Scope of Practice8 min read · Published 2026-10-29

Who Can Inject Botox in New Mexico? Board Rules Explained

A patient guide to the Medical Board's Medical Spa Policy, the cosmetic injection rule, nursing and dental rules and official license checks, with primary sources checked October 29, 2026.

Two Letybo 100 Units vials, four orange-capped syringes, two McKesson alcohol prep pads and a gauze square on a teal drape in a steel tray
An illustrative photograph of vials and syringes laid out for a procedure. It was not taken at any practice named or regulated in this guide.Photo: The Search Sherpa (thesearchsherpa.com)

The short answer

The New Mexico Medical Board's Medical Spa Policy, revised September 26, 2025, says Botox and other injections must be performed by an MD, DO, APRN or PA, not delegated to medical assistants or estheticians. Rule 16.10.13 NMAC says cosmetic injections cannot be delegated to medical assistants, and the nursing rule says LPNs may not provide aesthetic injections.

By Medical Spa Providers Editorial Team (Independent editorial research; primary references listed below)Updated 2026-10-29

Which New Mexico boards matter for Botox


Start with the full name and license type of the person who will treat you, and separately the provider who authorizes the treatment. The board that matters depends on the license, and New Mexico's boards publish different kinds of documents. This guide treats a rule in the New Mexico Administrative Code differently from a board's policy document, and says which is which.

The New Mexico Medical Board says its jurisdiction covers the licensing and discipline of medical doctors, physician assistants, osteopathic doctors and several other professions. It also says it does not regulate hospitals or healthcare facilities, or any other practitioners. Nurses are licensed by the Board of Nursing, estheticians and cosmetologists by the Board of Barbers and Cosmetologists, and dentists by the Board of Dental Health Care.

Treat this guide as a way to prepare better questions. It does not decide whether a particular clinic's staffing satisfies every applicable rule.

RoleBoard named in the sourcesWhere to check
Physician (MD or DO), physician assistantNew Mexico Medical BoardThe Medical Board's Licensee Lookup
RN, LPN, APRN-CNPNew Mexico Board of NursingThe Board of Nursing's License / Certification Verification Portal
Esthetician, cosmetologistBoard of Barbers and CosmetologistsThe Regulation and Licensing Department's Boards and Commissions license lookup, which asks you to select the profession
DentistBoard of Dental Health Care (16.5.14 NMAC)Not covered by the pages we captured

What the Medical Board's Medical Spa Policy says


The Medical Board's Medical Spa Policy shows a date issued of 12/13/2023 and a date revised of 9/26/2025, and names the New Mexico Medical Board as approver. It is a board policy document, not a statute or an administrative rule, so this guide describes it as the board's policy. It says its purpose is to ensure compliance with board regulations on scope of practice, supervision, staff qualifications, informed consent, delegation and facility standards.

On injections, the policy says any injection or tissue-penetrating procedure, with Botox, fillers, microneedling and chemical peels given as examples, must be performed by a licensed medical provider, which it lists as MD, DO, APRN or PA. It says delegation to medical assistants, estheticians or cosmetologists is prohibited.

On supervision, the policy says the medical director must be a New Mexico-licensed MD or DO competent in aesthetic medical procedures. Listed responsibilities include approving protocols, patient evaluation, planning and follow-up, and being physically present or readily available during procedures. The policy also says the supervising physician's identity must be visibly posted for patients.

On consent, the policy says patients must receive written informed consent before treatment, covering risks, benefits, alternatives and staff roles, and should be told clearly who is performing the procedure. It also says New Mexico allows non-physician ownership of med spas, while all medical procedures must be overseen by a supervising physician.

An earlier board document, Medical spa practice, shows a date issued of December 13, 2023 and a date revised of March 18, 2024. We relied on the 2025 policy and on the rule text below.

What 16.10.13 NMAC says about cosmetic injections


Rule 16.10.13 NMAC is issued by the Medical Board and is titled Delegated use of devices and procedures by medical assistants; cosmetic injections. Section 9 says the injection of cosmetic or aesthetic substances is considered the practice of medicine and shall not be delegated to medical assistants.

The rule defines a medical assistant as someone who is not licensed as a healthcare practitioner in New Mexico and works under a licensed physician's direction and supervision. It adds that licensed practitioners, including registered nurses and physician assistants, are not considered medical assistants under the rule.

For energy-based devices, the rule limits medical assistants to non-incisive and non-ablative devices. It requires device-specific certification and says the supervising physician must be immediately available on the premises. Before a medical assistant treats you, the physician must provide the patient history, physical examination, diagnosis, treatment protocol and medical record, and must make sure you know the person treating you is a medical assistant.

The rule also says any public communication offering a cosmetic medical procedure must identify the physician or surgeon responsible for it or for its direct supervision. A clinic's website or advertisement is a reasonable place to look for that name.

Nurses, nurse practitioners and physician assistants


The Board of Nursing's rule on nurse licensure, 16.12.2 NMAC, has a section on LPNs. It says LPNs may perform selected aesthetic procedures, such as laser treatments, under the direct supervision of a qualified provider. It also says LPNs may not provide aesthetic injections. The section's history note shows an amendment dated 5/21/2024.

In the New Mexico pages we reviewed, we found no statement that addresses RNs and cosmetic neurotoxin injections by name. The Medical Board's earlier March 2024 document says the supervising physician is responsible for the care nurses (RN and LPN) provide in medical spa procedures and must ensure they are trained, with a training certificate provided to the board, but it does not say which injections an RN may give. The Medical Spa Policy's list of who may inject names MD, DO, APRN and PA and does not mention RNs. The nursing rule says a delegating nurse is accountable for each delegated activity and may not delegate nursing assessment, evaluation and nursing judgment to non-licensed persons. None of this settles every RN arrangement, so ask the clinic who authorizes your treatment. Our RN delegation guide and nurse practitioner guide explain those questions.

The nursing rule also says nurses must identify themselves by name and licensure category and permit inspection of their license when requested. That gives you a basis for asking to see a license.

RoleWhat the New Mexico sources sayQuestion to ask the clinic
LPN16.12.2 NMAC: no aesthetic injections; selected aesthetic procedures such as lasers under direct supervision.If an LPN is offered for an injection, what is the basis for that?
RNNot named in the Medical Spa Policy's injection list; the nursing rule sets delegation accountability.Who authorizes my treatment, and who supervises the RN?
APRN or PANamed in the Medical Spa Policy's list of licensed medical providers.Which provider evaluated me, and what is their license type?
Medical assistant16.10.13.9 NMAC: injections cannot be delegated to medical assistants.Who will actually inject, and what is their license?

Estheticians, cosmetologists and dentists


The Medical Spa Policy says an esthetician or cosmetologist who lacks medical assistant training and physician delegation must not perform medical spa procedures such as lasers, IPL, injectables or microneedling. It says they may assist only in a medical assistant role under physician training and supervision, and that delegating medical procedures to unlicensed staff outside that role is prohibited. The policy also says they may not use a non-medical license to run lasers or IPL unless they are operating as medical assistants under protocol and physician supervision. Our esthetician scope guide covers what their own license allows.

Dentists are covered by a separate rule from the Board of Dental Health Care. Rule 16.5.14.8 NMAC says the board does not issue permits for botulinum neurotoxin or dermal fillers. Before administering them in connection with the practice of dentistry, a dentist must have satisfactory training at an accredited dental institution or complete a board-approved continuing education course. The course content listed in the rule includes 16 hours total, with at least eight hours of live patient hands-on training. The rule defines dermal fillers, for its purposes, as products for the oral and maxillofacial regions. It says these products may only be administered in dental offices using universal precautions, and that dental auxiliaries are prohibited from administering them.

How to check a license in New Mexico


For a physician or physician assistant, use the Licensee Lookup that the Medical Board links from its website. The Medical Board also says any licensure action it has taken against a physician is public information and can be found under the licensee's profile on its website. Complaint records themselves are confidential, while licensure actions are public information on the profile.

For other professions, the Regulation and Licensing Department's Verify a License page describes a Boards and Commissions lookup in three steps: select the profession, select the license type or enter a name, license number, status or address, then select Search. The page we reviewed does not list which professions the lookup covers. The department says checking a license is an important tool to protect public health and safety.

For nurses, the Board of Nursing's License / Certification Verification Portal offers a search by name, license number or NCSBN ID. It accepts partial names, and recommends the license number or NCSBN ID for a more accurate result. The license types include RN, LPN and APRN-CNP. The portal also links to Nursys, which it describes as a national licensure and disciplinary database.

Ask the clinic for the injector's full name and license number, and match them to the person assigned to your appointment. Our license verification guide and consultation checklist cover the rest.

Where to send a concern


The Medical Board accepts complaints about its licensees through an online portal, where you can upload supporting documents. It accepts anonymous complaints but reviews them to decide whether a formal investigation is warranted. It can discipline a licensee only on evidence that the Medical Practice Act or board regulations were violated. The board says a complaint will not resolve a dispute with your doctor or obtain financial compensation, and that its investigation files are confidential unless a matter goes to a formal hearing.

The Board of Barbers and Cosmetologists says it investigates complaints from customers and inspects establishments. Its page links to a complaint form. The Regulation and Licensing Department's license lookup page also asks people to report unlicensed activity or other health and safety issues to the department by filing a complaint.

The Board of Nursing's website links a Nursing Practice Complaint page for concerns about nurses. We did not review that page, so check it for the board's process. Our complaint guide explains how to choose the right agency and what to include.

A license check is only part of the decision

A license lookup does not judge technique or whether a treatment suits you. Ask about the injector's experience with your proposed treatment, how you will be assessed, which products are used and what aftercare and follow-up the practice provides. Discuss suitability with the licensed professional who evaluates you.

Frequently asked questions

Can a nurse inject Botox in New Mexico?

The sources we reviewed do not give RNs a single yes or no. The Medical Board's Medical Spa Policy names MD, DO, APRN and PA for injections and does not mention RNs, and the Board of Nursing's rule says LPNs may not provide aesthetic injections. Ask who authorizes your treatment and verify each license.

Can an LPN inject Botox in New Mexico?

The Board of Nursing's rule, 16.12.2 NMAC, says LPNs may perform selected aesthetic procedures, such as laser treatments, under direct supervision of a qualified provider, but may not provide aesthetic injections. If a clinic offers an LPN for injections, ask for its basis and check the license on the Board of Nursing portal.

Can a medical assistant inject Botox in New Mexico?

No. Rule 16.10.13.9 NMAC says injecting cosmetic or aesthetic substances is the practice of medicine and shall not be delegated to medical assistants. The Medical Board's Medical Spa Policy says the same for Botox and fillers, and says medical assistants may not penetrate tissue. Ask who will actually inject you.

What do New Mexico sources say about a doctor being present at a med spa?

The Medical Board's Medical Spa Policy, a board policy and not a statute, says the medical director's responsibilities include being physically present or readily available during procedures. Separately, rule 16.10.13 NMAC says a certified medical assistant may use a cosmetic device only when the supervising physician is immediately available on the premises. Ask the clinic who supervises your appointment.

How do I check a New Mexico provider's license?

Use the Medical Board's Licensee Lookup for physicians and physician assistants, the Board of Nursing's verification portal for RNs, LPNs and APRNs, and the Regulation and Licensing Department's Boards and Commissions lookup for other professions. Get the full name and license number from the clinic first, then match the result.

Sources

Primary references behind this guide. Each link opens the publisher’s own page.

  1. Medical Spa Policy (issued 12/13/2023, revised 9/26/2025)New Mexico Medical Boardaccessed 2026-10-29
  2. Medical spa practice (issued December 13, 2023, revised March 18, 2024)New Mexico Medical Boardaccessed 2026-10-29
  3. 16.10.13 NMAC: delegated use of devices and procedures by medical assistants; cosmetic injectionsNew Mexico State Records Center and Archivesaccessed 2026-10-29
  4. 16.12.2 NMAC: nurse licensureNew Mexico State Records Center and Archivesaccessed 2026-10-29
  5. 16.5.14 NMAC: dentists, adjunctive dental servicesNew Mexico State Records Center and Archivesaccessed 2026-10-29
  6. Filing a ComplaintNew Mexico Medical Boardaccessed 2026-10-29
  7. New Mexico Medical Board home page (Licensee Lookup link)New Mexico Medical Boardaccessed 2026-10-29
  8. Verify a LicenseNew Mexico Regulation and Licensing Departmentaccessed 2026-10-29
  9. License / Certification Verification PortalNew Mexico Board of Nursingaccessed 2026-10-29
  10. Welcome to the New Mexico Board of NursingNew Mexico Board of Nursingaccessed 2026-10-29
  11. Barbers and Cosmetologists: overview and contact informationNew Mexico Regulation and Licensing Departmentaccessed 2026-10-29

Browse the register

Compare New Mexico med spas

Use the directory to find locations and contact details, then verify the professionals assigned to your appointment.

Browse New Mexico listings

Educational information about licensing and patient questions, not medical or legal advice. Primary sources were checked October 29, 2026. Confirm current guidance with the relevant board for a specific arrangement.

For med spa owners

Own a med spa? Get on the register.

People compare providers here by rating and services. Make sure your listing is present, current, and correct. It's free.

List your spa →