Can You Call Yourself a Doctor When You Have a Doctorate in Nursing?

Pursuing additional degrees and certificates is a great way to expand your role as a nurse. It can lead to better job opportunities and a much-needed raise, but you should refrain from referring to yourself as a doctor in public in certain states – even if you have a doctorate in nursing.

Sarah Erny, RN, NP, was fined $20,000 for implying that she was a medical doctor, according to a recent settlement from the District Attorney’s office for San Luis Obispo County in California, including $16,000 to the Consumer Protection Trust Fund and $3,750 to cover the costs related to the investigation of the case.

The court ordered her to cease all claims of her being a “doctor” with regards to her role as a healthcare provider to the public. She must also work to correct information on websites that refer to her as a “doctor” or use the “Dr.” prefix before her name.

Under California law, only a select group of healthcare professionals can call themselves “doctor” or “physician,” a rule that’s designed to protect the public, the District Attorney’s office noted in its ruling.

When it comes to nurses with advanced degrees, only titles such as “certified nurse practitioner” and “advanced practice registered nurse,” are permitted.

Court documents show Erny started promoting herself as “Doctor Sarah Erny” shortly after she earned a doctorate in nursing practice. She hosted a website and various social media accounts from October 2018 to March 2022 that listed the nurse practitioner as a doctor.

Although Erny indicated that she was a nurse practitioner in most cases, the court ruled that she didn’t do enough to inform the public that she wasn’t a medical doctor or supervising physician. In some cases, her professional listings made no mention of her being a nurse.

The District Attorney’s office also noted that Erny’s patients began calling her “Dr. Erny” because they were so proud of her achievement.

Records show she opened a business called, “Holistic Women’s Healing,” in 2018 that provided medical services and products to patients. Erny saw eight to 10 patients a day three days a week, but most of them weren’t aware of the arrangement she had with a nearby supervising physician. In addition to selling services and products to patients, Erny also prescribed medication to patients.

The court pointed to several surveys that indicate most Americans are confused about who is a doctor of medicine and who is not.

“We want all health care professionals to clearly display their education and licensure so that patients know who is providing their care,” said Dan Dow, District Attorney for San Luis Obispo County.

“All forms of professional medical services advertising, including websites and social media accounts, must be free of deceptive or misleading information and must clearly identify the professional license held by the advertiser. Providing patients upfront with the proper title of our healthcare professionals aids consumers in making a more informed decision about their healthcare.”

But Erny’s lawyer, Melanie Balestra, NP, said lots of different types of healthcare professionals use the prefix “Dr.” in front of their names, including naturopaths, psychologists, physical therapists, acupuncturists, and optometrists, but “no one has gone after them.”

“Why is Ms. Erny singled out?” Balestra stated. “Is this discrimination against Nurse Practitioners?”

Balestra added that Erny “always explained she was a nurse practitioner,” on her website. “No evidence was ever presented where she stated or wrote she was a physician. There was no witness that stated Ms. Erny stated she was a physician. She held herself out as Dr. Sarah, the nurse practitioner, or Dr. Sarah Erny, DNP.”