Most medical spa procedures are considered medical in nature. Because of this, most states require, and AmSpa recommends, that prior to your initial treatment, the medical spa should offer you an in-person exam by either a doctor, a nurse practitioner or a physician assistant.

This is an important question as medical treatments trigger specific requirements–face-to-face consult with a doctor, nurse practitioner, or physician assistant, to name one–that non-medical treatments do not. A medical treatment is a treatment that impacts or affects the living tissue of the body. For example, most states believe that any treatment that affects anything outside the dead skin cells, i.e. the epidermis, is considered to be a medical treatment. There is some confusion about whether certain treatments constitute medical treatments, such as microneedling and dermaplaning. Most states do believe these are medical treatments and it’s always better to err on the side of caution. It’s never a bad thing when a doctor performs a treatment or is on site.

AmSpa encourages consumers to be aware that oftentimes noncompliant medical spas will indicate that medical spa treatments are not medical treatments, when they are in fact considered medical treatments by the state. Body sculpting and laser treatments are often considered medical treatments, for instance, even though they are often advertised as nonmedical treatments. It’s in your hands to do the proper research. There are medical spas out there that aren’t necessarily always honest or even aware about compliance and legalities. The laws are changing and difficult to find, therefore it’s incumbent upon all of us to be aware of the legalities of the industry.

Not always. While a doctor doesn’t always have to be on-site for every medical spa procedure; however, you should have a face-to-face consultation with a doctor, physician assistant or nurse practitioner prior to each medical spa treatment. Once that happens, a doctor doesn’t necessarily have to be on-site. However, most states require, and AmSpa recommends, that a medical professional always be on-site to ensure proper treatment and supervision. Note that if you are ever offered a medical treatment without first seeing a doctor, nurse practitioner or physician assistant, that medical spa is likely operating illegally.

Not only should you be making sure the medical spa you are visiting is one of high standing that offers a safe, clean, legally compliant environment for you to have your treatments, but also ensure that the professional performing the procedure is the right person for the job. Did you know that each state has different requirements in regard to what type of licensed professional can do what type of treatment in a medical spa and medical aesthetics environment? For specific treatments, check out the question “Who can safely administer this treatment?” in our Medical Spa Treatment Directory to help guide you on what to expect in regard to the professional administering your procedure.

As a general rule, however, all medical treatments should be performed by medical professionals under the supervision of a physician. This is not always an easy distinction to make, however, as many treatments offered at medical spas are clearly not medical (European facials, for example) and some, at least at first blush, are sort of medical (i.e. microneedling and some laser treatments). As we discuss in the Medical Spa Treatment Directory, legally speaking, most states consider any treatment that “affects” the living tissue to be a medical treatment, although there are exceptions to this rule, depending on which state you are in.

The reality is that most treatments you’ll receive at a medical spa—lasers, fillers, Botox, radiofrequency, ultrasound, microneedling, to name a few—are considered to be medical treatments by the state. This is important because medical treatments require an in-person medical exam by a doctor (either MD or DO) or a mid-level practitioner (nurse practitioner or physician assistant) before the treatment is performed. They should also be performed by trained, experienced, and supervised professionals.

Every treatment is different and every state is different, so determining who can do what is not an easy task. But as a general rule, anything with needles or a scalpel should be performed by a practitioner who is, at a minimum, an RN. Laser treatments can usually—but not always—be performed by anyone with sufficient training, but many states are passing laws with specific requirements for firing a laser.

Bottom line, call your state board of medicine or nursing, a health care lawyer, or AmSpa to get updated information.

Check out our Medical Spa Treatment Directory for information on the top medical spa treatments available, ranging from botulinum toxin A (Botox/Dysport) to Vampire Face Lifts.

The American Med Spa Association defines a medical spa as a hybrid between an aesthetic medical center and a day spa” with four core elements: (1) the provision of non-invasive (i.e. non-surgical) aesthetic medical services; (2) under the general supervision of a licensed physician; (3) performed by trained, experienced and qualified practitioners; (4) with onsite supervision by a licensed healthcare professional.