Medical spas in Pennsylvania

Botox Cosmetic is a prescription medicine, according to its FDA label, so a prescriber has to authorize it. Pennsylvania's State Board of Medicine lets a medical doctor delegate a medical service to another health care practitioner or a technician only if the doctor knows that person has the education, training, experience and continued competency to do it safely, and the delegation does not create an undue risk for the patient. A doctor may not delegate work whose performance or complications call for knowledge nonphysicians do not ordinarily have.

The delegation rule sets no fixed on-site requirement. The doctor stays responsible and must be available as the difficulty of the procedure, the skill of the person and the patient's risk require, and the patient must be told the service is delegated and must not object. Registered nurses may administer a drug ordered for a patient in the dosage and manner prescribed, and the nursing rules we read are general rather than written for cosmetic injectables.

Certified registered nurse practitioners (CRNPs) diagnose and prescribe under a written, signed collaborative agreement with a physician, who must be immediately available, and that availability may be by direct communication, radio, telephone or telecommunications, so the definition does not require the physician on site. Physician assistants work under a written agreement with a named supervising physician, and the statute says supervision does not require the physician's on-site presence. Two bills that would amend the CRNP provisions, SB 25 and HB 739, had not been reported from committee when we read them, so they are proposals, not law.

On exams, the State Board of Medicine's written rule requiring an initial medical history and physical exam before prescribing covers controlled substances. We found no rule that expressly requires a prescriber's exam before a cosmetic neurotoxin or filler treatment, nor one saying specifically whether a cosmetic injection may be delegated to an unlicensed technician, so ask who examines you and who injects.

We found no Pennsylvania statute, regulation or board page that specifically addresses who may operate a cosmetic laser or IPL device, or whether laser hair removal is the practice of medicine. Because the rules we read do not settle it, ask any spa who operates the device, what license that person holds and who supervises.

A Pennsylvania esthetics license covers facial massage, applying cosmetic preparations, lotions and creams to the face, removing hair by tweezers, depilatories or waxes, and dyeing eyelashes and eyebrows. That definition does not mention lasers or IPL, and we found no Board of Cosmetology rule that expressly permits or forbids them for estheticians.

The State Board of Cosmetology's published cases treat several med spa services as outside cosmetology. In a 2023 consent agreement the respondent acknowledged that Botox, face fillers and microneedling are outside the scope of cosmetology and that performing them in a cosmetology salon violates the rule against using a salon for other purposes. Later cases reached similar results for dermaplaning and milia removal and for permanent makeup, and in one the respondent acknowledged that performing dermaplaning, hydro-dermabrasion and oxygen therapy in a salon was a violation. These are disciplinary case outcomes, not regulations.

So neither an esthetics license nor a salon's cosmetology license is a license to inject. We also found no Pennsylvania rule specific to who may own a med spa, so we make no claim about ownership; check the license of each person who treats you instead.

The Department of State's Pennsylvania Licensing System (PALS) lets anyone look up a professional's license number and status. It covers licenses issued by the Department's boards, including physicians under Medicine and Osteopathic Medicine, physician assistants, RNs, LPNs, CRNPs and estheticians under Cosmetology, and the Department's verification page links to professional licensing disciplinary actions.

Know which board you are checking. The State Board of Medicine covers MDs and physician assistants working with MDs, the State Board of Osteopathic Medicine covers DOs and physician assistants working with DOs, the State Board of Nursing covers RNs, LPNs and CRNPs, and the State Board of Cosmetology covers estheticians, cosmetologists and salons.

Pennsylvania is a Nurse Licensure Compact state, so an RN or LPN with a multistate license from another compact state may practice here under that license. That license is issued by the nurse's home state, not by Pennsylvania, so ask which state issued it.

To complain about a licensed professional, or about someone you suspect is practicing without a license, submit a Statement of Complaint Form to the Department of State through PALS.