Who can inject Botox in Texas?
In Texas, cosmetic Botox and filler injections are the practice of medicine. Physicians can inject, and a physician can delegate injections to a properly trained person, such as a physician assistant, nurse practitioner, registered nurse or licensed vocational nurse, under written orders. Before a delegated injection, a physician, PA or nurse practitioner must establish a relationship with the patient, and one of them must be onsite or immediately available during the procedure. Estheticians cannot inject under their license.
Who can inject in Texas: role by role
| Role | Botox (neurotoxins) | Dermal fillers | Conditions |
|---|---|---|---|
| Physician (MD/DO) | Yes | Yes | Must be trained in, or familiar with and able to perform, any procedure they delegate. The delegating physician stays responsible for the delegate's work. |
| Physician assistant | Yes, with conditions | Yes, with conditions | Works under physician delegation and supervision. A PA can establish the patient relationship and be the onsite or on-call provider for delegated injections. |
| Nurse practitioner (APRN) | Yes, with conditions | Yes, with conditions | Needs physician delegation; Texas APRNs do not have full practice authority. Cosmetic work must fit the NP's licensed role and population focus. An NP cannot pass physician-delegated acts on to RNs or LVNs. |
| Registered nurse | Yes, with conditions | Yes, with conditions | Only as a delegated medical act: a physician's written order, a prior patient relationship set up by a physician, PA or NP, documented training, and a physician, PA or NP onsite or immediately available. The RN cannot diagnose or choose the treatment. |
| LPN/LVN | Yes, with conditions | Yes, with conditions | Same delegation rules as an RN, and the LVN must always work under supervision (RN, APRN, PA or physician). The Board of Nursing tells LVNs to check whether a supervising RN and the ordering provider are onsite. |
| Medical assistant | Not addressed | Not addressed | No board statement found that names medical assistants. Texas has no medical assistant license. The Medical Board rule lets a physician delegate cosmetic injections to a trained "individual" and does not list license types, so the same order, exam and supervision rules would apply. Ask the delegating physician to confirm in writing before you inject. |
| Esthetician | No | No | The esthetician and cosmetology licenses do not allow needle injections of Botox, fillers or other substances. The licensing agency says these must be provided under a physician's order and delegation and refers delegation questions to the Medical Board, which has no statement on estheticians. |
Fillers follow the same rules as Botox. The Medical Board rule covers "the injection of medication or substances for cosmetic purposes," and the Board of Nursing names both Botox and Restylane as needing physician delegation.
The patient exam before treatment
Before anyone performs a delegated cosmetic injection, a physician, or a PA or nurse practitioner acting under physician delegation, must establish a practitioner-patient relationship with the patient and keep an adequate medical record (22 TAC §169.26(c)). The patient must also be told the name and title of the person who will inject.
An RN or LVN cannot do this step. Texas nurses who are not APRNs may not make a medical diagnosis or prescribe treatment, so the decision about what to inject has to come from a physician, PA or NP.
The rule does not say whether the relationship must be set up in person or can be set up by telehealth. No Medical Board statement on telehealth exams for cosmetic injections was found. A separate Texas statute on prescriptions accepts a live audio-video visit as a valid relationship when the standard of care is met, but it does not mention cosmetic delegation. Ask your delegating physician how your practice handles it.
Supervision and delegation
- Who delegates: a physician. Nurse practitioners and PAs work under physician delegation themselves. The Board of Nursing says what a physician delegates to an APRN cannot be delegated by the APRN to others, and APRNs cannot write standing delegation orders for others.
- Who must be available: during the procedure, a physician, PA or NP must be onsite or immediately available for emergency consultation, and the physician must be able to see the patient for an emergency appointment if needed (§169.26(d)). Texas does not require a physician to be in the building for every injection.
- Written orders: the delegating physician must write or approve in writing an order that names the physician and sets patient screening criteria, the care to give, and steps for complications and emergencies (§169.27). The injector signs and dates the written protocol. Under the Board's general delegation rule, protocols are signed by the delegating physician, state the level of supervision and are reviewed each year (§169.2).
- Onsite safety: at least one person trained in basic life support must be present while the patient is onsite.
- Posting and badges: each public area and treatment room must show how to file a complaint with the Medical Board and the delegating physicians' names and Texas license numbers. Injectors wear a name tag showing their credentials (§169.28).
- Nursing rules on top: the Board of Nursing's Position Statement 15.11 lets an RN or LVN carry out a delegated medical act only with documented training and competence, written policies, an order from an appropriate practitioner, and medical and nursing backup.
Med spa ownership and the medical director
Texas restricts the corporate practice of medicine. The Medical Board can discipline a physician who helps an unlicensed person or company practice medicine (Tex. Occ. Code §164.052(a)(17)). Physicians may form a professional entity with PAs, but a physician must organize and control it and PAs may hold only a minority share (Tex. Bus. Orgs. Code §301.012). Nurse practitioners and RNs are not on that list of co-owners.
Industry sources describe non-physician owners using a management services company that runs the business side while a physician owns the medical practice. No Texas statute or board rule sets out this model, so have a Texas health care lawyer review the setup.
No Texas statute or Medical Board rule was found that requires a med spa "medical director." The rules require a named delegating physician who writes or approves the orders and whose name and license number are posted. A 2025 bill would have required a physician med spa director, but that part was removed before it passed.
Training and certification
Texas has no state injector certificate or required course for Botox or fillers. The delegating physician must make sure the injector is trained in technique, care before and after the procedure, infection control, contraindications and managing complications. The Board of Nursing expects your training and skills check to be documented in your personnel record, and says you will be expected to show evidence of your training and competence if you ever have to defend your practice. Continuing education builds skill within your license level but cannot move an RN or LVN to a higher level of practice.
Recent changes
- January 9, 2025: the Medical Board reorganized its rules. The old cosmetic delegation rule, §193.17, was repealed and replaced by 22 TAC §§169.25 to 169.28. Older guides that cite §193.17 are out of date.
- September 1, 2025: Jenifer's Law (HB 3749) took effect. As passed it covers only elective IV therapy, not Botox or fillers. A physician may delegate giving elective IV therapy to a PA, NP or RN under adequate physician supervision. The med spa and filler provisions in the bill's first draft did not become law.
- June 2025: the Governor vetoed SB 378, which would have barred barbers and cosmetologists from injecting through the skin unless otherwise licensed or authorized by law.
- 2025: SB 2696, which would have created a state cosmetic injector certificate, passed the Senate but did not pass the House. SB 1117, which would have let general dentists give cosmetic Botox after board-approved training, also did not pass.
FAQ
Can an RN inject Botox in Texas without a doctor onsite?
Yes, if a physician, PA or nurse practitioner is immediately available for emergency consultation and the physician can see the patient urgently if needed. A physician's written order and a prior patient relationship are still required.
Can a nurse practitioner supervise an RN injector in Texas?
An NP can be the onsite or on-call provider and can establish the patient relationship. The delegation itself must come from a physician, because Texas APRNs cannot pass physician-delegated medical acts on to RNs or LVNs.
Can an LVN do Botox in Texas?
The Board of Nursing treats Botox by an LVN as a delegated medical act, so it can be within scope with a physician's order, documented training and proper supervision. LVNs can never work independently.
Can a nurse practitioner own a med spa in Texas?
Not the medical practice itself. The Texas law on joint practices lets physicians and PAs co-own one, with a physician in control, and does not list NPs. Industry sources describe NPs owning a management company that serves a physician-owned practice, but have a Texas health care lawyer review that structure.
Does Jenifer's Law change who can inject Botox?
No. As passed, it covers elective IV therapy only. Botox and filler rules are still the Medical Board's delegation rules.
Sources
- Texas Medical Board, FAQ 312: license or training needed to offer Med Spa services such as Botox
- Texas Medical Board, 22 TAC §169.25, Other Delegation
- Texas Medical Board, 22 TAC §169.26, General Standards
- Texas Medical Board, 22 TAC §169.27, Physician Responsibilities Related to Written Order
- Texas Medical Board, 22 TAC §169.28, Notice and Identification Provisions
- Texas Medical Board, 22 TAC §169.2, General Responsibilities of Delegating Physician
- Texas Medical Board, 22 TAC §193.17 (repealed January 9, 2025)
- Texas Medical Board, Rule Changes Effective January 9, 2025
- Texas Medical Board, Jointly Owned Entities: Physician and Physician Assistant
- Texas Board of Nursing, Nursing Practice FAQ (Cosmetic Procedures for RNs and LVNs)
- Texas Board of Nursing, APRN Practice FAQ (Cosmetic Procedures for APRNs)
- Texas Board of Nursing, Position Statement 15.11, Delegated Medical Acts
- Texas Department of Licensing and Regulation, Medical Spas
- Texas Legislature, Occupations Code §157.001
- Texas Legislature, Occupations Code §164.052
- Texas Legislature, Occupations Code §111.005
- Texas Legislature, Business Organizations Code §301.012
- Texas Legislature, HB 3749 (Jenifer's Law), enrolled and introduced versions
- Texas Legislature, SB 378 bill history
- Texas Legislature, SB 2696 bill history and Senate Research Center bill analysis
- Texas Legislature, SB 1117 bill history
- American Med Spa Association, How the Texas Corporate Practice of Medicine Relates to Medical Spa Ownership (industry source)
Rules change and boards interpret them case by case. If your situation is unusual, ask the Texas board or a health care attorney.
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