Who Can Inject Botox in Arkansas? What the Boards Say

Three Arkansas regulators matter for an injectable appointment. The Arkansas State Medical Board licenses physicians and physician assistants. The Arkansas State Board of Nursing oversees nursing licenses and certificates of prescriptive authority. The Arkansas Department of Health licenses aestheticians under the state's Cosmetology Act.

In the official pages we reviewed, we found no Arkansas document that names which licenses may inject Botox. Of the sources we reviewed, the nearest are the nursing board's position statement on aesthetics and the medical board's delegation and laser rules. This guide describes each one as the kind of document it is.

Position Statement 21-1, Role of the Licensed Nurse in the Practice of Aesthetics, is listed under Position Statements on the Board of Nursing's Laws and Rules page, separately from the Nurse Practice Act and the board's rules. The copy linked there shows it was adopted January 7, 2021 and revised September 8, 2022. Read it as the board's position statement, not as a statute or an administrative rule.

The statement says aesthetic procedures are within the scope of practice of a trained APRN or RN as part of a medically prescribed plan of care, either for treating dermatological conditions or as part of a health maintenance and health promotion regime. It says they are not within the scope of practice of an LPN or a licensed psychiatric technician nurse (LPTN). It speaks of aesthetic procedures in general and does not name Botox or any other product.

Training is part of the statement. The nurse shall have documented educational preparation, supervised clinical practice experience and competency validation appropriate to the nurse's responsibilities, the treatment provided and the patient population served, and the delegating physician or supervising APRN documents the RN's competency. The statement adds that the APRN and RN should gain and demonstrate 13 listed items of knowledge and skill before engaging in aesthetic procedures. They include the anatomy, physiology and pathophysiology of the integumentary system and of the systems specific to the procedure, pharmacology, management of complications or adverse reactions and infection control, and the list ends with supervised clinical practice experience and competency validation.

Position Statement 21-1 says aesthetic procedures shall be prescribed by a qualified physician or an APRN with prescriptive authority. On orders, it says two things in the same paragraph. RNs shall practice under a patient-specific order written by the delegating physician or supervising APRN. Standing orders for aesthetic cosmetic procedures are acceptable, provided they are documented in the patient's medical record and reviewed by the prescriber every year.

The standing orders it describes must contain patient-specific details. The statement says they shall contain nine items: the patient's name, a patient-specific diagnosis, the procedure, the treatment site, the drug and dosage when applicable, the frequency, instructions for emergency and follow-up care, and the prescriber's signature and date.

During a procedure, the APRN or physician shall be available to the RN in person or through electronic communications, and the practice's standard procedures and protocols must say so. The statement also points nurses to Position Statement 98-6, the board's scope of practice decision-making model.

The Medical Board publishes the Medical Practices Act and its rules in one compilation, revised August 19, 2025. The Act defines the practice of medicine to include prescribing or administering any form of treatment for the relief or cure of a physical condition or defect with the intention of receiving a fee, performing any kind of surgical operation, and delegating certain medical practices to other personnel under the board's rules. Its exemptions section says nothing in the Act prohibits or requires a license for the rendering of nursing services by registered or other nurses in the lawful discharge of their duties, or for the practice of cosmetology as defined by Arkansas law.

Rule 22, the board's laser surgery guidelines, defines surgery as any procedure in which human tissue is cut, altered or otherwise infiltrated by mechanical means, including lasers. It says the use of medical lasers on people for therapeutic or cosmetic purposes is the practice of medicine. Within this laser rule, for minor procedures, a physician may delegate certain tasks to trained non-physician office personnel under a protocol: the physician must personally diagnose the patient and prescribe the treatment and must be available if complications arise, and should document who performed the procedure. Rule 22 does not name injections. The rule was last amended effective July 11, 2022.

Rule 31, the physician delegation rule, covers tasks a physician delegates to qualified, trained employees who are not licensed to perform them, commonly called medical assistants. Delegated tasks are performed under the physician's supervision, the physician remains responsible, and the employee may not be presented to the public as a licensed nurse or other licensed provider or pass the task on to someone else. Before delegating, the physician must determine that the task can be appropriately delegated, considering whether it can be performed without judgment based on medical knowledge, according to exact, unchanging directions, and without complex observations, critical decisions or repeated medical assessments. The physician may delegate only the administration of drugs that do not require substantial, specialized judgment and skill, only within the physician's offices, after evaluating the patient's acuity and determining the employee's competency, including through personal observation. The rule bars delegating anesthesia to an unlicensed person. Rule 31 does not name cosmetic injections or Botox.

In that compilation of statutes and rules, we found no Medical Board rule that addresses medical spas, cosmetic injections or neurotoxins by name.

For APRNs, Position Statement 21-1 says the practice of aesthetics must fall within the scope of practice for the APRN's population focus. For an APRN practicing under a collaborative practice agreement, the collaborating physician documents the APRN's competency. An APRN with prescriptive authority is one of the two kinds of prescriber the statement names.

A collaborative practice agreement is not the only arrangement in the board's rules. 17 CAR Part 130 defines full independent practice authority as the ability of a certified nurse practitioner or clinical nurse specialist to practice with prescriptive authority without a collaborative practice agreement. Applicants must meet listed qualifications, including documentation of at least 6,240 hours of practice. The Full Independent Practice Credentialing Committee, whose eight members are appointed under Arkansas Code 17-87-314, reviews those applications and written complaints against practitioners who hold that authority. It may suspend or revoke the independent practice certificate but may not act against the nursing license, and it reports all complaints and actions to the board. Ask an APRN which kind of authority they hold. Our nurse practitioner guide explains the general terms.

Physician assistants are licensed by the Medical Board. Under the physician assistant statutes in the same compilation, a PA may perform duties delegated by a supervising physician under an agreement determined at the practice level, including prescribing, ordering and administering drugs, when the service is within the PA's skills and the supervising physician's scope of practice. The board's Rule 24 says the delegation agreement must be accepted by the board before the PA is licensed, and any authorization to prescribe must be stated in it and approved by the board. A PA's prescriptive authority may never exceed the supervising physician's, and Schedule II drugs are limited. Supervision must be continuous, but the supervising physician need not be physically present as long as the two are or can easily be in contact by radio, telephone or another telecommunication device.

Arkansas law spells the license aesthetician. The Cosmetology Act, as published by the Department of Health, defines an aesthetician as a person who beautifies the body by cleaning, waxing, externally manipulating or stimulating it with the hands, devices or appliances, with or without cosmetic preparations, antiseptics, tonics, lotions and creams. That definition does not mention injections.

The Department of Health's cosmetology rule, 17 CAR 54-207(z), sets limits on equipment and chemicals. Apart from ear-lobe piercing with a piercing gun, cosmetologists and aestheticians may not use any device, tool or machine that removes or destroys a client's skin beyond the epidermis. Their devices may not be FDA Class III, IIIa or IIIb devices or Class III or IV lasers, and they may not use medical-grade or prescription retinoids. The rule makes prohibited services grounds for disciplinary action.

That rule section does not mention injections either. If an aesthetician is presented as your injector, ask what license authorizes the procedure and verify it. Our esthetician scope guide covers the general distinction between skin care and medical treatment.

The Board of Nursing's license verification page says the public can confirm whether a person holds a current, valid Arkansas nursing license. It warns not to accept the blue plastic card or a copy of a verification report, and to check for yourself. It points to the board's ASBN Registry Search license lookup portal, which it calls a primary source of verification, and to Nursys, and notes that Arkansas RNP and LPTN licenses must be verified through the ASBN Registry Search. Disciplinary documents can be downloaded from Nursys or the board's license lookup; for disciplinary actions older than 2017, the board says to contact its office.

The Medical Board's public page lets you verify a medical practitioner's license status by license number or last name. Its directory search lists only practitioners with an active Arkansas license and a United States address. The Department of Health's cosmetology page links a separate license verification site. Our license verification guide walks through the general steps.

The Board of Nursing takes complaints online and says a complaint cannot be opened without enough information to identify the correct nurse. The Medical Board does not accept verbal complaints. You write a letter by mail, email or fax that says you wish to file a complaint and gives the practitioner's full name, the patient's full name, your full name and return address, the details and your signature. The board sends a copy to the practitioner, the full board reviews it and you are notified by mail. The cosmetology page links an online complaint form. See also our complaint guide.

Ask who prescribes your treatment and whether that person is a physician or an APRN with prescriptive authority, since Position Statement 21-1 names those two. Ask who will perform it and what license they hold. If an RN will treat you, ask whether there is a patient-specific order or a standing order documented in your record, and how the prescriber will be available during the procedure.

If the injector is an LPN or an aesthetician, ask what authorizes the procedure, because the position statement places aesthetic procedures outside LPN scope and the cosmetology sources do not mention injections. Then verify each named person yourself. Our consultation checklist and nurse injector delegation guide can help organize the rest.

Arkansas sources apply to Arkansas appointments. The broader state-by-state injector guide covers other states, and if you are comparing clinics in Tennessee or Oklahoma, check that state's own boards. A directory listing or rating does not verify an injector's scope.