Registered nurses (RNs)
Yes, under physician delegation; RN may inject with written standing orders or protocol from supervising physician
Nurse practitioners & physician assistants
NP/PA may inject under physician collaboration; independent practice for injectables not clearly permitted
Supervision & the medical director
Required; physician must oversee the medical spa and delegate procedures
The exam requirement
Required; in-person exam by physician or qualified provider before treatment
What to verify in Colorado
Retain a Colorado-licensed physician as medical director with clear written delegation protocols for all injectors, and verify current telehealth GFE rules with the Colorado Medical Board.
Primary source: Colorado Medical Board; Colorado Board of Nursing
General business information for Colorado medical-spa owners, current as of 2026 — not legal advice. State boards update rules often; confirm specifics with the Colorado board (and your own counsel) before you act.