Medical spas in South Carolina

A joint advisory opinion of the Boards of Dentistry, Medical Examiners and Nursing (last revised in October 2022) says three things about cosmetic neuromodulators such as Botox. A bona fide practitioner relationship must be established by a physician, physician assistant (PA) or advanced practice registered nurse (APRN), and cannot be established by a registered nurse (RN). Cosmetic use is a delegable act, and the physician, dentist or APRN must be on site and readily available. An RN may inject a cosmetic neuromodulator only with on-site supervision by a physician or APRN.¹

For dermal fillers, the Board of Nursing's Advisory Opinion 39 gives RNs the same frame: documented training, written facility policies, a physician or APRN assessment, and a physician or APRN who is immediately available on site and able to respond within five minutes.²

South Carolina law also says what a certified medical assistant cannot be given. A PA or APRN may not delegate to a certified medical assistant the injection of neurotoxin products, neuromodulatory agents or tissue fillers. The statute does not mention delegation by a physician.³ We found no source that lets a licensed practical nurse inject cosmetic neuromodulators or fillers.

The Board of Medical Examiners has a process by which a PA adds aesthetic procedures to their scope, with proof of competency for both the PA and the supervising physician.²⁵ A PA must wear a badge with their name and the words "Physician Assistant", "PA-C" or "PA".⁵ Prescribing based solely on answers to a set of questions is unprofessional conduct.⁴ Ask who will inject you, what their licence is, and who the physician or APRN on site is.

The Board of Medical Examiners' guidance says lasers, pulsed light and radiofrequency devices used for ablative and non-ablative treatment are surgery and the practice of medicine. It recognises that their use may be delegated to appropriately trained and licensed PAs and nurse practitioners, and that physicians, PAs and nurse practitioners may delegate non-ablative treatments to others when state law permits. Practitioners must examine each patient before any initial treatment or before authorising treatment by a non-physician.⁶

The Board's June 2025 summary says RNs may perform them under the direct supervision of a physician, APRN or PA.⁷ The Board of Nursing's Advisory Opinion 81 (March 2026) says an APRN may delegate non-ablative procedures to an RN, with a supervising physician or APRN on site and able to respond within five minutes. It gives laser hair removal and spider vein laser treatment as examples of non-ablative lasers.⁸

The Board's summary also lists certified medical assistants for non-ablative lasers under direct supervision. State law bars a PA or APRN from delegating "lasers or instruments that results in tissue destruction" to a certified medical assistant. The two do not obviously agree, and we have not found a source that settles it.³⁷ We found no South Carolina laser operator licence or certificate.

The Cosmetology Act defines an esthetician as licensed to practise skin care, make-up or similar work, and says skin care is for the sole purpose of beautifying the skin.⁹ The Act and the regulation we read do not name lasers, peels, microneedling or injectables for estheticians, so what they may do is not settled by the text. A bill in committee, S. 539, would create an advanced esthetician licence with microneedling, dermaplaning and peels. It is not law.¹⁰ For RNs, Advisory Opinion 39 treats superficial peels and microdermabrasion as additional acts requiring documented training.²

The three boards' joint statement on retail IV therapy says diagnosing, recommending and prescribing IV treatment is the practice of medicine and that only a physician, PA or APRN may order it. It says standing orders in a walk-in menu model do not satisfy the law, that an RN may administer an IV only after a valid prescription from a physician, PA or APRN, and that licensed practical nurses may not take part. Adding drugs or vitamins to an IV bag is compounding. A site that stores prescription drugs needs a Board of Pharmacy permit unless it is entirely owned by physicians, APRNs or PAs.¹¹ It is a position statement, not a rule. Ask who will examine you, who ordered the drip, and who will place the IV.

A Board of Medical Examiners notice says a physician may not compound, administer, prescribe or dispense research-grade or FDA-ineligible peptides, including semaglutide, and may not delegate them to APRNs or PAs. It says practitioners must buy prescription products from entities licensed by the Board of Pharmacy.¹² The notice's text is undated.

State law lets physicians who administer compounded medications in an office order them from a compounding pharmacy and store them for future administration, not for resale.¹³ The Board of Pharmacy has approved proposed compounding regulations, open for comment until 23 November 2026, that are not yet in force.¹⁴ The Attorney General's January 2025 consumer alert says compounded tirzepatide and semaglutide sold by compounding pharmacies, med spas, wellness centers and online retailers are not FDA approved, and that compounded drugs can be appropriate when a consumer cannot access an approved drug and a physician prescribes them. It is a consumer alert, not a rule.¹⁵ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

South Carolina law does not use "medical director" for med spas. The retail IV statement says a physician, PA or APRN may be called a "medical director" or "on staff", but that if only the RN treats the patient that is insufficient to establish a valid practitioner-patient relationship.¹¹ The Board of Medical Examiners' advisory opinion on the corporate practice of medicine says the Board does not license corporations, that a licensee must control their clinical judgment at all times, and that it is unlawful and unprofessional for a licensee to permit an unlicensed person to direct, participate in or interfere with the licensee's practice of medicine.¹⁹ Professional corporations may render professional services only through licensed individuals.²⁰

In South Carolina, permanent makeup is a medical service. The Code makes it unlawful for a tattoo artist to tattoo any part of the head, face or neck.¹⁶ The Department of Public Health's FAQ says tattoo artists cannot perform microblading, permanent makeup or micropigmentation, which are reserved to physicians or other legally authorised health care providers, and that tattoo removal is outside a tattoo artist's authority.¹⁷ The Board of Medical Examiners' 2005 policy says permanent cosmetics can be performed only under a physician's direction, and that the physician must directly supervise the person performing the procedure and be on site.¹⁸