The North Carolina Board of Nursing has released a comprehensive position statement outlining when and how registered nurses (RNs) and licensed practical nurses (LPNs) may legally perform cosmetic and aesthetic dermatological procedures. While the statement does not carry the force of law, it provides authoritative guidance for nurses seeking to remain within their legal and professional scope of practice.
According to the Board, it is within the scope of both RNs and LPNs to perform a range of cosmetic procedures—including Botox and dermal filler injections, chemical peels, laser hair removal, sclerotherapy, and micropigmentation—so long as the procedures are ordered or prescribed by a licensed healthcare provider with prescriptive authority. This may include a physician, nurse practitioner, physician assistant, or other authorized healthcare professional, all of whom must be acting within their own legal scope of practice.
The position statement makes an important distinction between the roles of RNs and LPNs. While RNs are not required to have the prescribing provider present on-site during the procedure, LPNs must have direct, on-site supervision from an RN, physician, nurse practitioner, or other qualifying provider. Regardless of licensure level, the nurse performing the procedure must have documented training, knowledge, and demonstrated competency in the specific technique being used. In addition, the healthcare setting must have written policies in place addressing both cosmetic procedures and emergency response protocols.
The Board also provides guidance for nurses working in non-traditional or independent settings. If a patient independently seeks treatment—without a prior assessment and order from a licensed healthcare provider—then the nurse must also hold licensure under the North Carolina Electrolysis Practice Act or Cosmetic Arts Act, depending on the nature of the service provided. Furthermore, any nurse engaging in services outside the traditional nursing context (e.g., massage or bodywork) must secure appropriate licensure before offering those services.
Registered nurses interested in launching independent practices that offer cosmetic dermatology services—such as a professional corporation (PC) or professional limited liability company (PLLC)—must comply with all elements of the Board’s position statement and may need to seek legal guidance. LPNs, however, are not permitted to own or co-own such professional nursing entities under North Carolina law.
Finally, nurses planning to perform laser-based procedures are specifically advised to consult the North Carolina Medical Board’s guidance on laser hair removal and tattoo removal before proceeding.
This position statement underscores the growing role of nurses in the aesthetic medicine industry while emphasizing the need for regulatory compliance, proper training, and clear professional boundaries. Healthcare attorneys and consultants advising nurse-led practices and med spas in North Carolina should review this guidance closely to ensure legal and professional alignment.
Revolution Law Group is located in Greensboro, NC, and serves individuals and small businesses throughout the Triad and surrounding areas. To contact us please visit Revolution.law or call 336-333-7907.
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