Opening a MedSpa? What Nurse Practitioners Need to Know

A nurse practitioner reader recently posted a comment on ThriveAP related to MedSpas and delegating to aestheticians. The question is a good one. A number of entrepreneurial nurse practitioners are going the MedSpa route, opening practices catering to cosmetic procedures. In many states, nurse practitioners are able to start such businesses independently, taking advantage of favorable state scope of practice laws. If you’re interested in opening a MedSpa as a nurse practitioner, what legal regulations do you need to consider?

Guidelines surrounding MedSpas and the performing of cosmetic procedures in general, vary by state. The American MedSpa Association gives a summary of such state guidelines, although to access this resource, one must pay to become a member of the organization. This may be worth the investment if you are a nurse practitioner considering opening a cosmetic practice of your own, although you will also need to dig into state regulations themselves for more detail.

There are a few main scope of practice considerations to consider before you open a cosmetic practice as a nurse practitioner.

1. Do you as a nurse practitioner require supervision?

Physician collaboration and supervision guidelines still apply to NPs looking to practice in the cosmetic setting. If you plan to offer services considered ‘medical’ by your state, you may need an MD onboard in your business. You must comply with physician supervision guidelines if you work in a state where NPs cannot practice independently. This can look like having an MD on site, employing a physician available for phone consultation, or hiring a physician who agrees to review a certain percentage of your patient’s charts.

Not only must you review scope of practice guidelines for NPs in your state, you must also look at guidelines specific to owning a MedSpa or practice offering cosmetic procedures. Most states have specific regulations for these facilities that may extend beyond scope of practice regulations.

2. Will your staff require supervision?

If you plan to employ other providers of cosmetic procedures, such as aestheticians or nurses, you must also comply with supervision guidelines for these employees. Nurses, for example, are not permitted to practice aesthetics independently in any state. You must familiarize yourself with what this supervisory relationship must look like for individuals providing services in your practice.

3. What services are you and your staff permitted to provide?

Structuring your menu of services requires careful attention to state laws. States specifically regulate the type of professional that can offer treatments like laser therapy and cosmetic injectables.

States classify interventions as ‘medical’ or ‘non-medical’, or as administered with ‘prescriptive devices’ or ‘non-prescriptive devices’. Interventions designated as medical, or performed with so-called ‘prescriptive devices’, must be performed by a licensed healthcare provider. Lasers and injectables, for example, fall into this category. Non-medical interventions, or those administered with non-prescriptive devices may likely be performed by non-healthcare providers such as aestheticians.

The type of procedures you perform as a nurse practitioner must fall within your scope of practice, and state guidelines for cosmetic procedures. If you have other types of professionals, such as aestheticians or nurses joining your practice, you must ensure that these individuals comply with state scope of practice guidelines as well. Offer only services that fall within your scope of practice, and/or that of the individuals you employ. Know who can laser, who can inject, and who cannot!

4. Are cosmetic providers properly trained?

While performing cosmetic procedures may fall within the scope of practice of nurse practitioners, states specify that to perform these interventions, training is required. Specifics of the requirement for such training is outlined by state Boards of Medicine and Boards of Nursing. Make sure that you and your staff are properly trained in the administration of cosmetic procedures before opening the doors of your MedSpa.

5. Who must be present at the MedSpa?

In some states, scope of practice guidelines specify that a physician must be present on site in order for the nurse practitioner to practice. Similar guidelines may be in place for nurse practitioners delegating to nurses or estheticians in the MedSpa setting. Plan to staff your MedSpa accordingly to fulfill such supervision requirements.

Opening a MedSpa can be a profitable way for nurse practitioners to utilize their skills in an entrepreneurial endeavor. Care must be taken in planning for such a business, particularly when it comes to state scope of practice, supervision, and training requirements.