Idaho Medical Spa State Regulations: Scope and Supervision

Last reviewed November 4, 2026. We checked each legal point below against Idaho administrative rules and state board publications, and removed points we could not confirm. Rules change often, so confirm with your state licensing board or a healthcare attorney before you rely on them.

Who can perform botulinum toxin injections and soft tissue fillers?

Idaho Board of Medicine rules treat cosmetic treatments that use prescriptive products, such as fillers and muscle immobilizers, as the practice of medicine. Only a physician, or medical personnel under the supervision of a physician, may perform them. Physicians who supervise cosmetic treatments must be trained in the safety and use of these devices and products (IDAPA 24.33.01.002 and 24.33.01.200.04). A PA can perform injections within the scope set out in their collaborative practice agreement (IDAPA 24.33.02.200.01). An NP (advanced practice registered nurse) is a licensed independent practitioner and may provide the services they are educationally prepared and competent for (IDAPA 24.34.01.200.04).

Medical personnel providing cosmetic treatments are limited to devices and products that are exclusively non-incisive and non-ablative.

Who can perform lasers treatments?

Lasers and intense pulsed light devices count as prescriptive medical/cosmetic devices. A physician can perform these treatments, or medical personnel can perform them under a supervising physician, using only non-incisive, non-ablative devices. The supervising physician must be on-site or immediately available and may not supervise more than three medical personnel providing cosmetic treatments at the same time, or six with prior Board approval (IDAPA 24.33.01.200.04).

Who can perform Laser Hair Removal?

Laser hair removal uses a prescriptive device, so the same rule applies: a physician, or medical personnel under a supervising physician (IDAPA 24.33.01.200.04).

Is a good faith examination needed?

Before medical personnel give the first treatment, the supervising physician must document a legible patient record of the physician's evaluation, assessment and plan for the patient (IDAPA 24.33.01.200.04.b.i).

Can a physician assistant practice independently?

No. A PA practices through a collaborative practice agreement or through the bylaws or procedures of a facility with credentialing and privileging systems (IDAPA 24.33.01.200.01).

Collaborative Practice Agreement

The collaborative practice agreement must comply with Idaho Code §54-1807A(2) and name the parties, the authorized scope of practice for each PA, and any monitoring parameters if necessary (IDAPA 24.33.02.200.01).

What kind of physician supervision is needed for a registered nurse (RN) in a medical spa?

When an RN provides cosmetic treatments as medical personnel, such as laser hair removal, the supervising physician accepts full responsibility for the treatments and must verify the RN's training on the Board's Medical Personnel Supervising Physician Registration form (IDAPA 24.33.01.200.04).

What is a medical assistant? What role do they play in a medical spa?

Medical assistants are professional multi-skilled persons dedicated to assisting in all aspects of medical practice under the direct supervision and responsibility of a physician. This practitioner assists with patient care management, executes administrative and clinical procedures, and often performs managerial and supervisory functions.

a) What is the legal scope of medical assistants in Idaho?

Idaho Board of Medicine rules do not single out medical assistants. They cover "medical personnel," meaning any individual who provides treatments under the direction and supervision of a supervising physician. That physician accepts full responsibility for the treatments and must make sure the person has the proper training (IDAPA 24.33.01.002.08 and 24.33.01.200.04).

b) Should a medical assistant disclose, while working, his or her name and the practitioner’s license status on a nametag?

The rules do not mention nametags. The supervising physician must make sure every patient is told the education and training of the medical personnel treating them and that they are not licensed physicians (IDAPA 24.33.01.200.04.b.v).

c) May medical assistants perform any procedure in a medical spa so long as they are properly supervised?

No. Treatments by medical personnel must stay within the scope of practice of the supervising physician, and cosmetic treatments are limited to non-incisive, non-ablative devices and products (IDAPA 24.33.01.200.04.b.iv).

d) Are medical assistants allowed to pierce the skin or inject Botox and fillers?

The rules list fillers such as collagen and fat, and muscle immobilizers, as prescriptive medical/cosmetic products. Medical personnel may use them only under a supervising physician and only if the product is exclusively non-incisive and non-ablative. Non-incisive means it does not cut human tissue, and non-ablative means it does not remove or destroy it (IDAPA 24.33.01.002 and 24.33.01.200.04.b.iv).

e) Are medical assistants allowed to use lasers or intense light devices to remove hair, scars, moles or other blemishes?

Only under a supervising physician, and only with lasers or intense pulsed light devices that are non-incisive and non-ablative (IDAPA 24.33.01.200.04.b.iv).

Questions this guide does not answer

If I’m not a doctor, can I share in the profits of a medical spa?
Can a nurse, physician assistant or nurse practitioner take a commission for administering laser treatments or injectables like Botox?
What are the penalties for improperly owning a medical spa by violating the Corporate Practice of Medicine Doctrine?
Do I have to be a doctor to own medical spa equipment, like lasers, or real estate?
Do I need to charge sales tax on procedures like Botox?
What type of insurance does a medical spa need?
Can a medical spa pay a person or entity to market the practice’s services?
Can a medical spa offer discounts through Groupon or other similar social networking websites?
What type of information must a medical spa post?
Which procedures at medical spas constitute medical treatment?
How many physician assistants can a physician supervise?
Can an advanced practice registered nurse practice independently?
Can a dentist inject Botox?
Is Informed Consent required?
Can a med spa hire an aesthetician to perform nonmedical dermabrasion, cosmetic facial and skin treatments?
What about nurse practitioners and physician assistants? Can they see new patients or must a physician do it?
Does a medical spa need to obtain a license to operate?
Must I follow OSHA regulations?
What type of records are medical spas required to keep of their patients?
How long do I have to keep the patient’s records?
Can a med spa text or email patients to convey confidential medical information?
Are Botox parties legal?
Does Idaho have its own version of HIPAA? How does it differ?
What is a DEA Registration Number?
What is the FDA and what do they do?
Can a chiropractor or dentist serve as a medical director?

For these, check with your state licensing board or a healthcare attorney.

See also: business courses for med spa owners. Disclaimer: The information and answers contained in these frequently asked questions provide a general guide to certain laws that apply to "medical spas" and cosmetic medical treatment in this particular state. The information on this site is for general reference only and accuracy cannot be guaranteed, as medical spa legalities and regulations change very frequently. This information is not intended to provide legal advice, and it should not be relied upon as legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Readers: You should not act upon this information without seeking knowledgeable legal counsel that takes the laws of your jurisdiction into account. All uses of the content of this site, other than personal uses, are prohibited.

Idaho Medical Spa State Regulations