If you’re a registered nurse (RN) or a nurse practitioner (NP) interested in aesthetics, you’ve probably asked yourself:
“Can I order Botox and dermal fillers myself?”
The short answer: No, not directly.
The longer answer: Yes, but only if you have a medical director’s oversight and an NPI (National Provider Identifier) number tied to your practice.
This is one of the most common gray areas in the medspa world. Many nurses think they can just call Allergan or Galderma and open an account. In reality:
- Distributors and manufacturers will not release Botox®, Juvederm®, Dysport®, Restylane®, or similar products without a physician of record.
- You need a medical director’s NPI number and standing orders to legally buy and administer these products.
Once you have this structure in place, you can open accounts with major distributors like DeWitt Pharma, who often provide better pricing than manufacturers thanks to bulk purchasing power.
At Medical Director Co., we make this process seamless. We place a licensed physician as your medical director, prepare your standing orders, and help you get your NPI linked so you can order injectables legally—all starting at $799/month, no placement fees.
Why Nurses Cannot Order Botox Alone
FDA and DEA Classification
Botox and fillers are classified as prescription medical products. Only licensed prescribers can order them.
Distributors Require Physician Credentials
Allergan (Botox®, Juvederm®), Galderma (Dysport®, Restylane®), Revance (RHA® Collection), and Evolus (Jeuveau®) all require an NPI and medical director on file.
State Medical Board Oversight
In most states, RNs can inject under delegation but cannot independently prescribe or order. That prescribing pathway must come from a physician.
Without a medical director, trying to order Botox could trigger a compliance violation or even a board investigation.
The Role of the NPI Number
The NPI is a unique number used for prescribing and ordering medical products.
- Physicians automatically have NPIs.
- NPs may have NPIs, but their authority to use them depends on state law and collaboration agreements.
- RNs typically cannot use NPIs for ordering; they must rely on a supervising physician.
Bottom line: You need your medical director’s NPI tied to your account to legally order Botox and fillers.
How to Order Botox Once You’re Set Up
Here’s the step-by-step process once you have a medical director and NPI in place.
- Choose your supplier. While manufacturers sell directly at higher prices, distributors like DeWitt Pharma secure better rates through volume purchasing.
- Submit your account paperwork. This includes a medical license, NPI, and DEA if applicable.
- Begin ordering Botox and fillers. Do this under standing orders signed by your medical director.
Many medspa owners find distributors cheaper and more supportive than going straight to Allergan or Galderma, especially if they’re smaller clinics that don’t meet manufacturer volume discounts.
State-by-State Realities
Florida
- Only plastic surgeons or dermatologists can serve as medical directors for medspas.
- Nurses cannot order Botox or fillers independently.
- All accounts must run through a physician’s NPI.
We place Florida physicians within 24 hours, enabling distributor accounts legally.
Texas
- RNs and NPs cannot order Botox independently.
- Delegation agreements are required for prescribing and ordering.
- MSO structures are often needed for business ownership.
We provide Texas MDs + free MSO agreements.
California
- Strict Corporate Practice of Medicine laws prohibit nurses from owning or ordering injectables directly.
- All Botox orders must run through a physician’s NPI.
- An MSO structure is required for RN or NP-owned businesses.
We provide California physicians + free MSO setup.
Other Strict States to Note
- Ohio: NPs must file Standard Care Arrangements; RNs cannot order injectables.
- Indiana: Collaboration agreements are required for controlled prescribing and injectables.
- Washington: Full practice for NPs, but distributors still require MD accounts for Botox.
- Alabama: Very strict; every NP must have MD collaboration; RNs cannot order.
Clinical Example: How This Plays Out
An RN in Miami wanted to order Botox directly from Allergan. She was denied because she didn’t have an NPI tied to a physician of record.
She partnered with Medical Director Co., which:
- Placed her with a board-certified plastic surgeon within 24 hours.
- Prepared her standing orders.
- Helped her open an account with DeWitt Pharma, where she received lower pricing than Allergan offered because of distributor bulk discounts.
Within a week, she was legally ordering Botox at a better rate—and her business was open.
Why Distributors Like DeWitt Pharma Can Be Better
- Pricing: Distributors aggregate orders across thousands of clinics, securing volume discounts that manufacturers don’t extend to smaller buyers.
- Service: Distributors provide faster customer service and tailored support, especially for new medspas.
- Access: They carry multiple brands (Botox, Dysport, Jeuveau, Xeomin), plus fillers and ancillary products so that you can consolidate purchasing.
This makes distributors the go-to option once you’re set up with a medical director.
Why Medical Director Co. Is Different
Most companies charge thousands for:
- Placement fees ($3,000–$7,000)
- Agreement drafting ($2,500–$5,000)
- MSO setup fees ($2,000+)
We’ve eliminated those barriers.
✅ Starts at $799/month
✅ No placement or matching fees
✅ Complimentary MSO and collaborative agreements
✅ No switching fees
✅ Distributor account support included
✅ Nationwide placement within 24 hours
FAQs
Can an RN or NP open an Allergan account directly?
No, manufacturers require a physician of record and an NPI.
Can distributors like DeWitt Pharma sell to nurses?
Yes, but only under a physician’s NPI.
Is Botox cheaper from distributors?
Often, yes. Distributors negotiate high-volume discounts.
Do I need a DEA license to order Botox?
Not typically, since Botox is not a controlled substance. But your medical director must provide prescriptive authority.
Can I inject under standing orders?
Yes. Once your Medical Director signs them, you can legally inject patients.
Takeaway
So, can a nurse order Botox and fillers in 2025?
No, not independently. Nurses must work under a medical director’s authority.
You need an NPI number linked to your physician to open accounts with Allergan, Galderma, or distributors like DeWitt Pharma.
Once set up, you can order products legally, and often at better pricing from distributors than from manufacturers.
At Medical Director Co., we handle the entire process—physician placement, MSO or collaborative agreements, and account setup with distributors—starting at just $799/month, with no placement fees.
Ready to open your Botox account? Hire a medical director today and get set up in 24 hours.

Bolton M. Harris, J.D., is a seasoned attorney with a formidable background in criminal law and a focus on healthcare law and compliance. As the in-house legal counsel at Medical Director Co., Harris brings a unique blend of prosecutorial experience and regulatory expertise to support healthcare professionals across Texas. Her career spans roles as a prosecutor in multiple counties and now as a trusted advisor on the legal intricacies of medical practice operations.
Education & Early Career
Bolton Harris completed her undergraduate studies at Southern Methodist University (SMU) in 2013. During her time at SMU, she was not only a dedicated student but also a competitive athlete on the university’s women’s swimming team. She went on to earn her Juris Doctor from Texas A&M University School of Law in 2016 and became a member of the Texas Bar that same year. Armed with a strong academic foundation and discipline honed as a student-athlete, Harris embarked on a career in criminal law immediately after law school.
Prosecutorial Experience in Texas
Bolton Harris began her legal career in public service as a criminal prosecutor. She served as an Assistant District Attorney in multiple jurisdictions, where she quickly rose through the ranks and handled a broad spectrum of cases. Some highlights of her prosecutorial career include:
- Assistant District Attorney, Dallas County, Texas: Prosecuted a high volume of criminal cases in one of the state’s busiest DA offices, gaining extensive trial experience in both misdemeanor and felony courts.
- Assistant District Attorney, Ellis County, Texas: Continued to hone her courtroom advocacy skills, known for meticulous case preparation and a tenacious pursuit of justice on behalf of the community.
- Assistant District Attorney, Navarro County, Texas: Broadened her legal expertise by handling diverse criminal matters in a smaller county, working closely with law enforcement and community leaders to uphold the law.
Through these roles, Harris built a reputation for being a tough but fair advocate. She brought numerous cases to trial and developed an in-depth understanding of the criminal justice system. This distinguished prosecutorial background laid a strong foundation for the next phase of her career in the private sector.
Healthcare Law & Compliance at Medical Director Co.
After her tenure as a prosecutor, Harris shifted her focus to healthcare law, applying her legal acumen to the medical field. She recognized that the same attention to detail and tenacity that served her in criminal law could benefit healthcare providers navigating complex regulations. Embracing this new direction, Harris became well-versed in the intricate laws governing medical practices – from licensing requirements to patient safety and privacy standards – and is passionate about helping practitioners stay compliant.
In her current role as the in-house attorney for Medical Director Co., Bolton Harris oversees all legal and compliance matters for the organization and its clients. Medical Director Co. is a nurse-owned firm that connects nurse practitioners (NPs), physician assistants (PAs), and registered nurses with qualified medical directors and collaborating physicians, offering fast placements and comprehensive compliance support for healthcare practices. Harris ensures that each of these partnerships and clinical ventures adheres to all applicable state and federal laws. She is responsible for drafting and reviewing collaborative practice agreements, advising on regulatory requirements, and providing ongoing legal counsel as clients establish and grow their clinics. Drawing on her prosecutorial eye for risk management, Harris proactively identifies potential legal issues and addresses them before they escalate, giving healthcare professionals peace of mind.
Bolton M. Harris’s multifaceted expertise – spanning high-stakes courtroom litigation to detailed healthcare compliance – makes her a formidable legal ally. Whether advocating in front of a jury or guiding a medical practice through regulatory hurdles, she remains committed to the highest standards of the legal profession. Her blend of courtroom-tested skill and healthcare law knowledge ensures that clients of Medical Director Co. receive elite-level counsel and steadfast protection in an ever-evolving legal landscape.