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Frequently Asked Questions

Whether you’re a medical professional looking to open a med spa, or a prospective patient researching what a safe experience looks like, we have your answers.

The American Med Spa Association defines a medical spa as a hybrid between an aesthetic medical center and a day spa with four core elements: (1) the provision of non-invasive, non-surgical aesthetic medical services; (2) on-site supervision by a licensed health care professional; (3) the performance of treatments by trained, experienced, and qualified practitioners; and (4) a relaxing, spa-like environment for patients.

Here are three tips that will help you determine whether your medical spa is complying with the law:

Ask if you can see the doctor. The vast majority of treatments you receive at medical spas are considered medical treatments. Prior to treatment, you should see a doctor, nurse practitioner, or physician assistant for an in-person examination.

Make sure your practitioner is legally permitted to treat you. As a general rule, all medical treatments should be performed by medical professionals under the supervision of a physician. Most treatments you’ll receive at a medical spa are performed by doctors, nurse practitioners, physician assistants, or registered nurses.

Do your research. In this industry, experience matters. Internet searches can be done on everything from the spa itself to the physician, owner, and nurse you will be working with. Look beyond the first two pages of results and check state licensing boards.

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Common treatments include botulinum toxin A (Botox, Dysport, Xeomin), dermal fillers, laser hair removal, CoolSculpting, microneedling, microdermabrasion, chemical peels, PRP/PRF treatments, thread lifts, IV therapy, and more. Visit our Treatment Directory for detailed information on each procedure.

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As a general rule, all medical treatments should be performed by medical professionals under the supervision of a physician. Most treatments you’ll receive at a medical spa are considered to be medical treatments by the state. This is important because the administration of medical treatments is the practice of medicine, and a host of legal requirements are triggered.

Every treatment is different and every state is different, so determining who can do what is not an easy task. But as a general rule, anything with needles or a scalpel should be performed by a practitioner who is, at a minimum, a registered nurse under the supervision of a physician.

Call your state board of medicine or nursing, a health care lawyer, or AmSpa to get updated information for your specific state.

Not always. While a doctor doesn’t always have to be on-site for every medical spa procedure, you should have a face-to-face consultation with a doctor, physician assistant, or nurse practitioner prior to each medical treatment. The specifics vary by state, and many states have distance or documentation requirements for supervising physicians.

This is an important question, as medical treatments trigger specific requirements (face-to-face consult with a doctor, nurse practitioner, or physician assistant, to name one) that non-medical treatments do not. A medical treatment is broadly defined as a treatment that can affect any living tissue of the body, including anything under the top layer of the skin.

AmSpa encourages consumers to be aware that noncompliant medical spas may indicate that medical spa treatments are not medical treatments, when they are in fact considered medical treatments by the state.

Most medical spa procedures are considered medical in nature. Because of this, most states require, and AmSpa recommends, that prior to your initial treatment, the medical spa should offer you an in-person exam by either a doctor, a nurse practitioner, or a physician assistant.

Much confusion exists over who can perform laser hair removal, and the laws vary drastically from state to state. A number of states have developed specific laws regarding laser hair removal, so you are strongly encouraged to check with your state boards.

As a general rule, most states consider all laser treatments, including laser hair removal, to be medical treatments. AmSpa is aware that it is common for aestheticians to perform this procedure; however, most state boards consider it to be the practice of medicine.

No. Botox is considered a medical treatment. Prior to your initial treatment, the medical spa should offer you an in-person exam by either a doctor, a nurse practitioner, or a physician assistant. While each state varies, an aesthetician should not be performing Botox injections. As a general rule, only physicians, nurse practitioners, physician assistants, and registered nurses should be providing Botox injections.

It depends on your state, but as a general rule, yes, that’s perfectly fine. Nurse Practitioners and Physician Assistants are called “mid-level” providers. They can do many of the same things that a doctor can do, provided they are properly trained and experienced. They can see new patients, prescribe treatments, and perform them.

Most states do not require the overseeing doctor to be on site, although there are often distance and documentation requirements. As long as the NP or PA is properly trained and experienced, there should be no issue.

Don’t be shy! Ask about the NP’s experience, ask about their overseeing doctor, and ask to see all supporting documentation. All of this should be readily available.

It depends on your state, but as a general rule, yes, that’s perfectly fine. Most states allow RNs to inject Botox and fillers, with a few important caveats. First, you should always see a physician, NP, or PA prior to receiving treatment to establish the practitioner-patient relationship. Second, the RN must be properly trained, qualified, and experienced.

Don’t simply take their word for it. Ask for their license number (all nurses are registered with the state), ask to speak to their supervising physician, and ask about their training. Any practitioner should be happy to answer these questions.

Typically, yes, but you should definitely do some research to make sure the event is safe and compliant. Most medical boards don’t exclusively require Botox or fillers to be administered at the doctor’s office. However, all the requirements of medical treatments still apply, even though the treatment is being done offsite.

That means that, unless you have already been treated at the medical spa before, you should see a physician, NP, or PA face-to-face prior to treatment. You should also sign informed consent forms and receive follow-up care instructions.

If you are invited to a Botox party held by a nurse you have never met before (who is not accompanied by a doctor, NP, or PA), this is a huge red flag that the party is being held illegally and that proper medical protocols are not being followed.

Disclaimer: The information and answers contained in this section provide a general guide to laws that apply to medical spas. The information contained on this site is for general reference only. This information is not intended to provide legal advice or to serve as a substitute for legal research or consultation with a licensed attorney. We encourage you to consult with a licensed attorney in your state for guidance on any specific situation you may encounter.