAs to perform peripheral nerve blocks or lumbar intra-laminar epidural steroid injections, the Pain Management Act is evidence that the Legislature intended them to be part of a CRNA’s scope of practice. After all, why would the Pain Management Act make clear that it should not be construed to prohibit CRNAs from performing these procedures if the procedures were not part of a CRNA’s accepted scope of practice under the Nursing Act? See 59 O.S.2021, § 650(D). The inclusion of these procedures within section 650(D) demonstrates that the Legislature contemplated the limited participation of CRNAs in certain interventional pain procedures when performed under physician supervision. 7

The distinction drawn by the Legislature between permitted and prohibited procedures reflects meaningful differences in the nature of the interventions. Peripheral nerve blocks and lumbar intra- laminar epidural steroid injections are primarily medication-delivery techniques that produce temporary and reversible effects and are closely aligned with the administration of anesthesia. See, e.g., Anesthetic, STEDMAN’S MEDICAL DICTIONARY (27th ed. 2000) (defining anesthetic as “[a] compound that reversibly depresses neuronal function, which produces loss of ability to perceive pain and/or other sensations” (emphasis added). By contrast, procedures such as RFA involve highly targeted intervention, destruction or alteration of tissue, and a greater degree of medical judgment, with potentially permanent consequences. These differences support the Legislature’s decision to limit such procedures to licensed physicians while allowing CRNAs to perform specified anesthetic-related techniques under physician supervision. 8

CLEVELAND CLINIC, https://my.clevelandclinic.org/health/treatments/22091-lumbar-epidural-steroid-injection (last visited Apr. 21, 2026). Healthcare providers use lumbar epidural steroid injections to temporarily manage chronic pain known as lumbar radicular pain caused by spinal nerve root inflammation. Id.

7
Admittedly, there is an incongruity between the Pain Management Act contemplating physician “supervision” of these procedures, and the Nursing Act requiring only “collaboration” between the CRNA and the physician. Compare 59 O.S.2021, § 650(D) with 59 O.S.Supp.2025, § 567.3a(10)(a)(2). More than likely, the reference to “supervision” in the Pain Management Act is a vestige of the pre-2020 requirement that CRNAs be supervised by, rather than simply collaborate with, physicians with whom they work. See 2024 OK AG 14, ¶¶ 1, 6 (describing the history and effects of this statutory change). Indeed, the Pain Management Act has not been amended since 2010, it does not define “supervision” itself, and the definition of “supervision” in the Nursing Act does not apply to CRNAs at all. See 59 O.S.Supp.2025, § 567.3a(12). Nevertheless, for present purposes this office must construe the two statutes together “as a harmonious whole.” Stricklen, 2024 OK 1, ¶ 20, 542 P.3d at 868. Accordingly, while the Nursing Act generally requires only that a CRNA collaborate with a physician in his or her practice, a CRNA may perform peripheral nerve blocks and steroid injections described in the Pain Management Act only when requested by, and performed “under the supervision of,” an Oklahoma-licensed physician. 59 O.S.2021, § 650(D). This is the only part of a CRNA’s practice that still requires physician supervision. This office discussed the contours of physician supervision of CRNAs in Attorney General Opinion 2012-21. See 2012 OK AG 21, ¶¶ 6 – 7.
8
In your request, you also asked whether there is any conflict between the Nursing Act’s designated scope of practice for a CRNA and the Pain Management Act’s limitation on interventional pain management. As described above, the statutes are complementary in providing that a CRNA may administer anesthesia in collaboration with a physician as outlined in title 59, section 567.3a(10), but may not engage in interventional pain management except as provided in title 59, section 650(D).

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It is, therefore, the official Opinion of the Attorney General that:

1. The Pain Management Act applies only to the treatment of chronic pain as defined in title 59, section 650 of the Oklahoma Statutes.

2. CRNAs are not authorized to perform radiofrequency ablation because such procedures (i) fall outside the scope of practice authorized by the Nursing Act, and (ii) are not otherwise permitted by the Pain Management Act.

3. Properly licensed CRNAs in Oklahoma are permitted to perform peripheral nerve blocks and lumbar intra-laminar epidural steroid injections for the treatment of pain upon request, and under the supervision, of an Oklahoma- licensed allopathic or osteopathic physician.

GENTNER DRUMMOND
ATTORNEY GENERAL OF OKLAHOMA

SCOTT A. MAY
ASSISTANT ATTORNEY GENERAL