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

Question

I am seeing increasingly different "injectors" who are RNs doing filler and other injectables like Botox. However they are in "med spa" settings instead of medical facilities. It's my understanding that these are prescription medications requiring provider level licensure to be used. Is this safe/legal? I know not only physicians do filler, but how are nurses able to do this without the oversight? It's like every time I go online there is some new "injector" doing filler in an office.

Harold J. Kaplan, MD · Answer

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.

Jason Emer, MD · Answer

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.

Brent Moelleken, MD · Answer

In California, it is not permitted for an RN to practice medicine independently. In theory, there is a physician who is 'supervising' the clinic or medspa and is available in case of trouble (ie adverse result, infection, complication). Often, these physicians will 'sponsor' an RN in hopes of getting referrals for their fledgling practices and sacrifice their ethics (and possibly their medical license) in a very competitive business environment.

In practice, however, RN's are running their own practices, as are aestheticians and clinic employees with no medical qualifications at all. Caveat emptor!

In practice, however, RN's are running their own practices, as are aestheticians and clinic employees with no medical qualifications at all.  Caveat emptor!

Camille Cash, MD · Answer

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.

Anshul Gambhir, MD · Answer

Thank you for your question. It honestly all depends on how your state regulates cosmetic injections. Some states don't require supervision from a Physician to do cosmetic injectables like Botox or Fillers. It is technically safe and I would hope legal if they are following the state's laws. I am not personally familiar with the state of California's regulations on this. As long as they are properly trained through a cosmetic injecting course and have a good amount of experience then there shouldn't be much to worry about. Just make sure you do your research before picking an injector! Hope this helps!

Mimi P. Martins, MD · Answer

Hi,Every State is different, but most State laws permit RNs, to own and manage medical spa, as long as they have a medical doctor who is a physician or Nurse practitioner ( depends on the State). A skillful trained RN can certainly do safe injections including neurotoxins and dermal fillers, as long as they have in house or over sight medical director. To be comfortable, if you decide to visit any of these med spa check their website and see if they have a medical director or you could simply ask the Med Spa and I’m sure they will inform you.

Radiant Divine Medical Spa - Avon · Answer

Hello. Thank you for your question. Depending on the state, this is completely legal and typically very safe. For the state regulations, check with your states Board of Nursing. As with any injector, do your research, look at reviews, check out their before and afters and ask their certifications. This will let you know if they are qualified to inject you or not.

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

Answers (7)

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