02/12/2026
I have had several people ask about Jaclyn doing botox. I was not sure of the rules. I thought it was not in her scope because I was a Registered Nurse for many years before getting my A-APRN, and I didn't think it was in my scope to do it, but I never claimed to know it all, so I checked with a couple of healthcare attorneys and the consensus was the same with all of them ...it is not in her scope of practice, a RN cannot do it unless a MD is there with her and we do not have an MD on site. I attached information for clarification. Sorry...maybe y'all can help me talk her into going back to get her NP!!
FLORIDA AESTHETIC PRACTICE REGULATIONS - Required Reading for All Florida PAs, NPs, and RNs
THE GOVERNING STATUTE
Florida Statute 458.348(3)(c) - This is what regulates PAs and NPs practicing aesthetic medicine without onsite physician supervision. Every word matters.
REQUIREMENTS FOR PHYSICIAN ASSISTANTS
If you’re a PA providing primarily dermatologic or aesthetic skin care services (other than plastic surgery) at a location where you do NOT have onsite physician supervision, your supervising physician must comply with ALL of the following requirements:
1. Board Notification
The physician must submit to the Florida Board of Medicine the addresses of all offices where they are supervising a PA that are not the physician’s primary practice location.
2. Board Certification Requirement
The supervising physician MUST be board certified or board eligible in dermatology or plastic surgery as recognized by the Board pursuant to F.S. 458.3312.
This is non-negotiable. Your supervising physician needs to be board certified or board eligible in one of these two specialties. If they’re not, you’re operating outside the law.
3. Distance Requirements
All offices that are not the physician’s primary place of practice must be:
• Within 25 miles of the physician’s primary practice location, OR
• In a county that is contiguous to the county of the physician’s primary practice location
Additionally, the distance between any of the offices may not exceed 75 miles.
4. Office Limitation
The physician may supervise only ONE office other than their primary place of practice.
Not two. Not three. One.
5. Posted Schedule
The physician must conspicuously post in each office a current schedule showing the regular hours when the physician is present in that office and the hours when the office is open while the physician is not present.
Important note: Under this statute, the physician is NOT required to review and cosign charts or medical records prepared by the PA (per F.S. 458.347(4)(e)6).
REQUIREMENTS FOR ADVANCED PRACTICE REGISTERED NURSES (APRNs/NPs)
The requirements are identical to those for PAs listed above. Every single one applies.
Additional requirement for APRNs:
You must practice within the framework of an established protocol with your supervising physician per Florida Statute 464.012. This protocol must be maintained on-site at the location where you practice.
Regarding Autonomous Practice:
I know some of you have autonomous APRN licenses. This does NOT apply to aesthetic medicine. Autonomous practice is limited to primary care settings. Dermatology and aesthetic medicine are specialty practices, and you cannot practice aesthetic medicine autonomously regardless of your autonomous license status. You still need a supervising physician who meets all the requirements above.
REGISTERED NURSES (RNs)
The general rule: RNs cannot inject Botox or dermal fillers. The Florida Board of Nursing has historically held that “aesthetic injections” are not within the scope of practice for registered nurses.
Recent developments:
Between 2023 and 2024, the Board of Nursing has issued several declaratory statements that allowed specific RNs to perform aesthetic injections under very particular circumstances. These RNs had:
• Extensive documented training (in some cases 300+ hours of observation and training)
• Specific CME courses in aesthetic medicine
• Direct physician supervision with written orders
• A physician who examined the patient before treatment
Critical point: These declaratory statements apply ONLY to the specific RN who requested them. They are not blanket permissions for all RNs.
If you’re an RN and want to perform aesthetic injections, you need to either:
1. Obtain your own declaratory statement from the Florida Board of Nursing specific to your situation and qualifications, OR
2. Get a written legal opinion from a healthcare attorney that your specific situation complies with Florida law
If you’re doing injections without one of these, you’re risking your license and potentially facing criminal charges for practicing outside your scope.
WHY THIS MATTERS
The consequences of violating these regulations are severe:
• Disciplinary action by the Board of Medicine or Board of Nursing
• License suspension or revocation
• Criminal charges for practicing outside your scope of practice
• Your supervising physician faces disciplinary action and potential loss of their license
• Practice closure
• Significant fines
• Liability exposure that could follow you for years
WHAT YOU NEED TO VERIFY RIGHT NOW
If you’re currently practicing aesthetic medicine in Florida, verify the following:
1. Is your supervising physician board certified or board eligible in dermatology or plastic surgery? If not, you need to stop practicing immediately and address this.
2. How many aesthetic offices (not including their primary practice location) is your supervising physician supervising? If it’s more than one, someone is operating illegally.
3. What is the distance between your practice location and your supervising physician’s primary practice location? If it’s more than 25 miles and not in a contiguous county, you have a problem.
4. If you’re an APRN, do you have an established protocol on-site? If not, get one immediately.
5. If you’re an RN, do you have a declaratory statement or legal opinion? If not, you need to understand you’re at significant risk.
LEGAL CITATIONS
• Florida Statute 458.348 - Formal supervisory relationships, standing orders, and established protocols; notice; standards
• Florida Statute 464.012 - Certification of advanced practice registered nurses
• Florida Statute 458.347 - Physician assistants
• Florida Statute 459.022 - Physician assistants (osteopathic)
You can read the full text of F.S. 458.348 at:
