Who Can Inject Botox in Maryland? Physician and Nurse Rules

Three state bodies matter for a Botox appointment in Maryland. The Maryland Board of Physicians oversees physicians and physician assistants (PAs): its practitioner search covers both, and the state's PA statute says the board issues PA licenses. The Maryland Board of Nursing takes complaints about registered nurses (RNs), licensed practical nurses (LPNs) and advanced practice registered nurses, and its license lookup includes certified registered nurse practitioners (CRNPs). The State Board of Cosmetologists issues the limited esthetician license under Title 5 of the Business Occupations and Professions Article, separate from the Health Occupations Article that the health boards' cosmetic rules cite.

Each health board has a cosmetic chapter in the Code of Maryland Regulations (COMAR): COMAR 10.32.09 in the Board of Physicians subtitle and COMAR 10.27.25, Cosmetic Procedures, in the Board of Nursing subtitle. Both regulate professionals and procedures. In the pages we reviewed, we found no separate Maryland license for a med spa as a business. The State Board of Cosmetologists does issue beauty salon permits to businesses where cosmetology, which includes esthetic services, is practiced. For an injection, both cosmetic chapters set duties for individual practitioners, so check each person's health license.

COMAR 10.32.09 governs the performance, delegation, assignment and supervision of cosmetic medical procedures by a physician or under a physician's direction. It took effect August 23, 2010, and its defined terms were amended in 2016 and 2018. Its definition of a cosmetic medical procedure includes subcutaneous, intradermal or intramuscular injections of medical products. The rule names no brand.

Under the rule, a physician may delegate a cosmetic medical procedure to a physician assistant, or assign it to another health care provider licensed under the Health Occupations Article whose licensing board has determined that the procedure falls within that provider's scope of practice. The chapter says it does not authorize delegating duties to anyone who is not licensed under that article.

The physician must keep written office protocols at each site where delegated, assigned or supervised cosmetic medical procedures will be rendered, personally perform each patient's initial assessment, write a treatment plan, obtain the patient's informed consent to treatment by a non-physician and retain responsibility for delegated acts. Anyone to whom the physician delegates or assigns the procedure must have had the chapter's theoretical and clinical training plus any training their own health occupations board requires. A physician who performs these procedures, or assigns, supervises or delegates their performance by a non-physician, must first obtain training in them, and a manufacturer's or vendor's course may not be the physician's only education in the procedures.

The non-physician must follow the protocol, verify that the physician assessed the patient and gave written instructions, confirm that the patient knows a non-physician will treat them and has consented in writing, and report any adverse event or complication to the physician before the patient leaves. A non-physician who violates the chapter is, in the rule's words, guilty of the practice of medicine without a license and may face a fine of up to $50,000.

COMAR 10.27.25, Cosmetic Procedures, took effect May 30, 2011, and a records provision was added effective October 13, 2025. It defines a nurse as an RN or an LPN, and neuromuscular agents as injectable drugs that cause muscle weakness for the cosmetic softening of wrinkles, including but not limited to Botox and Dysport. These agents, dermal fillers and micropigmentation with topical anesthetics only form its Category D injectable treatments.

An RN may perform every category; an LPN may perform all except Category C, selective laser treatments. A nurse must first complete a program of study with theory and precepted clinical practice, including documented initial and annual competency in each procedure.

The rule lets the nurse perform a procedure when there is a completed prescriptive order from an authorized prescriber. The rule says the order includes, but is not limited to, the procedure, the treatment area and the medication, dosage, route and time interval; its list also covers identifying the light source and the radio frequency, current dosage, intensity and time period to be applied, and the use of any topical anesthetic. The nurse may not work from a standing order or protocol, and may not do the pre-procedure medical assessment, diagnose, prescribe, develop the treatment plan or do the post-procedure medical evaluation.

Nurses may not give injections for mesotherapy or lipodissolve or perform Sculptra injections. The Board of Nursing's FAQ page on declaratory rulings, marked as updated September 21, 2016, says the board withdrew all of its earlier declaratory rulings and that routine requests for them ceased in 2008; released copies carry a disclaimer that they are no longer valid board positions. In the pages we reviewed, we found no Board of Nursing declaratory ruling on cosmetic Botox.

Both rules address it, in different words. For procedures under a physician's direction, COMAR 10.32.09 requires the physician to provide onsite supervision whenever a non-physician is performing cosmetic medical procedures or using cosmetic medical devices. It defines on-site supervision as oversight by a supervising physician who is present at the site and able to respond in person during a delegated or assigned cosmetic medical procedure.

The exceptions are for physician assistants. The Board of Physicians may approve a delegation agreement that lets a physician delegate cosmetic procedures to a PA under immediately available supervision, which the rule defines as direction in person, by telephone or by other electronic means, after the physician has evaluated the patient and written a treatment plan. The rule also says a PA delegation agreement that includes cosmetic procedures and was approved by the Board before May 2009 is not affected by the chapter.

COMAR 10.27.25 puts the nursing side in terms of the authorized prescriber. For Botox and other Category D injectables, before the nurse performs the procedure, the prescriber must complete the assessment and treatment plan and be physically present in the setting, and must be immediately available when the procedure is performed and afterward to evaluate the patient. The chapter's exceptions regulation lets a nurse perform Category F peels and topicals, other than cryotherapy, without these prescriber requirements; it does not cover injectables. The nursing rule says prescriber rather than physician, so ask the clinic to name that person, their license, and where they will be during your appointment.

The nursing chapter says it does not restrict or limit a Maryland CRNP from possessing, prescribing, evaluating or performing its procedures, and does not apply to other practitioners authorized under their own practice acts. It says nothing more about CRNPs, so verify a CRNP's certification in the Board of Nursing lookup. Our nurse practitioner guide covers the wider topic.

For PAs, COMAR 10.32.09 uses terms that differ from the current statute: it refers to a physician assistant with a current certificate and to Board-approved delegation agreements, and its administrative history lists no amendment after 2018. The current PA statute, Health Occupations Article section 15-101, refers to licenses and collaboration agreements, and says collaboration does not require a collaborating physician's constant physical presence on site if that physician is accessible by electronic means.

In the pages we reviewed, we found no Board of Physicians statement reconciling the two for cosmetic procedures. Ask the clinic which physician the PA works with and how that physician can be reached during and after your treatment.

Maryland's statute defines esthetic services to include cosmetic microneedling, superficial exfoliation of the epidermis and nonablative skin rejuvenation, and says they do not include diagnosing illness, disease or injury or performing ablation of the dermis or hypodermis. The General Assembly's page shows that the 2024 bill altering this definition, House Bill 1302, was approved by the Governor as Chapter 325, effective October 1, 2024.

The State Board of Cosmetologists voted at its June 2026 meeting to adopt scope guidance for the limited esthetician license. The guidance lists Botox, fillers and injectables, laser hair removal and IPL, and IV therapy or injectable vitamins among prohibited services. It says any service that penetrates beyond the epidermis is not permissible for limited estheticians or cosmetologists unless the person also holds a health occupation license that authorizes the procedure. The board's home page also lists proposed regulations with a public comment deadline of August 25, 2025; the pages we reviewed do not show their final text, so confirm the current rules with the board.

The physician rule points the same way. It allows assignment only to providers licensed under the Health Occupations Article, and says a person who performs a cosmetic medical procedure without being a licensed physician or authorized under that chapter or another health board's regulations is guilty of the practice of medicine without a license. See our esthetician scope guide.

For a physician or PA, use the Board of Physicians' Practitioner Profile Search, by license number or last name. The board says physician license numbers start with D, H, X or T and PA numbers with C, followed by seven digits. For a nurse, use the Board of Nursing license lookup on the Maryland Department of Health site, which covers RNs, LPNs and CRNPs. Get the full name and license type from the clinic, then match the result to the person treating you. Our license verification guide covers the general steps.

The Board of Physicians' online complaint form asks for the practitioner's office phone number and lets you upload records, emails and photos. Its page says a submitted complaint cannot be withdrawn, the board cannot order a licensee to pay money to someone who believes they were harmed, anonymous submissions must be finished in one sitting, and statutes of limitations apply, with some exceptions.

The Board of Nursing says anyone may file a complaint against an RN, LPN or APRN on its downloadable form, by email or mail. It does not accept anonymous complaints, and a decision may take up to a year or longer. The State Board of Cosmetologists says it investigates complaints against its licensees and about unlicensed practice. See also our complaint guide.

Ask who assesses you and writes your plan, who injects, what license that person holds and who will be on site. Both rules expect you to know when someone other than a physician treats you: the physician rule calls for your written consent to treatment by a non-physician, and the nursing rule's policies cover consent that documents a licensed nurse will perform the procedure.

If the clinic mentions a medical director, ask for that person's name and license. Use our consultation checklist for other questions and the state-by-state injector guide for other states. A directory listing or rating does not verify an injector's scope.