AZ MedSPa compliance FAQs

  • To become a nurse injector in Arizona, you need the following:

    1. Nursing License

    • Be a Registered Nurse (RN) or Nurse Practitioner (NP) with an active Arizona license in good standing.

    2. Medical Director

    • You must work under the supervision of a licensed provider (MD, DO, or NP) who issues treatment orders for Level II/III procedures.

    3. Aesthetic Injector Training

    • Complete hands-on training from a reputable aesthetic education provider in:

      • Neuromodulators (e.g., Botox, Dysport)

      • Dermal fillers

      • Anatomy, safety, and complication management

    4. Proof of Competency

    • Maintain documentation of training and demonstrated competency for each treatment you perform.

    5. Compliance Knowledge

    • Understand Arizona Board of Nursing guidelines, including scope of practice, supervision, and documentation requirements.

    6. Good Faith Exam for each patient.

    Carry malpractice insurance with aesthetic coverage.

  • In Arizona, a medspa can be owned by anyone, including non-medical professionals. However, all medical services must be provided by or under the supervision of licensed professionals (e.g., nurse practitioners, physicians). This can be an offsite medical director. The medical director is responsible for overseeing clinical service protocols and ensuring compliance with Arizona law.

  • According to the Arizona State Board of Nursing Advisory Opinion on Medical Aesthetic Procedures, a medical director must be a licensed physician (MD or DO) or a nurse practitioner (NP) acting within their scope of practice. They are responsible for:

    • Overseeing medical procedures

    • Ensuring proper training and competency of staff

    • Providing orders for medical aesthetic services

    • Ensuring patient safety and legal compliance

    They must also be available for consultation and intervention if needed.

  • According to the Arizona Board of Nursing Advisory Opinion, any medical aesthetic procedure classified as a Level II or Level III service requires a provider order.

    A licensed provider (NP, MD, or DO) must issue the order, and the service must be within the provider’s scope of practice.

  • Yes. In Arizona, a Good Faith Exam (GFE)—also called a medical evaluation—is required before performing any medical aesthetic treatment (Level II or III procedures).

    The exam must be conducted by a licensed provider (MD, DO, or NP) and includes:

    • Reviewing the patient’s medical history

    • Assessing for contraindications

    • Determining if the patient is an appropriate candidate for treatment

    This evaluation must be documented and performed prior to the first treatment and repeated annually or upon change in health history.

    Schedule a Demo with GFE Telehealth provider Docovia Here:

    Schedule a Meeting

  • Yes. Even if your medical director is an MD or DO, a Good Faith Exam (GFE) is still required before any Level II or III treatment.

    The law applies to all medical aesthetic procedures—not just who owns or directs the practice. The GFE ensures:

    • The patient is medically appropriate for the treatment

    • Contraindications and risks are evaluated

    • A treatment plan is established

    The GFE must be performed by a licensed provider (MD, DO, or NP) before the first treatment and updated as needed. It is a legal and medical requirement separate from the role of the medical director.

  • According to the Arizona State Board of Nursing Advisory Opinion, Level II and III treatments are medical procedures that require a provider order and supervision. These include:

    Level II Treatments:

    • Botulinum toxins (e.g., Botox, Dysport, Xeomin)

    • Dermal fillers

    • Kybella

    • Sclerotherapy

    • Microneedling with substances (e.g., PRP, exosomes, serums)

    • Laser and light devices (e.g., IPL, hair removal, resurfacing)

    • Medium-depth chemical peels (e.g., TCA, VI Peel)

    • PDO threads

    • Plasma/fibroblast treatments

    Level III Treatments:

    • Microneedling with radiofrequency

    • Ablative laser resurfacing

    • Any treatment that penetrates into the dermis or deeper tissues

    These treatments must be performed by or under the supervision of a qualified provider, following a good faith exam and a documented provider order.

  • You can find the Arizona Board of Nursing (AZBN) Advisory Opinion on medical aesthetic procedures directly on their official website:

    👉 Link: AZBN Advisory Opinion: Medical Aesthetic Procedures

    This document outlines the scope of practice, levels of treatment, supervision requirements, provider orders, and who may perform aesthetic procedures in Arizona. It’s the most reliable and current guidance for medspa compliance in the state.

  • Yes. Patient consent is legally required before performing any medical aesthetic treatment in Arizona—especially for Level II and III procedures.

    A valid consent form must:

    • Explain the treatment purpose, risks, benefits, and alternatives

    • Include acknowledgment of off-label use if applicable

    • Be signed and dated by the patient before the procedure

    • Be specific to each treatment (e.g., separate consents for Botox, filler, laser)

    Electronic signatures are acceptable if they meet HIPAA and state requirements. Keeping signed consents on file is essential for legal protection and patient safety.

  • For medical aesthetic treatments in Arizona, the Good Faith Exam (GFE) must be performed by a licensed medical provider who is legally allowed to diagnose and create a treatment plan. This includes:

    • Nurse Practitioners (NPs)

    • Physicians (MD or DO)

    • Physician Assistants (PAs)

    Estheticians and RNs cannot perform GFEs, even if they are experienced in aesthetics.

    If you do not have a qualified provider on-site, you can use a telehealth service like Docovia, which connects your clients with licensed NPs who can perform GFEs virtually—compliantly and efficiently.

    We have a group for this service and you must be listed under our parent account. You can schedule a demo with Docovia here:

    Schedule a Meeting

  • These items will be available on your portal for your medical director services. You will have access to all documents upon completion of payment.

  • In Arizona, toxins and dermal fillers must be purchased directly from FDA-approved manufacturers or their authorized distributors. This ensures safety, authenticity, and compliance with state and federal regulations.

    Purchase Sources:

    Toxins:

    Dermal Fillers:

    • Juvederm® line – Allergan/AbbVie

    • Restylane® line – Galderma

    • Revanesse® – Prollenium

    • Radiesse® & Belotero® – Merz Aesthetics

    • Evolysse® - Evolus

    ⚠️ Never purchase from third-party resellers, online marketplaces, or international websites—these sources may offer counterfeit or unsafe products and put your license at risk.

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.