AZ MedSPa compliance FAQs

Board of nursing update:

The 2025 update to the Arizona Board of Nursing Advisory Opinion on Medical Aesthetic Procedures clarified several key points for those who are regulated by this board:

  1. Provider Orders Are Required
    All Level II and III procedures require a written provider order (from an MD, DO, or NP). Standing orders may be utilized as long as the patient has a Good Faith Exam (GFE) once per year or upon change in health history.

  2. Pre-Treatment Assessment Clarified (GFE)
    A licensed practitioner must perform a clinical assessment before treatment. This must be an NP, MD, or DO. This can be done via televisit. See FAQs below for options on this.

  3. Emphasis on Competency & Documentation
    Nurses must maintain proof of competency for all procedures they perform and must have an order for procedures according the to BON advisory opinion.

These updates reinforce the importance of direct provider involvement, proper documentation, and defined roles within the scope of practice for aesthetic nurses in Arizona. If you have any questions about this, please reach out to info@aestheticadvisoryboard.com. You may also find the official document from the Arizona Board of Nursing HERE.

Arizona Board of Cosmetology Policy Update – What Estheticians Need to Know (2024)

The Arizona State Board of Cosmetology released a new Substantive Policy Statement (2024.09) clarifying what licensed estheticians can and cannot do within a medspa setting. Here are the key takeaways:

Estheticians may NOT perform the following services:

  • Injections (Botox, filler, PRP, etc.)

  • Laser treatments (unless separately certified and compliant under radiation control laws)

  • Microneedling beyond 0.3mm depth

  • Medium-to-deep chemical peels

  • PDO threads or other medical-grade devices

  • IV therapy, plasma treatments, or any procedure that punctures the skin

This policy applies even if a medical director is present. Estheticians must work strictly within their license scope—no exceptions.

  • Currently the Arizona Board of Cosmetology does not require a Good Faith Exam for an esthetician providing the services within their scope. A medical director may be required for medical grade lines that are not prescription based.

For full medspa compliance guidance, visit:
Aesthetic Advisory Board – AZ Medspa Compliance

If you have any questions about this, please reach out to info@aestheticadvisoryboard.com.

Arizona Laser Technician Requirements – AZDHS Title 9 Compliance

If you’re offering laser treatments in Arizona, it’s critical to follow the regulations outlined in AZDHS Title 9, Chapter 7, Article 14. These laws apply to all cosmetic laser procedures, including hair reduction, tattoo removal, and skin resurfacing.

Here’s what medspas and laser technicians need to know:

All cosmetic laser procedures require a current Laser Technician certificate issued by the Arizona Department of Health Services (DHS).

Two levels of Supervision:

  • Laser Hair Reduction – Indirect Supervision: May perform procedures with a supervising health professional available remotely (e.g., by phone), but must meet additional training and experience requirements. A GFE is not required by the Bureau of Radiation Control for this.

  • Anything Besides Laser Hair Reduction– Direct Supervision: Can perform cosmetic laser procedures only when a licensed health professional is on-site.

Laser Safety Officer (LSO) is required on staff at any laser facility. The LSO is responsible for compliance, device logs, and safety protocols.

Documentation required:

  • Your laser binder should be completed and evaluated with your medical director every 6 months.

For more details on laser compliance, visit:
Laser Scope of Practice

Laser Forms

Laser Supervision Information

If you have any questions about this, please reach out to info@aestheticadvisoryboard.com.