Can RNs Perform Cosmetic Procedures?

Carolyn Buppert, MSN, JD


July 02, 2018

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A registered nurse (RN) asks, "Can I perform cosmetic procedures? I have a physician who will write standing orders."

Response from Carolyn Buppert, MSN, JD
Healthcare Attorney

The first thing to do, before performing any cosmetic procedure, is to check with your state's licensing agencies. Your state — the department of health, the esthetics or barbering board, the medical board, or the Board of Nursing — may have policies on this. Generally, an RN may perform a cosmetic procedure if a clinician who is authorized to diagnose and order medications and therapies has assessed the patient and written a patient-specific order. In this situation, a standing order alone won't give you the legal authority you would need.

For such procedures as a chemical peel or injection of a neuromodulator, a physician, nurse practitioner, or physician assistant will need to perform a face-to-face examination of the patient and determine that the patient is an appropriate candidate for the procedure. After that is done, as long as no state law or policy prohibits it, a properly trained RN could perform the procedure, with a patient-specific order.

Some dermatology experts would say an RN could administer a filler, but some dermatologic groups have held that only a nurse practitioner, physician, or physician assistant should perform that procedure. You will need to check with your state's Board of Nursing and Board of Medicine to see whether there is any statement about who can perform fillers. If you administer a filler and someone challenges your authority to do it, the Board of Nursing probably will engage a consultant expert. If the expert finds that professional groups have statements on who is authorized to perform any specific procedure, and RNs are not included in that authorization, then the expert may advise the Board of Nursing that fillers are outside of RN scope of practice. It is wise to find out what documents are readily available to experts, in support of or refuting your stand on any scope of practice question.

At least one nurse has been censured by a Board of Nursing for performing chemical peels, injecting a neuromodulator, and administering fillers with standing orders but without a face-to-face evaluation by a physician, nurse practitioner, or physician assistant. At least one nurse has been censured for injecting a non-US Food and Drug Administration (FDA)-approved mesotherapy supplement. The Board held that to inject a substance not approved by the FDA was a breach of the standard of care, was outside the RN's scope of practice, and was unprofessional conduct.

Boards of Nursing have the ultimate authority to make scope-of-practice decisions involving nurses. So, no matter what a business owner, administrator, or physician may tell you, it is wise to check with your state's Board before you perform a procedure that may be outside your scope of practice. It will be you, not the business owner, administrator, or physician, whose license will be in jeopardy, if you exceed your scope.


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