Medical spas in Colorado

A physician may inject personally and may delegate under Rule 1.17.¹² Physician assistants (PAs) need a collaborative agreement with a physician or physician group and may act within their education, experience and competency, including prescribing. A PA may delegate to unlicensed people acting under the PA's direct supervision, within the services the PA has been delegated.¹²

APRNs on the state registry may be authorised to prescribe. They must have a safe way to consult or collaborate with a physician.³ The Nurse Practice Act names no cosmetic injection for APRNs. The one medical-aesthetic provision is the notice duty above.³

Rule 1.17 does not govern registered nurses. Their work falls under the Nurse Practice Act, which lets an RN delegate tasks within the RN's scope but not the authority to select medications.²³ We found no Board of Nursing opinion on nurses injecting neurotoxin or fillers.¹⁶ Whether an RN may delegate injections to unlicensed staff is not settled by the text we read. We found no Colorado rule specific to licensed practical nurses injecting.

Dentists may order and administer neuromodulators and dermal fillers to their patients of record, for therapeutic and cosmetic purposes. Hygienists may do so under a dentist's direct supervision or a physician's delegation.¹²

Rule 1.17 says a person who is delegated work must not use "Dr." or "doctor", and an aesthetician must not use "medical" in a title, such as "medical aesthetician", unless licensed to do medical services.² Ask who will inject you, what licence they hold, and which physician or nurse practitioner delegated the work.

Under Rule 1.17, Class IIIb or higher lasers, intense pulsed light, radiofrequency devices and laser hair removal are medical-aesthetic services. They may be done by a physician, by another licensed provider within scope, or by a person delegated under the rule. Class I, II and IIIa devices are not medical services under the rule.²

The Medical Board's laser policy says laser surgery is the practice of medicine and that electrolysis is not. It is printed with both a "Repealed: Effective 11/16/2023" line and a 2024 revision date, so we cannot say whether it is in force.¹¹ We found no state laser operator licence, certificate or facility registration.

Estheticians complete 600 contact hours. Their scope is skin care, makeup and hair removal by depilatory, wax or tweezers, and, since 12 August 2026, body wraps, and it is "not for the treatment of disease".⁷ Under the Office of Barber and Cosmetology's hearing draft, an esthetician who has had extra training may use cosmetic resurfacing substances and microdermabrasion. The draft bars estheticians from anything that goes beyond the epidermis, and from Class IIIb or higher devices outside their intended use, unless medical work is delegated to them.⁸ The draft is not yet the rule. The hearing is on 3 November 2026.⁹

A place that offers esthetician services must be registered with the state.⁷ We found no Colorado microneedling rule.

We found no Colorado statute, rule or board statement on IV hydration or IV bars. The spokesperson quoted by Rocky Mountain PBS said such clinics are not regulated by the state.¹⁵ Only a licensed prescriber can prescribe, and delegation under Rule 1.17 cannot cover prescribing.² The Board of Nursing policies we read do not mention cosmetic or hydration IV work.¹⁶ Ask who will examine you before the drip, who ordered it, and who will place the IV.

No Colorado statute we read names semaglutide or tirzepatide. A 2026 law, HB26-1262, added to the Pharmacy Practice Act that, if done "in accordance with applicable federal and state law", a licensed person may compound a drug, a state-licensed pharmacy or a federal outsourcing facility may supply it to a licensed provider, and a licensed provider may obtain, dispense or administer it.⁵⁶ A practitioner may also personally compound and dispense a drug for a patient under their care.⁵ We found no Board of Pharmacy, Medical Board or Board of Nursing statement on compounded weight-loss drugs. The Board of Pharmacy held a rulemaking hearing on compounding on 1 October 2026, and we did not find its outcome. Federal rules on compounded drugs are outside this page.

The Medical Board's policies define a provider-patient relationship that includes identity checks and informed consent, "whether or not there has been an in-person encounter".¹¹ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

No Colorado statute uses "medical director" for a med spa. Rule 1.17 speaks of the delegating physician, and of any agreement a physician enters into "in order to serve as a medical director" as a document to keep.¹²

Colorado has a corporate-practice rule. Professional corporations that practise medicine may have only physician shareholders, except that PAs may hold a minority. The statute says "Corporations shall not practice medicine," and lay directors may not exercise authority over a physician's independent medical judgment.¹ A PA may not own a majority of a medical practice.¹ A 2026 bill to let PAs, nurses and estheticians own medical-aesthetics corporations, HB26-1249, was postponed indefinitely on 25 March 2026.¹⁴ We found no Colorado statute, opinion or case on management-company arrangements.

Colorado's Medical Practice Act defines the practice of medicine broadly. It exempts services, other than prescribing drugs, rendered by people qualified by experience, education or training under the personal and responsible direction and supervision of a licensed physician.¹

Medical Board Rule 1.17 builds on that exemption. It defines medical-aesthetic services as including the use of a Class IIIb or higher laser, radiofrequency device or intense pulsed light, or another technique that alters tissue or removes hair, and the injection of any substance.² A physician may delegate those services to a qualified person who is not licensed. The physician must be qualified, insured, actively perform the service and be available in the community, which means physically in Colorado, with telehealth allowed but not alone. The rule also requires the physician to:²

- watch the person work before authorising work outside the physician's presence; - reassess the person at least once a year; - monitor quality at the site on a set schedule; - review and initial each chart within fourteen days, unless the encounter was the same day; and - write procedure and emergency protocols.

The physician must have a written agreement with the person, and it must be available to the public at the site. A physician must be on the premises and readily available, though with specific written protocols presence may not be necessary, and a named covering physician is needed when the physician is away. Delegation cannot cover prescribing drugs. A person who has been delegated work cannot pass it on.²

So Colorado does not limit injections and laser treatments to licensed nurses. Unlicensed staff may do them under a physician who has taken on the delegation.

Since 6 August 2025, a physician or an advanced practice registered nurse (APRN) who delegates medical-aesthetic services to someone who is not a licensed health care provider must post a notice at the location. They must also put a delegation notice with the physician's name and licence number on the unlicensed person's website and advertising, get a signed informed consent, and keep it for seven years. The duty does not apply to facilities regulated under the state's health-facility title.¹³²⁰

Since 1 June 2026, an advertisement for health care services that names a practitioner must state the type of state licence the practitioner holds.⁴

There is no statewide tattoo artist licence in the sources we read. Since 12 August 2026, cosmetic tattooing on the face, including microblading of eyebrows, by tattoo artists is outside the Barber and Cosmetologist Act.⁷¹⁰ Under the hearing draft, estheticians and cosmetologists may do facial permanent makeup after 132 contact hours of training.⁸ So permanent makeup in Colorado is not limited to medical providers. Rule 1.17 says tattooing and permanent makeup are not medical services.²

Counties license body-art facilities. Weld County, for example, licenses tattoo and piercing facilities, including permanent makeup studios.¹⁹