A physician at a med spa can delegate certain tasks to qualified licensed healthcare professionals and unlicensed staff members who have the necessary training to perform specific procedures. Meaning, the roles of med spa employees are unique depending on their qualifications and licenses. Here, we outline the key personnel to whom a medical director can delegate.
Nurse Practitioners:
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Role: NPs can perform many medical and aesthetic treatments under a physician's supervision. They can also assess patients, diagnose conditions, establish treatment plans, and prescribe medications under a physician delegation agreement.
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Procedures: The procedures allowed include but are not limited to Botox injections, dermal fillers, laser treatments, microneedling, and consultations.
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Physician Assistants (PAs):
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Role: PAs are trained medical professionals who can also do intakes, histories, diagnose, form treatment plans, treat, and prescribe medications under a physician’s supervision. They often work closely with medical directors in med spas to perform both medical and cosmetic procedures.
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Procedures: Similar to NPs, PAs can perform a full array of non-surgical cosmetic procedures.
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Registered Nurses (RNs):
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Role: RNs can perform many treatments under the supervision of a physician or an NP/PA, and they often engage in follow-up care.
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Procedures: Like NPs and PAs, RNs can provide the full range of non-surgical cosmetic procedures so long as they are qualified and have been properly delegated.
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Licensed Practical Nurses (LPNs), Licensed Vocational Nurses (LVNs), and Certified Nursing Assistants (CNAs):
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Role: These individuals have a more limited scope than RNs in a typical medical practice but can still assist with patient care and perform the full range of non-surgical cosmetic procedures so long as they are qualified under the same type of supervision as RN’sÂ
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Procedures: They can provide the full range of non-surgical cosmetic procedures.They may also perform tasks such as pre-procedure preparation, post-treatment care, and assisting with patient management.
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Medical Aestheticians:
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Role: Medical aestheticians specialize in cosmetic treatments related to skin care. They can perform a variety of non-invasive procedures under the guidance of a physician.
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Procedures: As with the licensed individuals listed above, they can provide the full range of non-surgical cosmetic procedures under proper delegation so long as they are qualified.
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Laser Technicians:
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Role: These individuals are trained specifically in the use of laser technology. In many cases, they need certification in laser treatments, and a physician is responsible for their supervision.
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Procedures: Laser technicians perform laser hair removal, skin resurfacing, tattoo removal, and other laser-based treatments.
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Administrative Staff:
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Role: While not medical professionals, administrative staff can handle patient intake, scheduling, and help with the administrative side of treatments.
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Tasks: Administrative tasks include patient intake, scheduling consultations, maintaining records, and assisting with patient communication.
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Conclusion on Roles of Med Spa Employees
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While various roles with different delegation authority exist in a med spa setting, it is important to remember that anything related to performance of procedures relating to patients is within the purview of the medical director. In other words, the physician remains legally responsible for ensuring that the delegation follows the requisite regulations and that the delegated individuals are properly trained and licensed for the specific tasks.
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Feel free to reach out if you need more specific information or further clarification.
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Weitz Morgan is a leading law firm in Texas in providing comprehensive advice and guidance to med spas. With a deep understanding of the unique challenges and complexities faced by this rapidly growing industry, our team of experienced attorneys is dedicated to helping med spas navigate the legal landscape successfully.
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We recognize that med spas operate at the intersection of healthcare and beauty, which necessitates a multifaceted approach to representation. Our firm offers a range of services, including a flat-fee med spa formation package and an outside general counsel subscription, tailored to meet the specific needs of med spas, ensuring compliance, mitigating risks, protecting licenses, and fostering a legally sound business environment.
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