Who Can Inject Botox in Oklahoma? What 3 Boards Say

Three Oklahoma licensing boards have each published a document about med spas, and each speaks mainly to the professionals it licenses. The Medical Board and the Osteopathic Board both describe injection of neuromodulators and dermal fillers as a medical-grade med spa treatment. The Board of Nursing lists neuromodulator and dermal filler injections, with Botox as an example, among the cosmetic procedures its guideline covers.

These are guidelines and a policy, not statutes or administrative rules, so this guide says what each board states rather than what the law requires. The table shows who wrote what. Compare it with the person who will actually treat you, using our consultation checklist.

The Medical Board's guidelines say an MD who practices in a med spa must hold an active, full, unrestricted Oklahoma license. They also call for an established physician and patient relationship that includes an initial evaluation before treatment. The evaluation may be face to face or by telemedicine, and may be performed by the physician, a supervised PA, or a supervised APRN with prescriptive authority.

On supervision, the guidelines give different answers by type of helper. For unlicensed, trained assistants under a physician's control, the physician must be on site before, during and after the treatment. For a licensed physician assistant, the physician may delegate defined medical services under general supervision, and physical presence is not required if the two can easily reach each other by telecommunication.

For nurses and APRNs the Medical Board does not set a level itself. It says the physician should contact the Board of Nursing to learn the nurse's scope and the supervision required. For cosmetologists, barbers and similar practitioners it points to the Board of Cosmetology. It also says a physician may not let the practitioners it lists delegate the service further, and that physicians who are medical directors of med spas are subject to the guidelines.

The Osteopathic Board's policy says DOs must actively supervise their med spa. It repeats the initial-evaluation requirement and adds that the aesthetic healthcare professionals should develop a treatment plan covering risks, benefits, alternatives, follow-up and care for potential complications.

The policy says the supervising physician, PA or APRN may treat the patient or delegate the treatment to a licensed RN under the physician's general supervision, which does not require the physician to be in the office. If treatment goes to a licensed practical nurse, licensed esthetician, certified micropigmentologist, medical assistant or unlicensed assistant, the policy says the physician must provide direct supervision and be physically available before, during and after treatment.

It also says the supervising physician must provide timely and random chart reviews, ensure adequate training for staff, and conduct safety and compliance reviews. The board separately posts Osteopathic Medical Spa Guidelines whose wording largely matches the policy. Read the policy, which shows its adoption date.

The Board of Nursing's guideline says it is within the scope of practice of licensed nurses (RN and LPN) to perform cosmetic and aesthetic dermatological procedures as prescribed or ordered by a licensed physician, nurse practitioner, physician assistant or other practitioner with prescriptive authority acting within that practitioner's legal scope of practice, provided all of the guideline's criteria are met.

For an RN, it says the on-site presence of a physician, APRN, PA or other practitioner is not required if there is a valid order or prescription and a completed history and physical performed by the health care practitioner. For an LPN, it says the nurse requires supervision by an RN, physician or dentist, and again requires a valid order and a completed history and physical.

For both roles the guideline says standing orders are not an appropriate substitute for an individualized prescription or order and the history and physical. It also says the nurse must have the knowledge, skill and competency for the procedure, and that agencies and businesses shall establish and maintain on-site policies and procedures for the procedures and for emergency interventions.

The guideline's APRN section ties practice to the APRN's education, national certification and experience, and lists documentation that should show an initial evaluation, a diagnosis, a treatment plan and informed consent. The three boards wrote for different licensees, and this guide does not reconcile their wording. If a clinic says an LPN or RN will treat you, ask which provider ordered it and where that provider is.

The Board of Cosmetology and Barbering's rule on scope of practice (OAC 175:10-7-29) says cosmetology does not include services that puncture the skin or fall within the scope of the healing arts. It defines puncturing the skin to include injections, microneedling, laser treatments, high intensity focused ultrasound, cryolipolysis and dermabrasion, and says these are beyond the scope of a cosmetology or esthetician license.

The same rule lists intense pulsed light therapy devices within a category of light emitting diode devices approved by rule for cosmetic skin care. It also says estheticians may only exfoliate cells of the stratum corneum. The rule is detailed, so ask the Cosmetology Board about a specific device rather than relying on a summary.

On lasers in medical settings, the Osteopathic Board's policy says a physician is not required to be physically present for or to supervise laser hair removal but must be available for communication during the procedure. It says the facility's written protocols must use a physician, PA or APRN for complication management. The Board of Nursing's guideline advises nurses doing laser procedures to review the Oklahoma Laser Hair Removal Act (59 O.S. 538.3). We did not capture that statute, so this guide does not summarize it.

Get the full name and license type of each professional from the clinic, then search the board that licenses that type. For an MD, PA or other Medical Board licensee, use its licensee search. The board says its disciplinary action information dates back as early as 1984, and that some results for office hours, privileges and insurance may be incomplete.

For a DO, use the Physician Search on the Osteopathic Board's website. The board's FAQ says its Disciplinary Actions link gives an alphabetical list of physicians disciplined in the last five years, and that a public notice in a search result points to an earlier action you can ask the board about. For RNs, LPNs and APRNs, use the license verification lookup portal that the Board of Nursing's homepage links.

For an esthetician, the Cosmetology Board's homepage links to its licensing portal. On the homepage we reviewed, we did not find a description of a public license lookup, so confirm with the board. See also our general guide to verifying medical spa licenses.

File with the board that licenses the person you are concerned about. The Medical Board takes complaints through an online form and says it has jurisdiction over MDs and PAs, among other professions. It says it has no jurisdiction over people who do not hold one of its licenses, and that practice without a license should be reported to the county District Attorney.

The Osteopathic Board takes complaints about DOs through an online portal. The Board of Nursing accepts online complaint reports about RNs, LPNs, APRNs and advanced unlicensed assistants. The Cosmetology Board's rule on complaints about licensees, or people alleged to be practicing cosmetology or barbering without a license, says the complaint shall be signed and include the name and address of the person complained about, a detailed explanation, and the name and address of the person filing. The same rule says staff may investigate anonymous complaints to the extent needed to protect public health and safety, and that forms are available from the board's office.

Our guide on filing a complaint against a medical spa explains how to choose between regulators and gather your records.