Can Nurse Practitioners Offer Botox?

By Carolyn Buppert, NP, JD

Can Nurse Practitioners offer Botox, Restylane, Juvederm and other cosmetic treatments on their own?

The answer to this question is going to be state-specific. Here are the steps to follow:

1. Read your state's Nurse Practice Act section on scope of practice for nurse practitioners to answer these questions: What acts require physician collaboration or supervision? How is collaboration or supervision defined? (Boards of Nursing in the United States: State-by-State Web Links)
2. Go to your state's Board of Medicine Websites and search for any policies on provision of botulinum toxin (Botox®). Note that botulinum toxin is a prescription medication, so a prescription or order for the medication must be written and someone must administer the drug. If your state has policies on botulinum toxin, note the requirements for prescription and administration. Some states consider administration of botulinum toxin a medical act, and some states consider it to be within the scope of a registered nurse. Prescribing is always a medical act.
   
   If you live in a state that requires no physician collaboration when nurse practitioners prescribe, then as long as the Board of Medicine has no requirements with respect to botulinum toxin, you are free to proceed with your practice idea. If your state requires physician collaboration in order for nurse practitioners to prescribe, then you'll need to line up a collaborator. In most states, the collaborator does not need be on site, but in some states, the collaborator must practice at the site with specified frequency. Follow the rules as they relate to any prescribing.

About: Carolyn Buppert, NP, JD is an attorney practicing in Bethesda, Maryland.

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Comments

[lefty2g]

I can not even imagine anybody learning all this material in a short time. They obviously have no idea as to what you have to go through to be prepared to do this work effectively. You have to consider the time it takes to get "hands-on experience" too. Particularly, on ALL areas of the body on all types of skin, on patients of various ages and different color skin using a number of different lasers. I have the background in biology, physics, and chemistry plus a number of years in the pharmaceutical industry where I obtained the pharmacology training needed to understand the use of dermatologic drugs and products needed to help patients with various skin problems, consequently, my perception of this is different than the average person in this industry. Due to the inability, lack of knowledge, or unwillingness of of state governments to enforce laws that are already on the books, most of the people in the Spa and beauty business have little or NO training, and minimal experience for the procedures they do. Virtyally NO STATE ISSUES A LICENSE TO BE A LASER TECHNICIAN.

I am glad to see doctors trying to get the training needed to do this work, however, as doctors they know what it is to go through a "specialty training" program. That is why I believe many questions presented here are NOT by doctors as they would not even ask where to get training. Laser use is SURGERY. All the laser procedures were invented by Plastic Surgeons and Dermatologists. Even electrolysis was invented by a doctor but it is boring and not as gratifying as treating patients with assorted problems so it was turned over to his nurse. As medicine advanced, more information was developed and it became obvious no doctor could learn it all, consequently, we have the development of SPECIALISTS. Medical schools developed training programs to teach the various subjects as they are associated with hospitals where a large number of patients could be seen and referred to the particular department that was equipped to handle these patients and make available to doctors in training the assortment of problems they could expect to see in the office. NO LASER TECHNICIAN IN THIS COUNTRY (U. S.A.) HAS AN ADEQUATE OR PROPER SUPERVISED TRAINING EXPERIENCE to be doing these procedures. The famous Massachusetts General Hospital returned money to patients who had laser hair removal treatments and now has a rule that only Board Certified Doctors or surgical residents under the direct supervision of a Board Certified doctor can pick up a laser wand to treat anybody for anything. They no longer do laser hair removal at this hospital as a matter of policy as patients come there from all over the world to be treated by Board Certified Doctors. If they can not provide this they do not do it.

I AM AMAZED AT HOW MANY DO NOT BELIEVE ME WHEN I TOLD THEM LASER PROCEDURES ARE SURGERY. THEY CHOOSE TO IGNORE THIS FACT BECAUSE OF THE MONEY THEY THINK THEY CAN MAKE. THEY ARE IN FOR A BIG SURPRISE, Any procedure that alters the structure or function of the area being treated is SURGERY. They will have to have the same malpractice insurance as a doctor. Since they have much less instruction and education than a doctor the insurance company will be taking a huge risk for which they have to be paid. I would not be surprised if they insist on more premiums as premiums are based on the RISK they are exposed to. The greater the risk.... the greater the premium.

[lefty2g]

I checked with a few lawyers who ALL AGREED THAT... FDA regulations and rules out rank local , or state, or county, laws when they are about the same subject. NO NURSE PRACTITIONER CAN LEGALLY INJECT anything unless under a doctors ORDERS. SHE IS NOT LICENSED TO MAKE A DIAGNOSIS or administer medication by injection except what her state specifically allow. She is NOT covered by malpractice insurance for anything other than what the license allows... but.since FDA says cosmetic SURGERY AND INJECTIONS MUST BE SUPERVISED by a doctor she is stretching the definition of her license. GOOD LUCK TO THE PEOPLE SHE TREATS.