Who Can Inject Botox in Maryland? The On-Site Physician Rule

Most states answer "who can inject Botox" by asking what the injector's own license allows. Maryland asks a second question as well: where is the physician? The Board of Physicians wrote a chapter of regulations aimed squarely at cosmetic work, and that chapter keeps a physician in the room for nearly every injection a nurse gives. Operators who move a staffing model across the Potomac from Virginia, or up I-95 from a looser state, run into that requirement first.

Every state sets its own injector rules through its licensing boards, which is why the same nurse can be a lawful injector in one state and an unlicensed one in the next. Our national who-can-inject guide compares the states side by side.

The rest of this page deals only with Maryland. Every legal point traces to our Maryland record, last reviewed July 21, 2026, which you can read with its citations on the Maryland med spa regulations page. Where that record does not answer a question, we say so rather than guess.

Maryland's Cosmetic Procedure Rule, COMAR 10.32.09, in Plain Terms

Maryland did not pass a med spa law. Instead, the Board of Physicians regulates cosmetic treatment through a chapter of COMAR devoted to delegating and assigning cosmetic medical procedures and the use of cosmetic medical devices. According to our record, its scope provision (COMAR 10.32.09.01) says the chapter governs cosmetic medical procedures performed by a physician or under one. That framing matters. The chapter is written as a set of duties for physicians, and every other license reaches cosmetic work through a physician.

Two definitions decide what is covered

The definitions section, COMAR 10.32.09.02, does the sorting. Our record shows that it classifies injection as a cosmetic medical procedure, and that it classifies lasers, intense pulsed light, and radiofrequency equipment as cosmetic medical devices whose use is itself a cosmetic medical procedure. A Botox appointment, a filler appointment, and a laser hair removal appointment therefore sit under the same rule. Nothing in the Maryland chapter treats neurotoxin as a special category. It is simply one of the procedures the definition captures.

One consequence is that a Maryland practice cannot carve out a "light" injection service to escape the chapter. A small-unit neurotoxin touch-up and a full-face treatment are both injections, so both are cosmetic medical procedures. The amount of product does not change the classification.

Delegate and assign: two verbs for two kinds of license

COMAR 10.32.09.04 is titled qualifications of the individual to whom acts may be delegated and assigned, and the two verbs are not interchangeable. Our record describes a physician who may delegate a cosmetic medical procedure to a physician assistant, or assign it to another licensed health care provider whose own licensing board has determined that the procedure falls within that provider's scope of practice. The record names the nurse practitioner, acting under the CRNP's own advanced-practice scope, and the registered nurse as the providers who fit that description.

The condition attached to assignment is the part people skip. The physician's willingness is not enough. The other provider's licensing board has to treat the act as within that license. That is why the answer for an esthetician is no even when a physician is standing right there. The Board of Cosmetologists does not license medical procedures, so there is no scope for the physician to assign into.

Four duties the physician cannot hand off

Read together, the sections in our record put four duties on the physician that stay with the physician whoever holds the syringe:

1. Be licensed and trained first. COMAR 10.32.09.03 requires the physician to be licensed and trained before performing, delegating, assigning, or supervising a cosmetic medical procedure.
2. Assess the patient personally. COMAR 10.32.09.05 requires the physician to personally perform the initial assessment of each patient and to prepare a written treatment plan, including a diagnosis and a planned course of treatment.
3. Keep written protocols and stay responsible. The same section requires written office protocols and leaves the physician responsible for the acts delegated or assigned.
4. Supervise on site. Again under COMAR 10.32.09.05, the physician must provide on-site supervision whenever a non-physician performs a cosmetic medical procedure or uses a cosmetic medical device, with one PA exception covered below.

A fifth duty sits in COMAR 10.32.09.07: the non-physician has to be trained to competency under the delegating physician's direct, present observation before performing the procedure on their own. We come back to each of these after the role-by-role answers.

Maryland Licenses, the Boards Behind Them, and the Verdicts

Maryland splits aesthetic practice across three licensing bodies. The Board of Physicians licenses physicians and wrote COMAR 10.32.09. The Board of Nursing licenses registered nurses, licensed practical nurses, and certified registered nurse practitioners, and its rules appear elsewhere in COMAR Title 10. The Board of Cosmetologists, which sits in the Maryland Department of Labor rather than the health department, licenses estheticians and cosmetologists under COMAR 09.22. Physician assistants reach cosmetic work through the delegation route in the Board of Physicians' chapter.

The table puts the answers in one place. Each verdict is explained in its own section below.

The last column is what separates Maryland from most of its neighbors. In many states the open question for a nurse injector is whether the prescriber needs to be reachable. In Maryland, for everyone except a PA under an approved agreement, the answer in our record is that the physician needs to be there.

Can a Physician Inject Botox in Maryland? Yes, Once Licensed and Trained

Yes. A Maryland-licensed physician, MD or DO, may perform cosmetic Botox and filler injections. COMAR 10.32.09.03 requires the physician to be licensed and trained before performing the procedure or handing it to anyone else.

The physician answer is short, but the physician is also the only license that can start a Maryland cosmetic treatment chain. Every other "yes" on this page depends on a physician who has assessed the patient, written the plan, trained the injector, and is supervising.

"Trained" is a separate condition from "licensed"

The training requirement in COMAR 10.32.09.03 applies to the physician too. A Maryland medical license does not by itself show that the holder is trained in cosmetic neurotoxin. Our record does not name a particular course, certificate, or number of supervised cases that satisfies the requirement, and we have not found a Board of Physicians document that sets one. What the rule does make clear is that the training has to come before the physician injects, delegates, assigns, or supervises, so a physician who joins a med spa as its supervising doctor should be able to show cosmetic training from before the first clinic day.

The physician answers for the whole chain

Under COMAR 10.32.09.05, as our record reads it, the physician retains responsibility for the acts delegated or assigned. A Maryland physician who lends a name to a med spa and leaves the injecting to others is not reducing their exposure. Improper delegation, assignment, or supervision is grounds for discipline against that physician under COMAR 10.32.09.09A, even if the physician never touched a syringe.

Out-of-state physicians

The chapter speaks of physicians licensed by the Maryland Board. A physician who is licensed only in Virginia, Delaware, or the District of Columbia is not a Maryland physician for this purpose. Only an individual licensed by the Board may practice medicine in Maryland under Health Occupations §14-301, according to our record.

Can a Physician Assistant Inject Botox in Maryland? Yes, by Delegation

Yes. A Maryland physician may delegate cosmetic injections to a physician assistant under COMAR 10.32.09.04. The PA is also the only non-physician for whom our record describes a supervision exception: under a Board-approved delegation agreement, the physician may be "immediately available" rather than on site.

How the PA exception works

Our record describes the exception narrowly. It applies to a physician assistant working under a delegation agreement the Board has approved. It applies only after the physician has evaluated the patient and developed the written treatment plan. Once those conditions are met, the physician may supervise on an "immediately available" basis instead of being physically present. The exception does not remove the physician's personal assessment. It changes only where the physician is while the PA injects.

Our record does not define "immediately available" in minutes or miles. A practice relying on the exception should write its own definition into the PA's protocols, such as the means of contact, the maximum response time, and who covers when the physician is unavailable, and should be ready to show that the definition reflects how the clinic actually runs.

What a delegation agreement does not do

A Board-approved agreement does not let a PA accept new cosmetic patients the physician has never assessed. The PA can perform the procedure. The initial assessment is still the physician's under COMAR 10.32.09.05. A Maryland schedule that books new neurotoxin patients directly with a PA, with the physician signing off afterward, has the order of events backwards.

Training still comes first

The training rule in COMAR 10.32.09.07 applies to PAs like everyone else. Before a PA injects independently, the delegating physician should have observed the PA performing the procedure, directly and in person, until the PA is competent. Keep the record of those observed cases. It is the evidence that the delegation was proper.

Can a Nurse Practitioner Inject Botox in Maryland? Yes, Inside the Physician Framework

Yes. Our Maryland record lists the certified registered nurse practitioner among the licensed providers to whom a physician may assign cosmetic injections, acting under the CRNP's own advanced-practice scope. As our record reads COMAR 10.32.09, a physician still performs the initial assessment and supervises on site.

Why full practice authority is not the whole answer

Maryland is generally described as a full practice authority state for nurse practitioners, and our national guide counts it that way using AANP's state map. Operators sometimes conclude from that status that a CRNP can open a med spa and inject without a physician. Our Maryland record does not support that conclusion for cosmetic medical procedures. It frames the CRNP's cosmetic injecting as an assignment from a physician under the Board of Physicians' chapter, and it states that a non-physician cannot run the medical side of a cosmetic practice without a supervising physician.

We want to be clear about what is settled and what is not. The record's citations are to the Board of Physicians' rule. We have not located a Board of Nursing document that addresses whether a CRNP acting entirely on independent authority, with no physician involved, may perform cosmetic medical procedures in Maryland. Until a Maryland source answers that directly, the cautious structure is the one the record describes: a physician who assesses, plans, and supervises, with the CRNP injecting by assignment.

Where a CRNP adds value in a Maryland clinic

Inside that structure, a CRNP is a strong injector. The CRNP brings an advanced-practice license that the Board of Nursing already recognizes, prescribing experience, and clinical judgment for follow-up visits. What a CRNP does not replace in our record is the physician's personal initial assessment of each new cosmetic patient or the physician's on-site presence. Plan the schedule around the physician's hours, not around the CRNP's license.

Can a Registered Nurse Inject Botox in Maryland? Yes, With the Physician On Site

Yes. A Maryland physician may assign cosmetic Botox injections to a registered nurse. Our record conditions that on the physician's personal assessment and written treatment plan, training to competency under the physician's direct observation, and the physician's on-site supervision while the RN injects.

The treatment plan is the RN's starting point

An RN does not decide that a patient needs neurotoxin, how much, or where. COMAR 10.32.09.05 puts the assessment and the written treatment plan, including the diagnosis and the planned course of treatment, with the physician. The RN carries out that plan. When the RN sees something in the chair that the plan does not cover, such as a new complaint, a change in medical history, or a request for an area the plan does not include, the RN's job is to bring the physician in, not to adjust the plan.

On-site supervision applies to RNs without an exception

The on-site requirement in COMAR 10.32.09.05 covers any non-physician performing a cosmetic medical procedure. The only relaxation in our record is for a PA under a Board-approved delegation agreement. There is no matching exception for an RN. A Maryland "nurse injector night" with the physician at home on call does not fit the rule as our record describes it.

The Board of Nursing condition

Assignment under COMAR 10.32.09.04 works only if the provider's own board treats the act as within that provider's scope. Our record lists the RN among the providers who meet that condition. A practice building an RN injector program should still keep the Board of Nursing's current position in its compliance file. If the Board of Nursing ever narrows RN scope for cosmetic procedures, the assignment route narrows with it.

Can an LPN Inject Botox in Maryland? Treat It as No

Treat the answer as no. Our Maryland record lists physicians, physician assistants, nurse practitioners, and registered nurses as the licenses that may perform cosmetic injections. It does not list licensed practical nurses, and we did not locate a Board of Nursing determination that cosmetic injection falls within LPN scope.

The LPN question in Maryland turns on the wording of COMAR 10.32.09.04. Assignment is available to a licensed health care provider whose own licensing board has determined that the procedure falls within that provider's scope. An LPN is licensed, so the license itself does not rule the LPN out the way it rules out an esthetician. The missing piece is the board determination. Without a Board of Nursing statement placing cosmetic neurotoxin within LPN practice, the condition the regulation sets is not shown to be met.

Our national LPN table records Maryland the same way, as not squarely addressed, and the conservative reading of silence is no. If a Maryland practice wants an LPN to inject, the first step is a written answer from the Board of Nursing, not a training course. A certificate from an injector course does not change what the Board of Nursing has or has not determined about LPN scope.

Can an Esthetician or Cosmetologist Inject Botox in Maryland? No

No. Maryland estheticians are licensed by the Board of Cosmetologists in the Department of Labor, and COMAR 09.22.01.04 limits them to superficial, non-medical skin care. Injection is a cosmetic medical procedure, which our record places outside the esthetician's scope and inside medicine.

What the Maryland esthetician license covers

According to our record, COMAR 09.22.01.04 allows an esthetician to massage the skin for beautification and cleansing, exfoliate dead skin cells, and tone the skin through facials, masks, and wraps. It also allows cosmetic microneedling, but only with a non-medical device whose needles are no longer than 1 millimeter and do not penetrate beyond the epidermis. That microneedling limit is the clearest statement in the Maryland record of where the esthetician's work stops: at the epidermis.

A neurotoxin injection goes well beyond the epidermis by design. Our record states that anything that penetrates or ablates living tissue, including injections, ablative peels, and laser or IPL treatments, is a cosmetic medical procedure outside an esthetician's scope that requires a Department of Health license. Cosmetologists are licensed by the same Board, and nothing in that license reaches injections either.

Why the physician's presence does not change the answer

The assignment route in COMAR 10.32.09.04 is open only to a provider whose own licensing board treats the procedure as within scope. The Board of Cosmetologists does not license medical procedures. A Maryland physician therefore has nothing to assign into, however closely the physician supervises. An esthetician who injects under a physician's eye is still performing a cosmetic medical procedure without authorization, and the physician who allowed it has a COMAR 10.32.09.09A problem.

Where estheticians fit in a Maryland med spa

Estheticians remain central to most Maryland med spas, just not in the injection room. Facials, exfoliation, skin-care consultations within their scope, and microneedling inside the 1-millimeter, epidermis-only limit are all theirs. For a fuller treatment of the license, see our esthetician scope of practice guide.

Can a Medical Assistant Inject Botox in Maryland? No

No. A medical assistant is not among the licensed providers to whom COMAR 10.32.09.04 allows a physician to delegate or assign a cosmetic medical procedure, so a Maryland medical assistant may not inject Botox or filler.

The medical assistant question comes up because medical assistants in physician offices often perform tasks a physician hands them. Whatever a Maryland physician may hand a medical assistant in other settings, the cosmetic chapter is specific. Delegation runs to physician assistants. Assignment runs to licensed providers whose own boards have placed the procedure within their scope. A medical assistant fits neither description, and our record includes no route for one.

The same reasoning covers lasers and IPL. Our record states that unlicensed technicians may not operate cosmetic medical devices in Maryland, and a medical assistant without a qualifying license is in that group. "Laser tech" is a job title, not a Maryland license.

Can a Med Spa Owner or Unlicensed Staff Inject Botox in Maryland? No

No. A non-physician who performs a cosmetic medical procedure without proper authorization is practicing medicine without a license. Our record puts the fine at up to $50,000 under COMAR 10.32.09.09, with felony exposure under Health Occupations §14-606.

The owner question deserves a direct answer because it is the one most often asked quietly. An owner who trained at a weekend course, a front-desk manager who has "watched hundreds," a former sales representative for an aesthetic product: none of them holds a license that COMAR 10.32.09 recognizes, and none of them can be delegated or assigned a cosmetic medical procedure. Owning the business does not change that. Neither does a supervising physician's signature.

Owning the medical practice is limited as well

Maryland adds a second barrier. According to our record, Maryland enforces the corporate practice of medicine doctrine. Only an individual licensed by the Board may practice medicine (Health Occupations §14-301), and a corporation may render professional medical services only through individuals licensed to render them (Corporations and Associations §5-105). The record concludes that ownership of the medical practice is effectively restricted to licensed physicians, with limited hospital and HMO exceptions. A lay owner cannot own the practice that provides the injections, let alone perform them. We return to ownership models below.

Before Any Injection: The Maryland Physician's Personal Assessment

Many states talk about a "good faith exam" that any prescriber may perform. Maryland's cosmetic chapter is more specific about who performs it. Under COMAR 10.32.09.05, as our record quotes it, the physician must "personally perform the initial assessment of each patient" and "prepare a written treatment plan for each patient, including diagnosis and planned course of treatment." Our good faith exam guide covers the general concept. This section covers what Maryland adds to it.

"Personally" means the physician

The word "personally" is what sets Maryland apart. In our record, the initial assessment before a delegated cosmetic procedure belongs to the physician, not to the PA, CRNP, or RN who will inject. A practice that lets its nurse practitioner perform intake assessments for new neurotoxin patients, and has the physician countersign, is relying on a reading of the rule our record does not support.

What the written treatment plan should contain

The rule names two elements: a diagnosis and a planned course of treatment. A workable Maryland neurotoxin plan typically records the patient's relevant history and contraindication screen, the treatment areas, the product, the dose or dose range for each area, the planned interval for follow-up, and any conditions under which the injector must stop and call the physician. The rule does not prescribe that list. It is our recommendation for a plan that an injector can follow and a reviewer can check.

Can the Maryland assessment happen by telehealth?

Possibly, with caution. Our record notes that Maryland's telehealth rule, COMAR 10.32.05.05, permits a synchronous or asynchronous clinical evaluation appropriate to the patient before treatment or prescribing. On that basis the required evaluation can generally be done by telehealth. The record also flags the tension: the cosmetic rule says the physician must "personally" assess the patient, and injectables are a hands-on treatment. Our record calls an in-person assessment the safer practice, and we agree. If a Maryland practice does use telehealth for the initial assessment, the on-site supervision requirement still applies on treatment day, so the physician will be in the building anyway.

Returning patients

The rule speaks of the initial assessment of each patient. Our record does not say how often the physician must reassess a returning neurotoxin patient or when a written plan expires. A sensible Maryland protocol sets a reassessment interval, requires a new physician assessment whenever the treatment areas change or the medical history changes, and has the physician update the written plan rather than letting the injector extend it.

What "On Site" Means for a Maryland Injection Schedule

On-site supervision is the Maryland requirement that changes business plans most. Under COMAR 10.32.09.05, as our record describes it, the physician must provide on-site supervision whenever a non-physician performs a cosmetic medical procedure or uses a cosmetic medical device. Practices that grew up in states with remote or "available by phone" supervision have to rebuild their schedules around it.

Operating hours follow the physician

The practical consequence is simple. A non-physician injects in Maryland only when the supervising physician is on the premises, unless the non-physician is a PA under a Board-approved delegation agreement working on a patient the physician has already assessed and planned. Evening and weekend injection blocks need a physician in the building for those hours. If the physician leaves at 5 p.m., RN and CRNP injecting stops at 5 p.m.

Multiple locations need multiple physicians or a PA agreement

A physician cannot be on site at two clinics at once. A Maryland group running two locations at the same time needs a supervising physician at each one for RN and CRNP injecting. The PA exception is the one structural route our record describes for a non-physician working without the physician present, and it applies only under a Board-approved agreement and only after the physician's assessment and plan.

Document presence, not just availability

Because presence is the requirement, presence is what you need to be able to prove. A daily supervision log that records which physician was on site, the hours, and which non-physicians injected under that supervision costs little to keep. Our record does not require that specific log, but in a Board inquiry it is far more persuasive than a schedule that merely says the physician was expected to be there.

Training to Competency Under Direct, Present Observation

COMAR 10.32.09.07, as our record summarizes it, requires non-physicians to be trained to competency under the delegating physician's direct, present observation before performing the procedure. Three words in that phrase are worth reading slowly.

• Delegating. The observation is by the physician who will delegate or assign the procedure, not by a trainer the practice hired, and not by a course instructor in another state.
• Direct, present. The physician watches the non-physician perform the procedure, in person. A recorded video or a course certificate does not meet that description.
• Competency. The standard is competency, not a fixed number of cases. Our record does not specify a number, so the physician decides and documents when the injector is competent.

Outside courses still have a place. They teach anatomy, product handling, and complication management, and they show that the injector came prepared. In Maryland they are a supplement to the physician's observed training, not a replacement for it. A competency file for each Maryland injector should hold the outside training records, a log of the cases the physician observed, the physician's signed competency determination, and the scope of procedures the determination covers. When a new injector changes products or adds a new treatment area, extend the file rather than assuming the old determination covers it.

Six Maryland Staffing Plans, Tested Against COMAR 10.32.09

These scenarios apply the rule as our record describes it. They are not legal advice for your practice, but they show where common models land.

1. Physician assesses each new patient; RN injects while the physician sees other patients down the hall

Fits the rule. The physician personally assessed the patient and wrote the plan, and the physician is on site while the RN injects. Keep the RN's competency file and the supervision log current.

2. CRNP runs Saturday injections alone; the physician reviews charts on Monday

Does not fit. Our record requires on-site physician supervision whenever a non-physician performs a cosmetic medical procedure, and it describes no exception for a CRNP. Monday chart review is useful quality assurance, but it does not supply Saturday's supervision.

3. PA under a Board-approved delegation agreement treats established patients at a satellite office while the physician works at the main clinic

Can fit, with conditions. This is the structure the PA exception was written for, provided the physician has already assessed each patient and written the plan, and the physician is genuinely immediately available. New patients at the satellite still need the physician's personal assessment first.

4. RN performs intake on new patients and the physician signs the plan without seeing them

Does not fit. The initial assessment must be performed by the physician personally. A physician signature on an RN's intake is not a personal assessment.

5. Esthetician with an out-of-state injector certificate injects under the physician's direct watch

Does not fit. The certificate is education, not a Maryland license, and the Board of Cosmetologists' license does not cover cosmetic medical procedures. Physician supervision cannot create authority that the license lacks.

6. Physician-owned practice, physician assesses by video, RN injects next day with the physician on site

Probably fits, but not the safest version. Our record reads Maryland's telehealth rule as allowing the evaluation by telehealth, and the on-site requirement is met on treatment day. Our record also calls an in-person assessment the safer practice because of the word "personally." If the physician will be on site for the injection anyway, doing the assessment in person that day removes the question.

Beyond Botox: Fillers, Lasers, Microneedling, and IV Therapy in Maryland

The same staff usually handle more than neurotoxin, so it helps to know where the Botox answer carries over.

Dermal fillers, Dysport, Xeomin, and other injectables

The Maryland definition captures injection as a cosmetic medical procedure. It does not depend on the brand of neurotoxin or on whether the product is a toxin or a filler. Everything on this page about who may inject Botox applies in the same way to other neurotoxins and to dermal fillers.

Lasers, IPL, and radiofrequency

Our record states that lasers, intense pulsed light, and radiofrequency devices are cosmetic medical devices under COMAR 10.32.09.02 and that their use is regulated exactly like injections. A physician operates them or hands them, by delegation or assignment, to a PA, CRNP, or RN, with the same training and supervision requirements. Estheticians and unlicensed technicians may not operate them. For the broader picture, see our skin and laser compliance guide.

Microneedling

Microneedling is the one place where the esthetician's license and the cosmetic chapter meet. Under COMAR 09.22.01.04, an esthetician may perform cosmetic microneedling only with a non-medical device whose needles are no longer than 1 millimeter and do not penetrate beyond the epidermis. Anything deeper is a procedure that penetrates living tissue, and our record treats that as a cosmetic medical procedure outside the esthetician's license. Our microneedling scope of practice guide compares the approach in other states.

IV therapy

IV therapy runs on a different track. Our record cites the Board of Nursing's definition of infusion therapy at COMAR 10.27.20.02, the initiation and administration of medication, fluids, and nutrients through an intravenous access device. It is a regulated nursing act requiring documented education and competency. An authorized prescriber (a physician, CRNP, or PA) orders it after a valid patient evaluation, and RNs administer it, with LPNs only in limited settings our record does not spell out. A Maryland "drip bar" with no prescriber is unlawful. See our IV therapy compliance guide for the operational side.

Penalties for Unauthorized Botox Injections in Maryland

Maryland's penalty provisions fall on three different people, and a single bad staffing decision can reach all three.

The non-physician who injected

According to our record, a non-physician who performs a cosmetic medical procedure without proper authorization is guilty of practicing medicine without a license and is subject to a fine of not more than $50,000 under COMAR 10.32.09.09B and C. At the statutory level, Health Occupations §14-606(a)(4) treats a violation of the unlicensed-practice statute, §14-601, as a felony carrying a fine of up to $10,000, imprisonment of up to five years, or both. A disciplinary panel may separately levy a civil fine of up to $50,000. Our record notes that the criminal and civil exposure are cumulative, not alternatives.

The physician who delegated, assigned, or supervised

Improperly delegating, assigning, or supervising a cosmetic medical procedure, or letting an unqualified person perform one, is grounds for Board of Physicians discipline against the physician under COMAR 10.32.09.09A. Because the physician retains responsibility for delegated acts, the physician is exposed even when someone else held the syringe.

The business and anyone holding out

Under Health Occupations §14-206(e), as our record describes it, a Board disciplinary panel may issue a cease-and-desist order or seek injunctive relief against anyone practicing medicine without a license or falsely representing that they are authorized to practice medicine. Advertising "Botox by our master injector" for someone who is not a lawful Maryland injector invites exactly that kind of order.

Who Can Own the Practice Behind a Maryland Injector?

The injector question and the ownership question are separate, but in Maryland they point in the same direction. Our record states that Maryland enforces the corporate practice of medicine doctrine and that a medical practice entity must be a physician-owned professional corporation, with limited hospital and HMO exceptions. A lay corporation cannot practice medicine or employ physicians to deliver clinical care.

Our record also notes that Maryland has no med-spa facility license or registration. There is no state permit that makes a building a lawful place to inject. What makes an injection lawful is the chain this page describes: a physician-owned practice, a trained physician who assesses and plans, a properly delegated or assigned injector, and on-site supervision. If a non-physician investor is involved, the arrangement between that investor and the physician-owned practice is a question for Maryland health care counsel. Our record does not address management-company structures, and this page does not claim any particular one is permitted. For the national picture, see our guide to med spa ownership by state.

One point of tension is worth naming. Some of our national content lists Maryland among full practice authority states where nurse practitioners can own practices generally. Our Maryland record, which is specific to cosmetic medical procedures, describes a physician-owned and physician-directed model. Until a Maryland source resolves how those fit together for a cosmetic practice, the physician-owned structure is the one our record supports.

A Maryland Injector Compliance File, Item by Item

Every element of the Maryland chain should leave a document. If a Board investigator asks how a given injection was authorized, the answer should be a short stack of paper, not a conversation.

• Physician licensure and cosmetic training. The supervising physician's Maryland license and evidence of cosmetic training from before the physician began performing or supervising (COMAR 10.32.09.03).
• Written office protocols. The protocols COMAR 10.32.09.05 requires, covering each procedure the practice offers, contraindications, product handling, and complication response.
• Each injector's license and route. For each PA, CRNP, and RN: the license, whether the procedure is delegated (PA) or assigned (CRNP, RN), and the procedures covered.
• Competency file. The physician's direct, present observation log and signed competency determination for each non-physician (COMAR 10.32.09.07).
• PA delegation agreement. If the practice relies on "immediately available" supervision, the Board-approved agreement and the practice's written definition of immediate availability.
• Per-patient assessment and plan. The physician's personal initial assessment and the written treatment plan with diagnosis and planned course of treatment (COMAR 10.32.09.05).
• Supervision log. Which physician was on site, when, and who injected under that supervision.
• Consent and treatment records. Signed consent, the injection record tied back to the plan, lot numbers, and follow-up notes.
• Emergency readiness. Written complication and emergency protocols with the supplies to carry them out. Our Emergency Protocols Kit covers vascular occlusion and anaphylaxis.

A full Maryland compliance checklist that turns these items into a yes/no audit is in preparation and will be added to the Maryland hub (coming soon).

Where Maryland Law Is Silent or Unsettled

Our Maryland record answers the core questions, but it leaves some practical ones open. We list them so you know where to get a written answer before relying on an assumption.

• LPN scope. The record does not list LPNs, and we found no Board of Nursing determination for cosmetic injection. Treat it as no until the Board says otherwise in writing.
• Independent CRNP cosmetic practice. Maryland grants nurse practitioners broad practice authority generally, but our record frames cosmetic injecting as physician assignment. We found no Maryland source resolving whether a CRNP may perform cosmetic medical procedures with no physician involved.
• "Immediately available." The record does not define the term for the PA exception in time or distance.
• Reassessment of returning patients. The rule requires the physician's personal initial assessment. It does not say when a reassessment is required or when a written treatment plan lapses.
• Telehealth versus "personally." The telehealth rule permits a remote evaluation, while the cosmetic rule requires the physician to assess personally. Our record calls in-person the safer practice. We know of no Board statement settling the question.
• Training standard. Neither the physician's training requirement nor the non-physician's competency requirement comes with a defined course or case count in our record.
• Management arrangements. The record addresses who may own the medical practice, not how a lay-owned business may contract with one.

For each of these, the safest step is a written inquiry to the relevant board, with Maryland health care counsel reviewing the answer, before you build a schedule or a compensation plan around it.

Maryland Botox FAQ

MedSpa Standards publishes this guide as general information, not legal or medical advice. In Maryland, cosmetic procedure, scope, and supervision questions belong to the Board of Physicians, the Board of Nursing, and the Board of Cosmetologists, and the answer for your practice depends on your facts and on rules that change. Confirm the current position with the board that licenses each person involved, and have a Maryland health care attorney review staffing, supervision, or ownership changes before you make them.