The booming medical aesthetics industry has made Med SPAs a go-to destination for non-invasive cosmetic treatments. But with this popularity comes an important question: who is legally and professionally qualified to perform these Med SPA procedures? Understanding the roles and responsibilities of licensed professionals ensures patient safety, compliance with local laws, and the success of your Med SPA.

In this blog, we’ll explore who can perform injectables, laser treatments, microneedling, chemical peels, and more, along with the qualifications required for each Med SPA service.

Understanding Med SPA Licensing and Scope of Practice

Before getting into individual treatments, it’s important to understand that the scope of practice in Med SPAs varies by state and country. Each jurisdiction defines what licensed professionals can legally do. Most Med SPA treatments fall under medical procedures, meaning they require oversight from a licensed physician or medical director.

Key licensing authorities and titles may include:

• Physicians (MD/DO)

• Nurse Practitioners (NP)

• Physician Assistants (PA)

• Registered Nurses (RN)

• Licensed Practical Nurses (LPN)

• Licensed Estheticians or Medical Estheticians

Each role has a different level of training, responsibility, and authorization to perform specific cosmetic procedures. The ASDSA advises patients to have medical procedures done or closely overseen by a physician, ideally a board-certified dermatologist, as outlined in the “Medical Spa Safety Act.”

Who Can Perform Injectables in a Med SPA?

Botox and Dermal Filler Administration: Qualified Providers Only

Injectable neurotoxins like Botox and dermal fillers such as Juvederm and Restylane are considered medical treatments. As such, they should only be performed by:

• Physicians (MD/DO)

• Nurse Practitioners (NP)

• Physician Assistants (PA)

• Registered Nurses (RN) (under physician supervision)

In most states, RNs and PAs must work under a medical director or supervising physician. Even though some states allow delegation of these treatments, the overseeing provider is ultimately responsible for outcomes.

Why Proper Licensing Matters for Injectables?

Improper technique or insufficient anatomical knowledge can result in serious complications, such as vascular occlusion or drooping. That’s why training and licensure are crucial for Botox and filler injections. In 2023, the FDA advised that individuals seeking neurotoxins or dermal fillers should consult licensed, experienced providers who understand facial anatomy, treatment risks, and how to manage potential complications.

Who Can Perform Laser Treatments in a Med SPA?

Laser Hair Removal and Skin Resurfacing: Licensed Laser Technicians or Medical Professionals

Laser treatments, including hair removal, skin resurfacing, and tattoo removal, are regulated as medical devices by the FDA. Therefore, laser procedures typically require:

• Supervision by a physician

• Performance by a trained and certified laser technician, RN, NP, or PA

In some states, medical estheticians can perform laser treatments after obtaining a laser certification and under a medical director’s supervision. Each state has specific training hours and certification requirements for laser operation. Compliance not only prevents legal issues but also protects patients from burns, hyperpigmentation, and other side effects.

Who Can Perform Microneedling in a Med SPA?

Microneedling, especially when combined with PRP (Platelet-Rich Plasma), is considered a medical procedure in many states. The depth of the microneedles determines whether the procedure is cosmetic or medical.

• Cosmetic microneedling (≤ 0.3 mm): May be performed by licensed estheticians.

• Medical microneedling (> 0.3 mm or involving PRP): Must be performed by an RN, NP, PA, or physician.

Some states consider all microneedling medical, so it's critical to verify your local laws. In nearly 73% of major U.S. cities, Med SPAs outnumber physician-operated cosmetic clinics, pointing to the increasing need for standardized regulations and qualified oversight.

Who Can Administer Chemical Peels in a Med SPA?

Chemical peels vary in intensity and depth. While superficial peels like glycolic acid can be performed by licensed estheticians, medium-to-deep peels (like TCA or phenol peels) typically require a medical license.

• Licensed Estheticians: Can administer low-concentration peels

• RNs, NPs, PAs, and Physicians: Can perform stronger, medical-grade peels

Even for lighter peels, proper skin analysis and post-treatment care are critical to prevent adverse reactions.

Who Can Operate Body Contouring Devices?

Fat Reduction, Skin Tightening, and Muscle Stimulation

Non-invasive body contouring technologies (like CoolSculpting, Emsculpt, and radiofrequency devices) often require minimal medical intervention, but manufacturers usually recommend that trained medical professionals or certified technicians perform or supervise these treatments. State laws may still classify them under the scope of medical procedures due to the use of high-energy devices. As such:

• Certified estheticians or laser technicians may be able to perform them

• Supervision by a licensed physician is still typically required

Who Can Conduct IV Therapy and Vitamin Injections?

IV hydration, vitamin drips, and B12 injections are becoming increasingly popular in wellness-focused Med SPAs. These are considered medical procedures because they involve penetrating the skin and bloodstream.

Qualified providers include:

• Physicians (MD/DO)

• Nurse Practitioners

• Physician Assistants

• Registered Nurses (under physician supervision)

Proper technique, sterile procedures, and knowledge of possible reactions are essential when offering these treatments. In August 2024, the American Med Spa Association (AmSpa) released an IV Therapy Toolkit with consent forms, treatment logs, USP 797 guidelines, and training to help Med SPAs deliver safe, compliant IV services.

Conclusion: Prioritize Safety, Licensing, and Legal Compliance

Not everyone on a Med SPA team can legally perform every treatment. Making sure services are done by properly licensed professionals is essential for patient safety, legal compliance, and your business’s success. To stay aligned with state regulations, Med SPAs must delegate procedures appropriately, operate under a licensed medical director, and maintain clear documentation for every service.

DigiMEDSPA offers two essential solutions to help you stay compliant and operate confidently:

• DigiMEDSPA Connect: Gain access to and partner with licensed medical directors who provide the required oversight for injectables, laser treatments, microneedling, IV therapy, and other regulated procedures, ensuring your Med SPA meets legal standards across the board.

• HIPAA-Compliant EMR Software: Streamline your operations with features like provider-specific permissions, procedure tracking, digital consent forms, telehealth evaluations, and detailed documentation, keeping your practice safe, organized, and audit-ready.