Not in California, as long as the blood draw is done in the field, the California Department of Public Health can't regulate it, as it's in the Paramedic's Scope of Practice to do field draws. Once in hospital/clinic, a Paramedic must have a CPT-1 to do Phlebotomy. The California DPH also doesn't require Phlebotomist certification for other licensed medical personnel who have phlebotomy in their scope of practice. Simply specify that a Paramedic can function as a Paramedic inside or outside the clinical setting, and the CPT-1 requirement for Paramedics to have a CPT-1 certification in the clinical setting disappears.