In my opinion irrespective of state regulations, Ultherapy should not be performed by nonmedical professionals. The word non-invasive is a misnomer. This device, is as invasive as any laser that we are currently using, the only difference is that the lesions are subsurface so you dont see them. Histologically, you are looking at a similar discrete wounding patterns. Aestheticians are a wonderful adjunct to an aesthetic practice, however, there scope of practice is limited to the epidermal layer of the skin. They shoud not be utilized as cheap labor to run these deeper dermal and subdermal devices. There must be a line drawn in the sand at some point. I am sure they can be well trained, but so to can a PA and nurse practicioners be instructed in how to perform a facelift and I believe this would be considered non acceptable,.... or so I think.