Botox Cosmetic is a prescription medicine, according to its FDA label, so a prescriber has to authorize it. Who may perform the injection is set by Pennsylvania's licensing laws and board rules, and the nursing rules we read are general: they do not name cosmetic injectables.
The State Board of Medicine lets a medical doctor delegate a medical service to another health care practitioner or a technician only on listed conditions. The doctor must know the person has the education, training, experience and continued competency to do it safely, and must judge that the delegation does not create an undue risk for you. A doctor may not delegate a service the doctor is not trained and competent to perform, or one whose performance or complications call for knowledge nonphysicians do not ordinarily have.
The delegation rule sets no fixed on-site requirement. The delegating doctor stays responsible and must be available to the person treating you "as appropriate to the difficulty of the procedure", that person's skill and your risk. The rule also requires that the nature of the service, and the fact that it is delegated, be explained to you and that you do not object; the explanation can be oral and can come from the doctor's designee.
A registered nurse may administer a drug ordered for a patient in the dosage and manner prescribed, and nursing practice includes carrying out a physician's prescribed regimen but not diagnosing or prescribing. A licensed practical nurse likewise gives medication ordered for the patient and may take a written order from a practitioner authorized by law and facility policy to issue it.
A certified registered nurse practitioner (CRNP) diagnoses and prescribes under a written, signed collaborative agreement with a physician, who must be immediately available, and that availability may be by direct communication, radio, telephone or telecommunications, so the definition does not require the physician on site. That agreement must name the categories of drugs the CRNP may prescribe and how often the physician will personally see the patient. Two bills in the 2025-2026 session, Senate Bill 25 and House Bill 739, would amend these CRNP provisions; as of our reading neither had been reported from committee, so they are proposals, not law.
A physician assistant performs services delegated by a physician named in a written agreement that describes the PA's scope and the nature and degree of supervision, and the statute says supervision does not require the physician's on-site presence. A PA may prescribe only for a patient under the care of the PA's supervising physician.
Some questions the rules leave open. We found no Pennsylvania rule that says specifically whether a cosmetic injection may be delegated to an unlicensed technician or medical assistant. The delegation rule above is written for medical doctors; osteopathic physicians (DOs) have their own board, and we did not find an equivalent rule for them. If your injector is not a physician, PA or nurse, or the supervising doctor is a DO, ask the spa to explain the arrangement.
On the exam before treatment, the State Board of Medicine rule requiring an initial medical history and physical exam before prescribing is written for controlled substances. We found no rule that expressly requires a prescriber's exam before a cosmetic neurotoxin or filler treatment, so that rests on the general standard of care. Ask who will examine you, and when.
Lasers are less settled still. We found no Pennsylvania statute, regulation or board page that clearly addresses who may operate a cosmetic laser or IPL device, or whether laser hair removal is the practice of medicine. Ask who operates the device, what license that person holds and who supervises.
An esthetics license covers facial massage, applying cosmetic preparations and creams to the face, removing hair by tweezers, depilatories or waxes, and dyeing eyelashes and eyebrows. The definition does not mention lasers or IPL, and we found no Board of Cosmetology rule that expressly permits or forbids them for estheticians.
The State Board of Cosmetology's published cases go further than that definition. In a 2023 consent agreement the respondent acknowledged that Botox, face fillers and microneedling are outside the scope of cosmetology and that performing them in a cosmetology salon breaks the rule against using a salon for other purposes. Cases from 2024 treated dermaplaning and milia removal the same way and in another the respondent acknowledged that performing dermaplaning, hydro-dermabrasion and oxygen therapy in a salon was a violation, and a 2025 adjudication did the same for permanent makeup. These are disciplinary case outcomes, not regulations: the microneedling case draws no line on depth, and the hydro-dermabrasion case does not say who may lawfully perform it elsewhere.