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Who may own it, and who may treat the patient.

Five answers for every state: ownership, injections, NP and PA rules, and any exam required first, each with its source.

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Sources linked on every lineReviewed 30 July 2026Gaps marked, not filled in

The short answer: two rules decide most of what a med spa may do. Corporate practice of medicine decides who may own the practice: strict states require physician ownership, which is why non-physician owners use a management services organization alongside a physician-owned professional corporation. Delegation and supervision rules decide who may treat the patient. In 35 of the 50 states in this map, the rule names an examination a qualifying practitioner must perform before some or all treatment, and each state's note gives the scope. Pick your state below for both, with sources.

State by state

Your state, rule by rule

50 states

Alabama

Reviewed 30 July 2026
Nurse practitionersReducedCareer-long collaborative agreement with a physician, approved by the medical board, is required for CRNP practice and prescribing. source ↗
Physician assistantsBoard-approved registration agreement with a supervising physician source ↗
Who may own the practiceMinimalNo CPOM doctrine; corporations may employ physicians provided physicians retain independent clinical judgment, per a 1992 joint board declaration. source ↗
Who may injectThe medical board has authorized the performance or delegation of cosmetic botulinum toxin injection only for a PA or CRNP acting under a collaboration or registration agreement and the approved protocol, and bars delegation to RNs. The notice governs delegation and does not address a physician injecting personally. source ↗
Good faith examFor telehealth, a physician-patient relationship must be established at the patient's initiation or on referral from the patient's established physician. A controlled substance may be prescribed by telehealth only if the visit includes synchronous audio or audio-visual HIPAA-compliant communication, the prescriber has had at least one in-person encounter with the patient in the preceding 12 months, and the prescriber has established a legitimate medical purpose in the preceding 12 months. A person licensed by the medical or nursing board assisting at the patient's site, while the prescriber evaluates by video, can satisfy the in-person encounter. source ↗

Alaska

Reviewed 30 July 2026
Nurse practitionersFullNPs practice and prescribe independently under the Board of Nursing; no physician collaboration or supervision agreement required. source ↗
Physician assistantsWritten collaborative plan with a physician required source ↗
Who may own the practiceNo explicit CPOM prohibition confirmed; Alaska's professional corporation act requires all shareholders be licensed. source ↗
Who may injectAPRNs, RNs and LPNs may perform cosmetic injections only under a provider's order and supervision, never independently, and not on patients under 18. source ↗
Good faith examRequired: provider must perform and document an initial history and physical evaluation; telehealth is expressly acceptable source ↗

Arizona

Reviewed 30 July 2026
Nurse practitionersFullNPs practice and prescribe autonomously under the Board of Nursing; no supervising or collaborating physician is required. source ↗
Physician assistantsSupervision agreement; collaboration without supervision at 8,000+ board-certified hours source ↗
Who may own the practiceMinimalNo statute or strong case law bars non-physician ownership of a medical entity; among the more permissive states. source ↗
Who may injectRNs may inject neuromodulators and fillers only under a written order from an MD, DO or NP, who must supervise and remain reachable. source ↗
Good faith examRequired before Level II/III aesthetic procedures by a qualified licensed provider; telemedicine allowed for the initial exam source ↗

Arkansas

Reviewed 30 July 2026
Nurse practitionersReducedAPRNs must maintain a career-long collaborative practice agreement with a physician for prescriptive authority. source ↗
Physician assistantsBoard-approved delegation agreement with a designated supervising physician source ↗
Who may own the practiceStrictAll officers, directors and shareholders of a medical professional corporation must at all times be licensed Arkansas physicians. source ↗
Who may injectTrained APRNs and RNs may perform aesthetic injections under a patient-specific or annually reviewed standing order from a physician or APRN prescriber; LPNs may not. source ↗
Good faith examProcedures must be prescribed by a qualified physician or APRN with prescriptive authority; telehealth acceptability not addressed by the nursing board source ↗

California

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs generally require physician standardized procedures; AB 890 grants qualified NPs more autonomy after supervised transition hours. source ↗
Physician assistantsPractice agreement with a supervising physician (no task-by-task delegation) source ↗
Who may own the practiceStrictCalifornia-licensed physicians must hold the majority of a medical corporation's stock. Other licensed health care professionals, such as nurses, nurse practitioners and physician assistants, may together hold no more than 49%, and laypersons or lay entities may not own any part of a medical practice or control clinical, staffing, billing or records decisions. source ↗
Who may injectBotox, fillers and lasers may be delegated only to licensed RNs, NPs or PAs under physician supervision; medical assistants and estheticians are prohibited. source ↗
Good faith examAppropriate prior examination required; may not be delegated to an RN, though NPs may perform it under standardized procedures source ↗

Colorado

Reviewed 30 July 2026
Nurse practitionersFullNPs practice under exclusive Board of Nursing authority; no career-long physician collaborative agreement required. source ↗
Physician assistantsCollaborative agreement required; a supervisory agreement applies until 5,000 practice hours source ↗
Who may own the practiceStrictColorado bars corporations from practising medicine; only licensed physicians may own a professional medical corporation. source ↗
Who may injectInjections are the practice of medicine; a physician may delegate to qualified personnel under board rule, with RNs governed by the Nurse Practice Act. source ↗
Good faith examAn appropriate physician-patient relationship and initial consultation are required; telehealth may establish the relationship source ↗

Connecticut

Reviewed 30 July 2026
Nurse practitionersFullIndependent practice only after three years and 2,000 hours collaborating with a physician; no agreement required thereafter. source ↗
Physician assistantsSupervision agreement required: a clearly identified supervising physician providing active, direct supervision source ↗
Who may own the practiceModerateNo express CPOM statute, but medical professional corporations may have only licensed practitioners as owners, effectively barring lay ownership. source ↗
Who may injectOnly a physician, PA, APRN or RN may administer cosmetic medical procedures at a medical spa, and RNs act by delegation. source ↗
Good faith examRequired: a physician, PA or APRN must perform an initial IN-PERSON assessment; telehealth does not satisfy it source ↗

Delaware

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority under exclusive Board of Nursing licensure; the collaborative agreement requirement was removed in 2021. source ↗
Physician assistantsCollaborative agreement required, with a statutory independent-practice pathway after 6,000 postgraduate clinical hours source ↗
Who may own the practiceMinimalNo express corporate practice of medicine doctrine, though professional corporations may issue stock only to licensed practitioners. source ↗
Who may injectNo rule names injectables; physicians, APRNs and PAs may inject, and RNs only by physician delegation requiring on-site direct supervision under a prescription treatment plan. source ↗
Good faith examA provider-patient relationship is required before treatment and may be established by telehealth source ↗

Florida

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs need a written protocol with a supervising physician; autonomous registration is limited to primary care. source ↗
Physician assistantsSupervision required: the supervising physician must be easily available or physically present source ↗
Who may own the practiceModerateAs of 26 September 2026 we found no Florida statute that limits practice ownership to physicians. An entity that provides health care services and tenders charges for reimbursement needs a Health Care Clinic license unless an exemption applies, such as a practice wholly owned by licensed health care practitioners in the license classes the statute lists, with a licensed owner supervising the business and legally responsible for its compliance, and a licensed clinic must appoint a medical director or clinic director who accepts legal responsibility in writing. source ↗ source ↗ source ↗
Who may injectPhysicians, PAs and APRNs may inject; RNs may administer neuromodulators and fillers only when delegated by and under the direct supervision of a physician. source ↗
Good faith examFlorida's telehealth statute lets a provider use telehealth to perform a patient evaluation, and a provider whose evaluation is sufficient to diagnose and treat need not also do a physical exam first. As of 26 September 2026 we found no Florida statute or board rule that sets a separate exam requirement for cosmetic procedures. source ↗

Georgia

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs must work under a nurse protocol agreement with a delegating physician, filed with the medical board. source ↗
Physician assistantsSupervision required: a board-approved job description with a primary supervising physician source ↗
Who may own the practiceModerateNo standalone CPOM statute since the 1982 repeal, but professional corporation shares may be issued only to licensed practitioners, pushing lay owners into MSO structures. source ↗
Who may injectRNs, but not LPNs, may inject neuromodulators and dermal fillers only under an individualised order from a physician, NP or PA with prescriptive authority. source ↗
Good faith examRequired: the prescribing physician, NP or PA must personally perform the history and physical; standing orders are not an acceptable substitute source ↗

Hawaii

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose and prescribe independently under board of nursing authority; no physician collaborative agreement required. source ↗
Physician assistantsPhysician supervision required; written record-review guidelines kept at the practice site source ↗
Who may own the practiceMinimalNo CPOM statute or case law; ownership is limited indirectly because professional-corporation shares may be issued only to licensed practitioners. source ↗
Who may injectPhysicians and supervised PAs may inject; APRNs may inject and prescribe independently; RNs and LPNs only on a prescriber's order under nursing delegation. source ↗
Good faith examDocumented patient evaluation required; telehealth expressly acceptable, but an online questionnaire alone is not source ↗

Idaho

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose and prescribe independently under board of nursing authority; no physician collaboration required. source ↗
Physician assistantsWritten collaborative practice agreement required; no named supervising physician and no ratio source ↗
Who may own the practiceMinimalThe Board of Medicine formally disavowed the corporate practice doctrine in 2016; non-physicians may own practices and employ physicians. source ↗
Who may injectNeurotoxin and filler injection is the practice of medicine; physicians, or delegated medical personnel with the physician on-site or immediately available, may inject. source ↗
Good faith examRequired: physician must document evaluation, assessment and plan before initial treatment; telehealth acceptable, static questionnaire insufficient source ↗

Illinois

Reviewed 30 July 2026
Nurse practitionersReducedWritten collaborative agreement with a physician required unless the APRN qualifies for full practice authority. source ↗
Physician assistantsWritten collaborative agreement required; hospital and ASTC privileged PAs exempt source ↗
Who may own the practiceStrictOnly physicians, and APRNs for some services, may own a medical practice; lay corporations cannot employ physicians, hospitals excepted. source ↗
Who may injectPhysicians may inject and delegate to RNs, LPNs, APRNs or PAs under supervision; full-practice-authority APRNs act independently; estheticians may not inject. source ↗
Good faith examPhysician-patient relationship required, and a physician exam before laser treatment; no med-spa-specific telehealth guidance source ↗

Indiana

Reviewed 30 July 2026
Nurse practitionersReducedNPs must maintain a written collaborative practice agreement with a physician for prescriptive authority. source ↗
Physician assistantsWritten collaborative agreement required; dependent practice, maximum four PAs per physician source ↗
Who may own the practiceStrictWidely treated as a CPOM state requiring physician ownership, though the restriction is inferred from licensure statutes rather than expressly codified. source ↗
Who may injectOnly physicians, qualifying APRNs, and PAs with delegated prescriptive authority may order injectables; RNs may administer only under a physician-delegated regimen. source ↗
Good faith examNo express statutory good-faith-exam mandate; the duty flows from the prescribing standard of care. Telehealth permitted without a prior in-person exam source ↗
Coming changeSenate Enrolled Act 282 of 2026 (Public Law 136-2026) adds Indiana Code 25-22.5-12.5, effective 1 July 2026. From 1 January 2027 a medical spa must be registered with the Medical Licensing Board of Indiana to do business in the state, and the board must set up the registration procedure by 1 October 2026. A registered medical spa must designate a responsible practitioner who has prescriptive authority and education and training in the health care services and treatments being performed and the medications being dispensed or administered. A medical spa must notify the board not later than 15 days after the occurrence of a patient's serious adverse event. A physician's office and a facility or practice otherwise licensed by the state fall outside the definition. source ↗

Iowa

Reviewed 30 July 2026
Nurse practitionersFullARNPs evaluate, diagnose and prescribe independently under board of nursing authority; no physician agreement required. source ↗
Physician assistantsOptimal Team Practice: collaboration determined at the practice level; no supervisory agreement required source ↗
Who may own the practiceModerateProfessional corporations must be owned by same-profession licensees, but Iowa has no broad statutory ban on lay entities employing physicians. source ↗
Who may injectBotulinum toxin, fillers and other injectables are medical aesthetic services; non-physicians may perform them only when delegated and supervised by a medical director. source ↗
Good faith examIn-person interview and physical exam generally required; telemedicine acceptable if adequate, a static online questionnaire is not source ↗

Kansas

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose, and prescribe under board of nursing authority; no physician collaborative agreement required. source ↗
Physician assistantsSupervision agreement required; moves to a collaborative agreement after 4,000 hours from 1 January 2027 source ↗
Who may own the practiceStrictA business offering medical services may be owned only by physicians or other statutorily qualified licensees; violation is a felony. source ↗
Who may injectNo cosmetic-specific board rule exists. Under the general framework a prescriber orders treatment and an RN may then execute that patient-specific order. source ↗
Good faith examBoard guidance requires the prescriber to personally evaluate and diagnose the patient before ordering; standing orders are not valid prescriptions. Telehealth may establish the relationship source ↗

Kentucky

Reviewed 30 July 2026
Nurse practitionersReducedCareer-long collaborative agreement with a physician required, including a separate agreement to prescribe controlled substances. source ↗
Physician assistantsBoard-approved supervision agreement with a supervising physician required source ↗
Who may own the practiceModerateProfessional corporations must be owned by licensed persons, but the medical board declines enforcement absent interference with a physician's clinical judgment. source ↗
Who may injectAPRNs may inject within their population focus; RNs and LPNs administer neurotoxins only on a qualified provider's order under supervision, and LPNs may not inject fillers. source ↗
Good faith examDocumented provider assessment and treatment plan required before treatment; telehealth acceptable if standard of care met, static online questionnaires prohibited source ↗

Louisiana

Reviewed 30 July 2026
Nurse practitionersReducedNPs must maintain a collaborative practice agreement with a physician; fully independent practice is not permitted. source ↗
Physician assistantsSupervising physician required; written agreement updated annually, physical presence not required source ↗
Who may own the practiceModeratePhysician employment by a business corporation is not per se unlawful, but corporate control of clinical judgment is unauthorized practice of medicine. source ↗
Who may injectPhysicians, PAs, and APRNs may inject; trained RNs may give neurotoxins on a prescriber's order with a physician or NP on-site, but not dermal fillers. source ↗
Good faith examRequired: history and physical exam by a physician or collaborating NP must precede treatment; telehealth acceptability unverified source ↗

Maine

Reviewed 30 July 2026
Nurse practitionersFullFull authority after 24 months of supervised practice; no ongoing physician collaborative agreement required thereafter. source ↗
Physician assistantsPractice agreement required below 4,000 clinical hours; no agreement required above that threshold source ↗
Who may own the practiceMinimalNo CPOM statute or case law; non-physicians may own med spas, though only licensees may deliver medical services. source ↗
Who may injectOnly physicians, physician associates, and APRNs may evaluate, diagnose, and prescribe; RNs and LPNs may administer injectables under delegation; unlicensed personnel may never inject. source ↗
Good faith examRequired: history and exam by physician, PA, or APRN; telehealth acceptable if it supports an informed diagnosis; standing orders prohibited source ↗

Maryland

Reviewed 30 July 2026
Nurse practitionersFullNPs practice independently under Board of Nursing authority; no physician collaborative agreement or supervision required. source ↗
Physician assistantsCollaboration agreement with a patient care team physician (delegation agreements ended October 2024) source ↗
Who may own the practiceModerateDoctrine is uncodified and loosely enforced; medical practices generally must use physician-owned professional corporations rather than general business corporations. source ↗
Who may injectCosmetic medical procedures may be delegated to PAs or assigned to other licensed providers within their board-determined scope, generally with onsite physician supervision. source ↗
Good faith examRequired: physician must personally perform the initial assessment and written treatment plan; telehealth acceptability unverified source ↗

Massachusetts

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority: NPs may evaluate, diagnose, prescribe and manage treatment without a physician agreement. source ↗
Physician assistantsPhysician supervision agreement required, though on-site physician presence is not source ↗
Who may own the practiceStrictNon-physician ownership of a medical practice is not permitted; practices must be physician-owned professional entities or separately licensed clinics. source ↗
Who may injectAPRNs, RNs and LPNs may perform aesthetic injections within nursing scope and demonstrated competence; injected medications require an authorized prescriber's order. source ↗
Good faith examAuthorized-prescriber evaluation and order required; telehealth statutorily covers evaluating, diagnosing and prescribing source ↗

Michigan

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs require physician delegation, including for prescribing; no fully independent practice authority. source ↗
Physician assistantsPractice agreement with a participating physician (agreement-based rather than supervision) source ↗
Who may own the practiceStrictNon-physicians may not own or control a medical practice; professional entities must be owned by licensed physicians. source ↗
Who may injectCosmetic injections are medical acts; a physician may delegate them to a qualified NP, PA, or RN performing under the delegating licensee's supervision. source ↗
Good faith examNo statutory in-person exam mandate; telehealth prescribing permitted by a prescriber with patient consent source ↗

Minnesota

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority: NPs practice and prescribe independently without a physician collaborative agreement. source ↗
Physician assistantsEstablished practice agreement required; new PAs must complete 2,080 collaborative hours source ↗
Who may own the practiceStrictOnly licensed professionals may own a medical practice; non-profit corporations may employ physicians as a recognised exception. source ↗
Who may injectRNs may inject only pursuant to a licensed provider's order or delegation; NPs and PAs may inject within their own authorised scope. source ↗
Good faith examThe physician-patient relationship may be established via telehealth under the same standard of care source ↗

Mississippi

Reviewed 30 July 2026
Nurse practitionersReducedNPs must maintain a career-long collaborative agreement and protocol with a physician to practice and prescribe. source ↗
Physician assistantsBoard-approved supervising physician with a delegated-services protocol required source ↗
Who may own the practiceMinimalNo broad statutory corporate-practice ban; the medical board looks to physician clinical autonomy rather than entity ownership structure. source ↗
Who may injectRNs and LPNs may not perform neurotoxin or filler injections; physicians, PAs and qualified APRNs may. Lasers require on-premises physician supervision. source ↗
Good faith examAppropriate exam required before diagnosis and treatment; may be non-in-person where telehealth technology is sufficient source ↗

Missouri

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs must practice under a written collaborative practice arrangement with a physician; no independent practice. source ↗
Physician assistantsWritten collaborative practice arrangement; collaborating physician chart review at least every two weeks source ↗
Who may own the practiceMinimalMissouri does not apply a corporate practice of medicine doctrine; corporations have been permitted to employ physicians since 1907 case law. source ↗
Who may injectInjectables are medical acts; RNs may administer only as prescribed or delegated by a licensed prescriber, while NPs and PAs act under their collaborative arrangements. source ↗
Good faith examExam sufficient for diagnosis required; may be via telemedicine where the standard of care allows source ↗

Montana

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority; NPs evaluate, diagnose and prescribe without a physician collaborative agreement. source ↗
Physician assistantsOptimal Team Practice; the collaboration-agreement requirement is waived at 8,000 practice hours source ↗
Who may own the practiceModerateThe statutory ban was repealed in 1995, but board rules still treat partnering with unlicensed persons as unprofessional conduct. source ↗
Who may injectThe Board of Nursing's medical spa FAQ states that RNs and LPNs with appropriate training, education and supervision may inject prescribed medications as part of a medical treatment plan, and may not prescribe treatments or diagnose conditions. The FAQ is guidance, not a rule. source ↗
Good faith examFor telemedicine, physicians and PAs establish a provider-patient relationship before initiating care and take a medical history before treating or prescribing; telemedicine may establish it unless the standard of care requires in person. Board of Nursing FAQ: med spa injectables must be prescribed by a qualified provider. source ↗ source ↗ source ↗

Nebraska

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority; NPs practice and prescribe without a physician collaboration agreement. source ↗
Physician assistantsPhysician supervision with a written scope-of-practice agreement source ↗
Who may own the practiceMinimalNo CPOM doctrine; case law since 1905 lets corporations provide medical services through licensed physicians. source ↗
Who may injectThe Board of Nursing's advisory opinion on aesthetic nursing lets an RN perform Level II and III aesthetic procedures, which include neuromodulator and dermal filler injections, only after a licensed practitioner assesses, diagnoses and prescribes, and only under that practitioner's supervision. The opinion is non-binding. source ↗
Good faith examThe Board of Nursing's advisory opinion requires a licensed practitioner to assess and diagnose the patient and to prescribe or order each episode of care before an RN performs a Level II or III aesthetic procedure; standing orders are not accepted. The opinion is non-binding. source ↗

Nevada

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority; APRNs may evaluate, prescribe and practice without physician supervision. source ↗
Physician assistantsSupervising physician required; the board is notified of the supervisor and the supervised scope source ↗
Who may own the practiceStrictOnly physician-owned professional entities may practice medicine; corporate employment of physicians is barred outside limited statutory exceptions. source ↗
Who may injectPhysicians, PAs, APRNs and trained RNs may inject fillers with a practitioner's order; LPNs may not. Certain filler zones require immediate rather than direct supervision. source ↗
Good faith examRequired: an order per intervention from a practitioner who assessed the patient and established a bona fide relationship source ↗

New Hampshire

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority; NPs practice and prescribe independently without a collaborative agreement. source ↗
Physician assistantsWritten collaboration agreement required below 8,000 post-graduate hours; waiver available after source ↗
Who may own the practiceMinimalNo formal CPOM doctrine; physicians may be employed by corporations or practice through professional corporations. source ↗
Who may injectAs of 26 September 2026, we found no New Hampshire statute or board rule that names who may administer cosmetic injectables; we searched RSA 326-B, 328-D and 329 and the Board of Medicine and Board of Nursing rules. APRNs (within their scope) and PAs may administer drugs; non-binding Board of Nursing advisories say LNAs may not give intradermal Botox and refer the question of a physician on site to the Board of Medicine. source ↗ source ↗ source ↗ source ↗ source ↗ source ↗ source ↗
Good faith examRequired: a physician may not prescribe without a physician-patient relationship that includes an in-person or telemedicine exam, a history, a diagnosis, a treatment plan and drug documentation, with listed exceptions; the APRN-patient relationship is defined the same way. Not specific to cosmetic procedures. source ↗ source ↗ source ↗

New Jersey

Reviewed 30 July 2026
Nurse practitionersReducedA joint protocol with a physician is still required for aesthetics; the 2026 reform exempts only primary and behavioral health. source ↗
Physician assistantsPhysician supervision with a written agreement, set at practice level source ↗
Who may own the practiceStrictOnly physicians may own a medical practice; non-physicians must use an MSO alongside a physician-owned professional corporation. source ↗
Who may injectPhysicians and PAs may perform and delegate injectables; APNs and RNs inject only under a detailed physician-signed protocol. Unlicensed staff are prohibited. source ↗
Good faith examRequired before non-surgical cosmetic treatment, performed by a physician, PA or APN rather than an RN; telehealth acceptability unverified source ↗

New Mexico

Reviewed 30 July 2026
Nurse practitionersFullNPs practice and prescribe independently; no physician supervision or collaborative agreement is required. source ↗
Physician assistantsSupervision agreement required; collaboration permitted for primary-care PAs source ↗
Who may own the practiceMinimalNew Mexico has no corporate practice of medicine doctrine; non-physician entities may own practices and employ physicians. source ↗
Who may injectInjecting cosmetic substances is the practice of medicine and may not be delegated to unlicensed medical assistants; physicians, PAs, NPs and trained RNs may inject. source ↗
Good faith examPhysician must provide history, physical exam and diagnosis before delegated cosmetic device treatment; telehealth acceptability unverified source ↗

New York

Reviewed 30 July 2026
Nurse practitionersFullClassified as full practice by AANP. New York requires a nurse practitioner to practice under written practice protocols and a written practice agreement with a collaborating physician until the NP has completed 3,600 hours of experience; after that, current law removes those requirements. From July 1, 2030, an NP past 3,600 hours may instead keep collaborative relationships with a physician or hospital, attested on a state form. source ↗ source ↗
Physician assistantsContinuous physician supervision required; physical presence is not source ↗
Who may own the practiceStrictOnly licensed physicians may own the professional entity; med spas must be a PC, PLLC, or RLLP. source ↗
Who may injectRNs may inject only under a patient-specific order from a physician, NP or PA; cosmetic injectables are not covered by non-patient-specific standing orders. source ↗
Good faith examRequired: the prescriber must evaluate the patient and issue a patient-specific order; telehealth acceptability unverified source ↗

North Carolina

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs need career-long physician supervision or team management to deliver patient care. source ↗
Physician assistantsWritten supervisory arrangement with a primary supervising physician required source ↗
Who may own the practiceStrictNorth Carolina enforces CPOM relatively vigorously; medical practices must be physician-owned professional corporations or PLLCs. source ↗
Who may injectRNs and LPNs may perform neuromodulator and dermal filler injections when prescribed by a licensed prescriber; LPNs require on-site supervision, RNs do not. source ↗
Good faith examRequired: the prescriber must complete the client evaluation and issue the order; telehealth acceptability unverified source ↗

North Dakota

Reviewed 30 July 2026
Nurse practitionersFullFull practice authority; NPs diagnose and prescribe under nursing board licensure without a physician agreement. source ↗
Physician assistantsOptimal Team Practice: collaboration only; a written agreement is required under 4,000 practice hours source ↗
Who may own the practiceStrictNorth Dakota enforces CPOM by statute; practices must be wholly physician-owned professional entities. source ↗
Who may injectRNs with comprehensive accredited training may inject FDA-approved aesthetic agents as part of a prescriber's treatment plan, but may not select the agent or dose. source ↗
Good faith examRequired: a documented initial assessment of each client by the prescriber; telehealth acceptability unverified source ↗

Ohio

Reviewed 30 July 2026
Nurse practitionersReducedNPs require a career-long collaborative agreement with a physician to practice fully. source ↗
Physician assistantsWritten supervision agreement with a supervising physician required source ↗
Who may own the practiceMinimalOhio does not enforce CPOM; statute permits physicians to practice through corporations and other non-physician-owned entities. source ↗
Who may injectRNs and LPNs may administer cosmetic injectables only under a specific current order from an authorised prescriber; nurses may not prescribe or select the dose. source ↗
Good faith examFor prescribing, a PA works within a valid prescriber-patient relationship that includes a history and physical examination, and an APRN needs a valid prescriber-patient relationship; a physician sees and evaluates the patient before delegating non-ablative vascular laser. No cosmetic-specific exam rule found; telehealth is allowed for an initial visit that meets the standard of care. source ↗ source ↗ source ↗ source ↗

Oklahoma

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs need a written physician supervision statement for prescriptive authority until 6,240 practice hours are verified. source ↗
Physician assistantsDelegating-physician practice agreement on file; independent practice permitted after 6,240 verified postgraduate hours source ↗
Who may own the practiceMinimalOklahoma has no established corporate practice of medicine doctrine, so non-physicians may generally own practices subject to professional-entity rules. source ↗
Who may injectRNs and LPNs may inject neuromodulators and fillers on an individualised prescriber order after a history and physical; standing orders are prohibited. source ↗
Good faith examRequired initial evaluation establishing the practitioner-patient relationship before treatment; may be face-to-face or via telemedicine source ↗

Oregon

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose and prescribe independently under Board of Nursing authority; no physician agreement required. source ↗
Physician assistantsCollaborative practice agreement required rather than supervision; kept at the practice site source ↗
Who may own the practiceStrictOregon enforces CPOM, and 2025 legislation sharply limits MSO control and friendly-PC structures; practices must stay physician-owned. source ↗
Who may injectLicensees must examine the patient first; non-ablative cosmetic treatments may be delegated to trained staff, but ablative laser surgery may not. source ↗
Good faith examRequired: the licensee must examine each patient before initial treatment; telehealth acceptability not addressed by the board source ↗

Pennsylvania

Reviewed 30 July 2026
Nurse practitionersReducedCareer-long written collaborative agreement required, and at least two physicians for prescriptive authority. source ↗
Physician assistantsWritten agreement with a registered primary supervising physician, filed with the State Board of Medicine source ↗
Who may own the practiceStrictPennsylvania recognises the doctrine through case law; lay corporations may not employ physicians or control clinical judgment. source ↗
Who may injectNo board rule specific to injectables; under general rules an RN may administer a drug ordered by a licensed prescriber in the dosage and manner prescribed. source ↗
Good faith examPrescriber evaluation required before treatment; telemedicine only where the standard of care does not require a physical exam source ↗

Rhode Island

Reviewed 30 July 2026
Nurse practitionersFullCNPs diagnose and prescribe independently; only family and adult-gerontology CNPs may work in medical spas. source ↗
Physician assistantsCollaboration with a physician; the supervision requirement was repealed in 2019 source ↗
Who may own the practiceStrictUnlicensed owners need an ambulatory care facility licence, professional service corporations require licensed owners, and owners cannot control medical judgment. source ↗
Who may injectOnly physicians, PAs, and family or adult-gerontology CNPs may inject neuromodulators and dermal fillers; the state guidance chart excludes RNs and LPNs. source ↗
Good faith examRequired: the practitioner must personally take a history and perform a physical exam; standing orders prohibited and telemedicine-only exams discouraged source ↗
Coming changeThe Medical Spas Safety Act (Public Laws 2025, chapters 308 and 309) took effect on 30 June 2025 and is codified at Rhode Island General Laws chapter 23-105. Every medical spa must appoint a medical director, and procedures using ablative lasers or ablative energy devices are limited to physicians, physician assistants and certified nurse practitioners. The Department of Health was directed to adopt implementing rules by 1 July 2026. When we checked on 18 September 2026 we found no medical spa rule in the Rhode Island Code of Regulations or on the Department's rulemaking agenda. source ↗

South Carolina

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs must hold a written practice agreement with a physician to perform delegated medical acts. source ↗
Physician assistantsApproved primary supervising physician plus scope-of-practice guidelines filed with the board before practising source ↗
Who may own the practiceStrictSouth Carolina case law bars corporations from practising medicine, so practices must be owned and clinically controlled by licensed physicians. source ↗
Who may injectCosmetic neuromodulator injection is delegable: PAs per their practice guidelines, APRNs per written protocol, RNs only with on-site physician or APRN supervision. source ↗
Good faith examA bona fide practitioner-patient relationship is required before injection; telemedicine permitted unless an in-person exam is necessary for diagnosis source ↗

South Dakota

Reviewed 30 July 2026
Nurse practitionersFullNPs may evaluate, diagnose, prescribe and practice independently, with no physician collaborative agreement. source ↗
Physician assistantsCollaborative agreement required under 6,000 practice hours; none required once certified with 6,000+ hours filed source ↗
Who may own the practiceModerateSouth Dakota recognises corporate practice limits by statute and board policy; a professional corporation is required and non-physician ownership is limited. source ↗
Who may injectRNs and LPNs may give FDA-approved injectables such as neuromodulators but not dermal fillers, under a prescriber's plan of care; LPNs need direct supervision. source ↗
Good faith examTreatment must sit within a medically prescribed plan of care ordered and supervised by a physician, NP or PA; telehealth acceptability unverified source ↗

Tennessee

Reviewed 30 July 2026
Nurse practitionersRestrictedNPs need a supervising or collaborating physician with joint written protocols and periodic chart review throughout their career. source ↗
Physician assistantsSupervising physician with jointly developed written protocols, availability for consultation, and periodic chart review source ↗
Who may own the practiceStrictMedical practices must be wholly physician-owned; NPs, PAs, RNs and lay investors cannot own one, so MSO structures are used. source ↗
Who may injectPhysicians, NPs and PAs may inject; RNs only under physician delegation with written protocols. For supervisees other than NPs and PAs the board's position statement requires the supervising physician on site at least four hours per week and all charts reviewed and signed within seven days. source ↗
Good faith examRequired: before prescribing or dispensing any drug, the physician (or a licensed supervisee under protocols) or a prescribing APRN performs and documents an appropriate history and physical examination, a diagnosis and a discussed treatment plan, with listed exceptions; physician telemedicine is allowed under Rule 0880-02-.16. source ↗ source ↗

Texas

Reviewed 23 September 2026
Nurse practitionersRestrictedNPs prescribe under a prescriptive authority agreement with a delegating physician. A narrow exception lets physicians at a hospital or licensed long-term care facility delegate prescribing to facility-based NPs through facility-approved orders or protocols. source ↗ source ↗ source ↗
Physician assistantsPAs prescribe under a prescriptive authority agreement with a delegating physician, under adequate physician supervision. The same narrow hospital and long-term care facility exception allows facility-approved orders or protocols instead. source ↗ source ↗
Who may own the practiceStrictLegal guides describe Texas as limiting ownership of a medical practice to physicians. Physicians and PAs may jointly own a professional association or PLLC, but PAs together may hold only a minority interest, no PA may hold as much as any single physician owner, a physician must control and manage the entity, and jointly owned entities report to the medical board each year by April 30. Nonprofit health organizations certified by the medical board are another exception. source ↗ source ↗ source ↗ source ↗ source ↗
Who may injectCosmetic injection is the practice of medicine and may be delegated by a physician to a person with appropriate training. A physician, PA or APRN must be onsite during the procedure or immediately available for emergency consultation, and the physician must be able to conduct an emergency appointment with the patient if necessary. source ↗ source ↗ source ↗
Good faith examRequired: before a delegated cosmetic procedure, a physician, or a PA or APRN acting under a physician's delegation, must establish a practitioner-patient relationship, complete and maintain the medical record, disclose who will perform the procedure and their title, and have a BLS-trained person present. The written order the physician approves or writes must include patient selection criteria. In adopting the rule, the medical board said statute permits that relationship to be established in person or by telemedicine; Occupations Code §111.005 sets the telemedicine conditions. source ↗ source ↗ source ↗ source ↗

Utah

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose and prescribe independently under the nursing board with no physician collaboration agreement required. source ↗
Physician assistantsPractice-level collaboration; a collaborating physician is required for the first 10,000 post-graduate hours source ↗
Who may own the practiceMinimalUtah has no corporate practice of medicine doctrine; non-physicians may own a medical practice, though a professional corporation is typically used. source ↗
Who may injectPhysicians, NPs and PAs may perform or delegate cosmetic medical procedures, with statutory groups of licensees acting under defined supervision levels. source ↗
Good faith examThe supervisor must authorise the procedure for the specific patient. For a nonablative cosmetic medical procedure other than hair removal, a physician, nurse practitioner or physician assistant must develop the treatment plan and evaluate the patient in person or by a live telemedicine visit before a treatment protocol or series begins. source ↗

Vermont

Reviewed 30 July 2026
Nurse practitionersFullAPRNs diagnose and prescribe under the Board of Nursing without an ongoing physician collaboration or supervision agreement. source ↗
Physician assistantsWritten practice agreement with a participating physician, filed with the board source ↗
Who may own the practiceMinimalVermont has no corporate practice of medicine doctrine and permits non-physician ownership; legislation has been proposed to add restrictions. source ↗
Who may injectNo cosmetic-specific board rule located; physicians, APRNs and PAs may inject, while RN and LPN roles fall under general nursing scope and delegation. source ↗
Good faith examA licensed provider may, within the limits of their license, prescribe, dispense or administer drugs after an appropriate examination in person, through live audio-video telemedicine, or through transmitted images and records; for physicians, a questionnaire alone is inadequate for the initial evaluation, with one listed exception. Not specific to cosmetic procedures. source ↗ source ↗ source ↗

Virginia

Reviewed 30 July 2026
Nurse practitionersRestrictedPractice agreement with a patient care team physician required unless the NP attests to three years' clinical experience. source ↗
Physician assistantsPractice agreement with a patient care team physician; waivable after three years via board attestation source ↗
Who may own the practiceModerateProfessional corporation shares must be held by licensed practitioners; the boards publish no aesthetics-specific ownership guidance. source ↗
Who may injectNeuromodulators and fillers are prescription drugs requiring a prescriber's order; RNs and LPNs may administer under that order. No board-specific med spa guidance exists. source ↗
Good faith examRequired: a bona fide practitioner-patient relationship with an appropriate examination; telehealth expressly permitted source ↗

Washington

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose, and prescribe autonomously under exclusive Board of Nursing authority; no collaborative agreement required. source ↗
Physician assistantsCollaboration agreement required with one or more physicians or the PA's employer source ↗
Who may own the practiceStrictProfessional corporation stock may be issued only to licensed individuals, and Washington also recognises an implied corporate practice ban. source ↗
Who may injectA physician must take a history, examine, and diagnose, then may delegate the procedure to a properly trained PA, RN, or LPN. source ↗
Good faith examRequired: physician history, physical exam, diagnosis, treatment recommendation and informed consent before any non-surgical medical cosmetic procedure source ↗

West Virginia

Reviewed 30 July 2026
Nurse practitionersReducedA collaborative agreement with a physician is required for prescriptive practice during the first three years. source ↗
Physician assistantsCollaborating physician required with practice notification filed with the board; PAs may not practice independently source ↗
Who may own the practiceStrictCorporations need a Board of Medicine certificate of authorisation to practice medicine, and shareholders must be licensed physicians or podiatrists. source ↗
Who may injectRNs administer medications and treatments as prescribed by a physician, dentist, or APRN; no aesthetics-specific board rule or position statement exists. source ↗
Good faith examPrescribing without an ongoing provider-patient relationship is unprofessional conduct for physicians and PAs, with listed exceptions; the telehealth rules let physicians, PAs and APRNs establish that relationship in person, by video, or by real-time audio where the standard of care allows, never by questionnaire. source ↗ source ↗ source ↗ source ↗ source ↗

Wisconsin

Reviewed 30 July 2026
Nurse practitionersReducedNPs must maintain a collaborative relationship with a physician; modernisation legislation takes effect in September 2026. source ↗
Physician assistantsWritten collaborative agreement with a physician, or employment evidence that a physician directs the PA's professional activities source ↗
Who may own the practiceModerateService corporation shares may be held by any health care professional; the doctrine rests on licensure and fee-splitting rules rather than a bright-line ban. source ↗
Who may injectA physician may delegate injections to a person the physician directs, supervises and inspects; RNs act on orders or protocols within their competence. source ↗
Good faith examDocumented patient evaluation required; telehealth acceptable, but a static electronic questionnaire alone is insufficient source ↗

Wyoming

Reviewed 30 July 2026
Nurse practitionersFullNPs evaluate, diagnose, and prescribe under exclusive Board of Nursing authority; no collaborative agreement required. source ↗
Physician assistantsOptimal Team Practice: the degree of collaboration is determined at the practice level, with no required supervising physician source ↗
Who may own the practiceModerateAll professional corporation shareholders must be and remain licensed in the profession; no state case law or attorney general opinion located. source ↗
Who may injectTrained, competent RNs may inject neuromodulators and fillers under a prescriber's direction; LPNs may not perform injectable aesthetic procedures; APRNs may order and perform. source ↗
Good faith examRequired: the provider performs a documented history and physical and a client-specific treatment plan; telehealth expressly acceptable source ↗
The whole country

All 50 states at a glance

Nurse practitioner authority as classified by the American Association of Nurse Practitioners; corporate practice posture as we assessed it from the sources on each state's sheet. Select a state name for the full sheet with citations.

StateNP authorityPractice ownershipExam before treatmentPA framework
AlabamaReducedMinimalSee noteBoard-approved registration agreement with a supervising physician
AlaskaFullNot recordedYesWritten collaborative plan with a physician required
ArizonaFullMinimalYesSupervision agreement
ArkansasReducedStrictSee noteBoard-approved delegation agreement with a designated supervising physician
CaliforniaRestrictedStrictYesPractice agreement with a supervising physician (no task-by-task delegation)
ColoradoFullStrictSee noteCollaborative agreement required
ConnecticutFullModerateYesSupervision agreement required: a clearly identified supervising physician providing active, direct supervision
DelawareFullMinimalSee noteCollaborative agreement required, with a statutory independent-practice pathway after 6,000 postgraduate clinical hours
FloridaRestrictedModerateSee noteSupervision required: the supervising physician must be easily available or physically present
GeorgiaRestrictedModerateYesSupervision required: a board-approved job description with a primary supervising physician
HawaiiFullMinimalYesPhysician supervision required
IdahoFullMinimalYesWritten collaborative practice agreement required
IllinoisReducedStrictYesWritten collaborative agreement required
IndianaReducedStrictSee noteWritten collaborative agreement required
IowaFullModerateYesOptimal Team Practice: collaboration determined at the practice level
KansasFullStrictYesSupervision agreement required
KentuckyReducedModerateYesBoard-approved supervision agreement with a supervising physician required
LouisianaReducedModerateYesSupervising physician required
MaineFullMinimalYesPractice agreement required below 4,000 clinical hours
MarylandFullModerateYesCollaboration agreement with a patient care team physician (delegation agreements ended October 2024)
MassachusettsFullStrictYesPhysician supervision agreement required, though on-site physician presence is not
MichiganRestrictedStrictSee notePractice agreement with a participating physician (agreement-based rather than supervision)
MinnesotaFullStrictSee noteEstablished practice agreement required
MississippiReducedMinimalYesBoard-approved supervising physician with a delegated-services protocol required
MissouriRestrictedMinimalYesWritten collaborative practice arrangement
MontanaFullModerateSee noteOptimal Team Practice
NebraskaFullMinimalSee notePhysician supervision with a written scope-of-practice agreement
NevadaFullStrictYesSupervising physician required
New HampshireFullMinimalYesWritten collaboration agreement required below 8,000 post-graduate hours
New JerseyReducedStrictYesPhysician supervision with a written agreement, set at practice level
New MexicoFullMinimalYesSupervision agreement required
New YorkFullStrictYesContinuous physician supervision required
North CarolinaRestrictedStrictYesWritten supervisory arrangement with a primary supervising physician required
North DakotaFullStrictYesOptimal Team Practice: collaboration only
OhioReducedMinimalYesWritten supervision agreement with a supervising physician required
OklahomaRestrictedMinimalYesDelegating-physician practice agreement on file
OregonFullStrictYesCollaborative practice agreement required rather than supervision
PennsylvaniaReducedStrictYesWritten agreement with a registered primary supervising physician, filed with the State Board of Medicine
Rhode IslandFullStrictYesCollaboration with a physician
South CarolinaRestrictedStrictSee noteApproved primary supervising physician plus scope-of-practice guidelines filed with the board before practising
South DakotaFullModerateSee noteCollaborative agreement required under 6,000 practice hours
TennesseeRestrictedStrictYesSupervising physician with jointly developed written protocols, availability for consultation, and periodic chart review
TexasRestrictedStrictSee notePAs prescribe under a prescriptive authority agreement with a delegating physician, under adequate physician supervision. The same narrow hospital and long-term care facility exception allows facility-approved orders or protocols instead
UtahFullMinimalYesPractice-level collaboration
VermontFullMinimalSee noteWritten practice agreement with a participating physician, filed with the board
VirginiaRestrictedModerateYesPractice agreement with a patient care team physician
WashingtonFullStrictYesCollaboration agreement required with one or more physicians or the PA's employer
West VirginiaReducedStrictSee noteCollaborating physician required with practice notification filed with the board
WisconsinReducedModerateYesWritten collaborative agreement with a physician, or employment evidence that a physician directs the PA's professional activities
WyomingFullModerateYesOptimal Team Practice: the degree of collaboration is determined at the practice level, with no required supervising physician
A framed antique map of the United States is lit by a picture light above an oak console.
How to read it

What the three labels mean

Nurse practitioner authority

  • Full: the NP may evaluate, diagnose and prescribe under the exclusive authority of the state board of nursing. 27 states on this map.
  • Reduced: a career-long collaborative agreement with a physician is required for at least one element of practice. 12 states.
  • Restricted: career-long supervision, delegation or team management by a physician is required. 11 states.

For an owner, this is a cost line as much as a legal one: in reduced and restricted states, the collaborating or supervising physician is a recurring expense and a single point of failure the day that physician resigns.

Practice ownership: corporate practice of medicine

  • Strict: a medical practice must be physician-owned; non-physician owners structure around it with an MSO and a professional corporation. 22 states.
  • Moderate: the doctrine exists but is limited, uncodified, or lightly enforced. 12 states.
  • Minimal: no meaningful prohibition on non-physician ownership, though only licensees may deliver medical services. 15 states.

These labels compress a genuinely complicated body of law into one word, and several states are actively changing: a few have recently tightened the rules on management services organizations specifically. Use the label to know how hard the question is, then have a healthcare attorney licensed in that state draft the structure.

Who may inject, and the exam that comes first

These two rows travel together. The pattern in most states is that a practitioner authorised to diagnose (a physician, and depending on the state an NP or PA) must evaluate the patient and issue an order, after which a nurse may administer it. What varies is who may perform that evaluation, whether telehealth satisfies it, whether fillers are treated differently from neuromodulators, and whether the supervising practitioner must be physically present.

Several states have no cosmetic-specific board rule at all. Those rows say so. It is the honest answer, and it is also the useful one: in those states the question goes to the board in writing before you build a staffing model on an assumption.

Method

How this map was built, and what it is not

Each state was researched against primary sources first (state board rules, position statements, statutes and administrative code), falling back to well-known secondary sources where no primary source could be located. The nurse practitioner classifications come from the American Association of Nurse Practitioners. Every line carries its sources, so you can check our work rather than take our word.

Where a field could not be confirmed, it says so. We did not infer a rule from a neighbouring state, and we did not repeat a claim we could not trace to a source. Those gaps are real gaps in published guidance, and they are worth knowing about: a state with no cosmetic-specific rule is a state where the answer comes from a board opinion letter, not from a blog.

This is not legal advice and it is not a substitute for the boards. It is a starting point built by operators who place medical directors and pharmacy relationships for clinics, so that the first conversation with your attorney starts from the right question. If a row is wrong or has gone stale, tell us at justin@eventideaw.com and we will correct it and note the date.

Cite it freely. Associations, educators and journalists are welcome to quote or link any row with attribution to this page.

Download

Take the data: med-spa-compliance-v1

The whole map as a file, so you can check it, chart it, or cite a row without scraping this page. 50 states, 21 columns, every rule paired with its sources.

CSV68 KB, one row per state JSON120 KB, with the field dictionary and methodology

Version 1.0.6Full review 30 July 2026; cells re-verified since then carry their own date, most recently 26 September 2026 Coverage 50 statesRules with no source 0Rules with no government source 84 of 252 populated rule cells (300 schema slots)

The version in the filename is the schema's. med-spa-compliance-v1 freezes the columns and the identifiers: if a column is added, renamed or removed, that is a v2 at a new URL and this file stays where it is. Corrections to a row's content ship in place, move the third number, and are logged below with the date, so a citation can name the revision it read. This is v1.0.6, revised 2026-09-26.

The ownership column is the weakest in the file. 27 of 50 ownership_source values point at commercial compliance guides rather than a statute or a board document, because several states have no primary CPOM instrument to cite: the doctrine is built from case law and board opinion. Treat that column as a pointer for your attorney, not as a citation. Separately: North Carolina and North Dakota have boards that do not use .gov domains, so a missing .gov there is not a missing primary source.

No rule in the file ships without a source. A rule we could not confirm would ship with an empty _source value and the rule text intact, rather than being dropped to make the file look complete; since v1.0.5 there are none.

How to cite: Eventide Aesthetics & Wellness, US State Med Spa Compliance Map, v1.0.6 (revised 2026-09-26), full review 30 July 2026; cells re-verified since then carry their own date, most recently 26 September 2026. eventideaw.com/tools/state-compliance-map

Licence: CC BY 4.0. Reuse it, republish it, chart it, build on it commercially: the one condition is attribution in the form above. The page already invited quotation with attribution; this makes that a licence rather than a promise, so an association or a journalist can redistribute the file without asking. Note what the licence does NOT do: it grants rights in this compilation, and it makes no warranty that any row is current or correct. The rules themselves are public records and the limits in the methodology still apply.

What each column means

state
Full state name as published by the state. The join key for the other two artefacts on this site: it matches the sheet on the compliance map and the state on the coverage page.
state_code
Two-letter USPS abbreviation, uppercase. Provided so the file joins to census, licensure and claims datasets without a lookup.
np_authority
Nurse practitioner practice authority as classified by the American Association of Nurse Practitioners: Full, Reduced or Restricted. Empty where the map records no classification.
np_rule
What the state requires of nurse practitioners, as summarised from the cited source.
np_source
URL of the document the np_rule summarises. Empty means unconfirmed.
pa_rule
What the state requires of physician assistants.
pa_source
URL for pa_rule. Empty means unconfirmed.
ownership_posture
Corporate-practice-of-medicine posture as assessed from the cited source: Strict, Moderate, Minimal or similar. Empty where the map records no classification.
ownership_rule
Who may own the practice, and under what structure.
ownership_source
URL for ownership_rule. Empty means unconfirmed.
injection_rule
Who may perform cosmetic injections, and under what supervision or delegation.
injection_source
URL for injection_rule. Empty means unconfirmed.
good_faith_exam_rule
Whether an examination must precede treatment, who may perform it, and whether telehealth is accepted.
good_faith_exam_source
URL for good_faith_exam_rule. Empty means unconfirmed.
coming_change_rule
A pending statute or rule change the map has recorded. Empty where none is recorded.
coming_change_source
URL for coming_change_rule. Empty means unconfirmed or none.
medical_board_url
Home page of the state medical board: the body that decides delegation and good-faith-exam questions. This is where an unconfirmed row should be taken.
nursing_board_url
Home page of the state board of nursing: the body that decides what an RN or APRN may perform, which is often the binding constraint on a med spa staffing model.
reviewed
The date of this state's full review against its sources. Cells verified later carry their own date on the map.
map_url
The state's sheet on the compliance map.
coverage_page_url
Eventide's medical-director coverage page for the state.

Change log

  • v1.0.6 (2026-09-26): Nine rule cells in five states re-read against their primary texts after the Codex re-audit of 26 September 2026, and the documentation. Texas: ownership_rule now says legal guides describe Texas as limiting ownership of a medical practice to physicians, that physicians and PAs may jointly own a professional association or PLLC with the PAs together holding only a minority interest and a physician controlling and managing the entity (Texas Business Organizations Code section 301.012 and 22 TAC 174.5), that jointly owned entities report to the medical board each year by April 30, and that nonprofit health organizations certified by the medical board are another exception (the unsourced "MSO structures are standard" is gone); good_faith_exam_rule now says the written order the physician approves or writes must include patient selection criteria (22 TAC 169.27), and that in adopting the rule the medical board said statute permits the relationship to be established in person or by telemedicine, with Occupations Code section 111.005 setting the telemedicine conditions, where it used to say telehealth acceptability was unverified; np_rule and pa_rule now say NPs and PAs prescribe under a prescriptive authority agreement with a delegating physician, with the narrow hospital and long-term care facility exception of Occupations Code section 157.054. Alabama: good_faith_exam_rule now states the medical board's telehealth conditions in full: how the relationship must be established, and all three conditions for prescribing a controlled substance by telehealth, including an established legitimate medical purpose. New York: np_rule now says that after 3,600 hours current law removes the written practice agreement and protocol requirements, and that from 1 July 2030 an NP past 3,600 hours may instead keep collaborative relationships with a physician or hospital, attested on a state form (Education Law section 6902(3)(b)); the 1.0.3 entry below described that later text as the current duty. Florida: good_faith_exam_rule now says the telehealth statute lets a provider perform a patient evaluation by telehealth without a physical exam first, and that we found no Florida statute or board rule setting a separate exam requirement for cosmetic procedures; ownership_rule now says that as of 26 September 2026 we found no Florida statute limiting practice ownership to physicians, when a Health Care Clinic license is needed, that the practitioner-owned exemption covers only the license classes the statute lists with a licensed owner supervising the business and legally responsible for its compliance, and that a licensed clinic must appoint a medical director or clinic director who accepts legal responsibility in writing. New Hampshire: injection_rule now says when we searched and which statutes and board rules we searched for a rule naming who may administer cosmetic injectables, and the row links RSA 329 and both boards' rule sets beside its earlier sources. The added sources are linked on the map and the state pages; each changed cell's first source, the one its _source column carries, is unchanged, and so are np_authority and ownership_posture. On the map, Florida's exam column now reads See note, and the count of states whose rule names an examination moves from 36 to 35. The methodology now says each row was read from the documents linked in its sources and summarized, that most sources are state statutes, rules and board pages while some ownership rows rely on published legal guides, and that classifications and dated search results are our assessments; in 1.0.5 the known_gaps field rows_without_a_primary_source was 0 and counted rule cells with no source at all; 1.0.6 publishes that count as rows_without_a_source, which stays 0, and adds the field rows_without_a_government_source: 84 of 252 populated rule cells (300 schema slots) none of whose sources is a government document; it also says that each _source column holds the row's first source, and that the full list of sources for every row is on the compliance map and on the state's coverage page; the field dictionary now describes reviewed as the date of the state's full review against its sources, with cells verified later carrying their own date on the map; and the download block says every rule is paired with its sources, gives the full review date beside the latest cell verification and counts the rules with no government source. The map's Dataset structured data now states the same methodology as its measurementTechnique. The changed cells carry their own verified date, 2026-09-26; no state's review date, column or identifier moves, so this is still med-spa-compliance-v1 at the same URL, and the revision number moves to 1.0.6.
  • v1.0.5 (2026-09-23): Seven rule cells that carried no source were read against their primary texts, reworded to what those texts say and cited, so the rows with no source move from 7 to 0. Ohio's good_faith_exam_rule now states the prescriber-patient relationship a PA prescribes within, which includes a history and physical examination (Ohio Administrative Code 4730-2-07), the one an APRN needs (4723-9-10), and the physician evaluation before delegating non-ablative vascular laser (4731-18-03); it says no cosmetic-specific exam rule was found, and that telehealth is allowed for an initial visit that meets the standard of care (Ohio Revised Code 4743.09). Tennessee's good_faith_exam_rule now states the history and physical examination, diagnosis and treatment plan required before prescribing or dispensing, with listed exceptions, in the Board of Medical Examiners' rules (chapter 0880-02) and the Board of Nursing's APRN rules (chapter 1000-04), and physician telemedicine under Rule 0880-02-.16. New Hampshire's good_faith_exam_rule now states the physician-patient relationship required before prescribing, with its exam, history, diagnosis, treatment plan and drug documentation (RSA 329:1-c), the APRN-patient relationship defined the same way (RSA 326-B:2), and RSA 329:1-d. New Hampshire's injection_rule now says no New Hampshire statute or rule names who may administer cosmetic injectables, cites the APRN and PA statutes under which both may administer drugs (RSA 326-B:11 and RSA 328-D:3-b), and says what the Board of Nursing's non-binding scope advisories say. Vermont's good_faith_exam_rule now states that a licensed provider may, within the limits of their license, prescribe after an appropriate examination in person, by live audio-video telemedicine or through transmitted images and records, and that a questionnaire alone is inadequate for a physician's initial evaluation, with one listed exception (Vermont Statutes Title 18 section 9361, Title 26 section 1354 and Title 8 section 4098a). West Virginia's good_faith_exam_rule now states that prescribing without an ongoing provider-patient relationship is unprofessional conduct for physicians and PAs, and how the telehealth rules let physicians, PAs and APRNs establish that relationship where the standard of care allows (the West Virginia Code of State Rules, including the Board of Medicine's final 2023 licensing and discipline rule (11 CSR 1A), and West Virginia Code 30-3-13a). Montana's good_faith_exam_rule now states the telemedicine relationship and history rule for physicians and PAs (Administrative Rules of Montana 24.156.813), the Board of Nursing's medical spa FAQ, and Montana Code 37-2-305. Separately, the good_faith_exam_rule cells of Alabama, Minnesota and Arkansas drop a leading "Required" that the rest of each cell does not support (they describe a relationship or a prescription, not a required examination); no other word moves. Each cell's first source fills its _source column; the others are linked on the map and the state page. The changed cells carry their own verified date, 2026-09-23; no state's review date, column, identifier or classification moves.
  • v1.0.4 (2026-09-23): Texas only: five rule cells re-read against the Texas statutes and the Texas Medical Board's rules in Title 22 of the Texas Administrative Code, chapter 169, and Texas's review date. Texas's good_faith_exam_rule said a physician, PA or APRN must establish the practitioner-patient relationship and order treatment before delegation, and cited the board's home page; it now says what 22 TAC 169.26(c) requires before a delegated cosmetic procedure, that a physician, or a PA or APRN acting under a physician's delegation, establish a practitioner-patient relationship, complete and maintain the medical record, disclose who will perform the procedure and their title, and have a person trained in basic life support present, and what section 169.27 adds, that the written order the physician approves or writes sets patient selection criteria. good_faith_exam_source cites section 169.26, with section 169.27 linked beside it on the map and the state page. Telehealth acceptability is still unverified and the cell still says so. Texas's np_rule no longer says NPs prescribe "only" through a prescriptive authority agreement, because the statute it cites does not say only; np_source is still the AANP state resource sheet, which supports the Restricted classification and the no-independent-practice fact, and Texas Occupations Code section 157.0512, the delegation of prescribing through a prescriptive authority agreement, is linked beside it on the map and the state page. Texas's pa_rule now reads "PAs prescribe through a physician-delegated, signed prescriptive authority agreement, under physician supervision", which is what section 157.0512 governs, and pa_source moves from the board's home page to section 157.0512. Texas's delegation rule keeps its wording and its first source, the board's medical spa page, and the map and the state page now also link 22 TAC 169.25, which makes nonsurgical medical cosmetic procedures including cosmetic injection the practice of medicine that may be delegated and supervised, and 169.26, the onsite-or-available duty. Texas's ownership rule is respelled organizations (it read organisations); its ownership_source is still the secondary compliance guide, because the physician-only ownership rule is still carried on that guide's reading and section 162.001 speaks only to the exception, and the map and the state page now also link Texas Occupations Code section 162.001, under which the board certifies the non-profit health organizations the rule names as its exception. Texas's reviewed date moves from 30 July 2026 to 23 September 2026, the day its rows were re-read, as the review line on the Texas sheet shows; every other state's review date is unchanged, and the map's answer on how current it is now says that rows re-verified since 30 July carry their own date in this change log. No column, identifier, classification or board URL changed, and the count of rule cells with no primary source is still 7, so this is still med-spa-compliance-v1 at the same URL; the bytes at that URL did change, so the revision number moves to 1.0.4. The compliance map and the Texas coverage page were regenerated in the same commit, so the page and the file still state each rule identically.
  • v1.0.3 (2026-09-19): Eleven rule cells reworded or resourced against their primary documents, and the count of rule cells with no primary source moves from 10 to 7. New York's nurse practitioner rule said NPs may prescribe without a collaborative agreement; the Education Department's practice-requirements page says an NP practises under written practice protocols and a written practice agreement with a collaborating physician until 3,600 hours of experience are completed, and documents collaborative relationships after that, so the rule now says both and the source moves from the AANP classification page to the New York State Education Department. The AANP classification itself is unchanged and is still what np_authority records. California's ownership rule said non-physicians may not own a medical practice and cited SB 351; the Medical Board's own medical spa guidance states the ownership split directly, so the rule now states it as the board does, a majority of the stock held by California-licensed physicians, no more than 49 per cent held by other licensed health care professionals and no lay ownership at all, and the source moves to that guidance document. The SB 351 attribution is removed because it was not verified. Alabama's exam rule now carries the medical board's telehealth conditions in full, including the originating-site alternative it omitted, and Alabama's delegation rule stops saying only CRNPs and PAs may inject: the board notice governs DELEGATION under an approved protocol and says nothing about a physician injecting personally. Texas's delegation rule now states what the medical board states, that cosmetic injection is the practice of medicine and may be delegated to a person with appropriate training, with the onsite-or-available condition and the emergency-appointment duty, and the source moves from the board's home page to the board's own medical spa page. Tennessee's delegation rule now names the figures in the board position statement, four hours on site a week and charts signed within seven days, and says they apply to supervisees other than NPs and PAs. Utah's exam rule said an in-person evaluation is expressly required before tattoo removal; the statute says no such thing. It requires, for a nonablative cosmetic medical procedure other than hair removal, that a physician, nurse practitioner or physician assistant develop the treatment plan and evaluate the patient in person or by live telemedicine before a protocol or series begins, and that is what the rule now says. Both Utah rows move off a republished secondary copy of section 58-1-506 and onto the statute on the legislature's own site; no other Utah row was repointed, and the physician assistant row still cites section 58-70a-307. Three rows that carried no source now carry one. Montana's delegation rule is the Board of Nursing's medical spa FAQ, which lets RNs and LPNs with appropriate training, education and supervision inject prescribed medications as part of a medical treatment plan and bars them from prescribing or diagnosing; the FAQ is guidance, not a rule, and the cell says so. Nebraska's delegation and exam rules are both the Board of Nursing's aesthetic nursing advisory opinion, which lets an RN perform Level II and III procedures only after a licensed practitioner assesses, diagnoses and prescribes, and does not accept standing orders; the opinion is non-binding, and both cells say so. Montana's exam row and both New Hampshire rows are still unsourced and are unchanged. No column, identifier, classification, board URL or per-state review date changed, so this is still med-spa-compliance-v1 at the same URL; the bytes at that URL did change, so the revision number moves to 1.0.3. The eleven corrected rows, and the two corrected on 18 September, now carry their own verification date in the store, and the state pages say that a corrected row is dated here rather than at the 30 July review. The compliance map and all fifty state coverage pages were regenerated in the same commit, so the page and the file still state each rule identically. The Codex re-audit of the same day narrowed two of these readings before publication: California's rule names California-licensed physicians, as the Medical Board's guidance does, and Nebraska's two rows use the advisory opinion's own term, a licensed practitioner, because no definition of that term as a nurse practitioner or physician was verified. The revision number does not move again, because 1.0.3 has not been published.
  • v1.0.2 (2026-09-19): Two coming_change_rule cells reworded against the primary text, and their coming_change_source cells filled. Indiana's row was checked against Senate Enrolled Act 282 of 2026 (Public Law 136-2026), which adds Indiana Code 25-22.5-12.5 effective 1 July 2026: the claim that this was the first state med-spa registration statute is removed, because neither the act nor the bill record says so; "registration opens around October 2026" is corrected to the statutory duty, which is that the board shall establish a registration procedure not later than October 1, 2026 (Sec. 3(b)); registration is required to do business from January 1, 2027 (Sec. 3(a)); the responsible practitioner duty is stated as the act states it, on a registered medical spa, and with both qualifications the act requires, prescriptive authority and education and training in the services, treatments and medications concerned (Sec. 5(a)); the notice to the board is due not later than fifteen days after the occurrence of a patient's serious adverse event (Sec. 6(b)); and the exemptions cover a physician's office and a facility or practice otherwise licensed by the state (Sec. 1(b)). The source now filed in coming_change_source, and linked from Indiana's row on the map, is the enrolled act itself on iga.in.gov. Rhode Island's row was checked against Public Laws 2025 chapters 308 and 309, codified at Rhode Island General Laws chapter 23-105: the act took effect upon passage on 30 June 2025, the medical director requirement is 23-105-2(a), the ablative device restriction is 23-105-2(f), and the rulemaking deadline in 23-105-3 is a specific date, 1 July 2026, that has passed, so "implementing regulations due in 2026, re-check this row once those land" is replaced by what we found when we checked on 18 September 2026, which was no medical spa rule in the Rhode Island Code of Regulations or on the Department's rulemaking agenda. That last sentence is our own dated observation of the public listings on that date and is not something the statute says; the searches behind it are recorded in ledger row F-14. The source now filed in coming_change_source, and linked from Rhode Island's row on the map, is chapter 23-105 itself on webserver.rilegislature.gov. The count of rule cells with no primary source moves from 12 to 10. No column, identifier, classification, board URL, review date or other cell changed, so this is still med-spa-compliance-v1 at the same URL; the bytes at that URL did change, so the revision number moves to 1.0.2. The compliance map and both state coverage pages were regenerated in the same commit, so the page and the file still state each rule identically.
  • v1.0.1 (2026-09-10): Punctuation only, across 26 rule cells in 20 states. Where a rule opened with a label and an em dash before its detail, the em dash is a colon: "Required: provider must perform and document an initial history and physical evaluation". Rhode Island's pending-change row became two sentences. No rule, classification, source, board URL, review date or column changed, and no cell gained or lost a word. The columns and the identifiers are what v1 freezes and neither moved, so this is still med-spa-compliance-v1 at the same URL; the bytes at that URL did change, so the revision number moves to 1.0.1 and a citation can say which revision it read. The compliance map was retyped in the same commit, so the page and the file still state each rule identically. The field dictionary's two board_url descriptions, the methodology note, the ownership gap note and the attribution string were repunctuated the same way.
  • v1.0.0 (2026-09-01): Montana ownership_source repointed from the rules.mt.gov gateway deep link (now a 301 to a search page) to the search URL it resolves to. Rule text and classification unchanged; no column added, renamed or removed, so this stays 1.0.0.
  • v1.0.0 (2026-08-08): Licence set to CC BY 4.0 (was a pointer to the site terms, which is not a data licence). Data unchanged: no column added, renamed or removed, so this stays v1.0.0. Known gaps expanded to name the ownership column's reliance on secondary sources and to record that two states' boards are not on .gov domains.
  • v1.0.0 (2026-08-08): First published release. 50 states; 21 columns; nurse practitioner authority, physician assistant framework, corporate-practice-of-medicine posture, cosmetic injection delegation, good-faith-examination requirement, pending changes, both board URLs, and a primary source per rule. Content as verified 30 July 2026.
Common questions

Answers before you even ask

Which states allow a non-physician to own a med spa?

It turns on the corporate practice of medicine doctrine, which each state applies with different force. In strict states a medical practice must be owned by licensed physicians, and non-physician owners typically operate through a management services organization alongside a physician-owned professional corporation. In minimal states non-physicians may generally own the entity, though only licensees may deliver medical services. This map records each state's posture and links the source; the structure itself should be drafted by a healthcare attorney licensed there.

Can a registered nurse inject Botox or dermal filler?

In most states an RN may administer cosmetic injectables under an order from a prescriber who has evaluated the patient, but the details vary sharply. Some states exclude fillers while allowing neuromodulators, some require the physician on site, some exclude RNs entirely, and several have no cosmetic-specific board rule at all. Check the row for your state, and treat the absence of a rule as a reason to ask the board rather than as permission.

What is a good faith exam and does my state require one?

It is the evaluation that establishes the treatment plan before a patient is treated, performed by a practitioner authorised to do it. Most states require it in some form, whether through a med spa rule, a delegation rule, or the general prohibition on prescribing without a bona fide practitioner-patient relationship. Whether telehealth satisfies it is the question that varies most. Where we could not find a published rule, this map says so rather than guessing.

What do full, reduced and restricted practice mean for nurse practitioners?

They are the American Association of Nurse Practitioners classifications. Full practice means the NP may evaluate, diagnose and prescribe under the exclusive authority of the state board of nursing. Reduced practice means a career-long collaborative agreement or similar arrangement with a physician is required for at least one element of practice. Restricted practice means career-long supervision, delegation or team management by a physician is required.

How current is this map?

Every row was reviewed on 30 July 2026 against the sources linked in that row, and rows re-verified since then carry their own date in the change log below. State rules change, sometimes mid-year and sometimes through board guidance rather than statute, so treat this as a starting point for a conversation with the boards and your attorney rather than as a legal opinion. If you find a row that has gone stale, email justin@eventideaw.com and we will correct it.

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Educational reference for licensed medical providers and practice owners. This map is a plain-language summary compiled from the sources linked on each line and reviewed on 30 July 2026. It is not legal advice, it is not exhaustive, and it does not create any professional relationship. Requirements vary by state, license type, procedure, and practice structure, and they change, sometimes through board guidance rather than statute. Verify every requirement with the applicable state boards and a healthcare attorney licensed in that state before acting. Eventide is not a law firm and is not a medical practice.