Medical spas in Kentucky

No Kentucky statute we read names Botox or fillers as work for doctors or nurses. The one that names Botox is the esthetician statute above.¹ The practice of medicine is defined as treating any human condition "by any and all means, methods, devices, or instrumentalities".²¹

The Board of Nursing's opinion covers nurses. A registered nurse may do cosmetic and dermatological procedures under the supervision of a qualified healthcare provider, meaning a physician, advanced practice nurse, physician assistant or dentist, and may use standing orders or protocols that provider has set. Here supervision means the provider is on the premises or readily available by telephone.³¹⁵¹⁶ The opinion says it is not within a registered nurse's or practical nurse's scope to "independently practice, order products, prescribe treatments" or to perform medical aesthetic procedures such as Botox or dermal fillers independently. Its chart marks Botox-type injections for practical nurses, registered nurses and advanced practice nurses, and fillers for registered nurses and advanced practice nurses only. A practical nurse works under direct supervision, with the provider in the immediate patient care area and available to step in.³¹⁶¹⁸ The opinion is advisory and says it does not have the force and effect of law.³ It also says the provider must establish a practitioner-patient relationship and examine the patient in good faith before ordering a course of treatment.⁵

An advanced practice nurse may provide aesthetic services "provided the professional scope of practice indicates that such services could be within their role and population focus".³ To prescribe non-scheduled prescription drugs they need a written collaborative agreement with a Kentucky physician, for the first four years of prescribing under the statute's terms.¹⁴

A physician assistant may perform the services described in a supervision agreement with a physician, and may prescribe non-scheduled prescription drugs to the extent the supervising physician approves.¹² Supervision does not require the physician to be physically present.¹⁰ Under Senate Bill 116 (2026), in effect from 15 July 2026, the agreement must be signed before the assistant renders any service, and a physician may supervise no more than four assistants. The bill kept the supervision model.¹¹¹³ No text we read names Botox or filler injection as a physician assistant's work or bars it. It follows the agreement.

We found no Kentucky licence or scope rule for medical assistants. The three boards' joint statement, written about IV therapy, says a licence is not a "plus one": a licensee may not "train and delegate" their scope to an unlicensed person.⁷ A nurse may delegate a task to an unlicensed person only if it does not need "independent nursing judgment or intervention".¹⁶ We found no medical board opinion on an unlicensed assistant injecting.

Ask who will inject you, what their licence is, and which provider examined you and ordered the treatment.

We found no Kentucky licence or registration for people who operate lasers or light devices, in the statutes and regulations we searched. The one statute that speaks to it is the esthetician statute: an esthetician may do laser work only with a physician in the same room.¹²

The Board of Medical Licensure's 2011 opinion on laser surgery counts high-intensity pulsed light as a laser. It says a physician may delegate certain procedures to "certified or licensed non-physician" staff who have documented laser training, with the physician on site and immediately available, except for hair removal.⁶ For hair removal, the opinion says there must be a responsible physician for each patient, and that off-site treatment may be allowed. Staff need a laser course and a minimum of 30 cases under the direct supervision of the facility's medical director, and an annual competence review.⁶ A 2004 note in the same opinion says laser hair removal is within nursing scope for a nurse with the preparation and competence, under medical supervision. The opinion is not a statute or regulation and does not have the force of law.⁶

The Board of Nursing's chart marks non-ablative laser and pulsed light, including non-ablative laser for hair removal, for practical nurses, registered nurses and advanced practice nurses.³ The opinion contradicts itself on ablative lasers. Its text lists ablative laser among procedures outside registered and practical nursing, and its chart marks fractionated ablative laser for registered nurses and advanced practice nurses. It does not reconcile the two.³

For estheticians, a cosmetology rule also bars FDA prescription devices unless a physician is in the same room, and within that physician's scope. It separately bars any procedure in which tissue is "cut or altered by laser energy".² The rule does not say how that sits beside the statute's physician-in-the-room exception.

Here the sources conflict. The medical board's opinion lets a physician delegate laser hair removal to "certified or licensed" staff with the physician off site. The cosmetology statute lets an esthetician do any laser work only with a physician in the room. Neither text covers a person who is neither a nurse nor an esthetician, such as a laser technician with no licence. The sources we read do not settle whether that person may do laser hair removal. Ask who will run the device, what their licence or certificate is, and whether a physician will be in the room, in the building or reachable by phone.

Kentucky's esthetic practices include cleansing, exfoliating, facials, makeup and removal of superfluous hair, and care before and after surgery "either referred by or supervised by a medical professional".¹⁹ An esthetician must work in an establishment licensed by the Board of Cosmetology.²⁰

The cosmetology rule narrows it. Dermaplaning is for basic exfoliation only, with documented training. Blades, dermabrasion and microneedling are barred except basic exfoliation, advanced extraction of impurities with a small lancet, and advanced dermaplaning under a physician's direct supervision. Limited chemical exfoliation has set strength limits. Stronger acids, including phenol and any acid that needs a prescription, may be used only under the direct supervision of a licensed health care practitioner, which the rule defines as within immediate distance, such as on the same floor. A licensee may not use anything that pierces the skin beyond its basal layer. The rule says "medical procedures shall not be performed by an esthetics or cosmetology licensee". Clients must be told chemical exfoliation is for cosmetic and not medical purposes.²

For nurses, the Board of Nursing's chart marks light peels for practical nurses, registered nurses and advanced practice nurses, medium-depth peels for registered nurses and advanced practice nurses only, and phenol peels as outside registered and practical nursing.³ Ask who will do the treatment, what their licence is, and whether a physician or nurse oversees it.

The three boards' joint statement of 28 March 2025 says that diagnosing a condition that leads to an order for IV drugs, amino acids or vitamins is "unambiguously the practice of medicine", and that storing and giving them is also the practice of pharmacy and nursing. Only a physician, physician assistant or advanced practice nurse may diagnose and recommend IV treatment. A registered nurse recommending an IV "cocktail" is outside nursing scope. A "medical director", "on staff" or "available" practitioner is "insufficient to establish a valid practitioner-patient relationship" where only the nurse treats the patient. Standing orders from a practitioner do not satisfy the practitioner's duties to the patient, and the boards caution against standing orders that let unlicensed staff exercise discretion.⁷

The statement also says IV fluids are prescription drugs that must be bought under a qualified practitioner's authority, and that adding drugs or vitamins to a prescription IV bag is compounding that must follow the Board of Pharmacy's laws. Non-practitioners, including registered and practical nurses, may not possess or store prescription drugs, including overnight in a home or vehicle.⁷

The Board of Nursing says IV hydration clinics, mobile or freestanding, "are not regulated" in Kentucky, and that a nurse may give an IV only on a qualified provider's order. It also limits how many products a nurse may add to a bag.⁸ The Cabinet for Health and Family Services licenses ambulatory infusion agencies.⁹ The sources we read do not settle whether a retail IV clinic counts as one.

The sources also differ on practical nurses. The Board of Nursing's chart marks hydration and vitamin therapy for registered nurses and advanced practice nurses only, while a Board of Nursing regulation lets a practical nurse perform infusion therapy after training, under the direction and supervision of a registered nurse, advanced practice nurse, physician assistant, physician or dentist.³¹⁷ Ask who ordered the drip, who examined you, and who will place the IV.

The Board of Pharmacy says that in general, compounding pharmacies may not compound semaglutide or tirzepatide, which are commercially available, and that compounding them "is allowable only in certain narrow circumstances". It says FDA's period of enforcement discretion has ended for a state-licensed pharmacy or physician compounding them.²² Its November 2025 alert says outsourcing facilities "generally may not lawfully compound these drugs", and that a pharmacy dispensing unapproved drug products may face discipline.²³ We found no Kentucky text on a physician dispensing these drugs in the office. The Board of Medical Licensure's rule on amphetamine-like appetite suppressants does not mention them.²⁴ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

Kentucky has no med spa statute, licence or registry that we found. House Bill 340 (2022) would have defined a medical spa and required a licence from the Board of Cosmetology. It passed the House 77-19 and was sent to a Senate committee, and the legislature's record shows no later action.²⁵ House Bill 885 (2026), on cosmetology, passed the House and went to a Senate committee on 27 March 2026, with no later action shown.²⁶

No statute or rule we read requires a med spa to have a medical director or defines one. The Board of Nursing says an advanced practice nurse who meets the educational and experience requirements "may own a med spa and function as the medical director", and is expected to be prepared and competent to perform cosmetic and dermatological procedures.⁴⁵ The joint IV statement says a "medical director" on paper does not make a valid practitioner-patient relationship where only the nurse treats the patient.⁷

On ownership, the Board of Nursing says nursing law does not prohibit a nurse from owning a practice, that such a practice "may need to be licensed by the Kentucky Board of Cosmetology", and that it has no jurisdiction over healthcare facilities, which the Cabinet for Health and Family Services oversees.⁵ The joint statement says neither a business nor a business owner "can lawfully exercise control over the independent professional clinical judgment of a licensed healthcare professional".⁷ Whether a particular med spa is organised lawfully is a question for a health-care lawyer.