The Virginia Board of Dentistry adopted final regulations requiring training for dentists who administer cosmetic botulinum toxin, limiting certified oral surgeons to head and neck procedures, and clarifying provider scope for certain Med Spa aesthetic services.
Virginia Board of Dentistry Finalizes Cosmetic Procedure Training and Scope Requirements
On March 31, 2026, the Virginia Board of Dentistry filed final regulations establishing training requirements for dentists administering cosmetic botulinum toxin and certification-based scope limits for oral and maxillofacial surgeons.
The rule is scheduled in the April 20, 2026, Virginia Register and is planned to take effect on May 20, 2026. It defines when cosmetic injectables may be performed within dental practice and sets certification and anatomical limitations for specific procedures, including those offered in Med Spa settings.
Training Standards and Certification Requirements Established Under Final Rule
The Virginia Board of Dentistry’s final regulation (VA.R. Doc. No. R24-7739) permits dentists to administer botulinum toxin for cosmetic purposes, provided they complete specified training requirements.
The rule requires at least 12 hours of training, including four hours of in-person clinical instruction on live patients with post-procedure follow-up, with the remaining hours completed through didactic coursework from CODA-accredited dental programs, the American Dental Association, or its constituent or branch associations, or the Academy of General Dentistry.
Required training topics include patient assessment, informed consent (including off-label use), head and neck anatomy, pharmacology of botulinum toxins, recognition and management of complications and adverse reactions, treatment planning, patient expectations, and evaluation of outcomes.
These requirements reflect authority established under Chapter 413 of the 2023 Acts of Assembly (§ 54.1-2711.2), which permits dentists to administer cosmetic botulinum toxin, subject to Board-defined standards. An emergency regulation, effective May 6, 2024, previously allowed these services under temporary requirements prior to final rulemaking.
Separate provisions under 18VAC60-21-350 require Board certification for oral and maxillofacial surgeons performing aesthetic or cosmetic procedures and limit those procedures to areas above the clavicle, including the head and neck.
Eligible procedures include facial cosmetic treatments such as dermal filler administration and other procedures identified in 18VAC60-21-350, including rhinoplasty, blepharoplasty, rhytidectomy, submental liposuction, laser resurfacing, browlift techniques, otoplasty, and platysmal procedures.
Source Attribution
According to the Virginia Register of Regulations, the final rule (VA.R. Doc. No. R24-7739) is scheduled for publication in the April 20, 2026, Virginia Register (Vol. 42, Iss. 18), and amends 18VAC60-21 to establish training requirements for cosmetic botulinum toxin use and certification standards for oral and maxillofacial surgeons.
The full text of the regulation is available through the Virginia Regulatory Town Hall and Register system.
Compliance Context for Med Spa Operators
State regulators have increasingly focused on defining cosmetic procedure authority based on provider training, certification, and licensure. In Virginia, authority for cosmetic botulinum toxin use is established under § 54.1-2711.2, with training requirements defined in 18VAC60-21-55, while certification provisions for oral and maxillofacial surgeons under § 54.1-2709.1 and 18VAC60-21-350 limit procedures to the head and neck based on demonstrated competency.
For Med Spa operators, this type of framework is most relevant in models where injectable services are performed by dental providers or other non-physician licensees. Compliance exposure may arise where training documentation is incomplete, certification requirements are not verified, or procedures extend beyond the defined anatomical scope.
This approach is consistent with how state regulators apply existing scope-of-practice and supervision standards to medical aesthetic services. For example, Maine’s proposed rule applies existing scope-of-practice and supervision requirements to IV therapy and Med Spa businesses, reflecting how oversight is evaluated based on provider qualifications rather than business setting.
Additionally, clinic-based wellness models that incorporate provider-led intake, evaluation, and treatment workflows for services such as hormone therapy and injectables demonstrate how oversight requirements are implemented in practice.
These provisions define provider eligibility and procedural boundaries for injectable and facial aesthetic services within dental practice, including those performed in Med Spa settings. Together, they reinforce that compliance is evaluated based on provider training, certification, and scope of practice in Med Spa settings.
Practical Implications for Med Spa Operators
Based on the final regulation’s training and certification requirements, key compliance considerations include:
- Confirm that providers performing cosmetic injectables meet required training and credentialing standards under Virginia regulations
- Ensure injectable services are performed within approved anatomical areas, including procedures limited to the head and neck
- Establish clinical oversight structures that support compliant delivery of injectable services in accordance with Virginia regulations
- Maintain documentation of training, certification, and clinical oversight for all cosmetic procedures
- Verify treatment offerings to ensure injectable and aesthetic services comply with Virginia’s scope-of-practice requirements
What to Watch
The final regulation is scheduled to take effect on May 20, 2026, when training and certification requirements will apply to providers performing cosmetic procedures under dental licensure in Virginia.
Board communications and regulatory updates may further define how training documentation, certification review, and oversight expectations are evaluated in practice.
About Spakinect
Spakinect provides compliance infrastructure and telehealth-supported supervision solutions for medical aesthetic practices. For additional information, see our website.
Image Attribution: “State Capitol of the Commonwealth of Virginia, Richmond” by Ron Cogswell, via Wikimedia Commons, licensed under CC BY 2.0.
