Cosmetic Injections Uncovered: Who Is Legally Allowed to Administer Them in Texas?
The medical aesthetics industry in Texas is booming, but with that growth comes the need for strict adherence to healthcare regulations—especially when it comes to procedures involving The medical aesthetics industry in Texas is booming, but with that growth comes the need for strict adherence to healthcare regulations—especially when it comes to procedures involving cosmetic injections. Whether you’re launching a med spa, managing one, or working within one, understanding who can legally administer injectables like Botox or dermal fillers is essential for staying compliant with state law and ensuring patient safety. This guide breaks down the categories of professionals authorized to administer cosmetic injections in Texas—and under what conditions they can do so.
Understanding the Role of Professionals in Cosmetic Injections
Physicians: The Ultimate Clinical Authority for Cosmetic Injections
Only licensed physicians (MDs or DOs) in Texas hold unrestricted rights to assess patients, make diagnoses, and independently perform or delegate injectable procedures. In med spa settings, they bear ultimate responsibility for ensuring clinical standards are upheld, even when they aren’t the one holding the syringe.
Key duties include:
- Creating treatment protocols for cosmetic injections
- Performing in-person evaluations (or delegating when appropriate)
- Supervising mid-level and nursing staff
- Ensuring compliance with medical laws and board rules
Physicians don’t just perform procedures—they shape the standard of care across the entire facility when it comes to cosmetic injections.
Advanced Practice Providers: Nurse Practitioners (NPs) and Physician Assistants (PAs)
Nurse Practitioners and Physician Assistants can perform cosmetic injections—but only when working under a delegation agreement with a licensed physician. While they can conduct patient evaluations and carry out injectable treatments, they must do so under supervisory structures that comply with the Texas Medical Board’s rules.
Important facts:
- Supervision may be indirect but must be available (e.g., by phone or teleconference)
- NPs and PAs can’t independently operate a med spa offering medical services
- Their authority to perform cosmetic injections is tied to physician collaboration and delegation
Registered Nurses (RNs): Administering Under Protocol
Registered Nurses can perform cosmetic injections—but not autonomously. They must be working under supervision and follow a physician- or mid-level-established treatment plan.
Their scope of activity includes:
- Injecting neuromodulators and fillers
- Monitoring patient responses
- Following detailed clinical protocols for cosmetic injections
RNs cannot assess or diagnose patients or create individualized treatment plans. Their actions must align with the Texas Board of Nursing’s scope of practice rules.
Licensed Vocational Nurses (LVNs): Limited Injection Authority
LVNs in Texas can administer cosmetic injections—but only under direct supervision from a physician, RN, or mid-level provider. They must be working from an established treatment plan and cannot independently evaluate or treat patients.
Their authority is narrower than that of an RN and is often limited to less complex medical procedures involving cosmetic injections.
Medical Assistants: No Injection Privileges
Despite their administrative and support roles, medical assistants (MAs) are not permitted to administer cosmetic injections in Texas. Their functions are limited to assisting with prep, documentation, and non-clinical tasks.
Even under supervision, injectable procedures fall outside the scope of an MA’s role, and doing so may result in regulatory violations for the supervising physician.
Unlicensed Personnel and Estheticians: Conditional Participation
Texas law does not automatically exclude unlicensed or non-clinical personnel from participating in med spa treatments—but it does strictly regulate how and when they may be involved.
According to state administrative code, unlicensed staff may perform certain delegated tasks as long as:
- The patient has been properly assessed by a licensed provider
- The tasks are within the staff member’s competence and training
- They are under physician or mid-level supervision
Estheticians and cosmetologists may handle facials and skincare, but when it comes to cosmetic injections, they may only assist—not inject.
Compliance Essentials: What Every Med Spa Must Know
To stay within legal guardrails, every Texas med spa must address these non-negotiable compliance points related to cosmetic injections:
✅ Patient Evaluation
A licensed provider must assess each patient and establish a treatment plan prior to any injectable procedure. Telemedicine is acceptable in some cases, but initial in-person exams are often required.
✅ Delegation Agreements
A formal delegation agreement must define how tasks are assigned, supervised, and reviewed. This is especially critical when using mid-level providers or RNs.
✅ Consent and Disclosure
Patients must receive clear information about the procedure, risks, alternatives, and who will perform the treatment. Signed informed consent is required.
✅ Training and Credentialing
All personnel must be appropriately trained and certified in the cosmetic injections they perform. Documented proof of training should be maintained for compliance and insurance purposes.
Final Thoughts: Who Can—and Can’t—Inject at a Texas Med Spa
Injectables may appear cosmetic on the surface, but under Texas law, they’re recognized as medical procedures involving cosmetic injections. That means oversight, delegation, and licensure are more than just best practices—they’re legal requirements.
In summary:
Estheticians may only support procedures—not perform them
Physicians can diagnose, plan, and inject independently
NPs and PAs can inject under a delegation agreement
RNs and LVNs can inject under supervision
MAs and unlicensed staff cannot legally inject
If you need help reviewing your delegation agreements, clarifying staff roles, or developing
injection protocols, consulting with Dike Law Group experienced in Texas healthcare compliance
is a smart first step. If you prefer to learn through videos, be sure to visit our YouTube page for helpful content on these topics and more.
