Medical spas in Louisiana

Louisiana has no statute that names Botox or fillers. The Board of Medical Examiners' 2001 statement on lasers and chemical skin treatments says its position applies equally to "the injection or insertion of foreign or natural substances or soft tissue augmentation".³ The Board's rule bars a physician from any arrangement, "as medical director or otherwise", that lets an unlicensed person practise medicine unless the physician is physically present on the premises at all times that person is on duty.¹

The Board of Nursing's 2011 declaratory statement covers registered nurses. A registered nurse may give Botox or similar FDA-approved products for cosmetic purposes when a licensed prescriber orders it. The prescriber, a physician or nurse practitioner, must do the history, examination, diagnosis and consent, and must be physically present on the premises and immediately available at all times. The work must be done in a medical facility or medical office. The statement says a registered nurse's scope excludes all dermal fillers.⁴ It is guidance, and says declaratory statements do not have the force of law. It also says a registered nurse may apply standing orders and protocols for each procedure prescribed, while the Board of Medical Examiners calls standing orders for IVs unlawful (see IV drips). The two boards' statements do not line up, and the sources do not say which a clinic should follow. It also treats cosmetic work as a nurse practitioner sub-specialty that needs a collaborative practice agreement with a physician approved by the Board.⁴¹²

A physician assistant may do services the supervising physician delegates within the assistant's education, training and licence. The rule does not require the physician to be present in every case, but the two must be able to contact each other, and the level and method of supervision are set in writing and reviewed each year.¹¹ No text we found settles whether an injection delegated to a physician assistant is governed by that rule or by the on-site laser rule. We found no Louisiana statement on licensed practical nurses and cosmetic injections, and no medical assistant licence or scope rule. A licensed esthetician's work in a salon may not include anything that penetrates the dermis.⁵

Ask who will inject you, what their licence is, and which physician is responsible for your treatment.

The Board's rule is the one that matters here. The use of laser, pulsed light or similar devices, for invasive or cosmetic procedures, "is considered to be the practice of medicine" and is limited to physicians, podiatric physicians and qualified additional personnel directly supervised by a physician on the premises who would be directly involved in the treatment if required.¹ The Board's definition of surgery includes the use of lasers and "any elective procedure for aesthetic, reconstructive or cosmetic purposes".¹ The rule's note dates it to June 2025.

The Board's 2001 statement reached the same view earlier. Non-physicians may do laser and chemical treatments only under the immediate personal supervision of a Louisiana physician who is physically present on the premises and immediately available, and a "medical director" in title only does not meet it.³ A 2021 House resolution had said physicians' "designees" may operate certain lasers with a signed authorisation and asked the Board for rules.⁸ The resolution is not law, and the rule asks for more: a physician on the premises.

For nurses, the Board of Nursing's 2011 statement lets a registered nurse do non-ablative laser treatments, including laser hair removal, on a qualified prescriber's order, with that prescriber physically present and immediately available. Ablative laser is outside a registered nurse's scope. The statement also treats cosmetic work as an advanced practice nurse sub-specialty that needs a Board-approved collaborative practice agreement.⁴ The cosmetology board's rule bars every cosmetology and esthetics licence from using lasers in a licensed salon.⁵ We found no Louisiana licence or certificate for laser operators and no required training hours. If you are booked for a laser or light treatment, ask who will run the device, which physician is responsible, and whether that physician will be on the premises.

The Board's rules on surgery in a physician's office also reach lasers, but exempt surgery done with only local, topical or regional anaesthesia. The text does not settle whether a practice that only does cosmetic lasers must file the annual report those rules require.¹

Louisiana's cosmetology rule lists the esthetic services as makeup application, facials, superficial chemical peels, dermaplaning, microdermabrasion, nano-needling and similar services performed on the epidermis. It says an esthetician "shall only exfoliate or perform services which affect the epidermis". A licensed salon may not do micro-needling, micro-blading, deeper acid exfoliation, anything that penetrates the dermis, or use any FDA-classified medical device.⁵ Where a deeper peel or a medical device is used, the Board of Medical Examiners' 2001 statement treats chemical skin treatments by non-physicians as the practice of medicine that needs a physician's immediate personal supervision.³ Ask who will do the treatment, what their licence is, and whether a physician or nurse oversees it.

The Board of Medical Examiners' August 2024 statement says diagnosing a patient's condition and then recommending and giving IV therapy "unambiguously constitutes the practice of medicine". A real patient relationship is required and may be in person or by telemedicine. Standing orders directing IVs are "inappropriate and unlawful". Registered nurses may carry out patient-specific orders from a physician who has done an appropriate evaluation before treatment, and independent diagnosis or prescription of IV therapy by nurses or other personnel exceeds their scope. Menus or checklists offered by people without prescriptive authority violate the Medical Practice Act. Nurse practitioners and other advanced practice nurses with prescriptive authority may diagnose and manage within a collaborative practice agreement, and physician assistants may recommend IV therapy within a delegated scope. The statement names mobile clinics as part of the retail IV hydration model. It also says IV fluids are medications, and that mixing additives is compounding that must follow federal rules.⁶ The Board of Nursing allows a registered nurse to delegate set IV tasks to a licensed practical nurse with 30 hours of IV training.¹⁵ Ask who ordered the drip, who evaluated you, and who will place the IV.

We found no Louisiana Medical Board or pharmacy board statement on semaglutide or tirzepatide. The Medical Board's IV statement quotes the statute that lets Louisiana physicians compound and dispense medications to their patients if they meet standards akin to those pharmacists use, and says the pharmacy board requires a patient-specific prescription for pharmacist compounding.⁶ The Board's rules limit a physician assistant's treatment of obesity with controlled substances.¹¹ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

We found no Louisiana med spa statute, licence or registry. The only bill we found, Senate Bill 199 of 2020, would have created duties for a medical spa medical director and an on-site supervising physician. It was withdrawn from the files of the Senate on 9 March 2020.⁹ No law or rule defines a medical director. The Board's rule bars a physician from lending a medical director title to let an unlicensed person practise.¹

On ownership, the Board's December 2024 statement says a physician's employment by a corporation other than a professional medical corporation "is not per se unlawful". The corporation's management must not interfere with the physician's medical judgment, and one that controls how a physician provides medical services would be engaging in the unauthorized practice of medicine. The statement says medical corporations organised under the state's Professional Medical Corporations Act must be owned and governed exclusively by physicians. The Board treats other arrangements, such as compensation, case by case.⁷ A statement of position is not law, though the Board says people may rely on it. Whether a particular med spa is organised lawfully is a question for a health-care lawyer.