On March 24, 2026, the Oklahoma Board of Nursing approved Policy/Guideline #P-25, requiring nurses performing cosmetic dermatologic procedures in Med Spas to follow individualized provider orders, complete patient evaluations, and meet defined competency and supervision standards.
Guidance Addresses Orders, Competency, and Oversight
The Oklahoma Board of Nursing has issued guidance governing how nurses perform cosmetic and aesthetic dermatologic procedures within their scope of practice. Approved March 24, 2026, Policy/Guideline #P-25 requires individualized provider orders and patient evaluations and states that standing orders are not an appropriate substitute. The guidance applies to settings including Med Spas and outlines requirements related to competency, supervision, and compliance with applicable state laws.
Clinical Requirements for Cosmetic Procedures
The Oklahoma Board of Nursing’s Policy/Guideline #P-25 states that cosmetic and aesthetic dermatologic procedures may be performed by registered nurses and licensed practical nurses only when supported by a patient-specific order or prescription issued by a licensed provider with prescriptive authority, following completion of a patient history and physical. It further specifies that standing orders do not satisfy this requirement and cannot replace an individualized order or prior evaluation.
Within this framework, the document distinguishes role-based responsibilities. Registered nurses (RNs) may carry out ordered procedures without the on-site presence of the prescribing provider when all criteria are met. Licensed practical nurses (LPNs) must perform these services under supervision by an RN, physician, or dentist. In both cases, the nurse is responsible for ensuring appropriate training, competency, and clinical judgment before performing procedures.
The guidance outlines clinical accountability expectations, requiring nurses to recognize adverse, toxic, allergic, and unexpected responses, assess when a patient’s condition contraindicates continuation of treatment, and take appropriate action when patient safety may be at risk.
For advanced practice registered nurses (APRNs), the Board specifies that care must align with the practitioner’s education, certification, and prescriptive authority. Documentation must support the clinical basis for treatment, including patient evaluation, diagnosis, treatment planning, informed consent, and follow-up care.
The policy further directs nurses performing laser-based procedures to review the Oklahoma Laser Hair Removal Act, which establishes requirements related to practitioner training, facility oversight, and clinical protocols. It also requires facilities offering these services to maintain written policies and procedures, including emergency response protocols. It confirms that all services must comply with applicable state and federal laws governing nursing and prescribing practice.
Source Attribution
According to Policy/Guideline #P-25 approved by the Oklahoma Board of Nursing on March 24, 2026, the guidance outlines the scope of practice, supervision, and documentation requirements for nurses performing cosmetic and aesthetic dermatologic procedures. The document also references applicable Oklahoma statutes, including the Oklahoma Laser Hair Removal Act, which establishes additional requirements for laser-based procedures.
Individualized Orders, Nursing Scope, and Supervision in Med Spa Compliance
The Oklahoma Board of Nursing’s policies outline how cosmetic and aesthetic dermatologic procedures are performed within the nursing scope, including the role of provider orders, patient evaluation, and documentation associated with treatment. The document defines how responsibilities are assigned across RNs, LPNs, and APRNs based on licensure and prescriptive authority, and references applicable state law for services such as laser-based procedures.
Recent regulatory efforts in other jurisdictions have addressed similar areas of clinical practice for Med Spa clinics. A disciplinary matter reviewed by Connecticut regulators in February 2025 cited deficiencies in provider assessment, infection control, and documentation related to cosmetic procedures. A separate case in Florida involving a vitamin injection business alleges that an individual misrepresented nursing credentials, and state health authorities issued a cease-and-desist order following the December 2025 complaint.
These provisions apply to Med Spa settings where cosmetic procedures are performed by nursing staff under provider orders, including clinics offering injectable treatments and device-based services. Published guidance outlines how clinical responsibilities are structured across license types and identifies patient evaluation and documentation as part of the clinical process associated with treatment delivery.
Practical Implications for Med Spa Operators
Based on requirements outlined in the Oklahoma Board of Nursing’s Policy/Guideline #P-25, key compliance considerations for Med Spa operators include:
- Confirm that cosmetic procedures performed by nursing staff are based on patient-specific provider orders following a completed evaluation.
- Distinguish role-based responsibilities between RNs, LPNs, and APRNs when structuring delegation and service delivery.
- Verify that required provider-patient relationships and initial evaluations are established before treatment.
- Maintain documentation supporting patient assessment, treatment planning, and informed consent for aesthetic procedures.
- Ensure clinical protocols address supervision, competency, and emergency response for cosmetic services.
- Audit standing-order protocols, which Policy/Guideline #P-25 states cannot substitute for individualized orders.
- Review laser procedure protocols to ensure alignment with the Oklahoma Laser Hair Removal Act referenced in the policy.
What to Watch
The Oklahoma Board of Nursing’s Policy/Guideline #P-25 is in effect as of March 24, 2026, and applies to clinical practices where cosmetic procedures are performed by nursing staff, including Med Spas. Additional Board guidance, clarifications, or disciplinary actions may further define how requirements related to provider orders, supervision, and documentation are applied in practice.
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Image Attribution: “Oklahoma State Capitol” by Serge Melki, via Wikimedia Commons, licensed under CC BY 2.0.
