Medical spa

Understanding Roles and Services Offered at a Medical Spa

Exploring Roles and Responsibilities in the Evolving Landscape of Medical Spas

As newcomers to the healthcare scene, medical spas are revolutionizing the traditional medical practice paradigm. This fusion of medical expertise with day spa services has spawned a unique industry, subject to regulation by multiple governing bodies, each defining distinct roles within its framework.

Typically, medical spas offer a blend of medical and aesthetic procedures such as lasers, Botox, fillers, microneedling, microdermabrasion, dermaplaning, chemical peels and dermabrasion. This array of services often blurs the line between medical treatments and spa indulgences. While most states consider these procedures medical, exemptions exist in other jurisdictions. For instance, certain state cosmetology boards permit estheticians and cosmetologists to conduct microdermabrasion and dermaplaning as long as these procedures do not penetrate the skin’s dermal layer. Conversely, more stringent state regulations confine esthetic and cosmetology practices to superficial skin layers. This discrepancy begs the question: who can perform which tasks in a medical spa?

The authority to administer medical aesthetic treatments follows a hierarchical structure:

1. Physicians: Physicians wield the broadest authority, often serving as owners or medical directors of medical spas. They oversee the delegation of medical treatments to other staff members, including nurse practitioners and physician assistants.

2. Nurse Practitioners (NPs) and Physician Assistants (PAs): In states where NPs have independent practice authority, they can conduct medical procedures within their scope of practice without physician supervision. Otherwise, both NPs and PAs operate under varying levels of physician supervision as dictated by state laws.

3. Registered Nurses (RNs): RNs operate under stricter delegation and supervision compared to NPs and PAs. They may perform delegated medical tasks within their scope of practice under the supervision of a qualified physician or independent practice NP.

4. Licensed Practical Nurses (LPNs)/Licensed Vocational Nurses (LVNs): LPNs/LVNs have a more limited scope of practice and are subject to stricter delegation and supervision compared to RNs, NPs, and PAs. State laws dictate the medical tasks they can perform and the level of supervision required.

5. Estheticians and Cosmetologists: While licensed by cosmetology boards, estheticians and cosmetologists are considered unlicensed personnel in the medical field. They are typically restricted to performing spa procedures within their cosmetology licensure and are prohibited from undertaking tasks requiring medical expertise.

6. Unlicensed Personnel: This category includes medical assistants (MAs) who, despite being unlicensed for medical treatments, may perform certain procedures in medical spas within the confines of state law. However, their limited medical training often necessitates on-site, direct supervision by delegating practitioners, and caution must be exercised when delegating medical treatments to them.

For expert advice on legal matters about your medspa business, consider scheduling a free discussion with Dike Law Group. You can do this at

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