How Medical and Nursing Board Rules Work Together

A single patient visit often involves professionals regulated by different licensing boards. For example, a physician may establish physician oversight, a nurse practitioner may perform the good faith exam where permitted, and a registered nurse may administer treatment under delegated authority. Because each provider is accountable to a different regulatory board, med spas must understand how these requirements work together instead of treating them as separate compliance obligations.

In practice, this means a compliant workflow should address responsibilities across multiple regulators, including:

• Physician oversight: Medical board regulations establish the physician’s responsibilities for patient care, delegation, supervision, and clinical decision-making.
• Nursing scope of practice: Nursing board rules define the procedures registered nurses and nurse practitioners may perform and the conditions under which those services can be provided.
• Delegation and supervision: Both boards establish requirements that determine how medical procedures can be delegated and the level of provider oversight required throughout treatment.
• Documentation and accountability: Each licensed professional is responsible for maintaining documentation and practicing within the standards established by the board that regulates their license.

Reviewing guidance from both the medical board and the nursing board provides a more complete understanding of the requirements governing physician oversight, delegation, and patient care. It also helps med spa owners identify compliance gaps before they become regulatory issues.

States With Med Spa-Specific Good Faith Exam Guidance

Reading state law alone often does not answer every compliance question. Advisory opinions and declaratory statements issued by medical and nursing boards provide additional guidance on how regulators expect physicians, nurse practitioners, registered nurses, and other licensed professionals to perform medical aesthetic procedures. Several states have published guidance specific to med spas and cosmetic treatments.

Arizona

The Arizona State Board of Nursing has issued an advisory opinion addressing medical aesthetic procedures performed by registered nurses and nurse practitioners. The guidance outlines the education, competency, delegation, and clinical judgment expected when nurses participate in aesthetic treatments.

For med spas operating in Arizona, this advisory opinion provides practical direction on:

• The responsibilities of registered nurses performing delegated procedures
• The role of nurse practitioners in patient evaluation and treatment
• Required competency before performing medical aesthetic services
• The importance of practicing within the individual’s authorized scope of practice

While the advisory opinion does not replace Arizona law, it explains how the board interprets nursing responsibilities in aesthetic medicine and should be reviewed alongside applicable statutes and regulations.

Kentucky

The Kentucky Board of Nursing has published an advisory opinion on cosmetic and dermatological procedures performed by nursing professionals. Instead of creating new law, the opinion explains how existing nursing regulations apply to common aesthetic treatments.

The guidance addresses topics such as:

• Scope of practice for registered nurses and advanced practice registered nurses
• Provider competency and education requirements
• Delegated medical procedures
• Clinical accountability when providing cosmetic services

Practices employing nursing professionals should understand that compliance involves more than physician supervision alone. Nursing board expectations also influence how aesthetic services are delivered.

Louisiana

The Louisiana State Board of Nursing has issued a declaratory statement addressing cosmetic procedures performed by registered nurses. It explains the conditions under which nurses may participate in aesthetic treatments and reinforces the importance of physician orders, delegation, and clinical oversight.

The statement also emphasizes that:

• Cosmetic procedures remain medical procedures when they involve the practice of medicine
• Registered nurses must work within their authorized scope of practice
• Delegated treatments require appropriate physician involvement
• Clinical decisions remain the responsibility of the qualified provider directing patient care

For Louisiana med spas, this guidance provides additional clarity on how nursing regulations intersect with physician oversight requirements.

What These States Have in Common

Although Arizona, Kentucky, and Louisiana have issued different forms of regulatory guidance, their recommendations reinforce many of the same compliance principles. While the language varies by state, the expectations for provider involvement, delegation, and clinical oversight remain consistent.

Across these states, med spas are expected to:

• Ensure qualified provider involvement: Good faith exams and medical aesthetic procedures require active participation from a qualified provider, not administrative approval or retrospective sign-off.
• Follow delegation requirements: Delegating a procedure does not transfer the supervising provider’s responsibility for patient care or clinical decision-making.
• Maintain provider competency: Physicians, nurse practitioners, registered nurses, and other licensed professionals must perform only those procedures they are qualified and authorized to provide.
• Document clinical decisions: Good faith exams, treatment orders, delegation, and physician oversight should be supported by complete and accurate documentation.
• Define clinical roles clearly: Every member of the care team should understand their responsibilities and practice within the scope of their license and state regulations.

Practices in states without similar advisory opinions should not assume fewer requirements apply. Instead, they should review their state’s medical practice act, nursing practice act, delegation regulations, and any guidance issued by the appropriate licensing boards to confirm that their physician oversight model complies with current requirements.

How to Determine Good Faith Exam Requirements Without State-Specific Guidance

Many states have not issued advisory opinions specifically addressing med spas or good faith exams. That does not mean practices operate without regulatory requirements. In most cases, compliance is determined by applying existing healthcare laws that govern the practice of medicine and nursing.

These sources typically include:

• Medical Practice Acts: Define physician responsibilities, delegation authority, and standards for practicing medicine.
• Nursing Practice Acts: Establish the scope of practice for registered nurses and nurse practitioners, including when collaboration or physician oversight is required.
• Delegation regulations: Explain which medical procedures may be delegated, who may perform them, and the level of supervision expected.
• Prescriptive authority rules: Determine which providers can evaluate patients, issue treatment orders, and prescribe medications used during aesthetic procedures.
• Telehealth regulations: Specify whether good faith exams may be performed remotely and the conditions that must be met before treatment begins.

Because these requirements vary by state, med spa owners should review the current regulations published by both their state medical board and nursing board instead of relying on general online summaries. Establishing physician oversight around current regulatory guidance helps reduce compliance risks as laws and board interpretations continue to evolve.

How Medical Director Co. Tracks the Rules That Apply to Your Practice

Medical Director Co. helps med spas establish compliant physician oversight by matching practices with qualified medical directors who understand the regulatory requirements in the states where they practice. Every placement is designed to support physician oversight that aligns with current state requirements rather than relying on generic compliance approaches.

Our placement process includes:

• Matching your practice with a qualified physician: Work with a medical director licensed in your state and familiar with its regulatory requirements.
• Supporting physician oversight that reflects board guidance: Build provider relationships that align with current medical and nursing board expectations.
• Providing attorney-reviewed agreements: Receive documentation that supports compliant delegation and physician oversight.
• Helping practices maintain compliant provider relationships: Access ongoing support as regulations, board guidance, and practice needs evolve.

By combining qualified physician placement with attorney-reviewed documentation and ongoing compliance support, Medical Director Co. helps practices build physician oversight programs that reflect their state’s current regulatory requirements.