The Texas Medical Board treats nonsurgical cosmetic procedures, including cosmetic injections and the cosmetic use of a prescription medical device, as the practice of medicine that a physician may delegate and supervise. Texas law lets a physician delegate a medical act to a qualified and properly trained person under the physician's supervision, and the physician remains responsible for that person's acts.
When a cosmetic procedure is delegated, Texas Medical Board rules set conditions. The physician must make sure the person performing it is trained in the technique, its contraindications and the recognition and management of complications, and has signed and dated a written protocol; the physician must also be trained in, or familiar with and able to perform, the procedure according to the standard of care. A physician, physician assistant (PA) or advanced practice registered nurse (APRN) must be onsite or immediately available for emergency consultation, and the physician must be able to see you for an emergency appointment if needed. Written orders must name the delegating physician and set patient screening criteria and procedures for complications and emergencies.
Before the procedure, a physician, or a PA or APRN acting under the physician's delegation, must establish a practitioner-patient relationship with you and complete a medical record. You must be told the identity and title of the person who will treat you, and at least one person trained in basic life support must be present while you are onsite. Rule 169.26 does not say whether that relationship can be set up by video. A Texas telemedicine statute treats a live audio and video visit that meets the standard of care as a valid practitioner-patient relationship, but it does so for a pharmacy provision on valid prescriptions, and we found no source applying it to cosmetic injections, so ask how and by whom it is done.
The business must post, in each public area and treatment room, the Texas Medical Board's complaint notice and the name and Texas license number of each delegating physician, and everyone performing a delegated procedure must wear a name tag or similar identification showing their identity and credentials. These standards do not apply to procedures that a physician, or a PA or APRN supervised by that physician, performs at the physician's own practice. When we checked on September 24, 2026, the Board's later rule packages had not changed these cosmetic delegation rules, which took effect January 9, 2025.
Nurses answer to their own board. The Texas Board of Nursing says a registered nurse may perform a cosmetic procedure only when it has been ordered for that patient by an authorized prescriber and the nurse judges it within their own scope, and should not do it without the training, the order and appropriate supervision. For licensed vocational nurses, the Board does not say whether cosmetic injections are within scope; each LVN must decide, and may act only with an appropriate order and supervision.
Texas APRNs, including nurse practitioners, do not have full practice authority, and the Board of Nursing says Botox and filler treatments require physician delegation. A physician assistant provides services a supervising physician delegates; that supervision must be continuous but does not require the physician's constant presence if the two can easily reach each other.
One question the sources we read do not settle is whether a physician may delegate neurotoxin or filler injections to an unlicensed person, such as an esthetician acting as the physician's delegate rather than under an esthetics license. The delegation statute and rule name no required credential. If the person treating you is not a physician, PA or nurse, ask what license they hold and how the delegation is set up.
Jenifer's Law, in effect since September 1, 2025, covers elective IV therapy, meaning IV drips for temporary discomfort or wellness given outside a physician's office, a licensed health facility or certain hospitals. It does not cover Botox or filler injections. A physician may delegate ordering it only to a PA or APRN, and giving it only to a PA, APRN or registered nurse, each under adequate physician supervision. The Texas Board of Nursing says LVNs, EMTs, paramedics and unlicensed staff may not be delegated elective IV hydration or vitamin infusions. The bill as first introduced would have required a medical spa director and a notice when no physician is present; the law as enacted does not contain those provisions.
Laser hair removal has its own program. Texas defines it to include pulsed light devices, so IPL hair removal is covered too, and no one may perform it without a certificate from the Texas Department of Licensing and Regulation (TDLR) unless they are a physician or a physician's delegate, or another licensed health professional acting within their own scope. A laser hair removal facility needs its own TDLR license for each location unless it is a physician's medical practice, a licensed hospital or a hospital clinic, and it must have a certified professional or a licensed health professional present to supervise during operating hours.
A licensed facility must also hold a written contract with a consulting physician whose practice is within 75 miles, who sets its protocols and audits them onsite at least quarterly, unannounced unless the physician decides advance notice will not compromise the audit. Every client must get a written statement of the risks that includes an eye-protection warning, and the facility may not advertise the procedure as risk-free or as having a medical benefit. Only devices the FDA has approved for hair removal may be used.
For lasers beyond hair removal, such as tattoo removal, TDLR lists the Department of State Health Services and the Texas Medical Board as the regulators, and the Medical Board treats cosmetic use of a prescription device as a medical act a physician may delegate. TDLR also notes that Texas nurses may not deliver laser energy as an independent nursing function and must meet Board of Nursing criteria to accept a physician's delegation.
A Texas esthetician license covers cleansing and massaging the face, neck, shoulders and arms, beautifying them with cosmetic preparations, facial treatments, removing superfluous (unwanted) hair with depilatories, tweezers or similar devices, and eyelash extensions. TDLR says it does not authorize injecting Botox or any other substance with a needle, or using lasers for hair removal or skin resurfacing, and a physician cannot delegate cosmetology procedures, only medical ones. Estheticians may do light or superficial peels that do not penetrate the dermis; medium and deep peels are medical procedures regulated by the Texas Medical Board.
TDLR lists microneedling with PRP, Botox, IV hydration and CoolSculpting as regulated by the Texas Medical Board. Whether an esthetician may do plain microneedling without PRP is not clearly addressed in any source we read, so ask who performs it and under what license. Estheticians may perform esthetic services only in a TDLR-licensed establishment, and TDLR says a medical office where they provide esthetic services should hold that establishment license.
