Who Can Inject Botox in Maine? Chapter 15 and Nurse Rules

Three licensing boards set the standards for the medical, osteopathic and nursing licensees who work in Maine's medical spas. The Board of Licensure in Medicine licenses allopathic physicians (MDs) and physician associates (PAs). The Board of Osteopathic Licensure licenses osteopathic physicians (DOs) and physician associates. The State Board of Nursing licenses registered nurses (RNs), licensed practical nurses (LPNs) and advanced practice registered nurses, including nurse practitioners.

Together the three boards issued Chapter 15, a joint rule titled "Joint Rule Regarding Standards of Practice for Intravenous (IV) Therapy Businesses, Medical Spas and Medical Aesthetic Businesses." The Board of Licensure in Medicine's summer 2026 newsletter says it became effective on July 14, 2026. The rule's opening statement names neurotoxin treatment and dermal fillers as health care services and procedures, and it defines a medical aesthetic business as one that provides services including neurotoxin treatment, dermal fillers, laser treatments and medical weight loss treatment.

Estheticians are licensed in a different category, aesthetics, under the barbering and cosmetology licensing chapter of Maine's professions law (Title 32, chapter 126).

Chapter 15 sets standards for licensees who work in medical spas; it does not widen who may inject. It states that providing care in a medical spa does not expand any licensee's scope of practice or change how licensees delegate health care services. Its aim, in the rule's own words, is "to clarify which individuals may be authorized to provide which services."

The rule holds licensees in medical spas to the same standards of care and professional ethics as licensees in traditional health care settings, and says failing to meet them may lead to discipline by the boards. It requires RNs and LPNs who care for patients located in Maine to hold an active Maine nursing license or an active multistate license from a nurse compact state. In its opening statement of purpose, the rule also says that "a course certificate of completion does not constitute a license," and that people with no professional license are prohibited from performing any medical procedures. Its operative delegation section, covered below, separately bars licensees from handing medical tasks to unlicensed health care personnel.

The rule calls the use of standing orders in medical spas for an individualized assessment, diagnosis and treatment of patients unprofessional conduct that may result in discipline, and says any violation of the rule by a licensee is grounds for discipline.

Chapter 15's opening statement says only physicians, physician associates and advanced practice registered nurses with prescriptive authority can evaluate the patient, make a diagnosis and prescribe a treatment, and that this authority "cannot be delegated to any person without prescriptive authority, including a registered nurse." Although that statement introduces the rule rather than setting a numbered requirement, it is the boards' position: in a Maine medical spa, the decision whether to prescribe a treatment such as Botox belongs to one of those three professions. The rule's operative sections back this up by having a physician, PA or APRN generally perform the clinical interview and physical exam, and by treating standing orders for individualized assessment, diagnosis and treatment as unprofessional conduct.

Being the med spa's owner, investor or medical director is not enough. The same opening statement says a physician, PA or APRN may hold any of those roles, but that none of them is sufficient to establish the valid licensee-patient relationship required before the prescription and administration of "drugs including IV therapies, aesthetic treatments and medications requiring prescriptions." A medical director who never sees you has not examined you.

Maine's nursing law says a certified nurse practitioner who qualifies as an APRN may prescribe and dispense drugs or devices in accordance with board rules. The same statute contains a transitional condition: until the State Board of Nursing adopts certain practice-standard rules, a nurse practitioner must practice for at least 24 months under the supervision of a licensed physician or a supervising nurse practitioner, or be employed by a clinic or hospital with a physician medical director. The statute text does not say whether those rules have since been adopted, so ask the State Board of Nursing if this matters to you. Our guide to nurse practitioner independent practice explains how this varies across states.

Maine's nursing law defines professional nursing to include the "administration of medications and treatment as prescribed by a legally authorized individual," and Chapter 15 lists registered nurses among the authorized licensees who may provide health care services in a medical spa within their legally permitted scope of practice. Neither document singles out who may inject neurotoxins such as Botox, and when we checked on November 12, 2026, the State Board of Nursing's position statements and advisory rulings pages listed no statement on cosmetic injections. Read together, these sources describe an RN who may give a prescribed treatment within the RN's legally permitted scope, education, training and experience, not one who decides on it: under Chapter 15's opening statement, evaluation, diagnosis and prescription stay with a physician, PA or APRN with prescriptive authority. Chapter 15's licensing section also says that authorizing and administering "parenteral and IV preparations" requires appropriate supervision of the administration by a physician, PA or APRN. The rule defines parenteral as any route other than the digestive system, although that section is written around IV therapy.

When an RN sees you, Chapter 15 expects a nursing assessment, generally in person, and says a static internet questionnaire is not an acceptable clinical interview. Because standing orders for individualized assessment, diagnosis and treatment are unprofessional conduct under the rule, ask who prescribed your treatment and when that clinician examined you. Our guide to registered nurse injector delegation rules compares how other states handle this.

Licensed practical nurses are also authorized licensees under Chapter 15. Maine law defines practical nursing as work done in a structured health care setting under the direction of a registered nurse or a licensed or otherwise legally authorized physician, podiatrist or dentist, and lets RNs delegate selected nursing services to LPNs, including giving prescribed medications, when the services use standardized protocols and procedures leading to predictable outcomes.

Maine law defines the practice of aesthetics as beautifying, massaging, cleansing, stimulating, toning or exercising the skin with cosmetic preparations or devices for the care of the skin, applying makeup or eyelashes, and trimming or tinting eyebrows and eyelashes. The same definition says it "does not include the diagnosis, treatment or therapy of any dermatological condition." Injections are not on the list, and an esthetician is not one of the physician, PA, RN, LPN or APRN licensees that Chapter 15 calls authorized licensees.

For staff who hold no health care license, Chapter 15 is direct: under no circumstances may a licensee delegate to unlicensed health care personnel the examination, nursing assessment, diagnosis, prescription or administration of medications to patients in a medical spa. Where a licensee does rely on unlicensed health care personnel for other health care services, the licensee must verify that systems are in place to ensure those staff are qualified, trained and authorized, and must be available in person or electronically to consult, particularly in an injury or emergency.

Our guide to medical esthetician scope limitations covers what estheticians can usually offer instead.

Chapter 15 says a physician, PA or APRN should generally perform an in-person clinical interview and physical examination for each patient. A telehealth visit can stand in only when the technology is sufficient to reach an informed diagnosis as though the exam had been done in person, and a static internet questionnaire does not count. The rule's opening statement adds that a simple questionnaire without an appropriate clinical assessment does not meet the standard of care.

Before treatment, the licensee must ensure you give informed consent and that it is documented in your medical record. The rule describes informed consent as a shared decision-making process covering treatment alternatives and what, if any, treatment to accept. The medical record must include, to the extent the standard of care requires, your history and current medications, exam results, nursing assessment, diagnosis, the risks and expected benefits of all options including forgoing treatment, records of drugs given, your decision and any need for follow-up or emergency care.

If a clinic offers Botox from a menu with no exam, no one asks about your medications, or you cannot find out who prescribed your treatment, those are questions to raise before you book. Our list of questions to ask at a med spa consultation can help.

Maine's Regulatory Licensing and Permitting search (ALMS) lets you look up many state licenses and view a licensee's current status and license or disciplinary actions. The Board of Licensure in Medicine directs anyone checking an MD or PA license, or whether a physician or PA has been disciplined, to that search. Its license FAQ notes that a physician or PA who is not licensed with it may be licensed with the Board of Osteopathic Licensure, which keeps a similar database. The State Board of Nursing's home page links to the same search for nurses through "Verify a license." Ask for the clinician's full name and license type so you search the right board.

To complain about an MD or PA, the Board of Licensure in Medicine accepts complaints in writing, through an online complaint or a letter, and says its review relies on written documents, so include all facts and concerns. The Board of Osteopathic Licensure takes complaints about DOs electronically, by mail on its complaint form, or by letter. The State Board of Nursing takes complaints about RNs, LPNs and APRNs through an online form or a detailed letter, and does not accept anonymous complaints. Our guide on how to file a complaint against a medical spa walks through what to include.

If you are comparing clinics in Portland, our Portland, Maine med spa listings show locations and contact details. Use them alongside the license search, not instead of it.