Florida's Nurse Practice Act lets a registered nurse administer medications and treatments that a licensed practitioner has prescribed or authorized. For cosmetic injections specifically, the Florida Board of Nursing has answered one nurse at a time, through declaratory statements issued to nurses who petitioned it.
The Department of Health's index lists eight Board of Nursing orders from July 2023 to May 2024 on registered nurses giving Botox and, in some, fillers. In the orders we read, the Board said yes under a physician's direction. All concerned Botox or a similar neuromodulator, and two, from October 2023 and February 2024, also covered dermal fillers. On one May 2024 petition that asked about neuromodulators and cosmetic fillers, the Board's answer named Botox Cosmetic only.
The May 2024 orders set conditions. The delegation had to come from a Florida MD or DO, direct supervision meant the physician "has visualization of the injection", and the nurse's part in the treatment had to be stated in the informed consent given to the patient. When one nurse asked to inject under either a physician or a nurse practitioner, the Board approved delegation from a physician only. In the petitions the Board approved, a physician assessed the patient and wrote the treatment order before handing off the injection; the first, in July 2023, spelled out the muscles to be injected and the units per injection site.
These orders are not a blanket rule. Under Florida's declaratory statement law, each one answers how the law applies to the petitioner's own circumstances. The Board has also said no: in 2017 it found aesthetic injections outside nursing scope for a petitioner who did not define the level of physician supervision, and in June 2020 it denied another nurse's petition on fillers and botulinum toxin, with the minutes giving no reasoning.
Licensed practical nurses are not covered by any of these orders. Every approval we read involved a registered nurse, and the statute says only that practical nurses work under the direction of a registered nurse or a physician. Whether an LPN may give cosmetic injections in Florida is not clearly addressed in the rules we read, so if an LPN is offered as your injector, ask the spa to explain the basis.
A nurse practitioner, called an APRN in Florida, works within a written protocol kept on site, with a supervising physician directing the course of medical treatment, and within that protocol may prescribe and administer drugs. A registered autonomous APRN may practice without a physician only in primary care. Whether cosmetic injections count as primary care is not clearly addressed in the rules we read; the Board of Nursing's primary-care definition does not mention cosmetic or aesthetic services.
A physician assistant works under physician supervision, which Florida law defines as the physician's easy availability, including by telecommunication, or physical presence. Board of Medicine rules call it direct supervision when the physician is on the premises and indirect supervision when the physician is easily available and within reasonable physical proximity. A PA who prescribes must clearly tell you that he or she is a physician assistant.
One rule is something you can check on the wall. When a physician supervises an APRN or PA at an office other than the physician's main practice, with no physician supervising on site, and the office mainly offers dermatologic or aesthetic skin care, Florida law requires that physician to be board certified or board eligible in dermatology or plastic surgery. The physician may supervise only one such office, within 25 miles of the main practice or in a neighboring county, and must post in each office a current schedule of the hours the physician is there and the hours it is open without the physician. The office limits do not apply where the only service is laser hair removal by an APRN or PA.
We found no source establishing that Florida licenses med spas as their own type of facility; that satellite-office rule is the closest provision. On the exam before treatment, Florida's telehealth law lets a practitioner evaluate you by telehealth, without a physical exam, if the evaluation is enough to diagnose and treat. We found no general Florida rule requiring an in-person or good-faith exam before a cosmetic neurotoxin or filler; the exam appears only as a fact in individual nursing approvals. Ask who will examine you, how and when.
Laser hair removal has the clearest rules. Anyone other than an MD or DO who performs laser or light-based hair removal must be appropriately trained and work only under a physician's direct supervision and responsibility. For licensed electrologists, Board of Medicine rules require specified training and a trained supervising physician who is on the premises or supervising by live telehealth from within 150 miles. A physician may supervise no more than four electrologists at a time, and each patient's first consultation must include an exam and assessment by an MD or DO.
Electrology needs a Department of Health license, and the only exemptions are MDs, DOs and students in approved training programs. In 2002 the Board of Nursing declared that registered nurses may not perform laser hair removal unless they also hold an electrology license, and we found no later nursing order revisiting it.
Other lasers are less settled. Who may perform laser or IPL treatments other than hair removal, such as resurfacing or photofacials, and under what supervision, is not clearly addressed in the rules we read; the Board of Medicine's laser rule covers hair removal only. The Board of Medicine does direct laser device owners to the Department of Health's Bureau of Radiation Control for registration.
Florida's skin care credential is a facial specialist registration under the cosmetology law, not an esthetician license, and it requires 220 hours of training. Cosmetology is defined as treatment for "aesthetic rather than medical purposes", and the Board of Cosmetology rule puts injections, lasers, IPL, ultrasound and HIFU, plasma pen, Hyaluron pen and FDA-approved medical devices beyond a facial specialist's scope. It names microneedling and microblading as beyond that scope too. A facial specialist may do skin care, dermaplaning with a #10 blade and non-invasive hair removal such as waxing, but not electrolysis.
On IV drips, bills to regulate IV vitamin treatment were considered in Florida in 2023 and 2024, and neither became law.
