Medical spas in New Mexico

Injection of cosmetic or aesthetic substances is the practice of medicine, and the Medical Board's rule says it may not be delegated to medical assistants.¹ The Medical Board's policy goes further: it says delegation to medical assistants, estheticians or cosmetologists is prohibited.³

For nurses, the Board of Nursing's rule says:

- APRNs may do aesthetic procedures within their population focus, licensure, national certification and education.² - Registered nurses may do them only if delegated by, and under the indirect supervision of, an APRN or other clinical supervisor.² "Indirect" means the supervisor is outside the facility but on call, within a reasonably close distance, and able to respond and travel in.² - Licensed practical nurses may not perform aesthetic injections.²

Physician assistants and physicians are the other injectors the Medical Board names. The Board's guidance says a PA, whether collaborative or supervised, will need a supervising physician who is trained and experienced in the procedures being done when the work is not primary care.⁴

Ask who will inject you, what their licence is, and who the clinical supervisor or supervising physician is.

We found no New Mexico operator licence or facility registration for cosmetic lasers in the board sources we read. The Medical Board's rule lets a physician delegate the use of non-incisive, non-ablative devices to a certified medical assistant when the supervising physician is immediately available on the premises. It requires the physician to complete a certificate of training form and send it to the Board before the assistant uses the device.¹ The Board's policy says direct physician supervision, and its FAQ says the physician must be physically present and available, so the three wordings differ.¹³⁵

Nurses may do these procedures only as set out above.² Estheticians are licensed by the Board of Barbers and Cosmetologists, whose rule lists light therapy, high-frequency and other facial treatments and hair removal except electrolysis or invasive techniques.⁸ The Medical Board's view is that an esthetician's licence does not cover lasers or intense pulsed light, but the rule text does not say so.⁴⁵

The Medical Board's policy says microneedling, PRP and chemical peels need a physician, an APRN or a physician assistant.³ The Board of Nursing's rule names microneedling of any depth and medium-depth peels as aesthetic procedures.² The Board of Barbers and Cosmetologists' rule says an esthetician may not perform any services other than those it lists, and it bars the title "medical esthetician" as misleading.⁸

The Medical Board's IV therapy policy says IV therapy falls under the practice of medicine. It requires a compliant telemedicine evaluation by a licensed prescriber before any IV treatment, treatment ordered by a licensed prescriber on clinical need, and fluids from a properly licensed source. It says only licensed medical providers may place IVs and that medical assistants may not.⁶³ The Board of Nursing's FAQ, which is guidance, says RNs, LPNs and APRNs may give IV hydration on a valid order from a licensed independent provider, and that standing orders for elective IV therapy are not permitted.⁷ Ask who will examine you, who ordered the drip and who will place the IV.

The only New Mexico board text we found on compounded GLP-1 drugs is a Board of Nursing FAQ, which is guidance, not law. It says a nurse who prescribes compounded GLP-1 medications should confirm compounding is legally permissible, use appropriately licensed pharmacies, tell patients when a medication is compounded, and keep it patient-specific. It says prescribing based only on a questionnaire, without adequate clinical evaluation, may not meet the standard of care.⁷ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

New Mexico does not require a med spa to have a "medical director" by that name. The duties fall on a supervising physician under the Medical Board's rule and a clinical supervisor under the nursing rule.¹² The Medical Board's 2025 policy says the medical director must be a New Mexico-licensed MD or DO. Its 2024 guidance and FAQ say a nurse practitioner or PA could qualify.³⁴⁵ Any public communication that offers a cosmetic medical procedure must identify the physician responsible for it or for its direct supervision.¹

On ownership, the Medical Board's policy says New Mexico allows non-physician ownership of med spas, but that all medical procedures must be overseen by a supervising physician.³ A 2025 bill that would have created a Corporate Practice of Medicine Act died.⁹ The Board of Nursing says a facility that is not owned and operated solely by exempt licensed practitioners may be a "clinic" that needs a limited drug permit from the Board of Pharmacy. We do not know whether the Board of Pharmacy applies that to med spas.⁷

Since 21 May 2024, a Board of Nursing rule covers nurses working in aesthetic healthcare facilities, meaning any business that provides aesthetic procedures to the public. It defines aesthetic healthcare procedures to include laser and energy-based hair removal, intense pulsed light, ultrasound and radiofrequency devices, microneedling of any depth, injection of soft tissue fillers, PDO threads or neuromodulators, IV therapy, medium-depth chemical peels and hormone pellet insertion.²

Licensees may work in such a facility only if it employs a clinical supervisor: an advanced practice registered nurse (APRN) or another licensed independent practitioner who is responsible for supervising all aspects of the facility's clinical practice, including protocols and clinical staff. A registered nurse or licensed practical nurse may not be the clinical supervisor.²

Before any aesthetic procedure, an APRN or other licensed independent practitioner must examine the patient face to face, make a diagnosis and prescribe a treatment plan. The rule says that examination, diagnosis and plan may never be delegated. Telemedicine may be used if the video does not reduce the quality of the assessment.²