Medical spas in Texas

Texas has no list of the licence types that may inject. A physician may delegate a medical act to "a qualified and properly trained person" who works under the physician's supervision.⁷ The Board's rules add conditions. The person must have training in the technique, the reasons not to do the procedure, and spotting and managing complications, and must sign a written protocol.²

Before the procedure, a physician, or a physician assistant (PA) or advanced practice registered nurse (APRN) acting on the physician's delegation, must establish a practitioner-patient relationship, keep a medical record, tell you the identity and title of the person who will treat you, and make sure someone trained in basic life support is present while you are there.² A physician, PA or APRN must be onsite during the procedure or immediately available for emergency consultation, and the physician must be able to see you in an emergency appointment if needed.²⁵ A business may work from a written order covering the whole facility if the delegating physician has approved it in writing. The order must name the delegating physician and set out how patients are screened, what appropriate care is and what happens in a complication or emergency.³

The rules leave two things open. They do not say whether a first treatment needs an in-person examination or whether a remote review can satisfy the "practitioner-patient relationship" requirement. And the Board's determination "does not include" procedures "performed at a physician's practice by the physician or physician assistant or advanced practice registered nurse acting under the physician's supervision".¹ We found nothing that says where that line falls for a clinic owned by a physician but staffed by delegates.

The Board of Nursing has no list of cosmetic tasks a nurse may do. It says each nurse must use sound judgment, and that a registered nurse (RN) should not do a cosmetic procedure without the education and skill, an appropriate order, and appropriate nursing or medical supervision. Its checklist asks whether the ordering provider is on site.⁹ A nurse stays accountable as a nurse for what they do at a med spa.⁹ For licensed vocational nurses (LVNs) the Board's FAQ gives the same checklist, adds that on-the-job training cannot raise an LVN to the level of care of an RN or APRN, and does not say whether an LVN may inject. The statute and the Board's FAQ word the supervisors of an LVN differently, so ask who supervises the person treating you.⁹¹⁴

A PA provides medical services delegated by a supervising physician, within the PA's education, training and experience, and wears a name tag that identifies them as a PA.¹¹ A PA or APRN who prescribes does so under a written prescriptive authority agreement with a physician, and a physician may have such agreements with at most seven PAs and APRNs together, with some exceptions.¹² An APRN may do only what is within their Board-authorised scope and training, and the Board of Nursing says what a physician delegates to an APRN cannot be delegated onward by the APRN to others.¹³¹⁰

Medical assistants are a gap. We found no Texas source that says whether a medical assistant may inject neurotoxin or filler, or that rules it out. The general rule is that the person must be qualified, trained and under a physician's supervision.⁷² Ask who will inject you.

Laser hair removal is a licensed activity run by the Texas Department of Licensing and Regulation, not the health department. A person who performs it needs an individual certificate, at one of four levels, from apprentice-in-training to professional.¹⁸²⁰ Each laser hair removal location needs a facility licence and a written contract with a consulting physician, whose primary practice site must be within 75 miles.¹⁸¹⁹ There are exceptions. A facility "owned or operated by a physician for the practice of medicine" is exempt from the facility licence. A licensed health professional working within their own board's scope does not need the individual certificate, and nor does a physician or a physician's employee or delegate.¹⁸ The certificate covers only non-ablative hair removal.¹⁸

For other cosmetic lasers and intense pulsed light (IPL), we found no operator certificate. These are delegated medical acts.¹ The Department of State Health Services' rule says lasers and IPL devices must not be used on people unless under the supervision of a licensed practitioner of the healing arts and within the scope of that practitioner's licence.²¹ The Board of Nursing says it may be within a nurse's scope to deliver laser energy on a valid order, if the nurse has the education, and that a nurse cannot delegate any aspect of laser use to an unlicensed person.¹⁰ An esthetician or cosmetology licence does not cover lasers.²²

Estheticians are licensed by the Department of Licensing and Regulation and may work only at an establishment it licenses. Their rule bars any product, preparation or procedure that "comes into contact with or penetrates the dermis layer of the skin".²⁴²² The Department says light or superficial peels and microdermabrasion that removes only dead cells from the outer layer are within an esthetician's licence, while medium and deep peels are medical procedures regulated by the Medical Board.²² Its summary table assigns microneedling and platelet-rich plasma facials to the Medical Board, and sorts dermaplaning by tool: with a razor it falls under the Department's own barber licence, and with a medical scalpel under the Medical Board.²³

For body contouring the same table says "Texas Medical Board, some are unregulated, DSHS for certain equipment". It lists body wraps and eyebrow threading as not regulated.²³ A physician cannot delegate cosmetology, the Department says, only medical procedures.²² If you are booking a peel or microneedling, ask who will do it and what their licence is.

Since 1 September 2025 Texas has a law for elective IV therapy: an IV sought to relieve temporary discomfort or improve temporary wellness, and not given in a physician's office or a licensed health facility. A physician may delegate ordering it to a PA or APRN, and giving it to a PA, APRN or RN, each acting under adequate physician supervision. LVNs are not on the list.¹⁵ The Medical Board's FAQ puts it the same way: the drip must be ordered by a physician or a PA or APRN under supervision, and given by "a licensed professional nurse or higher-level licensee".¹⁶ The Board of Nursing says an LVN may not do IV therapy until completing a validation course.¹⁰

The Medical Board says its med spa standards apply to every delegated act, including IV hydration.⁸ An early version of the bill would have created med spa directors. The law as passed does not.¹⁷ We could not tell from the sources whether a standing order may be used for elective IV therapy. Ask who ordered the drip, who examined you and who will place the IV.

We found no statement from the State Board of Pharmacy on compounded semaglutide or tirzepatide. What the sources do show is who may prescribe: a PA or APRN prescribes under a written agreement with a physician.¹² Ask who prescribes your medicine, whether it is an FDA-approved product or a compounded one, and which pharmacy prepares it.

A business that provides these delegated acts must post, in each public area and treatment room, the Medical Board's notice of how to file a complaint and the name of each delegating physician, including their Texas medical licence number. Each person performing a delegated act must wear a name tag or similar means that shows their identity and credentials.⁴ The complaint notice must be in English and Spanish and displayed prominently.²⁹ These are met in the clinic, so a website that does not show them proves nothing. The Medical Board's President wrote that "all advertising materials must feature the supervising physician's name", but the advertising rule we read is narrower: it requires disclosing medical directorship, supervision or delegation at a location that is not the physician's primary practice location where care is given under standing orders.⁸²⁸ Look at the wall and the name tag.

We found no "medical director" role for med spas in Texas law. It uses "delegating physician" for the physician who delegates the cosmetic procedures, "supervising physician" for a PA, and "consulting physician" for laser hair removal.²¹¹²⁰ The Department of Licensing and Regulation, asked whether a laser hair removal facility needs a medical director, says no, but it needs a written contract with a consulting physician.²⁰

The Medical Board describes the corporate practice of medicine as a legal doctrine that generally prohibits corporations, entities or individuals who are not physicians from practising medicine, and says medical decision-making policies must include physician involvement. It says it cannot give legal advice about a specific organisation.²⁵ A physician can be disciplined for permitting another person to use their licence, or for aiding the practice of medicine by a business that is not licensed to practise.²⁶ Texas business law lets a professional entity provide a professional service only through people authorised to provide it, and requires its owners to be authorised persons.²⁷ The sources do not say whether a non-physician may own a company that contracts with a physician-owned practice.

The Department of State Health Services licenses tattoo studios. An office or clinic of a person licensed by the Medical Board is exempt.³⁰ The Department of Licensing and Regulation's table assigns permanent makeup and tattoos to the Department of State Health Services, and microblading to that Department and the Medical Board.²³