2025 Board of nursing update:
The 2025 update to the Arizona Board of Nursing Advisory Opinion on Medical Aesthetic Procedures clarified several key points:
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.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.Emphasis on Competency & Documentation
Nurses must maintain proof of competency for all procedures they perform.
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.
AZ MedSPa compliance FAQs
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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.
You can use a service such as Spakinect.com for this. We have a group purchase option for this.
Carry malpractice insurance with aesthetic coverage.
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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.
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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.
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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.
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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
Creating or approving a treatment plan
This evaluation must be documented and performed prior to the first treatment and periodically reassessed based on medical judgment.
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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.
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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.
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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.
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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.
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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 SpaKinect, which connects your clients with licensed NPs who can perform GFEs virtually—compliantly and efficiently.
We have a group discount for this service! Email us for that info:info@aestheticadvisoryboard.com
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These items will be available on your portal for your medical director services. You will have access to all documents upon completion of payment.
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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:
Botox® – Purchase from Allergan/AbbVie (www.allerganaccess.com)
Dysport® – Purchase from Ipsen (www.ipsenaesthetics.com)
Jeuveau® – Purchase from Evolus (www.evolus.com)
Xeomin® – Purchase from Merz Aesthetics (www.merzaesthetics.com)
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.