Medical spas in Utah

Utah defines a cosmetic medical procedure to include injecting a neurotoxin or a filler for cosmetic purposes, and performing one counts as the practice of medicine.⁴

Medical assistants may not do it. State law lets a medical assistant do delegated tasks under a physician's indirect supervision, except what the Division of Professional Licensing's rules bar.⁵ The Division's rule bars a medical assistant from injecting a medication or substance, including a neurotoxin or filler, for cosmetic purposes.⁶

APRNs may prescribe and administer drugs within their scope.⁹ Physician assistants work with a physician and must collaborate with one until they have 8,500 post-graduate hours.⁸

The section on who may be delegated cosmetic work, 58-1-506, is written for nonablative procedures such as lasers and light devices. It names no injectable.² So the statute does not say, in terms, whether a registered nurse or an esthetician may inject. Ask who will inject you, what their licence is and who supervises them.

Hair removal and other nonablative procedures, such as lasers, intense pulsed light, radiofrequency and body contouring devices, are the main subject of the delegation rules.²⁴ A supervisor (physician or APRN) must develop the treatment plan. For hair removal, a "hair removal review", an in-person interview about the patient's medical history, comes first and may be delegated to a registered nurse, physician assistant, master esthetician or electrologist.²

Who may perform the procedure depends on their licence:

- Registered nurses, master estheticians and, for laser hair removal, electrologists work under general supervision, which means the supervisor is within 60 minutes or 60 miles and able to attend in person if there is a problem.² - Practical nurses, estheticians and, for hair removal, qualified medical assistants work under closer supervision. For hair removal that is indirect supervision, where the supervisor is in the facility.² For other nonablative procedures, estheticians and practical nurses need direct supervision, with the supervisor present and available face to face.² - Physician assistants follow the physician assistant law.² - Everyone delegated to must have documented education and experience of at least 80 hours, covering topics that include skin physiology, laser safety and recovery from complications.²

For nonablative procedures other than hair removal, a physician, nurse practitioner or physician assistant must evaluate the patient in person or by live video visit before treatment begins.²

Ablative procedures, which remove tissue, are reserved to physicians. A physician may delegate only two laser resurfacing procedures to an APRN, and only with 50 hours of specific training and the physician's indirect supervision.⁷ We found no separate Utah licence for laser operators.

Utah licenses master estheticians, who may use cosmetic medical devices to perform nonablative procedures under the supervision rules above. The same law says they may not perform any service for the treatment of medical, physical or mental ailments.¹⁰ A proposed rewrite of the esthetics rule would address microneedling depth and deeper peels, but it is not law.

A licensed dispensing medical practitioner (a physician, PA or nurse practitioner, among others) may dispense an injectable weight-loss drug that they prescribed to the patient.¹¹ A pharmacy may compound a drug for sale to a practitioner for office use only, to be given in the office and not dispensed.¹² We found no Utah Pharmacy Board rule on compounded semaglutide or tirzepatide. Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

We found no Utah statute or rule on elective IV therapy or drip bars. The licence of the person who orders and gives the drip is the thing to check. Ask who will examine you before the drip, who ordered it, and who will place the IV.

Utah law calls a cosmetic medical facility a physician's office or a facility that has a supervisor. Cosmetic medical procedures may only be performed in one, and the person doing them must be supervised by a supervisor.¹ A supervisor is a physician (MD or DO) with an unrestricted licence, or an advanced practice registered nurse (APRN) with an unrestricted licence, acting within their scope of practice.¹

A facility may not advertise or hold itself out as a "medical spa", "medical facility" or "medical clinic" unless a physician, osteopathic physician or nurse practitioner is on the premises while a cosmetic medical procedure is performed.³

Whoever supervises must have their name posted at the facility and a copy of their licence on the wall. The patient must get written information naming the supervisor and the person performing the procedure, and a phone number that is answered within 24 hours.²

We found no Utah requirement that a med spa have a medical director. The supervisor required by the cosmetic medical procedure rules is the person to ask about.¹ Who may own a med spa is not settled in what we read.