Sunday, November 8, 2026 Never miss a recall or a rule change Get the free brief →
Inside MedSpa
FDA Recall & Compliance Alerts for Medspa Owners
MarketAllergan posts nine ASDS abstracts, two on GLP-1 patientstodayMarketRevance survey: 74% say menopause raised aesthetic interest6 days agoBusiness & M&AEvolus posts Q3 loss of $0.09, revenue tops estimatestodayBusiness & M&AAbbVie director Jennifer Davis resigns to lead Align5 days agoRegulatoryJudge bars Medicare price for Botox over plasma ruleyesterdayRegulatoryFDA clears AMIRO LED wrinkle mask under 510(k)5 days agoBusiness & M&AHugel Signs Half of Target U.S. Accounts Post-SwitchyesterdayBusiness & M&AGalderma nine-month sales hit $4.77B, guidance raised4 days agoBusiness & M&AMaple Grove med spa adds PA-led hormone and weight program2 days agoBusiness & M&ASofwave names Optimedic main distributor in Spain4 days agoBusiness & M&ASofwave Q3 revenue up 35% to $28.5M; China nod3 days agoBusiness & M&AEvolus Q3 revenue up 13%, fourth straight positive EBITDA quarter3 days ago
Compliance · Updated continuously

Medical-Spa Regulation, State by State

The rules that decide whether you're operating legally — who can inject, whether you need a medical director, the good-faith-exam requirement, and the Corporate-Practice-of-Medicine posture — for all 50 states and DC. Free, fast, and in plain English. Tap any state for the full breakdown.

Get the all-50-states cheat-sheet (free, printable) →

Orientation, not legal advice. Aesthetic regulation changes constantly and is interpreted by each state's medical and nursing boards. Use this to know what to ask — then confirm specifics with your state boards or healthcare counsel before you act.
51states + DC tracked
17Strict
33Moderate
1Lenient
41require a medical director
0allow telehealth exams
51 shown

Alabama

Moderate
Who can inject
Physicians (MD/DO) and, under physician supervision/delegation, RNs and other licensed staff acting under medical orders; neurotoxin and filler administration is treated as the practice of medicine.
RNs injecting
RNs may inject only under a valid physician order and supervision/delegation by a physician; they cannot independently prescribe or diagnose. Scope is interpreted by the Board of Medical Examiners and Board of Nursing together, so verify the specific delegation documentation.
Medical director
Practically required: a supervising/collaborating physician must be in place for delegated injectables and NP/PA work; formal medical director structure is expected by many operators and boards.
Good-faith exam
A good-faith exam by a licensed prescriber is required before treating; in-person examination is the conservative standard.
Who can own
Physician-owned or physician-controlled; non-physician ownership generally requires a structure where the clinical practice is physician-owned (MSO-style arrangement) — verify with counsel.

Full Alabama breakdown →

Alaska

Moderate
Who can inject
Physicians and physician assistants and nurse practitioners within their scope; RNs and other licensed staff may inject under physician or prescriber orders. Interpretation varies by board.
RNs injecting
RNs may inject under a valid prescriber order or delegation; independent RN practice of prescription injectables is not clearly authorized. Verify scope with the Alaska Board of Nursing.
Medical director
Medical director or supervising physician is commonly expected; confirm specific requirements with the Alaska Board of Medical Examiners.
Good-faith exam
A good-faith exam by a licensed prescriber is required before treatment; in-person examination is the conservative standard.
Who can own
Physician-owned or physician-controlled clinical entity is the conservative approach; non-physician ownership usually requires an MSO-style management structure.

Full Alaska breakdown →

Arizona

Moderate
Who can inject
Physicians, NPs, and PAs with appropriate scope; RNs may administer injectables under a prescriber order or delegation.
RNs injecting
RNs may administer neurotoxins and fillers under a valid prescriber order and within delegation rules; they cannot prescribe independently. Verify scope with the Arizona State Board of Nursing.
Medical director
Medical director is commonly expected for operations; not always strictly mandated for all settings — verify with the Arizona Medical Board.
Good-faith exam
A good-faith exam by a licensed prescriber is required before treatment; in-person examination is the conservative standard, with telehealth permitted only under specific conditions.
Who can own
Physician-owned or physician-controlled with MSO-style management structures; non-physician ownership of the clinical practice is restricted.

Full Arizona breakdown →

Arkansas

Strict
Who can inject
Physicians and, under physician supervision/delegation, RNs, NPs, and PAs; neurotoxin and filler administration is treated as the practice of medicine.
RNs injecting
RNs may inject only under a physician order and supervision; no independent prescribing authority. Verify delegation scope with the Arkansas State Board of Nursing.
Medical director
Physician supervision and a medical director are expected; formal arrangements are commonly required for delegated services.
Good-faith exam
A good-faith exam by a licensed prescriber is required before treatment; in-person examination is the conservative standard.
Who can own
Physician-owned or physician-controlled; non-physician ownership requires MSO-style structure with clinical control retained by physicians.

Full Arkansas breakdown →

California

Strict
Who can inject
Physicians (MD/DO) directly; RNs, NPs, PAs, and LVNs/MAs under delegation or supervision of a licensed physician, with scope varying by license type and delegation rules
RNs injecting
RNs may inject neurotoxins and fillers only under physician delegation/standing order or supervision; BRN and Medical Board interpretations on scope of delegation are nuanced, so verify with counsel
Medical director
Physician supervision/delegation required; a supervising physician must be identified and oversee injectable protocols, with formal medical director role expected in most multi-provider settings
Good-faith exam
Required before treatment; in-person or telehealth GFE allowed under state telehealth rules with appropriate establishment of a physician-patient relationship, but details vary by board interpretation
Who can own
Physician-owned or MSO-based structure; non-physicians may not directly own the clinical practice

Full California breakdown →

Colorado

Moderate
Who can inject
Physicians and licensed providers acting within scope; RNs, NPs, and PAs may inject under the state's delegation and supervision framework, with physician oversight expected for many procedures
RNs injecting
RNs may inject under delegation and supervision principles of Colorado nursing law; scope interpretations vary, so verify with counsel
Medical director
Medical director or supervising physician arrangement is commonly expected; specific requirements vary by board interpretation
Good-faith exam
Required before treatment; in-person exam preferred, telehealth GFE permitted under Colorado telehealth rules within clinical limits; verify current requirements
Who can own
Physician-owned preferred; non-physician ownership may be possible through management structures with appropriate compliance review

Full Colorado breakdown →

Connecticut

Moderate
Who can inject
Physicians directly; APRNs and PAs under their respective scope and supervision rules; RNs and LPNs under delegation or supervision
RNs injecting
RNs may inject under delegation or supervision of a physician or APRN with prescriptive authority; verify specific protocols with counsel
Medical director
Medical director or supervising physician commonly expected for medspa operations; specifics vary by facility and board interpretation
Good-faith exam
Required before treatment; in-person or telehealth exam allowed within state telehealth rules, with appropriate clinical justification; verify current requirements
Who can own
Physician-owned preferred; non-physician ownership requires careful structuring and counsel review

Full Connecticut breakdown →

Delaware

Moderate
Who can inject
Physicians directly; NPs, PAs, and RNs under delegation or supervision within their scope
RNs injecting
RNs may inject under physician delegation or supervision; verify scope specifics with counsel
Medical director
Medical director or supervising physician commonly expected; verify facility-specific requirements
Good-faith exam
Required before treatment; in-person or telehealth GFE allowed within Delaware telehealth rules; verify current requirements
Who can own
Physician-owned preferred; non-physician ownership requires structuring and counsel review

Full Delaware breakdown →

Who can inject
Physicians (MD/DO) and, under physician delegation/supervision, licensed RNs and PAs; NPs under the DC NP scope framework with physician collaboration as applicable. Verify exact delegation terms with the Board.
RNs injecting
Generally yes, under physician order/delegation for neurotoxins and fillers; RN injection scope is tied to physician orders and facility policy. Verify specifics with the Board of Nursing.
Medical director
Practically required: a licensed physician is needed to supervise injectables, prescribe, and sign orders. Exact title and documentation requirements vary, verify with the Board.
Good-faith exam
A good-faith examination by a prescriber is required before administering prescription injectables; in-person exam is the expected standard.
Who can own
Physician-owned or physician-controlled; non-physician ownership generally requires an MSO/management structure with physician control of clinical decisions. Verify structure with counsel.

Full District of Columbia breakdown →

Florida

Strict
Who can inject
Physicians (MD/DO) may inject directly. Licensed RNs may administer neurotoxins and fillers under a delegated order from a supervising physician; APRNs may practice under collaborative protocols with a supervising physician. LPNs and estheticians are restricted from independent injection.
RNs injecting
Yes, but only under a physician delegation or protocol, and typically with a physician responsible for supervision and prescribing. Verify delegation terms with the Board of Nursing.
Medical director
Required in practice: a physician must supervise and delegate injectable procedures, and clinics often must name a medical director. Details vary by license type and facility, verify.
Good-faith exam
A good-faith exam by a licensed prescriber is required before prescribing or administering injectables; in-person examination is the expected standard.
Who can own
Physician-owned; non-physicians generally cannot own a clinic providing medical services, requiring a physician-controlled entity and management services arrangement.

Full Florida breakdown →

Georgia

Strict
Who can inject
Physicians may inject directly. RNs may administer injectables under a physician's order or protocol; APRNs under physician collaboration; PAs under a supervision agreement. Estheticians and unlicensed staff may not inject.
RNs injecting
Yes, under physician order or protocol; verify the delegation documentation required by the Georgia Board of Nursing and Medical Board.
Medical director
Practically required: a supervising physician is needed for injectables and delegation. Specific title and record requirements should be verified.
Good-faith exam
A good-faith exam by a prescriber is required before injectable treatment; in-person exam is the expected standard.
Who can own
Physician-owned or physician-controlled clinical entity; non-physicians typically participate via a management services arrangement. Verify structure with counsel.

Full Georgia breakdown →

Hawaii

Moderate
Who can inject
Physicians may inject directly. RNs may administer injectables under a physician's order or delegation; APRNs and PAs practice under collaboration or supervision with a physician. Verify specific delegation terms.
RNs injecting
Generally yes, under physician order or delegation; verify the scope and documentation expectations with the Hawaii Board of Nursing.
Medical director
Practically required: a supervising physician is needed for injectables and delegation. Verify title and documentation requirements.
Good-faith exam
A good-faith exam by a prescriber is required before injectable treatment; in-person exam is the expected standard.
Who can own
Physician-owned or physician-controlled clinical entity; non-physicians generally participate via management arrangements. Verify structure with counsel.

Full Hawaii breakdown →

Idaho

Moderate
Who can inject
Physicians, NPs, and PAs with delegation; RNs may inject under physician or NP/PA order and delegation, with scope limited by Idaho Nurse Practice Act and Board of Medicine rules
RNs injecting
Conditional: RNs may administer neurotoxins and fillers only under valid physician or APRN/PA order and delegation; independent RN practice is not permitted
Medical director
Not universally mandated by statute; supervising physician oversight is expected for injectables — practice-specific requirements vary by board interpretation
Good-faith exam
Required in-person or by appropriate evaluation before prescribing or delegating treatment; telehealth GFE is conditionally allowed under Idaho telehealth rules — verify specifics
Who can own
Generally physician-owned or management-services structure; non-physician ownership of clinical practice is restricted — verify with counsel

Full Idaho breakdown →

Illinois

Strict
Who can inject
Physicians and licensed prescribers (APRNs/PAs) under supervision; RNs and LPNs may administer under physician delegation and written protocol with Illinois Nurse Practice Act limits
RNs injecting
Conditional: RNs may administer under a physician's written order/protocol and delegation; RNs cannot independently assess, diagnose, or prescribe
Medical director
Physician collaboration/supervision is required; a medical director is expected and documented practice arrangements must be in place
Good-faith exam
Required before treatment; in-person evaluation expected — telehealth GFE is not clearly permitted for the initial visit without verification
Who can own
Physician-owned or MSO structure required; non-physician ownership of clinical medical practice is restricted

Full Illinois breakdown →

Indiana

Strict
Who can inject
Physicians and supervised clinicians; RNs and NPs may administer under physician supervision/delegation and written protocols; PAs under supervision agreement
RNs injecting
Conditional: RNs may administer under physician order and delegation; independent RN assessment and prescribing are not permitted
Medical director
Physician supervision and collaborative arrangements are required; a medical director or supervising physician must be documented
Good-faith exam
Required before treatment; in-person evaluation generally expected — telehealth GFE is not clearly permitted for initial visit without verification
Who can own
Physician-owned or physician-controlled structure required for clinical practice; non-physician ownership restricted

Full Indiana breakdown →

Iowa

Moderate
Who can inject
Physicians, APRNs, and PAs with appropriate prescriptive authority; RNs may administer under a prescriber's order/delegation with Iowa Nurse Practice Act limits
RNs injecting
Conditional: RNs may administer under a valid prescriber order and delegation; independent RN assessment and prescribing not permitted
Medical director
Collaborative/supervising physician arrangements are expected for APRN and PA practice; a dedicated medical director is not uniformly mandated for all medspas — verify with the board
Good-faith exam
Required before treatment; in-person evaluation expected for initial visit under typical interpretation — telehealth GFE status should be verified
Who can own
Physician-owned or management-services structure typically required; non-physician ownership of clinical practice is restricted — verify with counsel

Full Iowa breakdown →

Kansas

Moderate
Who can inject
Physicians and PAs under delegation; NPs with prescriptive/delegated authority; RNs may administer under physician delegation/protocol. Verify current scope with the Board of Nursing.
RNs injecting
RNs may administer neurotoxins and fillers only under a physician order or protocol; independent RN prescribing/diagnosis is not permitted. Exact delegation documentation expectations vary by board interpretation — verify with counsel.
Medical director
Practice-level medical director or supervising physician arrangement is expected; exact formal requirements vary by board interpretation.
Good-faith exam
A good-faith exam by a licensed prescriber is expected before treatment; in-person requirement is the conservative reading. Verify specifics with the Board.
Who can own
Physician-owned or physician-controlled structures are the safest path; non-physician ownership through a management/MSO arrangement requires careful structuring.

Full Kansas breakdown →

Kentucky

Moderate
Who can inject
Physicians and PAs under supervision/delegation; APRNs with prescriptive authority and collaborative agreements; RNs may administer under physician order or protocol. Verify current scope with the Board.
RNs injecting
RNs may administer under a valid physician order or protocol; independent RN assessment and prescribing for injectables is not permitted. Details vary by board interpretation.
Medical director
A supervising or medical director physician is expected for clinical oversight; exact requirements vary by board interpretation.
Good-faith exam
A good-faith exam by an appropriate prescriber is expected before treatment; in-person is the conservative reading. Confirm with the Board.
Who can own
Physician-owned or physician-controlled clinical structure is the safest path; non-physician ownership requires careful MSO-style structuring.

Full Kentucky breakdown →

Louisiana

Strict
Who can inject
Physicians directly; PAs and APRNs under supervision/collaboration; RNs and LPNs may administer only under a physician order and supervision. Verify exact scope with the Board.
RNs injecting
RNs may administer neurotoxins and fillers only under physician order and supervision; independent RN injection is not permitted. Details vary by board interpretation.
Medical director
A supervising physician is expected; formal medical director requirements vary by board interpretation.
Good-faith exam
A good-faith exam by a licensed prescriber is expected before treatment; in-person is the conservative reading. Confirm with the Board.
Who can own
Physician-owned or physician-controlled clinical structure is required in practice; non-physician ownership needs careful structuring and counsel review.

Full Louisiana breakdown →

Maine

Moderate
Who can inject
Physicians directly; PAs and NPs under supervision/collaboration; RNs may administer under physician order or protocol. Verify current scope with the Board.
RNs injecting
RNs may administer under physician order or protocol; independent RN prescribing and assessment for injectables is not permitted. Details vary by board interpretation.
Medical director
A supervising or medical director physician is expected; exact requirements vary by board interpretation.
Good-faith exam
A good-faith exam by a licensed prescriber is expected before treatment; in-person is the conservative reading. Confirm with the Board.
Who can own
Physician-owned or physician-controlled structure is the safest path; non-physician ownership requires careful MSO-style structuring.

Full Maine breakdown →

Maryland

Moderate
Who can inject
Physicians (MD/DO) and, under delegation, RNs and LPNs may administer neurotoxins and fillers under physician supervision; NPs may inject within their scope under collaborative agreement with a supervising physician.
RNs injecting
Yes, RNs may inject under physician delegation and an established protocol; the RN is not independently authorized to determine candidacy or prescribe the product, so a physician must order and oversee.
Medical director
A supervising/collaborating physician is needed for delegated and NP/PA practice; a formal medical director designation is advisable and often expected by boards and insurers, verify exact requirements with counsel.
Good-faith exam
A good-faith exam by a licensed prescriber is required before administering prescription drugs such as neurotoxins; in-person examination is the expected standard.
Who can own
Physician-owned or management-services structure typically required; non-physicians generally cannot directly own clinical practice.

Full Maryland breakdown →

Who can inject
Physicians and, under physician supervision, NPs and PAs may inject; RNs and LPNs may administer under physician-delegated protocols, with board and facility requirements applying.
RNs injecting
Conditional, RNs may administer injectables under a physician order and delegation, not independently determine treatment.
Medical director
Physician oversight is required; a medical director or supervising physician is needed for delegated services and must be physically accessible per board expectations, verify details with counsel.
Good-faith exam
A good-faith examination by an appropriately licensed prescriber is required before treatment with prescription neurotoxins or fillers; in-person exam is the expected standard.
Who can own
Physician-owned or physician-controlled; non-physicians cannot own the clinical practice outright and must work through a compliant structure, verify with counsel.

Full Massachusetts breakdown →

Michigan

Moderate
Who can inject
Physicians, and under delegation and supervision, NPs, PAs, and RNs may administer neurotoxins and fillers; Michigan's rules allow delegation with physician oversight.
RNs injecting
Yes, RNs may inject under physician delegation and an established protocol, with the physician responsible for oversight.
Medical director
A supervising physician or medical director is generally required for delegated injectable services; verify the scope of required oversight with counsel.
Good-faith exam
A good-faith exam by a licensed prescriber is required before administering prescription neurotoxins or fillers; in-person examination is the expected standard.
Who can own
Physician-owned clinical practice generally required; non-physician ownership through a compliant MSO structure, verify with counsel.

Full Michigan breakdown →

Minnesota

Strict
Who can inject
Physicians and, under delegation and supervision, NPs, PAs, and RNs may administer neurotoxins and fillers; Minnesota requires physician oversight for these services.
RNs injecting
Conditional, RNs may inject under physician delegation and an established protocol with oversight; independent RN injection is not permitted.
Medical director
Physician oversight and a medical director or supervising physician are expected for delegated and NP/PA injectable services; verify exact requirements with counsel.
Good-faith exam
A good-faith exam by a licensed prescriber is required before treatment with prescription neurotoxins or fillers; in-person examination is the expected standard.
Who can own
Physician-owned clinical practice generally required; non-physician ownership must be structured through a compliant arrangement, verify with counsel.

Full Minnesota breakdown →

Mississippi

Moderate
Who can inject
Physicians and NPs with appropriate authority inject; RNs and LPNs may administer under physician order/delegation. Scope varies by board interpretation of 'medical treatment'.
RNs injecting
Generally not independently; RNs may administer neurotoxins/fillers under a physician's delegation and order. Verify with Board of Nursing and Board of Medical Licensure.
Medical director
Physician supervision/oversight is expected; a medical director is commonly required by boards in practice, specifics vary.
Good-faith exam
In-person good-faith exam by the treating prescriber is expected before treatment; exact requirements vary by board interpretation.
Who can own
Physician-controlled ownership is the safe path; non-physician ownership typically requires an MSO/management structure with physician ownership of the clinical entity.

Full Mississippi breakdown →

Missouri

Moderate
Who can inject
Physicians inject directly; NPs and PAs may inject under their scope and collaborative/supervision agreements; RNs may administer under a physician's order and protocol.
RNs injecting
RNs may administer injectables under physician orders/protocols; independent RN prescribing or independent evaluation for neurotoxins is not permitted. Verify specifics with the Missouri State Board of Nursing.
Medical director
Physician collaboration/supervision is required; a medical director is commonly used to satisfy oversight expectations.
Good-faith exam
A good-faith exam by a qualified prescriber is expected before treatment; specifics depend on board rules and the scope of the provider.
Who can own
Physician-controlled ownership of clinical operations; non-physician investors typically participate through a management services arrangement.

Full Missouri breakdown →

Montana

Lenient
Who can inject
Physicians, NPs, and PAs with appropriate authority inject; RNs may administer under a physician or provider order. Scope depends on the practitioner's license and board rules.
RNs injecting
RNs may administer under a physician or provider order; independent evaluation and prescribing of neurotoxins is not generally within RN scope. Verify with the Montana Board of Nursing.
Medical director
Not uniformly required by statute; a supervising or collaborating provider is needed for certain practitioners, so verify by license type.
Good-faith exam
A good-faith exam by the treating prescriber is expected before treatment; specific requirements vary by license type.
Who can own
Open to a broader range of ownership structures than many states, but clinical services must still be performed by licensed providers; confirm the structure with counsel.

Full Montana breakdown →

Nebraska

Moderate
Who can inject
Physicians and NPs with appropriate authority inject; PAs under supervision; RNs may administer under physician or provider order and delegation.
RNs injecting
RNs may administer under a physician or provider order; independent prescribing or evaluation for neurotoxins is not within RN scope. Verify with the Nebraska Board of Nursing.
Medical director
Physician collaboration or supervision is expected; a medical director is commonly used, with specifics depending on provider type.
Good-faith exam
A good-faith exam by the treating prescriber is expected before treatment; details depend on the prescriber's license and board rules.
Who can own
Physician-controlled ownership of clinical operations; non-physician business participation typically via management services arrangements.

Full Nebraska breakdown →

Nevada

Moderate
Who can inject
Physicians (MD/DO), and NPs/PAs/RNs under delegation or supervision; RNs may administer neurotoxins and fillers only under a physician's delegation/protocol, and the scope is set by the Nevada State Board of Nursing and Board of Medical Examiners.
RNs injecting
Conditional: RNs may inject under a physician's delegation/supervision and written protocol; they cannot independently prescribe or select treatment for medspa use. Verify exact scope with the boards.
Medical director
Practical requirement: a supervising/collaborating physician is needed for injectables and many medspa services; formal medical director designation depends on structure and board interpretation.
Good-faith exam
A good-faith exam (in-person or telehealth) is generally needed before prescribing or delegating treatment; specifics vary by board interpretation.
Who can own
Physician-owned or MSO/management services structure is typically required for non-physician investors; verify with counsel.

Full Nevada breakdown →

New Hampshire

Moderate
Who can inject
Physicians and licensed providers acting within scope; RNs and APRNs may administer neurotoxins and fillers under physician delegation or collaboration, with scope set by the NH Board of Nursing and Board of Medicine.
RNs injecting
Conditional: RNs may inject under physician delegation or collaborative practice agreements; independent RN prescribing or selection is generally not permitted. Verify the specific delegation rules.
Medical director
Physician oversight or collaboration is practically required for injectables; formal medical director designation is advisable and depends on structure.
Good-faith exam
A good-faith exam is generally required before prescribing or delegating injectables; the exam may be in-person or telehealth depending on the provider and board rules.
Who can own
Physician-owned or MSO/management services structure is typically advisable; verify with counsel.

Full New Hampshire breakdown →

New Jersey

Strict
Who can inject
Physicians and, under physician supervision, APNs/NPs and PAs; RNs may administer injectables only under physician order and supervision. Scope is set by the NJ Board of Medical Examiners and Board of Nursing.
RNs injecting
Conditional: RNs may administer injectables under a physician's order and supervision; independent RN injection or selection is not permitted.
Medical director
Physician supervision is required; a medical director or supervising physician is practically mandatory for injectable services.
Good-faith exam
A good-faith exam is generally required before prescribing or delegating; in-person vs. telehealth scope should be verified with the boards.
Who can own
Physician-owned; non-physician ownership of clinical medspas is generally restricted, with MSO structures used cautiously.

Full New Jersey breakdown →

New Mexico

Moderate
Who can inject
Physicians, and APRNs/PAs with appropriate authority; RNs may inject under physician delegation or collaborative practice. Scope set by the NM Medical Board and Board of Nursing.
RNs injecting
Conditional: RNs may inject under physician delegation or a collaborative practice agreement; independent RN selection and prescribing is not permitted.
Medical director
Physician oversight is required for injectables; a supervising physician or medical director is practically necessary.
Good-faith exam
A good-faith exam is generally required before prescribing or delegating; telehealth rules should be verified.
Who can own
Physician-owned or MSO structure is typically advisable; verify with counsel.

Full New Mexico breakdown →

New York

Strict
Who can inject
Physicians (MD/DO) and, under physician supervision/delegation, RNs and PAs; NPs may inject within their certified scope with physician collaboration per Education Law rules; aesthetic injections are treated as medical acts.
RNs injecting
Yes, RNs may administer neurotoxins and fillers only under a physician's order and supervision (delegation of medical acts); RNs cannot independently assess or prescribe.
Medical director
Effectively required in practice: a supervising/collaborating physician must oversee medical procedures, and facilities should have a licensed physician responsible for protocols; verify exact structure with counsel.
Good-faith exam
Required: a physician or qualified prescriber must perform an in-person evaluation (good-faith exam) before treatment; interpretation of exam requirements varies by board guidance.
Who can own
Physician-owned or MSO/management-services structure required; non-physicians may own the business side via an MSO but not the medical practice.

Full New York breakdown →

North Carolina

Moderate
Who can inject
Physicians and, under delegation/supervision, NPs and PAs; RNs may administer under a physician's order or delegation. Injections are considered medical acts requiring a licensed prescriber's oversight.
RNs injecting
Conditional: RNs may administer injectables under a physician's order or delegation, but cannot independently assess or prescribe; NC Board of Nursing guidance governs.
Medical director
Medical oversight by a physician is expected; a formal medical director requirement varies by facility type and board interpretation, so verify.
Good-faith exam
Required: a physician, NP, or PA must conduct an in-person evaluation before prescribing or delegating injectables; telehealth allowances are narrow and interpretation varies.
Who can own
Physician-owned or MSO/management-services structure; non-physicians may own the business via an MSO but not the medical practice.

Full North Carolina breakdown →

North Dakota

Moderate
Who can inject
Physicians and, under delegation/collaboration, NPs and PAs; RNs may administer under a physician's order or delegation. Specific aesthetic-injection rules are not widely detailed and should be verified.
RNs injecting
Conditional: RNs may administer injectables only under a physician's order or delegation; independent assessment and prescribing are not permitted.
Medical director
Physician oversight expected; a formal medical director requirement varies by facility type and board interpretation.
Good-faith exam
Required: an in-person evaluation by a physician or qualified prescriber is expected before treatment; telehealth allowances vary and should be confirmed.
Who can own
Physician-owned or MSO/management-services structure is the common approach; non-physician ownership of the medical practice is generally restricted.

Full North Dakota breakdown →

Ohio

Moderate
Who can inject
Physicians and, under delegation/collaboration, NPs and PAs; RNs may administer under a physician's order or delegation, with Ohio's Board of Nursing guidance governing.
RNs injecting
Conditional: RNs may administer injectables under a physician's order or delegation; independent assessment and prescribing are not permitted.
Medical director
Physician oversight required for medical procedures; a formal medical director requirement depends on facility and board interpretation.
Good-faith exam
Required: an in-person evaluation by a qualified prescriber is expected before treatment; telehealth allowances are limited and should be verified.
Who can own
Physician-owned or MSO/management-services structure; non-physicians may own the business side but not the medical practice.

Full Ohio breakdown →

Oklahoma

Moderate
Who can inject
Physicians (MD/DO) directly; RNs, LPNs, NPs, and PAs may inject under physician delegation/supervision per their scope and protocols
RNs injecting
Yes, RNs may administer neurotoxins and fillers only under a delegating physician's order/protocol; RN independent ownership or independent prescribing of injectables is not permitted
Medical director
Practical requirement in practice: a supervising/collaborating physician is needed for delegated injectable services; verify exact delegation documentation with the board
Good-faith exam
Required before treatment (in-person evaluation by the prescriber); verify current scope of acceptable telehealth evaluation with the board
Who can own
Physician-owned or management-services structure (MSO-type) typically required; non-physician direct ownership of the clinical practice is generally not permitted

Full Oklahoma breakdown →

Oregon

Strict
Who can inject
Physicians and licensed providers acting within scope; RNs and NPs may inject under scope and protocols; LPNs and unlicensed staff require direct supervision and are limited
RNs injecting
Yes, RNs may inject within scope, but the medical oversight and protocol requirements are strict and should be verified with the Board of Nursing
Medical director
Medical oversight is expected for injectable services; the exact requirement depends on the service and provider type, so verify with the board
Good-faith exam
Required before treatment; the in-person versus telehealth standard should be verified with the board because interpretations vary
Who can own
Physician-owned or structured through a compliant management arrangement; non-physician direct ownership of the clinical practice is generally not permitted

Full Oregon breakdown →

Pennsylvania

Strict
Who can inject
Physicians directly; RNs, NPs, and PAs may inject under physician delegation or collaborative agreement within scope; unlicensed staff are restricted
RNs injecting
Yes, RNs may inject under physician delegation/protocol; independent RN injectable practice without physician order is not permitted
Medical director
A supervising or collaborating physician is required for delegated injectable services; verify the specific documentation requirements
Good-faith exam
Required before treatment; the in-person versus telehealth standard should be verified with the board
Who can own
Physician-owned or structured through a management services arrangement; non-physician direct ownership of clinical practice is generally not permitted

Full Pennsylvania breakdown →

Rhode Island

Moderate
Who can inject
Physicians directly; NPs and RNs may inject within scope under physician collaboration or protocol; unlicensed staff are restricted
RNs injecting
Yes, RNs may inject under physician protocol or collaboration; independent RN injectable practice without a physician framework is not permitted
Medical director
A supervising or collaborating physician is expected for injectable services; verify documentation requirements with the board
Good-faith exam
Required before treatment; the in-person versus telehealth standard should be verified with the board
Who can own
Physician-owned or structured through a management services arrangement; non-physician direct ownership of clinical practice is generally not permitted

Full Rhode Island breakdown →

South Carolina

Moderate
Who can inject
RNs and NPs may inject neurotoxins and fillers under physician supervision or delegation; LPNs and estheticians generally may not inject prescription neurotoxins; physician oversight required for the medical component.
RNs injecting
Yes, RNs may administer neurotoxins and fillers under a physician's order/protocol and supervision; RN independence is limited, so verify the specific delegation documentation with counsel.
Medical director
Physician supervision or a collaborating/supervising physician is required for medical aesthetic procedures; formal medical director expectations vary by facility and board interpretation.
Good-faith exam
A good-faith exam by an appropriately licensed prescriber is required before prescribing or delegating injectable treatments; in-person vs telehealth should be verified with the Board.
Who can own
Physician-owned or physician-controlled structure generally required; non-physician ownership via management structure requires counsel review.

Full South Carolina breakdown →

South Dakota

Moderate
Who can inject
RNs, NPs, and PAs may inject under physician or prescriber authority; estheticians may not inject prescription products; LPN scope is limited and requires supervision.
RNs injecting
Yes, RNs may inject under a prescriber's order or protocol; independence depends on delegation documentation.
Medical director
Medical director or supervising physician arrangement is expected for medical aesthetic services; specifics vary by board interpretation.
Good-faith exam
A good-faith exam by a licensed prescriber is required before treatment; in-person vs telehealth should be verified with the Board.
Who can own
Physician-owned structure generally expected; non-physician owners typically use a management structure requiring counsel review.

Full South Dakota breakdown →

Tennessee

Strict
Who can inject
Physicians, NPs, and PAs may inject; RNs may inject neurotoxins and fillers only under a physician's delegation/order; LPNs and estheticians may not inject prescription products.
RNs injecting
Yes, but only under a physician's delegated order or protocol; RNs cannot independently prescribe or own the medical component.
Medical director
Medical director/supervising physician required; Tennessee has been active on physician supervision of medspas.
Good-faith exam
A good-faith exam is required before prescribing or treating; telehealth GFE is restricted and verification with the Board is essential.
Who can own
Physician-owned required for the medical practice; non-physician owners generally cannot own the medical component.

Full Tennessee breakdown →

Texas

Strict
Who can inject
Physicians may inject; RNs and LVNs may inject neurotoxins/fillers only under physician delegation (delegated medical acts); estheticians may not inject prescription products; NPs and PAs may inject under delegation/prescriptive authority.
RNs injecting
Yes, but only under physician delegation through a delegation order and supervision; RNs cannot independently prescribe injectables.
Medical director
Physician supervision and delegation documentation required; Texas enforces delegation rules for injectables.
Good-faith exam
A good-faith exam by an appropriately licensed prescriber is required before prescribing or delegating; telehealth GFE is restricted and verification with the Texas Medical Board is essential.
Who can own
Physician-owned medical practice required; non-physician owners typically operate through an MSO/management structure with counsel review.

Full Texas breakdown →

Utah

Moderate
Who can inject
Physicians, PAs, and NPs (with prescriptive authority) may inject; RNs and LPNs may inject only under delegation/supervision of a physician or APRN per Utah scope rules
RNs injecting
Conditional: RNs may administer neurotoxins and fillers under delegation and supervision of a licensed prescriber; verify current delegation specifics with the Utah Division of Professional Licensing
Medical director
Not uniformly mandated by statute for all medspas; a supervising/collaborating physician or prescriber relationship is generally needed for injectables and prescribing — varies by license type, verify with counsel
Good-faith exam
Physician or prescriber must establish a patient relationship and evaluate the patient before prescribing or delegating Rx-only treatments; in-person requirement details vary by board interpretation
Who can own
Non-physicians may generally own through management structures (MSO-style) with physician oversight of clinical services; verify structure with counsel

Full Utah breakdown →

Vermont

Moderate
Who can inject
Physicians, PAs, and APRNs may inject; RNs may inject under delegation from a licensed prescriber; LPNs only under direct supervision of a prescriber
RNs injecting
Conditional: RNs may perform injections under a licensed prescriber's delegation and orders; verify whether the specific delegation documentation requirements apply to your facility
Medical director
Not uniformly mandated for all medspas; a supervising or collaborating prescriber is generally needed for injectables and Rx-only treatments — verify scope with the Board
Good-faith exam
Prescriber must evaluate the patient before prescribing or delegating Rx-only treatments; in-person requirement specifics vary by board interpretation
Who can own
Physician-owned or management-structured; non-physician ownership is possible in some structures but verify with counsel given fee-splitting and CPOM-adjacent rules

Full Vermont breakdown →

Virginia

Strict
Who can inject
Physicians, and NPs/PAs under supervision or collaboration per Virginia scope rules; RNs may inject only under a licensed prescriber's order and delegation; LPNs under supervision
RNs injecting
Conditional: RNs may administer injections under a prescriber's order and delegation, but independent RN injection of neurotoxins/fillers is not clearly permitted; verify with the Board of Nursing
Medical director
Generally required in practice: a supervising physician or collaborating prescriber is needed for injectables and Rx-only treatments
Good-faith exam
Prescriber must establish a valid patient relationship and evaluate the patient before prescribing or delegating Rx-only treatments; in-person requirement varies by board interpretation
Who can own
Physician-only or MSO/management structure with clinical control by licensed physicians; non-physician direct ownership of clinical practice is generally not permitted

Full Virginia breakdown →

Washington

Moderate
Who can inject
Physicians, APRNs, and PAs may inject with appropriate authority; RNs may inject under delegation/order from a licensed prescriber, with LPNs under RN supervision and delegation
RNs injecting
Conditional: RNs may administer neurotoxins and fillers under a prescriber's order and under Washington nursing delegation rules; verify facility-specific documentation requirements
Medical director
Not uniformly mandated by statute for all medspas; a prescriber must be responsible for Rx-only treatments, and a medical director arrangement is commonly used — verify with counsel
Good-faith exam
Prescriber must evaluate the patient before prescribing or delegating Rx-only treatments; in-person requirement details vary by board interpretation
Who can own
Licensed-professional ownership through professional service corporations is typical; non-licensed ownership of clinical services is restricted — verify structure with counsel

Full Washington breakdown →

West Virginia

Moderate
Who can inject
Physicians, PAs and NPs with prescriptive authority and delegation; RNs and LPNs may administer under delegation/supervision of a physician or licensed prescriber.
RNs injecting
RNs may administer neurotoxins and fillers only under a physician's or qualified prescriber's order and delegation; they cannot independently assess and prescribe. Verify scope specifics with the West Virginia Board of Nursing.
Medical director
Physician oversight or medical direction is expected for injectable services; formal medical director designation details vary by board interpretation — verify with counsel.
Good-faith exam
A good-faith exam (in-person evaluation by the prescriber before treatment) is expected for prescription neurotoxins and fillers; the exact GFE standard is interpreted by the Board of Medicine.
Who can own
Physician-owned or MSO/management-services structure; non-physicians generally cannot own the clinical practice outright.

Full West Virginia breakdown →

Wisconsin

Strict
Who can inject
Physicians, and PAs/NPs under their scope and collaboration/prescribing rules; RNs may administer injectables under a physician's order or delegation, and LPNs under RN or physician direction.
RNs injecting
RNs may administer neurotoxins and fillers under a valid prescriber's order; independent prescribing or assessment authority is limited, so the physician or prescriber must have examined the patient and ordered the treatment.
Medical director
A physician (or qualified prescriber) must supervise and order treatments; a formal medical director arrangement is strongly recommended and often expected in practice — verify specifics with the Medical Examining Board.
Good-faith exam
A good-faith exam (in-person evaluation by the prescriber before treatment) is required before administering prescription neurotoxins and fillers; the specific standard is interpreted by the Medical Examining Board.
Who can own
Physician-owned or MSO/management-services structure; non-physicians cannot own the clinical practice.

Full Wisconsin breakdown →

Wyoming

Moderate
Who can inject
Physicians, and NPs and PAs under their prescriptive authority and collaboration/supervision; RNs and LPNs may administer under a physician's or prescriber's order or delegation.
RNs injecting
RNs may administer neurotoxins and fillers under a valid order from a physician or qualified prescriber; RNs cannot independently assess and prescribe these treatments.
Medical director
A supervising physician or qualified prescriber is required for injectable services; formal medical director details vary by board interpretation — verify with counsel.
Good-faith exam
A good-faith exam (in-person evaluation by the prescriber before treatment) is expected before prescription neurotoxins and fillers; the specific standard is interpreted by the Board of Medicine.
Who can own
Physician-owned or MSO/management-services structure; non-physicians generally cannot own the clinical practice.

Full Wyoming breakdown →

When your state's rules change, know the same day.

This tracker updates as boards and legislatures move. Get the free Inside MedSpa brief by email: no card, and one click to leave.

Get the free brief
Inside MedSpa · Free brief

By the time it's news, it's too late.

FDA decisions, recalls and the rules you operate under, drafted from the source documents and sent free by email.

Get the free brief The free Inside MedSpa brief · no card · unsubscribe anytime.
FDA, recalls and rule changes for practice owners Get the free brief →