Medical spas in North Carolina

The practice of medicine includes giving or prescribing any drug or medicine for another person. The law lets a physician delegate to "a qualified person" acts that are otherwise permitted by law or established by custom.¹ Neither neurotoxins nor fillers are named in the statute or the Medical Board's position statements. We found no Board statement on whether an unlicensed person may inject under a physician's delegation.

Physicians may inject. The Board expects a licensee to base novel or off-label use on sound published evidence, and calls prescribing from answers to a set of questions inappropriate.²

Physician assistants (PAs) work under a physician's supervision, which is continuous but does not require the physician to be present. The supervising arrangement is written and signed by both.³⁴ Since 30 June 2026, a PA with more than 4,000 hours of practice, and more than 1,000 in the specialty, may practise in a team-based setting without a supervising physician after registering with the Board.¹⁵²⁶ Whether a team-based PA may work in a med spa not owned by physicians is not settled by the texts we read.

Nurse practitioners prescribe only with a supervising physician who gives written instructions and a policy for periodic review.¹

The Board of Nursing says cosmetic procedures, including neuromodulator and dermal filler injections, are within an RN's scope as prescribed or ordered by a physician, nurse practitioner, PA or other prescriber. The prescriber's presence on site is not required, but the prescriber must complete the client evaluation and issue the order. A licensed practical nurse needs on-site supervision. Where a client walks in with no prior prescriber evaluation, a nurse may do these procedures only if also licensed under the Electrolysis Practice Act or the Cosmetic Art Act.⁶

Medical assistants are not licensed and have no scope of practice set by the Board of Nursing. They may work under delegation from licensed providers if all applicable laws permit it.⁸

The Dental Board's interpretive statement says a properly trained general dentist could use Botox to treat a diagnosed dental condition, and that purely cosmetic facial procedures may be outside the scope of dentistry.⁹

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

The Medical Board's position is that laser surgery, meaning revision, destruction, incision or other structural alteration of tissue, should be done only by a physician or by a licensed professional with appropriate training under a physician's supervision, preferably on site.² Its guidance says hair and tattoo removal with lasers should be done only by a physician or a person a physician designates as trained, and that a physician, PA or nurse practitioner should examine each patient before the first treatment.²¹⁰

Laser hair removal has its own licence. A laser hair practitioner must be a licensed electrologist who has completed a Board-approved course of at least 30 hours, and must practise under a physician's supervision. The physician must be readily available but not on site. Only a physician may use these devices for ablative procedures.¹¹ Electrologists with this licence may not remove tattoos.²

The Board's guidance on lasers says only a physician, PA, nurse practitioner or licensed laser hair electrologist may own a laser business. A lay owner may sell the laser, manage the office for a fee, or employ operators at a salary or hourly wage, but may not split per-procedure fees.¹⁰ We found no laser registration or facility licence.

A North Carolina esthetician is licensed for skin care only, and the Cosmetic Art Act does not apply to people authorised to practise medicine and to nurses while doing their professional duties.¹² The Cosmetic Art Examiners' ruling says esthetics does not include any practice that constitutes the practice of medicine, and bars any product, device or technique that penetrates the skin beyond the epidermis. It names devices in FDA classes 3 to 4 and other radiation-emitting devices as outside an esthetician's scope. It says licensees may not refer to their practice as "Medical" or "Master".¹³

The Board of Nursing says RNs and LPNs may give IV fluids and medications on a valid order from a physician, nurse practitioner, PA or other prescriber, including at walk-in or mobile hydration clinics and drip bars. The nurse needs an individualised order and a completed client evaluation. A business must keep policies on site for giving IV treatment and for emergencies. An independent walk-in client still needs an individualised order. Standing orders are not client-driven.⁷

North Carolina's pharmacy law defines a pharmacy as any place where prescription drugs are dispensed or compounded.¹ Whether a nurse adding vitamins to a saline bag at a clinic is compounding under that law is not settled by the sources we read.

We found no North Carolina board statement on compounded semaglutide or tirzepatide. A pharmacy may supply compounded drug products to practitioners for office use if it complies with federal law, but compounded preparations may not be offered for resale.¹⁷ A physician who dispenses prescription drugs for a fee must register with the Board of Pharmacy, and a dispensing physician may not compound for dispensing.¹¹⁸ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

No North Carolina statute uses the term medical director for med spas.¹ The Medical Board's Position Statement 10.1.2 says businesses practising medicine in North Carolina "must be owned in their entirety by persons holding active North Carolina licenses", and the Board may seek an injunction against lay owners.² A professional corporation may be formed by a physician and a PA, by a physician and nurse practitioners and certain other advanced nurses, or by nursing professionals for nursing services.¹⁴ The Board's practice ownership FAQ says a PA may own a majority of a practice with physicians, and a practice owned only by PAs may not hire physicians.¹⁵

A Board article calls a paid "medical director" with a minimal role in a lay-owned practice a licensee aiding the unlicensed practice of medicine.¹⁶

No person may tattoo without a permit from the Department of Health and Human Services, issued through the local health department. A physician, and a PA or nurse practitioner under a physician's supervision, is exempt. The permit does not authorise tattoo removal.¹⁹ County pages say microblading and permanent makeup need the tattoo permit.²⁰