The Florida Board of Medicine and Board of Osteopathic Medicine have been working to implement several healthcare-related bills passed during the 2024 Legislative Session, while also addressing routine matters. These efforts are intended to integrate new regulations into Florida’s medical regulatory framework.
At a February meeting, the Florida Society of Plastic Surgeons and Florida Academy of Dermatology petitioned for a rule requiring any physician serving as a medical director at a medspa to prominently display specific information about their qualifications. This would include posting the supervising physician’s name, specialty certification, contact details, and other locations they supervise on both the medspa’s website and in its waiting room. The aim is to increase public awareness regarding who oversees these facilities, amid concerns about unqualified personnel performing procedures.
After discussion, the boards concluded they lacked authority to enact such a rule without legislative action. They agreed instead to send a letter to the Legislature supporting this transparency measure. “This request stems from ongoing concerns about substandard medical spa services performed by unqualified personnel under the supervision of physicians with little to no experience in this field. The goal of the rule is to increase public awareness of the qualifications of such medical directors.”
In another matter, the Board of Medicine considered whether physicians could employ and directly supervise naturopathic healthcare consultants who advise patients on alternative treatments. Naturopaths have not been licensed in Florida since 1959; efforts to reestablish licensure stalled in 2024 but may be revisited in 2025. The board determined that allowing naturopaths to consult with patients would amount to unlicensed practice of medicine and denied the petition. “Ultimately, the board denied the petition, determining that the proposed activity of a naturopath consulting with patients and making recommendations would amount to the unlicensed practice of medicine.”
A question also arose regarding whether physician assistants (PAs) holding an area of critical need (ACN) license can prescribe medication under state law. Following changes made during the 2024 session, temporary licensure now includes PAs for ACN roles. Many applications came from Puerto Rico-trained PAs who lack prescriptive authority there; approvals were granted contingent on completion of additional education and exams.
The Florida Academy of Physician Assistants has requested further development of rules clarifying that ACN-licensed PAs should not have prescriptive authority unless fully licensed—a process being monitored by stakeholders.
Senate Bill 7016 (“Live Healthy”) was among significant legislation passed in 2024 impacting physician licensure. It established a Graduate Assistant Physician (GAP) limited license for unmatched medical graduates who passed all USMLE or COMLEX exams but did not secure residency placements. GAPs may provide care only under direct supervision by approved physicians, who may oversee up to two GAPs each and are liable for their actions or omissions.
“Although only a small percentage of medical school graduates do not match into a residency program, the Legislature hopes the creation of this limited license will increase workforce mobility and expand opportunities for graduates while they find placement in residency programs.” The GAP license is valid for two years with one possible renewal; rules governing supervision took effect November 14, 2024.
Additionally, SB 7016 created a new licensure pathway for foreign-trained physicians who meet certain requirements and agree to work within Florida for at least two years post-licensure. The Board is developing criteria defining which foreign training programs are “substantially similar” to U.S.-accredited ones; ACGME-International accredited programs will qualify automatically under draft language.
Florida has also joined the Interstate Medical Licensure Compact (IMLC), which allows eligible physicians expedited licensing across participating states while maintaining oversight by local boards. Applications through IMLC began processing in December 2024; more information is available from either state board.
