An RN can inject Botox in a med spa only when a physician delegates that specific task in writing under a documented protocol. An NP can perform the same injection under her own license, without waiting for anyone’s sign-off, depending on her state’s practice authority tier. The gap between RN delegation and NP scope is exactly where staffing decisions go wrong, and it carries real licensing consequences, not just paperwork risk. RN authority runs on delegation from a physician, NP authority runs on the practitioner’s own license and state practice tier, and treating the two as interchangeable is the most common compliance mistake clinics make.

What an RN Can Do Under Delegation

An RN’s authority to perform medical aesthetic procedures comes from a physician who delegates a specific task in writing, under a documented protocol. Without that delegation on file, the RN cannot legally perform the procedure, no matter how many times she has done it before. Delegation covers implementation, not clinical judgment, so it only holds up when the physician’s protocol names the exact task being performed.

• Diagnosis and treatment plan: The physician diagnoses the patient and sets the treatment plan before delegating any task.
• Signed protocol: The physician signs a protocol that names the exact procedure the RN is authorized to perform.
• Active supervision: The physician stays available for supervision and chart review, as outlined in our standing orders vs. protocols guide.

That’s the boundary RN delegation rules draw in a med spa: a signed protocol authorizes the exact task it describes, not variations on it. If an RN adjusts a dosage, adds a different injectable, or treats a complaint the protocol doesn’t name, that action falls outside the delegation and outside her legal authority to perform it.

What an NP Can Do Under Their Own Scope of Practice

A nurse practitioner’s authority comes from her own license, graduate education, and national certification. Her state’s practice authority tier determines how much of that authority she can exercise without a collaborating physician. The American Association of Nurse Practitioners groups states into three categories: full practice, reduced practice, or restricted practice.

• Full practice: An NP in a full practice state holds independent practice authority to evaluate, diagnose, and manage treatment without a physician’s sign-off.
• Reduced practice: An NP in a reduced practice state keeps most clinical judgment but needs a collaborative agreement for specific elements, often prescribing.
• Restricted practice: An NP in a restricted practice state needs physician supervision or delegation for most of her clinical decisions.

An NP’s scope of practice exists whether or not a physician is present that day, because the authority sits with her license rather than with someone else’s delegation. That’s the detail most staffing mistakes miss when clinics assume RN and NP roles are interchangeable with enough supervision layered on.

Where Clinics Commonly Get This Wrong

Most staffing mistakes in med spas start with the same assumption: if an NP can perform a task, an RN can perform it too with a little more oversight. That assumption is the most common compliance gap reviewers flag during a staffing audit. RN and NP authority run on separate sources, not different points on one scale.

• Blanket delegation: Clinics treat RN delegation as a blanket allowance instead of a task-specific one.
• Overbroad standing orders: Clinics assume a standing order covers every injectable rather than only the ones it names.
• Unsupervised treatment: Clinics let an RN treat a patient without confirming a physician is actively supervising that day.

Each of these mistakes turns a routine treatment into an unlicensed act, and the liability doesn’t stop with the RN who performed it. A state board investigation typically also names the delegating physician and the clinic, since both signed off on a structure that didn’t match what actually happened at the chair.

How Delegation Authority Is Documented

Delegation has to be documented in writing, tied to a specific task, and signed by the physician granting it. A vague reference to “standing orders” is not enough on its own. A defensible delegation record names the exact procedure, states the required supervision level, and gets reviewed and re-signed on a set schedule, not once at hiring and never again. Clinics that keep it current pass an audit without a scramble; clinics that file it away and forget it get flagged.

How Medical Director Co. Helps Clinics Structure This Correctly

Medical Director Co. connects clinics with a collaborating physician or medical director who builds delegation protocols specific to the tasks each RN will actually perform. Every placement documents supervision level, chart review cadence, and scope by role, so the paperwork matches what happens on the floor. That structure is what a state board wants to see, and it protects both the clinic and the practitioner delivering care. Placements start in as little as 24 hours, 12 in Texas, starting around $799 a month with no long-term contract.