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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 18 October 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 34 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 18 October 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 practiceMinimalIn October 1992 the Board of Medical Examiners and the Medical Licensure Commission each ruled that a business corporation is not engaged in the unlicensed practice of medicine solely by employing a licensed physician who keeps final authority over medical decisions. source ↗
Who may injectThe medical board allows cosmetic botulinum toxin injection by a PA or CRNP only under a collaboration or registration agreement and the approved protocol, and has not authorized delegation to RNs. The board's protocol, revised in April 2026, requires a qualified collaborating, supervising or covering physician to stay on site at all times while the PA or CRNP injects, and allows injections only in a medical setting, never in a private residence or event venue. The notice and protocol govern delegation and do not address a physician injecting personally. source ↗ 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 18 October 2026
Nurse practitionersFullNPs practice and prescribe independently under the Board of Nursing; no physician collaboration or supervision agreement required. source ↗
Physician assistantsSince 16 September 2026 (SB 89, chapter 21 SLA 26), a PA practices under a written collaborative agreement with a physician licensed in Alaska, who need not be located in the state, unless the PA works at a facility directed by a physician, osteopath or podiatrist, a health care facility licensed by the Department of Health, a federal or tribal facility, a federally qualified health center or rural health clinic, or a military or veterans' facility, or the medical board approves a facility-specific exemption. One collaborating physician is enough. source ↗ source ↗
Who may own the practiceWe found no Alaska statute or board rule that expressly prohibits the corporate practice of medicine. Under Alaska's Professional Corporations Act, a professional corporation may issue shares only to persons licensed to render its professional service. source ↗
Who may injectRNs and LPNs may perform cosmetic injections only on a provider's order and under the supervision of a trained physician, APRN or PA who has assessed the patient, set a treatment plan and is available in person or electronically during the procedure. They may not inject independently or treat patients under 18. APRNs, who practice independently in Alaska, may be the supervising provider. source ↗
Good faith examRequired: provider must perform and document an initial history and physical evaluation; telehealth is expressly acceptable source ↗

Arizona

Reviewed 18 October 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 practiceMinimalAs of 18 October 2026 we found no Arizona statute that bars non-physician ownership of a medical practice, and legal guides describe Arizona as among the more permissive states. source ↗
Who may injectRNs may inject neuromodulators and fillers, which the Board of Nursing classes as Level III procedures, only on an order from a specifically trained licensed independent practitioner, with written informed consent and under that practitioner's supervision. The practitioner must be licensed in Arizona, reachable by telecommunication and able to assess the patient within a medically reasonable time. source ↗
Good faith examRequired before Level II/III aesthetic procedures by a qualified licensed provider; telemedicine allowed for the initial exam source ↗

Arkansas

Reviewed 18 October 2026
Nurse practitionersReducedAPRNs prescribe under a collaborative practice agreement with a physician. A certified nurse practitioner or clinical nurse specialist with at least 6,240 hours under such an agreement may apply to the Full Independent Practice Credentialing Committee for authority to prescribe without one. source ↗ source ↗ 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 18 October 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 18 October 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 practiceStrictA professional service corporation for the practice of medicine must be majority owned by Colorado-licensed physicians; licensed physician assistants may hold minority shares, and lay directors and officers may not exercise authority over independent medical judgment. 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 examWhen a physician delegates medical services, including injections, to unlicensed personnel under Medical Board Rule 1.17, the services must be given within an appropriate physician-patient relationship, shown by factors such as the physician's initial consultation with the patient and review of the delegatee's care. The delegating physician must be physically present in Colorado and may use telehealth for consultation and follow-up but should not rely on it alone. source ↗

Connecticut

Reviewed 18 October 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 18 October 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 practiceMinimalAs of 18 October 2026 we found no Delaware statute or board rule that bars lay ownership of a medical practice. A professional corporation may issue stock only to individuals licensed to render the same professional service (Delaware Code title 8, section 610). source ↗
Who may injectAs of 18 October 2026 we found no Delaware statute or board rule that names cosmetic injectables. Physicians, APRNs and PAs act within their own licenses. Under the medical board's delegation rule a physician who delegates to a non-physician stays responsible and must supervise, and the physician must be on the premises when a medical diagnosis is made or a treatment plan involving prescription medications is begun. source ↗
Good faith examA provider-patient relationship is required before treatment and may be established by telehealth source ↗

Florida

Reviewed 18 October 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 may inject; PAs inject as their supervising physician delegates, and APRNs within their protocol. No Florida statute or board rule addresses cosmetic injections by RNs; the Board of Nursing has addressed them only in declaratory statements issued to individual nurses, each specific to the nurse who asked. source ↗ source ↗ 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 18 October 2026 we found no Florida statute or board rule written for cosmetic injectables that sets a separate exam requirement. For office surgery, which the Board of Medicine's rule defines to include elective cosmetic procedures and the use of lasers, the surgeon must examine the patient immediately before the surgery. source ↗ source ↗

Georgia

Reviewed 18 October 2026
Nurse practitionersRestrictedNPs work under a nurse protocol agreement with a delegating physician, which the physician files with the medical board. The delegating physician must observe the NP's practice on site at least once a year and review records quarterly, and since 25 May 2026 a physician may hold protocols or job descriptions for no more than the combined equivalent of eight APRNs or PAs at one time. Georgia law bars a physician from being the employee of an APRN the physician must supervise, outside listed practice settings, and in a 7 May 2026 position statement the medical board said it reads this to cover any compensation from the APRN or an APRN-owned company for serving as delegating physician, including payment routed through a matching or staffing company. On 4 June 2026 the board said it is not terminating active protocols and will closely examine the physician and APRN relationship when it approves protocols. source ↗ source ↗ source ↗ source ↗
Physician assistantsSupervision required: a board-approved job description with a primary supervising physician. Since 25 May 2026 a physician may supervise no more than the combined equivalent of eight APRNs or PAs at one time, and a physician may not be the employee of a PA the physician supervises unless the board approved the arrangement before 1 July 2009. source ↗ source ↗ source ↗
Who may own the practiceModerateProfessional corporation shares may be issued only to people licensed in the corporation's profession (O.C.G.A. 14-7-5). Georgia law also bars a physician from being the employee of an APRN or PA the physician must supervise, outside listed exceptions, and the medical board's 7 May 2026 position statement reads this to reach compensation from an APRN-owned company. source ↗ 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 18 October 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 practiceMinimalAs of 18 October 2026 we found no Hawaii statute or court decision that bars lay ownership of a medical practice. Ownership is limited indirectly, because professional corporation shares may be issued only to individuals licensed to render the corporation's professional service. 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 18 October 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. Medical personnel may use only non-incisive, non-ablative products, and a physician may supervise no more than three of them at once without board approval. In non-binding guidance adopted 13 March 2026, Idaho's boards of medicine, nursing, pharmacy, dentistry, and barber and cosmetology services list neurotoxins, fillers and IV hydration as lifestyle injectables, expect prescribers to evaluate each patient, and note that Idaho's practice acts speak of supervising providers rather than medical directors. source ↗ source ↗
Good faith examWhen medical personnel perform cosmetic treatments or give parenteral admixtures, the supervising physician must document an evaluation, assessment and plan before the initial treatment. Idaho's virtual care law lets a provider establish the provider-patient relationship by virtual care if the community standard of care is met, and treatment based solely on a static online questionnaire is not an acceptable standard of care. source ↗ source ↗ source ↗

Illinois

Reviewed 18 October 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 practiceStrictUnder the state's medspa memo, a medspa must be owned and operated by physicians, or by APRNs for some services, and only physicians or APRNs may be its shareholders or members, officers, directors or managers, with limited exceptions. 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 the physician examines the patient before laser treatment, except that since 1 January 2025 a non-ablative laser hair removal procedure may follow an APRN's examination when the facility follows a physician delegation protocol, a trained RN or LPN performs it on a physician's delegation and a physician is available by phone or other electronic means. We found no med-spa-specific telehealth guidance. source ↗ source ↗

Indiana

Reviewed 18 October 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 practiceStrictLegal guides describe Indiana as a corporate practice of medicine state, reading the Medical Practice Act's definition of the practice of medicine, which includes maintaining a place to examine or treat patients, as limiting who may own a medical practice; we found no Indiana court decision applying it. The 2026 medical spa act requires registration and a responsible practitioner and does not address ownership. source ↗ source ↗
Who may injectPhysicians, APRNs with prescriptive authority and PAs with delegated prescriptive authority may prescribe injectables, and only they may serve as a medical spa's responsible practitioner under the 2026 medical spa act. Under the nursing act an RN executes medical regimens delegated by a physician. source ↗ 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. On 30 September 2026 the board announced that registration opens on 1 January 2027, through Apply for a New License under Online Services on the Professional Licensing Agency home page. 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 ↗ source ↗

Iowa

Reviewed 18 October 2026
Nurse practitionersFullARNPs evaluate, diagnose and prescribe independently under board of nursing authority; no physician agreement required. source ↗
Physician assistantsCollaboration is set at the practice level and no supervisory agreement is required, except that a physician associate in independent practice (their own professional corporation or PLLC) must be supervised by a physician for the first two years unless they already have two years of supervised or collaborative practice. source ↗
Who may own the practiceModerateProfessional corporation shares may be issued only to licensees of the professions the corporation practices (physicians and physician associates may practice together in one). The medical board says non-physicians may own med spas, as long as every service is supervised by a physician or another licensed provider working within their scope. source ↗ source ↗
Who may injectAt a medical spa, botulinum toxin, fillers and other injectables are medical aesthetic services. A nonphysician licensee may perform them only when a medical director delegates and supervises them, including at least four hours a week of in-person, on-site supervision. The rule does not prevent a qualified nonphysician licensed health professional from serving as the 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 18 October 2026
Nurse practitionersFullNPs evaluate, diagnose, and prescribe under board of nursing authority; no physician collaborative agreement required. source ↗
Physician assistantsSupervision under a written agreement is required. From 1 January 2027 (House Bill 2702 of 2026), a PA who attests to 4,000 or more hours of postgraduate clinical experience and has no board discipline may practice in collaboration with a physician under a practice agreement kept at the practice site; PAs below 4,000 hours stay under supervision. source ↗ 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 injectWe found no Kansas board rule specific to cosmetic injections. Under the Nurse Practice Act a registered nurse carries out the medical regimen a physician prescribes, so a prescriber evaluates the patient and orders treatment, and an RN may then carry out that patient-specific order. source ↗
Good faith examThe healing arts and pharmacy boards' 2026 joint statement on IV therapy, which they say is not a binding legal document, says the prescriber must personally evaluate and diagnose each patient before ordering treatment and that non-patient-specific standing orders are not valid prescriptions. Under the Kansas Telemedicine Act, telemedicine may be used to establish a valid provider-patient relationship. source ↗ source ↗
Coming changeHouse Bill 2702 of 2026, signed by the governor, takes effect on 1 January 2027 and lets a PA who attests to 4,000 or more hours of postgraduate clinical experience, with no board discipline, practice in collaboration with a physician or physician group under a practice agreement; a PA with fewer than 4,000 hours stays under physician supervision. source ↗ source ↗

Kentucky

Reviewed 18 October 2026
Nurse practitionersReducedAPRNs prescribe under two written collaborative agreements with a physician: one for non-scheduled drugs (CAPA-NS) and one for controlled substances (CAPA-CS). After four years of prescribing, an APRN in good standing may drop the CAPA-NS by notifying the nursing board, and may stop using a CAPA-CS once the board reviews the license and confirms in writing that it is no longer required. AANP still classifies Kentucky as Reduced because of career-long limits on NP prescribing of controlled substances. source ↗ source ↗
Physician assistantsBoard-approved supervision agreement with a supervising physician required source ↗
Who may own the practiceModerateProfessional service corporations may be formed and owned only by individuals licensed to render the same or related professional services. We found no current medical board opinion on lay ownership; the board's published list of opinions does not include one. source ↗ source ↗ source ↗
Who may injectAPRNs may inject within their role and population focus. The nursing board's June 2026 revision says nurses may not perform Botox or fillers independently; its chart lets RNs administer neuromodulators and fillers under a qualified provider's supervision, and LPNs administer neuromodulators only under direct supervision, with no fillers. source ↗
Good faith examThe medical board's opinion, which it says does not itself have the force of law, treats a documented medical evaluation and relevant history before treating or prescribing as acceptable practice; treatment based solely on a static online questionnaire does not meet the standard of care. source ↗

Louisiana

Reviewed 18 October 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 may inject, and NPs with a board-approved collaborative practice agreement may perform cosmetic procedures within their clinical practice guidelines. The Board of Nursing's declaratory statement lets trained RNs give Botox and similar neurotoxins, but not dermal fillers, on the order of a physician or collaborating NP who is physically present on the premises. Since 1 August 2026 state law also lets an RN prepare, mix or reconstitute medication for immediate administration when carrying out an authorized prescriber's order. source ↗ source ↗
Good faith examThe nursing board's 2011 declaratory statement, which it says does not have the force of law, expects a history and physical exam by a physician or collaborating NP before an RN performs a cosmetic procedure. The medical board's 2024 statement on IV hydration accepts a patient relationship formed in person or through telemedicine. source ↗ source ↗

Maine

Reviewed 18 October 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 practiceMinimalWe found no Maine statute or board rule that bars non-physicians from owning a med spa. The boards' 2026 joint rule lets a physician, physician associate or APRN own or direct a med spa, holds licensees there to the same standards of care as in any practice, and allows an injected or IV preparation only after a physician, physician associate or APRN has examined and diagnosed the patient. source ↗ 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 ↗
Coming changePublic Law 2025, chapter 738 replaces the Board of Licensure in Medicine and the Board of Osteopathic Licensure with a single Maine Board of Medicine from 1 January 2027 (32 M.R.S. chapter 153). The physician associate agreement rule carries over with the same 4,000-hour threshold. source ↗ source ↗

Maryland

Reviewed 18 October 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 practiceModerateMaryland has no corporate practice statute, but the doctrine is drawn from its statutes and cases: an ordinary corporation may not operate a medical practice through employed physicians unless it is owned exclusively by physicians or related licensed professionals, or is itself licensed or permitted by statute to practice medicine, as hospitals and HMOs are. The Board of Physicians says it does not advise on corporate issues. source ↗ 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 18 October 2026
Nurse practitionersFullFull practice authority after 2 years of supervised practice (or approved equivalent experience). During those 2 years an NP prescribes under guidelines agreed with a supervising physician or an NP who has independent practice authority. source ↗ source ↗
Physician assistantsPhysician supervision agreement required, though on-site physician presence is not source ↗
Who may own the practiceStrictA med spa that provides medical services must be licensed by the Department of Public Health as a clinic unless it is wholly owned and controlled by the practitioners who provide its services. Professional corporation shares may be held only by licensees. source ↗ source ↗ 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 examThe nursing board's advisory ruling requires a comprehensive, documented evaluation by an authorized prescriber, and a nurse performs each procedure on that prescriber's patient-specific order. State law defines telehealth to include evaluating, diagnosing and prescribing. source ↗ source ↗

Michigan

Reviewed 18 October 2026
Nurse practitionersRestrictedNurse practitioners and other APRNs may prescribe nonscheduled prescription drugs on their own authority, and Schedule 2 to 5 controlled substances only as a physician's delegated act, with both names on the prescription. AANP classes Michigan as restricted practice. source ↗ source ↗
Physician assistantsPractice agreement with a participating physician (agreement-based rather than supervision) source ↗
Who may own the practiceStrictMichigan applies a corporate practice of medicine doctrine. A professional corporation or professional LLC that provides medical services must be owned by people licensed to provide that service; physicians may share ownership with osteopathic physicians, chiropractors, podiatrists and physician assistants. source ↗ source ↗ source ↗
Who may injectMichigan has no rule written for cosmetic injections. A physician may delegate an act within the physician's scope to a person qualified by education, training or experience, licensed or not, to perform under the physician's supervision, unless the act needs the physician's own level of education, skill and judgment. PAs inject under their practice agreement, and APRNs may prescribe nonscheduled drugs on their own authority. source ↗ source ↗ source ↗
Good faith examNo statute requires an in-person exam. A prescriber may prescribe during a telehealth visit, within their scope of practice, once the patient has consented to telehealth care. For Schedule 2 to 5 controlled substances the prescriber needs a bona fide prescriber-patient relationship, which includes a medical evaluation in person or by telehealth. source ↗ source ↗ source ↗

Minnesota

Reviewed 18 October 2026
Nurse practitionersFullFull practice authority after a postgraduate period. A newly licensed NP first practices 2,080 hours under a collaborative agreement with a physician, or with an APRN who has at least three years of practice, and an NP whose services are not primary care or mental health, aesthetics included, completes those hours in a setting where APRNs and physicians work together. After that, NPs practice and prescribe without a collaborative agreement. source ↗ source ↗ source ↗
Physician assistantsA practice agreement is required, and a physician reviews it every year. A newly licensed PA first practices 2,080 hours under a collaborative agreement in a hospital or integrated clinical setting where PAs and physicians work together. source ↗ source ↗
Who may own the practiceStrictSince mid-2026 Minnesota's medical practice act says only a natural person may practice medicine (Laws 2026, chapter 115, article 12). Physicians, physician assistants, registered nurses and other listed health professionals may own a professional firm together under chapter 319B. Legal guides describe a nonprofit exception that lets nonprofit corporations employ physicians; we have found no guidance yet on how the 2026 change affects it. source ↗ source ↗ 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 18 October 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 practiceMinimalThere is no broad statutory corporate-practice ban. The medical board's policy, which it says is not a rule, does not concern itself with the form of a physician's business arrangement as long as the physician is licensed and keeps sole control of treatment and billing. A professional corporation that renders medical services may have only licensed physicians as shareholders. source ↗ source ↗
Who may injectRNs and LPNs may not perform Botox or filler injections, microneedling, sclerotherapy for varicose veins or laser vascular lesion removal; an appropriately prepared RN may perform laser hair removal. The medical board requires a physician on the premises for laser use. source ↗ source ↗
Good faith examAppropriate exam required before diagnosis and treatment; may be non-in-person where telehealth technology is sufficient source ↗

Missouri

Reviewed 18 October 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 examBefore treating by telemedicine, the physician must evaluate the patient, collect or review the medical history and perform an examination sufficient for diagnosis and treatment; telemedicine can establish the relationship where the standard of care does not require an in-person visit. Since August 28, 2026, a patient questionnaire counts only if the treating professional reviews it and it gives the same information as an in-person evaluation, and a provider who uses one must be employed by or contracted with a business licensed to provide health care in Missouri. source ↗

Montana

Reviewed 18 October 2026
Nurse practitionersFullFull practice authority; NPs evaluate, diagnose and prescribe without a physician collaborative agreement. source ↗
Physician assistantsA PA with fewer than 8,000 hours of postgraduate clinical experience practices under a collaborative agreement with a physician, or with a PA who has 8,000 or more hours; from 8,000 hours no agreement is required. source ↗
Who may own the practiceMinimalMontana repealed its statutory corporate-practice ban in 1995, and in 2022 the medical board repealed the rule that treated partnering with unlicensed persons as unprofessional conduct. State law still makes it unprofessional conduct for a licensee to assist unlicensed practice or to let another person or organization practice on the licensee's license. The Board of Nursing's medical spa FAQ, which is guidance, says a person who holds no professional license may own a medical spa, while licensed providers perform or supervise the medical procedures. source ↗ source ↗ 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 18 October 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 inject neuromodulators and dermal fillers (Level III procedures) only after a licensed practitioner assesses, diagnoses and prescribes for each episode of care, and only under direct supervision, with the practitioner physically present in the facility. For this opinion a licensed practitioner is a physician or NP with board or specialty certification and aesthetic competencies. 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 18 October 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 practiceStrictA professional corporation or professional LLC that practices medicine must be organized by people licensed to provide that service, and a medical entity may combine physicians with osteopathic and homeopathic physicians, chiropractors, naprapaths, genetic counselors and psychologists. Legal guides read Nevada law, with an attorney general opinion, as barring other business entities from practicing medicine. source ↗ source ↗ source ↗
Who may injectBy statute, dermal fillers may be injected only by physicians, PAs, RNs, APRNs and trained dentists and podiatric physicians, and only in a medical facility or the office of a physician, PA, dentist, APRN or podiatric physician. Under the Board of Nursing's 2025 practice decision, RNs inject neuromodulators and fillers on a practitioner's order with direct supervision, and with immediate supervision for under-eye, nasal, jawline and temporal filler; LPNs may inject neither. APRNs with independent practice authority need no supervision. source ↗ 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 18 October 2026
Nurse practitionersFullFull practice authority; NPs practice and prescribe independently without a collaborative agreement. source ↗
Physician assistantsA PA with fewer than 8,000 post-graduate clinical hours who practices without a New Hampshire physician in the group, practice or health system needs a written collaboration agreement with a New Hampshire physician. Until January 1, 2027, a PA past 8,000 hours in that setting needs a Board of Medicine waiver, and from January 1, 2027 the law drops the waiver, so a PA past 8,000 hours needs neither. source ↗ source ↗
Who may own the practiceMinimalNo formal CPOM doctrine; physicians may be employed by corporations or practice through professional corporations. source ↗ 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 18 October 2026
Nurse practitionersReducedA joint protocol with a collaborating physician is still required for aesthetic and cosmetic work. A March 30, 2026 law lets APNs with more than 5,000 hours practice without one only in primary or behavioral health care, and it excludes elective aesthetic or cosmetic services. source ↗ source ↗
Physician assistantsPhysician supervision with a signed written delegation agreement; supervision is continuous, but the physician does not have to be on site. source ↗
Who may own the practiceStrictOnly licensed health care professionals may own a medical practice; a partnership, professional association or LLC must be made up solely of licensees in the same or closely allied fields, and a physician may not be employed by a practitioner with a narrower license. A business corporation may contract to provide only non-professional services, such as office management, space, equipment and billing, to the licensee-owned practice. source ↗
Who may injectWe found no New Jersey rule written for cosmetic injectables. RNs give injections on a prescriber's order, and APNs doing aesthetic work need a joint protocol with a physician. A Board of Medical Examiners rule lets a physician direct a certified medical assistant to give intradermal, intramuscular or subcutaneous injections only after examining the patient and writing the exact treatment, and only while the physician stays on the premises; it excludes local anesthetics and drugs without FDA approval. source ↗ source ↗
Good faith examRequired before prescribing: the prescriber takes a history, examines the patient, makes a diagnosis and sets a treatment plan. A telehealth visit can establish the relationship if it meets the in-person standard of care, but not a prescription based only on an online questionnaire. Not specific to cosmetic procedures. source ↗ source ↗

New Mexico

Reviewed 18 October 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 ↗ source ↗
Who may injectInjecting cosmetic substances is the practice of medicine and may not be delegated to unlicensed medical assistants. The Medical Board's 2025 medical spa policy names physicians, APRNs and PAs for injectables; its 2024 FAQ also names nurses. For procedures outside the nursing body of knowledge, Board of Nursing rules require national certification and say a course certificate is not evidence of competency. source ↗ source ↗ source ↗ source ↗ source ↗
Good faith examPhysician must provide history, physical exam and diagnosis before delegated cosmetic device treatment; telehealth acceptability unverified source ↗

New York

Reviewed 18 October 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 ↗ 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 18 October 2026
Nurse practitionersRestrictedNPs need career-long physician supervision or team management to deliver patient care. source ↗
Physician assistantsA written supervisory arrangement with a primary supervising physician is required unless the PA has registered with the Medical Board for team-based practice. Since June 30, 2026, a PA with more than 4,000 hours of practice, including more than 1,000 in the specialty, may register to work in a team-based setting (a majority physician-owned practice in the same clinical area, or a qualifying facility) without a supervising physician, collaborating with the team instead. A practice that specializes in pain management is not a team-based setting. Every PA, team-based or not, still needs physician supervision to compound or dispense drugs and to give the final interpretation of plain film radiographs, and a team-based PA practicing in a perioperative setting, including surgical or anesthesia-related services, must be supervised by a physician. A PA may not give the final interpretation of CT, MRI, nuclear medicine, PET, mammography or ultrasound studies. source ↗ source ↗ source ↗ source ↗ source ↗
Who may own the practiceStrictMedical practices must be owned by licensees: every share of a professional corporation must be held by licensees, and a medical PC may be owned by physicians alone or by a physician together with a PA or nurse practitioner. Lay investors cannot hold shares. source ↗ 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 18 October 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 PA must practice at a licensed health care facility, a facility with credentialing and privileging, a physician-owned facility or practice, or a practice the Board of Medicine approves, and a PA with fewer than 4,000 practice hours at a practice the Board approves needs a written collaborative agreement with a physician. source ↗
Who may own the practiceStrictWe found no North Dakota statute that bans lay ownership outright. The Attorney General's office advised informally in 1990 that state public policy bars a corporation other than a professional corporation from employing physicians, and a statute lets hospitals, nonprofit entities and charitable trusts employ physicians under a written contract that protects their independent judgment. For a for-profit med spa, plan on a physician-owned professional entity. source ↗ 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 18 October 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 18 October 2026
Nurse practitionersRestrictedNPs need a written physician supervision statement for prescriptive authority until 6,240 practice hours are verified. source ↗
Physician assistantsA PA with fewer than 6,240 postgraduate clinical hours, or whose hours the Medical Board has not yet verified, practices under a delegating physician with a practice agreement on file with the Board; once the Board verifies 6,240 hours the PA may practice without one (in force since 29 August 2025). source ↗ 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 18 October 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 limits who may own a medical practice: in a medical professional corporation, Oregon-licensed physicians must hold a majority of the voting shares and be a majority of the directors (licensees, in a corporation that joins physicians, physician associates and nurse practitioners). Senate Bill 951 (2025) bars a management services organization and its people from owning or controlling a majority of a practice it manages or exercising de facto control over its clinical decisions. The management services organization limits apply from 1 January 2026 to entities formed after the law took effect and from 1 January 2029 to entities that already existed. source ↗ source ↗
Who may injectNo Oregon rule lists who may inject. The Board of Nursing says an RN may perform a cosmetic procedure only when it is within that nurse's individual scope of practice and as part of a provider's treatment plan, since an RN may not diagnose or prescribe. The Medical Board expects a medical spa's medical director to confirm each staff member's training before delegating and not to delegate diagnosis or the treatment plan to staff not licensed to exercise independent medical judgment. Laser surgery, including ablative treatment, is the practice of medicine; non-ablative treatments may be delegated where state law permits. source ↗ source ↗ source ↗
Good faith examRequired: the Medical Board expects a medical spa's medical director to treat spa clients as patients, with an evaluation to establish the diagnosis and treatment before any procedure, and expects licensees to examine each patient before a first laser or energy treatment. Telemedicine is a delivery tool held to the same standard of care, and treatment based solely on an online questionnaire does not meet it. source ↗ source ↗ source ↗

Pennsylvania

Reviewed 18 October 2026
Nurse practitionersReducedCareer-long written collaborative agreement required, and at least two physicians for prescriptive authority. source ↗
Physician assistantsWritten agreement signed by the PA and a primary supervising physician, filed with the State Board of Medicine and effective on submission. 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 examNo board rule sets a med spa exam; care must meet the acceptable and prevailing standard of care, and an RN gives a drug only as ordered for that patient by a prescriber. The Department of State says licensees may use telemedicine when appropriate and within accepted standards of care, but a telemedicine visit does not satisfy a regulation that calls for a physical examination. source ↗ source ↗

Rhode Island

Reviewed 18 October 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 injectThe Department of Health's guidance chart lists physicians, PAs and family or adult-gerontology CNPs, and also dentists and pharmacists (a pharmacist only on a valid prescription from a physician, PA or CNP), as able to inject neuromodulators and dermal fillers with the right training. It excludes RNs and LPNs, and says nurses are not able to examine, diagnose, prescribe or administer Botox. 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 October 2026 we found no proposed or adopted medical spa rule in the Department's regulatory news or on its rulemaking agenda with the Secretary of State, so the 1 July 2026 deadline has passed without implementing rules. source ↗ source ↗

South Carolina

Reviewed 18 October 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 may be delegated to an appropriately qualified licensee with a physician, dentist or APRN on site and readily available: PAs under the scope of practice set with their supervising physician, APRNs under a written practice agreement, RNs only with on-site physician or APRN supervision. source ↗
Good faith examA bona fide practitioner-patient relationship must be established before any neuromodulator injection, by a physician, PA or APRN and not by an RN. A physician may establish it by telemedicine under the same standard of care as in person, but not for prescribing when an in-person physical examination is necessary for diagnosis, and prescribing based solely on answers to a set of questions is unprofessional conduct. source ↗ source ↗

South Dakota

Reviewed 18 October 2026
Nurse practitionersFullNPs evaluate, diagnose and prescribe independently once they have practiced 1,040 hours under a written collaborative agreement with a physician, certified NP or certified nurse midwife. source ↗
Physician assistantsCollaborative agreement required under 6,000 practice hours; none required once certified with 6,000+ hours filed source ↗
Who may own the practiceModerateBy statute a corporation may not practice medicine except as a professional corporation, but a corporation may employ a physician if the arrangement does not interfere with the physician's independent judgment, the corporation does not profit from the practice of medicine itself, and the agreement runs no longer than three years before annual renewal. source ↗
Who may injectThe Board of Nursing's guidelines, which do not have the force of law, say that, using products approved by the FDA, RNs may inject neuromodulators and temporary dermal fillers and LPNs neuromodulators only, after a physician, NP or PA has assessed the client and under a written medical order or protocol. By rule, an LPN works under supervision, and the supervising RN or APRN decides whether it must be direct or may be minimal; complex tasks need direct supervision. source ↗ source ↗
Good faith examThe Board of Nursing's guidelines, which it says do not have the force of law, expect a physician, nurse practitioner or physician assistant, for each episode of care, to review the client's history and do a medical assessment, write a treatment plan, and issue a medical order or protocol before delegating to a nurse. The board says that assessment may be in person or by telehealth under SDCL chapter 34-52. source ↗

Tennessee

Reviewed 18 October 2026
Nurse practitionersRestrictedNPs need a supervising or collaborating physician with joint written protocols and periodic chart review throughout their career. source ↗ source ↗ source ↗
Physician assistantsSupervising physician with jointly developed written protocols, availability for consultation, and periodic chart review. source ↗ source ↗
Who may own the practiceStrictShares in a Tennessee medical professional corporation may be owned only by licensed physicians or physician-owned entities, apart from the professional combinations the statute allows, so lay investors use management services structures. Every medical spa must register with the Board of Medical Examiners before it operates and renew each year, naming a medical director who is an MD or DO with an active Tennessee license and an in-person Tennessee practice and who accepts responsibility for its cosmetic medical services. source ↗ source ↗
Who may injectNo rule in the board's 2002 supervising-physician policy names who may inject. For supervisees other than NPs and PAs, the supervising physician must be on site at least four hours per week, compile protocols with the supervisee, keep a copy on site and update them at least annually, and review and sign all charts 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 18 October 2026
Nurse practitionersFullNPs evaluate, diagnose and prescribe independently under the nursing board with no physician collaboration agreement required. source ↗
Physician assistantsCollaboration is set at the practice level under written policies. A PA collaborates with a physician for the first 4,000 hours of post-graduate clinical practice, then works under a written collaborative agreement with a physician, or with a PA who has more than 8,500 hours in the same specialty, until reaching 8,500 hours (Utah Code 58-70a-307, as amended in 2026). 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 and nurse practitioners may perform cosmetic medical procedures, which include neuromodulator and filler injections, or supervise them; PAs perform them under the Physician Assistant Act, and RNs and other listed licensees act within their own scope under defined supervision levels. source ↗ 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 18 October 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. Act 133 of 2026 (18 V.S.A. chapter 233, in force 1 July 2026) bars a private equity group or hedge fund involved with a Vermont health care facility from interfering with providers' clinical judgment or controlling listed decisions such as clinical staffing, prices, coding and billing, and clinical hiring, and every health care facility and management services organization, apart from exempt types such as nursing homes, federally qualified health centers and telehealth-only services, must report any private equity or hedge fund ownership, or attest to none, to the Green Mountain Care Board by 1 March 2027. source ↗ source ↗
Who may injectVermont has no law or rule written for medical spas. A 2024 joint statement of the Office of Professional Regulation and the medical, osteopathic, nursing and pharmacy boards says these businesses follow the rules for any medical practice: only physicians, PAs, APRNs and naturopathic physicians with a prescribing endorsement may prescribe IV products, a prescription drug is given only on a valid prescription that follows the prescriber's own evaluation of the patient, standing orders from a clinic medical director are not valid prescriptions, and RN and LPN roles fall under general nursing scope and delegation. source ↗ 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 18 October 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 or podiatrist. A 2026 law (Chapter 418, HB 746) lets a PA with three years of full-time clinical experience practice without one after a physician attestation, but it takes effect only once the Board of Medicine adopts regulations, and as of October 18, 2026 those regulations had not been adopted. source ↗ source ↗ source ↗
Who may own the practiceModerateProfessional corporation shares must be held by licensed practitioners. The Department of Health Professions' October 8, 2026 guidance for med spas does not address ownership, and as of October 11, 2026 we found no Virginia board guidance that does. source ↗ source ↗
Who may injectA prescriber may administer prescription drugs and devices, such as neuromodulators and dermal fillers, or have a nurse, physician assistant or intern administer them under the prescriber's direction and supervision; under the Department of Health Professions' October 8, 2026 guidance, those drugs are given on a patient-specific order, not on protocols or standing orders. source ↗ source ↗
Good faith examRequired: a bona fide practitioner-patient relationship with an appropriate examination; telehealth expressly permitted. Under the Department of Health Professions' October 8, 2026 guidance, a questionnaire alone does not establish that relationship, and the patient must interact with the prescriber in real time. source ↗ source ↗

Washington

Reviewed 18 October 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 individuals licensed to render the same professional service, and commentators describe Washington as following a corporate practice of medicine doctrine drawn from case law and agency interpretation. source ↗ 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 18 October 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 authorization to practice medicine, and every shareholder must be a licensee: a physician (MD or DO), podiatric physician or physician assistant. 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. For retail IV therapy, a July 2026 joint advisory opinion of the medicine, osteopathic medicine and pharmacy boards adds that the prescriber personally evaluates the patient and does not issue standing orders. source ↗ source ↗ source ↗ source ↗ source ↗

Wisconsin

Reviewed 18 October 2026
Nurse practitionersReducedSince 1 September 2026 (2025 Wisconsin Act 17), an APRN practices in collaboration with a physician or dentist until the Board of Nursing verifies 3,840 hours of clinical nursing practice and 3,840 hours of APRN practice with a physician or dentist available, each over at least 24 months; the APRN may then practice independently. Treating pain syndromes with invasive techniques still requires a collaborating pain management physician, unless an independently qualified APRN does it in a hospital setting or under hospital privileges. AANP's practice environment map, dated May 2026, still classifies Wisconsin as Reduced. source ↗ source ↗ 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 shareholders, directors and officers must all be licensed in the same field or be health care professionals. 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 18 October 2026
Nurse practitionersFullNPs evaluate, diagnose, and prescribe under exclusive Board of Nursing authority; no collaborative agreement required. source ↗
Physician assistantsThe degree of collaboration is determined at the practice level, which may include the employer, group, hospital or credentialing system, with no required supervising physician. source ↗
Who may own the practiceModerateAll professional corporation shareholders must be and remain licensed in the profession; as of 18 October 2026 we found no state case law or attorney general opinion on lay ownership. 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 recordedYesSince 16 September 2026 (SB 89, chapter 21 SLA 26), a PA practices under a written collaborative agreement with a physician licensed in Alaska, who need not be located in the state, unless the PA works at a facility directed by a physician, osteopath or podiatrist, a health care facility licensed by the Department of Health, a federal or tribal facility, a federally qualified health center or rural health clinic, or a military or veterans' facility, or the medical board approves a facility-specific exemption. One collaborating physician is enough
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
FloridaRestrictedModerateYesSupervision required: the supervising physician must be easily available or physically present
GeorgiaRestrictedModerateYesSupervision required: a board-approved job description with a primary supervising physician. Since 25 May 2026 a physician may supervise no more than the combined equivalent of eight APRNs or PAs at one time, and a physician may not be the employee of a PA the physician supervises unless the board approved the arrangement before 1 July 2009
HawaiiFullMinimalYesPhysician supervision required
IdahoFullMinimalYesWritten collaborative practice agreement required
IllinoisReducedStrictYesWritten collaborative agreement required
IndianaReducedStrictSee noteWritten collaborative agreement required
IowaFullModerateYesCollaboration is set at the practice level and no supervisory agreement is required, except that a physician associate in independent practice (their own professional corporation or PLLC) must be supervised by a physician for the first two years unless they already have two years of supervised or collaborative practice
KansasFullStrictSee noteSupervision under a written agreement is required. From 1 January 2027 (House Bill 2702 of 2026), a PA who attests to 4,000 or more hours of postgraduate clinical experience and has no board discipline may practice in collaboration with a physician under a practice agreement kept at the practice site
KentuckyReducedModerateSee noteBoard-approved supervision agreement with a supervising physician required
LouisianaReducedModerateSee noteSupervising 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
MichiganRestrictedStrictYesPractice agreement with a participating physician (agreement-based rather than supervision)
MinnesotaFullStrictSee noteA practice agreement is required, and a physician reviews it every year. A newly licensed PA first practices 2,080 hours under a collaborative agreement in a hospital or integrated clinical setting where PAs and physicians work together
MississippiReducedMinimalYesBoard-approved supervising physician with a delegated-services protocol required
MissouriRestrictedMinimalYesWritten collaborative practice arrangement
MontanaFullMinimalSee noteA PA with fewer than 8,000 hours of postgraduate clinical experience practices under a collaborative agreement with a physician, or with a PA who has 8,000 or more hours
NebraskaFullMinimalSee notePhysician supervision with a written scope-of-practice agreement
NevadaFullStrictYesSupervising physician required
New HampshireFullMinimalYesA PA with fewer than 8,000 post-graduate clinical hours who practices without a New Hampshire physician in the group, practice or health system needs a written collaboration agreement with a New Hampshire physician. Until January 1, 2027, a PA past 8,000 hours in that setting needs a Board of Medicine waiver, and from January 1, 2027 the law drops the waiver, so a PA past 8,000 hours needs neither
New JerseyReducedStrictYesPhysician supervision with a signed written delegation agreement
New MexicoFullMinimalYesSupervision agreement required
New YorkFullStrictYesContinuous physician supervision required
North CarolinaRestrictedStrictYesA written supervisory arrangement with a primary supervising physician is required unless the PA has registered with the Medical Board for team-based practice. Since June 30, 2026, a PA with more than 4,000 hours of practice, including more than 1,000 in the specialty, may register to work in a team-based setting (a majority physician-owned practice in the same clinical area, or a qualifying facility) without a supervising physician, collaborating with the team instead. A practice that specializes in pain management is not a team-based setting. Every PA, team-based or not, still needs physician supervision to compound or dispense drugs and to give the final interpretation of plain film radiographs, and a team-based PA practicing in a perioperative setting, including surgical or anesthesia-related services, must be supervised by a physician. A PA may not give the final interpretation of CT, MRI, nuclear medicine, PET, mammography or ultrasound studies
North DakotaFullStrictYesOptimal Team Practice: collaboration only
OhioReducedMinimalYesWritten supervision agreement with a supervising physician required
OklahomaRestrictedMinimalYesA PA with fewer than 6,240 postgraduate clinical hours, or whose hours the Medical Board has not yet verified, practices under a delegating physician with a practice agreement on file with the Board
OregonFullStrictYesCollaborative practice agreement required rather than supervision
PennsylvaniaReducedStrictSee noteWritten agreement signed by the PA and a primary supervising physician, filed with the State Board of Medicine and effective on submission
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
UtahFullMinimalYesCollaboration is set at the practice level under written policies. A PA collaborates with a physician for the first 4,000 hours of post-graduate clinical practice, then works under a written collaborative agreement with a physician, or with a PA who has more than 8,500 hours in the same specialty, until reaching 8,500 hours (Utah Code 58-70a-307, as amended in 2026)
VermontFullMinimalSee noteWritten practice agreement with a participating physician, filed with the board
VirginiaRestrictedModerateYesPractice agreement with a patient care team physician or podiatrist. A 2026 law (Chapter 418, HB 746) lets a PA with three years of full-time clinical experience practice without one after a physician attestation, but it takes effect only once the Board of Medicine adopts regulations, and as of October 18, 2026 those regulations had not been adopted
WashingtonFullStrictYesCollaboration agreement required with one or more physicians or the PA's employer
West VirginiaReducedStrictYesCollaborating 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
WyomingFullModerateYesThe degree of collaboration is determined at the practice level, which may include the employer, group, hospital or credentialing system, 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. 11 states.
  • Minimal: no meaningful prohibition on non-physician ownership, though only licensees may deliver medical services. 16 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.

CSV92 KB, one row per state JSON149 KB, with the field dictionary and methodology

Version 1.0.8Full review 18 October 2026, Texas 23 September 2026 Coverage 50 statesRules with no source 0Rules with no government source 50 of 254 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 v1.0.8, revised 2026-10-18.

The ownership column is the weakest in the file. 18 of 50 ownership_source values point at published legal guides (compliance-guide sites and law-firm articles) 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, v1.0.8 (revised 2026-10-18), full review 18 October 2026, Texas 23 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

  • v1.0.8 (2026-10-18): Forty-nine states re-reviewed against their sources, fetched 18 October 2026 (every state but Texas), and reviewed moves from 30 July 2026 to 18 October 2026 on each of those rows. Rule cells re-read: Alabama: injection_rule and ownership_rule. Alaska: pa_rule, injection_rule and ownership_rule. Arizona: injection_rule and ownership_rule. Arkansas: np_rule. Colorado: good_faith_exam_rule and ownership_rule. Delaware: injection_rule and ownership_rule. Florida: good_faith_exam_rule and injection_rule. Georgia: np_rule, pa_rule and ownership_rule. Hawaii: ownership_rule. Idaho: good_faith_exam_rule and injection_rule. Illinois: good_faith_exam_rule and ownership_rule. Indiana: injection_rule, ownership_rule and coming_change_rule. Iowa: pa_rule, injection_rule and ownership_rule. Kansas: good_faith_exam_rule, pa_rule, injection_rule and coming_change_rule (new). Kentucky: np_rule and ownership_rule. Louisiana: good_faith_exam_rule and injection_rule. Maine: ownership_rule and coming_change_rule (new). Maryland: ownership_rule. Massachusetts: good_faith_exam_rule, np_rule and ownership_rule. Michigan: good_faith_exam_rule, np_rule, injection_rule and ownership_rule. Minnesota: np_rule, pa_rule and ownership_rule. Mississippi: ownership_rule. Missouri: good_faith_exam_rule. Montana: pa_rule and ownership_rule. Nebraska: injection_rule. Nevada: injection_rule and ownership_rule. New Hampshire: pa_rule and ownership_rule. New Jersey: good_faith_exam_rule, np_rule, pa_rule, injection_rule and ownership_rule. New Mexico: injection_rule and ownership_rule. New York: ownership_rule. North Carolina: pa_rule and ownership_rule. North Dakota: pa_rule and ownership_rule. Oklahoma: pa_rule. Oregon: good_faith_exam_rule, injection_rule and ownership_rule. Pennsylvania: good_faith_exam_rule, pa_rule and injection_rule. Rhode Island: injection_rule and coming_change_rule. South Carolina: good_faith_exam_rule. South Dakota: good_faith_exam_rule, np_rule, injection_rule and ownership_rule. Tennessee: np_rule, pa_rule and ownership_rule. Utah: pa_rule and injection_rule. Vermont: injection_rule and ownership_rule. Virginia: good_faith_exam_rule and pa_rule. Washington: ownership_rule. West Virginia: good_faith_exam_rule and ownership_rule. Wisconsin: np_rule and ownership_rule. Wyoming: pa_rule and ownership_rule. First sources that move, because the old one was dead, superseded, a page that does not carry the rule or a walled reproduction: Alabama ownership_source, Alaska pa_source, Alaska ownership_source, Colorado good_faith_exam_source, Florida good_faith_exam_source, Florida injection_source, Idaho good_faith_exam_source, Idaho injection_source, Kansas good_faith_exam_source, Kansas injection_source, Kentucky ownership_source, Massachusetts ownership_source, Michigan good_faith_exam_source, Montana pa_source, Montana ownership_source, Nevada ownership_source, New Jersey good_faith_exam_source, New Jersey pa_source, New Jersey injection_source, New Mexico ownership_source, North Carolina ownership_source, North Dakota ownership_source, Oklahoma pa_source, Pennsylvania pa_source, Pennsylvania injection_source, South Carolina good_faith_exam_source, South Dakota np_source, South Dakota ownership_source, Tennessee pa_source, Tennessee ownership_source, Utah pa_source, Vermont ownership_source, Washington ownership_source, Wyoming pa_source and Wyoming ownership_source. Montana's ownership_posture moves from Moderate to Minimal, because the board rule the old posture rested on was repealed in 2022. The map's count of rows that name an examination moves from 34 to 35: Kansas, Louisiana and Pennsylvania read See note, Florida, Michigan, South Dakota and West Virginia read Yes. No column, identifier or board URL changed, so this is still med-spa-compliance-v1 at the same URL; the bytes changed, so the revision number moves to 1.0.8.
  • v1.0.7 (2026-10-11): South Carolina: injection_rule re-read against the boards' 2022 revision of their joint advisory opinion, and injection_source now cites that revision, because the 2017 address no longer serves the opinion. Tennessee: injection_rule limited to what the board's 2002 policy says. Kentucky: injection_rule follows the nursing board's June 2026 revision, and good_faith_exam_rule says the medical board's opinion does not itself have the force of law, so on the map Kentucky's exam column now reads See note and the count of states whose rule names an examination moves from 35 to 34. Mississippi: injection_rule follows the nursing board FAQ, with the laser rule from the medical board. Virginia: injection_rule and ownership_rule cite the Department of Health Professions guidance adopted October 8, 2026. Every other changed cell keeps its first source, so no other _source column moves.
  • 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 state's rows were reviewed against the sources linked in them on 18 October 2026, and Texas's on 23 September 2026; 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 18 October 2026 (Texas on 23 September 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.