PendingHigh Impact
Indiana med spa registration requirements begin January 1, 2027
Indiana SB 282 requires medical spa registration beginning January 1, 2027 and adds a state framework involving responsible practitioners, public database requirements, adverse-event reporting, advertising requirements, and compounding-related oversight.
Operator impact: Indiana med spas should prepare responsible-practitioner documentation, facility records, adverse-event reporting workflows, advertising review, compounding and medication-source review, and registration readiness before the 2027 deadline.
Effective Jul 1, 2026
Deadline Jan 1, 2027
EffectiveHigh Impact
Rhode Island Medical Spas Safety Act creates med spa supervision framework
Rhode Island enacted the Medical Spas Safety Act, creating statutory rules for cosmetic medical procedures, supervision, delegation, and medical spa safety.
Operator impact: Rhode Island med spas should review facility licensure, procedure delegation, provider qualifications, supervision documentation, adverse-event workflows, and cosmetic medical procedure protocols.
Effective Jun 30, 2025
Deadline Jul 1, 2026
WatchHigh Impact
Washington publishes guidance for med spas and esthetic service businesses
Washington Department of Health guidance explains legal and practical considerations for businesses offering esthetic services, including injectables, lasers, body contouring, IV hydration, and telehealth-connected workflows.
Operator impact: Washington med spas should review ownership structure, medical director role, scope-of-practice boundaries, procedure delegation, telehealth use, licensed supervision, and whether staff are exceeding authorized practice.
WatchHigh Impact
Alaska medical spa services work group reviews high-risk med spa service lines
Alaska's Medical Spa Services Work Group is reviewing services including IV hydration, advanced esthetics, cosmetic injectables, prescription drugs, semaglutides, sildenafil, body contouring, and hyperbaric treatments.
Operator impact: Alaska med spas and wellness clinics should monitor work group output and keep provider scope, prescription workflows, medication sourcing, medical director oversight, and procedure documentation audit-ready.
EffectiveHigh Impact
Kentucky nursing advisory statement addresses cosmetic and dermatologic procedures
Kentucky Board of Nursing advisory guidance addresses cosmetic and dermatological procedures performed by nurses in aesthetic practice settings.
Operator impact: Kentucky med spas should review nurse competency, prescriber orders, delegation, scope boundaries, cosmetic procedure protocols, emergency procedures, and medical director oversight.
ProposedHigh Impact
Colorado SB26-130 would treat certain med spa failures as deceptive trade practices
Colorado SB26-130 would make certain conduct by medical spas involving prescription drugs an unfair or deceptive trade practice under the Colorado Consumer Protection Act.
Operator impact: Colorado med spas should monitor the bill and review prescription-drug acquisition, storage, preparation, administration, provider scope, delegation, compounding, sterile drug products, and patient-facing claims.
EffectiveHigh Impact
Colorado Rule 800 governs delegation and supervision of medical-aesthetic services
Colorado's medical delegation rule governs physician delegation and supervision of medical services, including medical-aesthetic services performed by non-licensed or non-physician personnel.
Operator impact: Colorado med spas should maintain written delegation agreements, procedure protocols, emergency protocols, chart review, staff qualification reassessments, and documented supervision for delegated aesthetic services.
ProposedMedium Impact
Connecticut HB 5399 would expand dentistry-related cosmetic injection authority
Connecticut HB 5399, a dentistry bill, includes provisions that would permit licensed dentists to administer cosmetic injections such as botulinum toxin and dermal fillers.
Operator impact: Connecticut med spas, dental spas, and aesthetic clinics should monitor the bill because dental injector expansion could affect local competition, scope boundaries, referral models, and consent/disclosure workflows.
EffectiveHigh Impact
Maryland COMAR chapter governs cosmetic medical procedure delegation and devices
Maryland COMAR 10.32.09 governs delegation and assignment of cosmetic medical procedures and use of cosmetic medical devices, including lasers, IPL, RF, injections, dermabrasion, and fat-reduction procedures.
Operator impact: Maryland med spas should review physician qualifications, delegation eligibility, written protocols, training, non-physician responsibilities, device use, cosmetic injectables, and discipline risk before expanding service lines.
EffectiveHigh Impact
California Medical Board states med spas offering medical procedures must be physician-owned
California Medical Board guidance states medical spas are marketing vehicles for medical procedures and, if offering medical procedures, must be owned by physicians.
Operator impact: California med spa founders, MSOs, investors, injectors, and marketing partners should review ownership, physician control, management-service agreements, advertising, medical decision-making, and non-physician financial control points.
EffectiveMedium Impact
Texas TDLR guidance separates cosmetology services from med spa medical treatments
Texas TDLR guidance explains that med spas may include cosmetology services, but Botox, filler injections, body contouring, laser-assisted skin treatments, and medical-grade facial treatments fall under medical treatment rules.
Operator impact: Texas med spas should separate cosmetology scope from physician-delegated medical procedures and make sure estheticians, cosmetology operators, laser staff, and medical staff are not crossing license boundaries.
EffectiveMedium Impact
Nebraska advisory opinion addresses aesthetic nursing and cosmetic procedures
Nebraska Board of Nursing advisory opinion addresses aesthetic nursing and references cosmetic and dermatologic procedure scope considerations for licensed nurses.
Operator impact: Nebraska med spas should review nurse scope, training, physician or prescriber orders, dermatologic procedures, cosmetic injectables, lasers, IPL, and documentation before expanding aesthetic services.
EffectiveHigh Impact
North Carolina nursing position statement sets ordered-procedure requirements for cosmetic dermatology
North Carolina Board of Nursing position statement requires evaluation or assessment by a licensed prescriber and an order before licensed nurses perform cosmetic or aesthetic dermatological procedures.
Operator impact: North Carolina med spas should confirm prescriber evaluations, procedure orders, onsite supervision, nurse competency, emergency policies, laser guidance review, and business-ownership boundaries for RN-led aesthetic models.
EffectiveHigh Impact
North Carolina Medical Board treats laser hair and tattoo removal as laser surgery
North Carolina Medical Board position statement says laser hair and tattoo removal implicate laser surgery and require physician, PA, or NP examination before initial treatment and adequate supervision.
Operator impact: North Carolina laser clinics and med spas should review pre-treatment exams, laser protocols, supervising physician availability, topical anesthetic prescribing, staff training, device logs, and tattoo-removal workflows.
EffectiveMedium Impact
Oklahoma nursing guidelines address cosmetic and aesthetic dermatological procedures
Oklahoma Board of Nursing guidance addresses cosmetic and aesthetic dermatological procedures and references med spa and osteopathic medical spa policy expectations.
Operator impact: Oklahoma med spas should align nurse roles, prescriber orders, competency validation, emergency policies, aesthetic procedure protocols, and board-specific scope limits before assigning injectables, lasers, or advanced procedures.
EffectiveMedium Impact
South Carolina medical board policy addresses lasers and other aesthetic devices
South Carolina Board of Medical Examiners policy addresses lasers and other devices, including delegation of non-ablative treatments and RN laser hair removal under direct supervision.
Operator impact: South Carolina med spas and laser clinics should review direct supervision, RN laser hair removal criteria, PA/NP/physician delegation, device classification, training, adverse-event protocols, and procedure documentation.
EffectiveMedium Impact
Oregon Board of Nursing FAQ addresses RN participation in cosmetic procedures
Oregon Board of Nursing FAQ states RN participation in cosmetic procedures depends on individual scope of practice analysis under Oregon nursing standards.
Operator impact: Oregon med spas should document RN scope analysis, orders, competency, policies, delegation, supervision, adverse-event response, and whether cosmetic procedures are being assigned without sufficient nursing-basis review.
ProposedMedium Impact
New York microneedling scope bill remains active for estheticians and cosmetologists
New York A3084 would allow licensed estheticians and licensed cosmetologists to perform microneedling after completing required training.
Operator impact: New York med spas and aesthetic clinics should monitor whether microneedling scope expands beyond current medical-provider workflows and update training, delegation, consent, and supervision policies if the bill advances.
WatchMedium Impact
Texas confirms no med spa registration but physician delegation remains required
Texas Medical Board states there is currently no registration for med spa clinics, but nonsurgical medical procedures performed in Texas med spas must be delegated by a licensed physician.
Operator impact: Texas med spas should not confuse lack of facility registration with lack of medical regulation; physician delegation, protocols, supervision, credential disclosure, and recordkeeping remain core risk points.
WatchMedium Impact
Florida med spa licensure bills died but prescription-drug oversight remains a watch item
Florida SB 1728 and companion HB 1429 proposed the Medical Spa Prescription Drug Oversight Act, but SB 1728 died in Health Policy on March 13, 2026.
Operator impact: Florida med spas should not treat the bill's death as a permanent safe harbor; prescription-drug sourcing, storage, adverse-event protocols, GLP-1 claims, pharmacy relationships, and medical oversight remain likely future pressure points.
ProposedHigh Impact
Arizona bill would regulate med spas handling prescription medications
Arizona HB 4047 would create medical spa licensure and regulation requirements, including prescription medication acquisition, storage, security, inspection, and dispenser-related obligations.
Operator impact: Arizona med spas offering injectables, GLP-1s, hormones, IV therapy, or other prescription-based services should monitor the bill and review medication sourcing, storage, DSCSA-style documentation, responsible-person structure, and patient-facing claims.
ProposedHigh Impact
Iowa medical spa oversight bill would create registration and practice requirements
Iowa HSB 591 would establish the Medical Spa Oversight Act and create a state framework for regulating medical spas that provide wellness services.
Operator impact: Iowa med spas and wellness clinics should monitor the bill and begin reviewing responsible-person assignment, registration readiness, prescription-medication handling, adverse-event workflows, and supervision protocols.
ProposedHigh Impact
Massachusetts H5455 would regulate operation of medical spas
Massachusetts H5455, a new draft of H5087, would regulate the operation of medical spas and was referred to the House Committee on Ways and Means on May 26, 2026.
Operator impact: Massachusetts med spas should monitor licensing, ownership, clinic-licensure, procedure delegation, supervision, and patient-safety requirements as the bill advances.
EffectiveMedium Impact
Massachusetts advisory flags clinic licensure for practitioner-controlled med spas
Massachusetts guidance states that a medical spa providing medical services is subject to clinic licensure if it is not wholly owned and controlled by one or more practitioners.
Operator impact: Massachusetts operators should review ownership, control, clinic licensure, provider authority, and whether aesthetic or wellness services are being delivered through a structure that requires state clinic licensure.
ProposedMedium Impact
Florida med spa supervision watch opened
Florida is queued for ongoing review around supervision, delegation, and injector workflow guidance as aesthetic medicine volume grows.
Operator impact: Ownership teams should keep medical director agreements, protocols, training records, and patient intake boundaries audit-ready.
