Alabama Med Spa Compliance Checklist (2026): Item by Item
An audit list for Alabama med spas, organized around the rules that make the state different: no RN Botox injectors, a physician in the building for CRNP and PA injections, and laser delegation under Chapter 540-X-11. Each item names its proof and its signer.
Quick Answer
Alabama has no med spa license, so this checklist is built around people and paperwork. Your physician takes responsibility for the cosmetic medical services. Every patient is evaluated before any drug is prescribed or given. Only a physician, or a CRNP or PA under a Board-approved protocol with a physician in the building, injects cosmetic Botox. RNs do not inject it. Laser delegation follows Chapter 540-X-11, and the physician's laser registration is renewed by January 31 each year.
Most state checklists start with whatever the state makes you file. Alabama gives you very little to file, which can lead an operator to assume there is little to do. That would be a mistake. The Board of Medical Examiners treats injectables, IV therapy, and lasers as the practice of medicine, and it has said in unusually specific terms who may perform each one and where the physician has to be while they do. The hard part of an Alabama audit is not a registration form. It is proving, for any given patient on any given day, that the right person did the work under the right arrangement.
This checklist breaks that proof into items. Each item states a requirement, names the document that shows you met it, and names the person whose signature gives that document weight. We take the legal requirements from our Alabama record in the regulations dataset, last reviewed July 21, 2026, and from our guide to who can inject Botox in Alabama. Where the record says nothing, we say that and label the item as good practice, so you can tell which items come from the Board and which are simply sound operations.
In short
An Alabama med spa passes an audit when it can show five things on paper. First, the physician exercises independent medical judgment, whoever owns the business. Second, the Board approved any CRNP or PA cosmetic protocol before the first injection. Third, a physician was physically on site for every CRNP or PA Botox session. Fourth, no RN, LPN, esthetician, medical assistant, or owner injected cosmetic Botox. Fifth, laser work was delegated under a written protocol by a physician whose registration is current. The penalty for unlicensed practice is a Class C felony.
Reading This Alabama Checklist
Each item has an ID, and you should not tick it until the proving document is in the binder. The IDs (E1, R2, S4, and so on) let you cite an item in a staff meeting, a corrective-action note, or an email to counsel without paraphrasing it. Every table uses the same four columns.
- ID: a section letter and a number. The letters are E for entity, R for Board filings, S for supervision, G for the exam, P for personnel scope, L for lasers, D for drugs and IV, C for consent and records, X for emergencies, A for advertising, and Q for Board inquiries.
- Requirement: what has to be true in the practice.
- Proof: the document that shows it was true on a specific date.
- Signs: the person whose signature makes the document credible. When the wrong person signs, the document does not prove the item.
Each section also opens with a record status line. "Record addresses this" means our Alabama record speaks to the topic and the unmarked items trace to it. "Record is silent" means our Alabama record has nothing on the topic, so every item in that section is marked (good practice). We do not fill those gaps with another state's rules.
Run the whole list before opening. Run it again whenever a physician, CRNP, or PA joins or leaves, when you add a service line, when the Board revises the cosmetic protocol, and every January before the laser registration deadline.
1. Entity and Ownership: The Employment Model and the PC Trap
Record status: Record addresses this
A non-physician may own an Alabama med spa, provided the business never controls how the physician practices medicine. Our record describes Alabama's approach as an "employment model." It comes from a joint declaratory ruling of the Medical Licensure Commission and the Board of Medical Examiners dated October 21 and 28, 1992, In re Brookwood Health Services, Inc., Ruling 2-1195, which the Commission reaffirmed in its Morpheus, Inc. ruling of November 6, 1995. Under that ruling, a business corporation that employs a licensed physician is not practicing medicine without a license, and is not splitting fees illegally, as long as the physician keeps independent and final authority over medical judgment and treatment.
That condition is the whole point of the model, and it is what the audit has to prove. A management agreement that lets an owner set injector staffing, choose products against the physician's view, or require a minimum number of treatments per patient undermines the very independence the ruling relies on.
When the professional corporation rules take over
The employment model covers an ordinary business corporation, LLC, or management company that employs a physician. If you choose to organize the operating entity as a medical professional corporation, the Alabama Professional Corporation Act applies. Stock may be issued or transferred only to "qualified persons," meaning individuals licensed to provide the professional service, or partnerships, PCs, or LLCs wholly owned by physicians or osteopaths (Ala. Code §§ 10A-4-3.01(a) and 10A-4-1.03(6)). The Board's own rule, Ala. Admin. Code r. 540-X-9-.01(2) and (7)(a), requires medical PCs to comply with that Act and imposes the physician or osteopath shareholder requirement on foreign medical PCs practicing in Alabama.
Decide on the structure before you form the entity, and write the reason down.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| E1 | The operating entity's form is chosen deliberately: a business entity employing a physician under the employment model, or a medical PC owned only by qualified persons | Formation documents plus a one-page structure memo stating which model applies and why | Owners; reviewed by Alabama healthcare counsel (good practice) |
| E2 | If the entity is a medical PC, every shareholder is a qualified person under §§ 10A-4-3.01(a) and 10A-4-1.03(6) | Stock ledger with each holder's license number and verification date | Corporate secretary; each physician shareholder |
| E3 | If the entity is a foreign medical PC practicing in Alabama, it meets the physician or osteopath shareholder requirement in r. 540-X-9-.01(7)(a) | Shareholder list with Alabama-relevant license verification | Corporate secretary |
| E4 | The physician's agreement reserves independent, final authority over medical judgment and treatment decisions | Physician employment or services agreement, with the clinical-independence clause flagged | Physician and an authorized officer of the business |
| E5 | No business policy sets clinical staffing, dosing, product choice, or treatment volume over the physician's objection (good practice) | Annual written attestation of clinical independence | Physician |
| E6 | Compensation terms are reviewed for fee-splitting risk against the conditions in the 1992 ruling (good practice) | Counsel's review note, dated | Alabama healthcare counsel |
2. Board Filings Before Opening Day
Record status: Record addresses this
Alabama has no med spa facility license or registration, but two Board filings can stop you from opening on schedule. Our record is clear on both.
The first is laser registration. A physician who uses lasers or other light-energy-based devices must register with the Board of Medical Examiners before using them, and must renew that registration every year by January 31 (Ala. Admin. Code r. 540-X-11-.13). The registration belongs to the physician, not to the building, so a change of physician means a new compliance question.
The second is protocol approval. A CRNP or PA may inject cosmetic botulinum toxin only under the Board's Cosmetic Botulinum Toxin Injection Protocol, which must be submitted to and approved by the Board of Medical Examiners before any injections begin. A CRNP's protocol also needs Board of Nursing approval. The version in our record was revised on September 18, 2025. Our who-can-inject guide notes that search results pointed to later-dated Board documents about the advanced practice provider protocol that we could not open, so get the current form from the Board before you file.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| R1 | A written determination that the practice needs no state med spa facility license, citing the absence of one in Alabama | Opening memo dated before the first patient | Responsible physician |
| R2 | Each physician who uses lasers or light-energy-based devices is registered with the Board of Medical Examiners before first use | Board registration confirmation per physician | Registering physician |
| R3 | Each laser registration is renewed by January 31 every year | Renewal confirmation, with a December reminder recorded in the compliance calendar | Registering physician |
| R4 | Each CRNP or PA cosmetic botulinum toxin protocol is approved by the Board of Medical Examiners before the first cosmetic injection | Board approval letter, with a date earlier than the first treatment in the injection log | Collaborating or supervising physician and the CRNP or PA |
| R5 | Each CRNP protocol is also approved by the Board of Nursing before the first cosmetic injection | Board of Nursing approval, filed with R4 | CRNP and collaborating physician |
| R6 | The protocol filed is the current Board version (good practice) | Download date and version date of the form used, noted on the filing copy | Practice manager |
3. Supervision and the Physician-on-Site Calendar
Record status: Record addresses this
For cosmetic Botox given by a CRNP or PA, the collaborating, supervising, or covering physician must be physically on site the whole time. This is the item that most often fails in practices run by operators from other states. Phone availability does not meet it, and neither does chart review the next morning. The physician has to be in the building.
Our record also confirms that Alabama has no statute creating a med spa "medical director." A responsible physician is still functionally required, because the cosmetic protocol needs a qualified collaborating or supervising physician and the laser rules need a delegating physician who keeps full professional and legal responsibility for the patient. If the practice offers both services, one physician can hold both roles, but the paperwork should show that they accepted each one.
Laser supervision runs on different terms
Under Chapter 540-X-11, "on-site supervision" means the physician is in the same building and immediately available. Level 2 laser delegates require it. Level 1 delegates may be supervised either on site or through "locally remote" supervision, with the physician close enough to respond to an emergency (r. 540-X-11-.02 and -.04). Because the Botox standard is stricter than the Level 1 laser standard, a day on which the physician is locally remote can still be a laser day for a Level 1 delegate, but it is not a Botox day for a CRNP or PA.
Build the calendar before the schedule
The simplest control is to treat the physician's presence as a resource in the booking system. A CRNP or PA Botox slot cannot be booked unless a qualified physician is marked present for that slot. When the physician leaves, the slot closes.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| S1 | A named physician accepts responsibility for the cosmetic medical services, including the protocol role and the laser delegating role where both apply | Signed role acceptance listing each service line | Physician |
| S2 | A collaborating, supervising, or covering physician is physically on site for every CRNP or PA cosmetic Botox session | Daily physician presence log, with times in and out, matched to the injection log | Physician on site that day |
| S3 | Covering physicians are qualified under the protocol and identified before they cover | Covering-physician roster with qualification notes | Collaborating or supervising physician |
| S4 | The booking system blocks CRNP or PA Botox slots when no qualified physician is marked present (good practice) | System configuration screenshot and a quarterly test record | Practice manager |
| S5 | Level 2 laser delegates work only when a physician is in the building and immediately available | Laser session log cross-referenced to the presence log | Delegating physician |
| S6 | Level 1 laser delegates have a documented on-site or locally remote arrangement, with the physician's emergency-response proximity defined | Written supervision plan per Level 1 delegate | Delegating physician and the delegate |
| S7 | The protocol's supervision and quality-assurance steps are carried out on the schedule the protocol sets | Completed QA records filed by month | Collaborating or supervising physician |
4. The Exam Before Any Drug
Record status: Record addresses this
Before any drug is prescribed or administered, a qualified provider must personally evaluate the patient, diagnose, and establish a physician-patient relationship. Our record names the qualified providers: a physician, or a PA, CRNP, or CNM working under a legal registration or collaboration agreement. Board rule Ala. Admin. Code r. 540-X-9-.11(1) requires the physician's examination of the patient before prescribing.
The evaluation has to be individual. A template with a pre-ticked box shows that a form was filled in, not that someone evaluated this patient. A defensible Alabama chart identifies who evaluated, what they assessed, the indication, and the treatment decision including product, dose, and sites.
Telemedicine: allowed for the exam, with limits
The Board's IV therapy declaratory ruling of July 21, 2022 says the evaluation and treatment "may occur in person or utilizing telemedicine" under Ala. Code § 34-24-703(b), and our record applies that to the general exam standard. A telemedicine evaluation does not change who may inject. It also does not remove the on-site physician requirement when a CRNP or PA gives cosmetic Botox. A remote exam followed by an RN injection is still an RN injection, and the Board has declined to authorize that.
Standing orders
The same IV ruling calls a model in which an RN alone assesses and treats walk-in patients under standing orders unlawful, and says it exposes the physician to liability for aiding and abetting unlicensed practice. If your current documents include a standing order that lets anyone other than a qualified provider decide on treatment, retire it before opening.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| G1 | Every new patient is personally evaluated by a physician, or by a PA, CRNP, or CNM under a registration or collaboration agreement, before any drug is prescribed or administered | Dated evaluation note in the chart, preceding the first treatment entry | The evaluating provider |
| G2 | The evaluation is individualized: history, contraindications, assessment, diagnosis or indication, and the treatment decision | Evaluation template with free-text fields completed | The evaluating provider |
| G3 | The evaluator's authority is on file: license, plus the collaboration or registration agreement for a CRNP, PA, or CNM | Credential file reference recorded in the chart or EHR user profile | Practice manager; agreement signed by the provider and the physician |
| G4 | Telemedicine evaluations are labeled as such and identify the evaluator | Encounter type field in the chart | The evaluating provider |
| G5 | No standing order lets an RN or other staff member assess and decide treatment | Retired standing orders, marked void and dated, plus the current order set | Responsible physician |
| G6 | Re-evaluation intervals for returning patients are defined (good practice; our record sets no interval) | Written re-evaluation policy | Responsible physician |
5. Who May Do What: The Alabama Staffing Matrix
Record status: Record addresses this
Alabama separates cosmetic Botox, lasers, and IV therapy into three regimes, and the same license can be a yes in one and a no in another. Your staffing matrix needs a separate column for each. The cosmetic Botox column must match our who can inject Botox in Alabama guide exactly, and it does.
| License | Cosmetic Botox | Non-ablative laser | IV therapy |
|---|---|---|---|
| Physician (MD or DO) | Yes, after the exam | Yes; ablative work is physician-only | Evaluates and prescribes |
| CRNP | Yes, under a protocol approved by both boards, with a physician on site | Level 1 delegate | Evaluates and prescribes under a collaboration agreement |
| PA | Yes, under a Board-approved protocol, with a physician on site | Level 1 delegate | Evaluates and prescribes under a registration agreement |
| RN | No | Level 1 delegate | Administers after a qualified provider's evaluation and prescription |
| LPN | No (treat as no) | Level 2 delegate | Record does not address |
| Esthetician / cosmetologist | No | Level 2 delegate | No |
| Medical assistant | No | Level 2 delegate | Record does not address |
| Laser technician | No | Level 2 delegate | Record does not address |
| Owner / unlicensed staff | No; unlicensed practice is a Class C felony | Not a listed delegate | No |
The RN column is not a typo
Our dataset records Alabama's cosmetic injector roles as physician, CRNP, and PA, and it flags the RN as excluded. The Board of Medical Examiners has declined to authorize delegation of cosmetic botulinum-toxin injections to registered nurses "or any other person," and it has warned that a conflicting Board of Nursing declaratory ruling may provide no legal protection. A physician in the room does not change that, because physician presence is a condition placed on CRNP and PA injections, not a source of authority for anyone else. The protocol does not allow further delegation, so a CRNP or PA cannot supervise RN injectors either.
This is the line most likely to be quietly "fixed" by a new hire, a consultant, or a corporate policy written for a multi-state group. Put it in writing, and get every clinical staff member to sign it.
LPNs, CNMs, and fillers
Our record has no LPN-specific statement on cosmetic neurotoxin. The Board's "any other person" language and the closed protocol mean the answer is still no. The CNM appears in our record only as a provider who may evaluate a patient and order IV therapy under a collaboration agreement. Our record does not show a CNM route to cosmetic Botox, so do not schedule a CNM as an injector without a written Board answer. Dermal fillers are not covered by a separate Board position in our record. Do not use a broader staffing model for filler than for Botox unless the Board has answered in writing.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| P1 | Only physicians, and CRNPs or PAs under an approved protocol, inject cosmetic botulinum toxin, including Dysport, Xeomin, Jeuveau, and Daxxify | Injection log listing injector name and license type for every treatment | Collaborating or supervising physician, monthly review |
| P2 | A written staffing policy states that RNs, LPNs, estheticians, cosmetologists, medical assistants, laser technicians, and non-clinical staff do not inject cosmetic botulinum toxin | Policy plus a signed acknowledgment from every staff member | Responsible physician; each staff member |
| P3 | No CRNP or PA supervises another person who injects cosmetic botulinum toxin | Organizational chart and the protocol on file | Collaborating or supervising physician |
| P4 | A CNM is not scheduled as a cosmetic injector without a written Board answer | Board correspondence, or a scheduling-system restriction | Practice manager |
| P5 | The filler staffing model is no broader than the Botox model unless the Board has answered in writing (good practice; our record has no filler-specific position) | Filler staffing policy and any Board correspondence | Responsible physician |
| P6 | Estheticians stay within non-invasive work on the stratum corneum that does not alter, cut, or damage living cells | Esthetician service menu, reviewed against the Board of Cosmetology scope | Responsible physician; esthetician |
| P7 | No esthetician performs microneedling outside the scope of a medical license issued by the Board of Medical Examiners | Service menu and appointment-type restrictions | Responsible physician |
| P8 | Every license is verified at the source before hire and at renewal (good practice) | Dated verification printouts in each personnel file | Practice manager |
| P9 | Out-of-state staff are briefed that Alabama scope applies to Alabama patients (good practice) | Signed orientation record | Staff member; practice manager |
The Operations & Compliance Kit includes the policy manual, medical director agreement, delegation and staffing policies, and audit templates. Adapt them to your Alabama physician, your CRNP or PA protocol, and your on-site calendar.
View Operations Kit — $1976. Lasers and Light-Based Devices Under Chapter 540-X-11
Record status: Record addresses this
Using a laser or light-energy-based device that affects living tissue is the practice of medicine in Alabama, and the Board has written a full delegation scheme for it. Ala. Admin. Code Chapter 540-X-11 is the most detailed part of our Alabama record, and it is the only service where the rules allow delegation to non-nurses.
Ablative procedures are reserved to physicians, as are endovascular laser ablation, laser-assisted liposuction, and laser-assisted surgery. A physician may delegate non-ablative treatments, such as IPL or BBL, laser hair removal, and photorejuvenation, under a written protocol and the required supervision. Delegates fall into two levels. Level 1 covers the PA, CRNP, and RN. Level 2 covers the LPN, medical assistant, aesthetician, cosmetologist, and laser technician. The delegating physician keeps full professional and legal responsibility for the patient.
Where audits find gaps
Three gaps come up most often. The first is a device whose settings can reach ablative parameters, used by a delegate for a treatment that becomes ablative. The second is a Level 2 delegate working while the physician is locally remote rather than in the building. The third is a registration that lapsed in January because nobody owned the renewal.
The training content and protocol contents Chapter 540-X-11 requires for each level are set out in the rule itself, and we do not reproduce them here. Read the current chapter and build your protocol from it.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| L1 | A device inventory classifies each device and each treatment as ablative or non-ablative | Device register with model, serial number, and treatment classification | Delegating physician |
| L2 | Ablative procedures, EVLA, laser-assisted liposuction, and laser-assisted surgery are performed only by physicians | Procedure log filtered by treatment type and operator | Delegating physician |
| L3 | Each delegated non-ablative treatment has a written protocol | Signed protocol per treatment type, dated | Delegating physician |
| L4 | Each delegate is assigned the correct level: Level 1 (PA, CRNP, RN) or Level 2 (LPN, medical assistant, aesthetician, cosmetologist, laser technician) | Delegate roster with license type and level | Delegating physician |
| L5 | Each delegate's training meets the Chapter 540-X-11 requirements for their level | Training certificates and competency sign-offs in the personnel file | Delegating physician; delegate |
| L6 | Supervision matches the level: on site for Level 2; on site or locally remote for Level 1 | Laser session log matched to the presence log (see S5 and S6) | Delegating physician |
| L7 | Physician laser registration is current (see R2 and R3) | Registration confirmation posted in the device binder | Registering physician |
| L8 | Device maintenance and safety checks follow the manufacturer's schedule (good practice) | Service records and pre-session safety checklist | Practice manager; operator |
7. IV Therapy, Drugs, and Storage
Record status: Record addresses IV therapy; silent on storage
An Alabama RN may hang the IV, but only after a qualified provider has evaluated the patient and written the prescription. The Board's IV therapy declaratory ruling of July 21, 2022 says that diagnosing a patient and recommending or prescribing IV therapy is the practice of medicine. Only a physician, or a PA, CRNP, or CNM under a registration or collaboration agreement, may evaluate, diagnose, and order it. An RN or another licensee acting within scope may then administer it.
The ruling also rejects the retail drip-bar model in which an RN alone assesses walk-in clients and treats them under standing orders. It calls that model unlawful and says the physician who allows it is liable for aiding and abetting the unlicensed practice of medicine, which is a disciplinary ground under Ala. Code § 34-24-360(13).
Storage and handling
Our Alabama record does not address drug storage, inventory, compounding, or sourcing for med spas. The storage items below are good practice, and they follow manufacturer labeling rather than any Alabama rule. If your practice handles controlled substances or compounded products, get advice that covers those specifically. Nothing in our Alabama record speaks to them, and we are not going to borrow rules from another state.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| D1 | Every IV treatment is ordered by a physician, or by a PA, CRNP, or CNM under an agreement, after an individualized evaluation (in person or by telemedicine) | Patient-specific IV order linked to the evaluation note | The ordering provider |
| D2 | The RN or other administering licensee administers only what the order specifies | Administration record matched to the order | Administering licensee |
| D3 | No IV menu is sold to walk-in clients for RN-only assessment and treatment | Intake workflow showing the evaluation step comes first | Responsible physician |
| D4 | Neurotoxin and other drugs are stored according to manufacturer labeling (good practice) | Temperature log for each storage unit | Clinical lead |
| D5 | Drug inventory is tracked by lot and expiry, with a recall procedure (good practice) | Inventory log; lot numbers recorded in each chart | Clinical lead |
| D6 | Expired or opened product is discarded according to labeling (good practice) | Waste log | Clinical lead; a witness |
| D7 | Drug sources are documented for every product (good practice) | Supplier invoices filed by product | Practice manager |
8. Consent and Patient Records
Record status: Record is silent
Our Alabama record contains no med-spa-specific consent rule or record-retention period, so every item in this section is good practice. We are not stating a retention period for Alabama, because we have not verified one. Get that number from Alabama counsel and write it into your policy.
Consent records are still essential in Alabama, because they are often where an auditor first sees who did what. A consent form signed before a CRNP's Botox treatment, which names the CRNP and the date, is evidence for items P1 and S2 as well as for consent. Design your forms to capture the treating provider's name and license type, and you get that cross-check without extra work.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| C1 | Procedure-specific written consent is signed before each new treatment type (good practice) | Signed consent in the chart, dated before the first treatment | Patient; treating provider |
| C2 | The consent names the treating provider and their license type (good practice) | Consent template with a provider field | Treating provider |
| C3 | Photographs are taken only with a separate written authorization (good practice) | Photo authorization form | Patient |
| C4 | The chart records who evaluated, who ordered, who treated, and, for CRNP or PA Botox, which physician was on site | Chart template fields completed | Treating provider |
| C5 | A record-retention period is set on Alabama counsel's advice (good practice; our record sets no period) | Records policy with the period and its source | Responsible physician; counsel |
| C6 | Patient records are kept under HIPAA-compliant access controls (good practice) | EHR access audit, run quarterly | Practice manager |
9. Emergency Preparedness
Record status: Record is silent
Our Alabama record does not address emergency equipment, drugs, or drills for med spas, so this section is good practice throughout. Alabama's supervision rules do help here. When a CRNP or PA is injecting Botox, a physician is in the building by rule, so your emergency plan can name the on-site physician as the first responder for those sessions. On Level 1 laser days with locally remote supervision, it cannot, and the plan has to say who acts first.
For the national framework behind these items, including anaphylaxis and vascular-occlusion response, see our med spa emergency protocol checklist.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| X1 | Written emergency protocols for each procedure with adverse-event risk (good practice) | Signed protocol set, posted in each treatment room | Responsible physician |
| X2 | The plan names the first responder for each supervision arrangement: on-site physician, locally remote physician, or none present (good practice) | Emergency roles page in the protocol set | Responsible physician |
| X3 | Emergency drugs and supplies are stocked and in date, including hyaluronidase where filler is used (good practice) | Monthly crash-cart check log | Clinical lead |
| X4 | Staff complete emergency drills at a set interval (good practice) | Drill records with attendees and debrief notes | Responsible physician |
| X5 | Adverse events are recorded, reviewed, and fed into the protocol QA (good practice) | Adverse-event log and review minutes | Collaborating or supervising physician |
| X6 | Protocols are reviewed at least once a year and after any serious event (good practice) | Review sign-off page with dates | Responsible physician |
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10. Advertising and Patient-Facing Claims
Record status: Record is silent
Our Alabama record has no advertising rule for med spas, so these items are good practice. They exist because your marketing can contradict your compliance file. An Instagram post that shows an RN with a syringe under a "Botox Tuesdays" banner is evidence of exactly the staffing model the Board has declined to authorize, whether or not the post is accurate.
The safest approach is to treat every public claim about who does what as part of the staffing file. If the website says "nurse injectors," either change the website or be ready to show that "nurse" refers to a CRNP working under an approved protocol.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| A1 | Public materials do not describe or show RNs, LPNs, estheticians, or medical assistants injecting cosmetic Botox (good practice) | Quarterly review of website and social channels, with screenshots | Practice manager; responsible physician |
| A2 | Provider credentials are stated accurately: MD, DO, CRNP, PA, RN, and so on (good practice) | Provider bio sheet checked against license verification | Each provider |
| A3 | No service is advertised before the filings it depends on are complete, such as protocol approval (R4) or laser registration (R2) (good practice) | Launch checklist for each new service | Practice manager |
| A4 | Before-and-after photos are used only with patient authorization (good practice) | Photo authorization referenced in the asset library (see C3) | Practice manager |
| A5 | Promotions do not offer treatment without the exam, for example "walk in, walk out" offers that skip the evaluation (good practice) | Promotion approval log | Responsible physician |
11. When the Board Asks: Inquiry and Complaint Response
Record status: Record addresses penalties; silent on procedure
Because Alabama has no facility license, a Board inquiry will usually be directed at a licensee, most often the physician. Our record does not describe the Board's complaint or investigation procedure, so we do not describe it either. It does set out the stakes. Practicing medicine without a certificate of qualification and license is a Class C felony under Ala. Code § 34-24-51. A physician who aids or abets unlicensed practice violates § 34-24-360(13), a ground for license discipline. Failing to meet the cosmetic protocol's supervision and quality-assurance requirements can lead to Board action against the physician's license.
A good response file works backward from those three exposures. For any patient named in an inquiry, you should be able to produce the evaluation note (G1), the order (D1 or the treatment decision), the injector's license and protocol approval (P1, R4), and the physician presence log for that session (S2) within a day. If you have to rebuild any of those from memory, the audit has already found a gap.
| ID | Requirement | Proof | Signs |
|---|---|---|---|
| Q1 | A named person receives and logs any Board correspondence the day it arrives (good practice) | Correspondence log | Practice manager |
| Q2 | Alabama healthcare counsel is engaged before any substantive response (good practice) | Engagement letter | Responsible physician; owners |
| Q3 | For each patient named, the full file is assembled: evaluation, order, consent, injector credentials, protocol approval, presence log (good practice) | Indexed response binder | Practice manager; responsible physician |
| Q4 | Records are preserved and not altered after notice (good practice) | Litigation-hold notice to staff, with acknowledgments | Responsible physician |
| Q5 | Gaps found during the response are corrected and documented (good practice) | Corrective-action plan with completion dates | Responsible physician |
| Q6 | The full checklist is re-run after any inquiry closes (good practice) | Dated checklist run | Responsible physician |
What Our Alabama Record Does Not Settle
Here is what this checklist leaves open, so you know where to ask before relying on it.
- The current protocol version. Our record cites the September 18, 2025 revision. Later-dated Board documents may exist. Get the current form from the Board.
- The protocol's detailed criteria. Training, physician qualification, and quality-assurance specifics are in the protocol itself and are not reproduced here.
- The Board of Nursing ruling. We know it exists and conflicts with the medical board's position only through the medical board's notice. We have not read its terms.
- Fillers, LPNs, and CNMs as injectors. No filler-specific or LPN-specific Board position is in our record, and no CNM route to cosmetic Botox.
- Consent, record retention, emergency equipment, drug storage, and advertising. Our record is silent on each, which is why those sections are marked good practice.
- Board complaint procedure. Our record states the penalties but not the process.
For any of these, the most reliable answer is a written question to the Alabama Board of Medical Examiners, reviewed by an Alabama healthcare attorney. The full cited record is on our Alabama med spa regulations page.
The Alabama Checklist Sorted by Signer
Most checklists finish with a summary by topic. In Alabama it is more useful to sort by signer, because most items rest on one physician's signature, and a practice that loses that physician loses most of its compliance file at once. Use this table to plan coverage when a physician leaves or goes on leave.
| Signer | Items | What breaks if this person leaves |
|---|---|---|
| Responsible / collaborating / delegating physician | E4, E5, R1–R5, S1–S3, S5–S7, G5, G6, P1–P3, P5–P7, L1–L7, D3, X1, X2, X4–X6, Q2–Q6 | CRNP and PA Botox stops until a new protocol is approved; laser delegation stops until a registered physician signs new protocols |
| CRNP or PA injector | R4, R5, G1–G4, D1, C1, C2, C4, A2 | That provider's protocol and agreement end; nobody else can inject under them |
| RN | D2, L5 (as Level 1 delegate), P2 acknowledgment | Laser and IV administration capacity; never Botox capacity |
| Level 2 laser delegates and estheticians | L5, P2 acknowledgment, P6 | Non-ablative laser capacity on on-site physician days |
| Practice manager | R6, S4, P4, P8, P9, L8, D7, C6, A1, A3, A4, Q1, Q3 | Calendars and logs that prove the physician items |
| Owners, corporate secretary, and counsel | E1–E3, E6, C5, Q2 | Entity structure and the employment-model file |
If one physician signs most of the first row, write a succession plan now. Name a second qualified physician who can cover on-site sessions under item S3, and know how long a new protocol approval takes before you need one.
This checklist is for informational purposes only and does not constitute legal or medical advice. Alabama scope-of-practice, supervision, protocol, laser, and ownership rules are administered by the Alabama Board of Medical Examiners, the Medical Licensure Commission, the Alabama Board of Nursing, and the Alabama Board of Cosmetology, and they change over time. Items marked good practice are not drawn from an Alabama rule. Confirm current requirements with the relevant Alabama board and consult an Alabama healthcare attorney before making staffing, structural, or clinical decisions.
Frequently Asked Questions
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