RN injecting in a med spa with no physician? Is this safe and legal?

Hello Vivid. The answer to your question for California is yes, nurses can perform these procedures under the supervision of a physician. To safely and legally perform injections, nurses should have some form of training and also be working under a document called a "standardized procedure". These documents are very common in healthcare settings like hospitals and they allow nurses to perform their normal everyday duties without consulting with the physician first.

You are correct that the injection products are prescriptions and as such the patient needs to be evaluated by a physician, nurse practitioner or physician assistant before moving forward with the treatment. The problem starts when a registered nurse level practitioner (RN) fails to have the patient evaluated before moving forward with treatment. This equates to a nurse practicing medicine without a license and he/she can have their license suspended or revoked for such an offense. As long as you are evaluated by a practitioner that can prescribe medication prior to your treatment, all is well.

As for oversight, this is not well defined by the nursing and medical boards of California. Should the MD be close by? Should he/she have their own cosmetic training? Should he/she be able to supervise multiple medical spas simultaneously (rent-a-doc style). None of these questions have been addressed effectively by the medical boards so most practitioners are left now knowing what "supervision" is actually required to be. One thing we do know is that if a physician has not been trained and has never performed the procedures he/she is supervising, then it would be difficult to supervise. In addition, if the physician does not review the charts and treatments for a certain sample of the patient population then he/she is not supervising.

Re: the location, the medical board stipulates that medical treatments shall be performed in medical offices. A medical spa is a medical office so that is not an issue. The issue is when an injector goes to a "Botox party" or a hair salon to inject. This is not looked kindly upon by the medical and nursing boards and can result in suspension or revocation of the nursing license.

Finally, at our organization, the nurses are the injectors. We like to say, "training not title determines competency". We tell our patients every day that if they want surgery, go to a surgeon. If they want injections go to an injector. We see patients every day that are unhappy with both nurse and physician injections so it's really not about the title as much as it is about training end experience. Hope this helps and best of luck.

The laws regarding Botox and filler injections by Registered Nurses varies by state. Often they are legally able to inject as long as they are under the supervision of a physician. If you are uncomfortable with a nurse injector you can request a physician injector when you make your appointment. It is also your right to ask what training has been completed by your injector.

Fillers can be injected by RNs but the laws of who can do what where is governed by each state. I suggest you go to an established brand and someone experienced. Best, Dr. Emer.