October 26, 2026 28 min read

Nevada Med Spa Compliance Checklist (2026): The Grid, the Order, and the 60/60 Rule

Nevada wrote down more of its med spa rules than most states did: a filler statute, a nursing board grid, a distance test for advanced esthetician supervision, and a physician ownership rule. That makes a Nevada audit concrete. Each line below says what to prove, which document proves it, and whose signature goes on it.

Quick Answer

To pass a Nevada med spa audit, a practice must show five things. The medical entity is physician-owned under NRS chapter 89, with any outside money in a management agreement. A qualified licensed practitioner assessed each patient, in person or by telehealth with a Nevada license, and wrote an order for each intervention. Registered nurses injected only on that order and under direct supervision, and LPNs, estheticians, medical assistants, and owners did not inject at all. Advanced estheticians did nonablative work only, under a physician, PA, or APRN who was reachable in real time and within 60 miles or 60 minutes. A practitioner controlled the dangerous drugs and approved the laser equipment. Nevada issues no med spa license, though esthetics rooms need a cosmetological establishment license.

Nevada issues no med spa permit, so an investigator asks instead for evidence that each treatment was lawful under four bodies of law: the medical and osteopathic practice acts (NRS 630 and 633), the Nevada State Board of Nursing's Practice Advisory Decision on Aesthetic/Cosmetic Procedures, the cosmetology chapter (NRS 644A), and the professional entity rules (NRS 89). Passing three does not excuse the fourth.

This checklist has ten audits and 65 numbered lines. Each line gives the requirement, the document that proves it, who signs that document, and the basis for the requirement. File the proof as you go and you finish with the binder an investigator would want.

The legal content comes from our Nevada record, last reviewed July 21, 2026, and the statute or board document behind each point is listed on the Nevada med spa regulations page. Every statement here about who may perform a procedure, and under whose order or supervision, matches our guide to who can inject Botox in Nevada. Where that record is silent, we say the topic is not specifically addressed, and we do not fill the gap with a rule from another state.

In short

Nevada gives you four written tests: who may own the medical entity (NRS 89), who may inject filler and where (NRS 629.086), what each nursing license may do in aesthetics (the Board of Nursing grid), and how an advanced esthetician is supervised (NRS 644A.545, with the 60-mile or 60-minute rule). Pass those four, then document the order for each intervention, and most of a Nevada audit is done.

What Makes a Nevada Med Spa Audit Different?

Short answer: Fewer gray areas and more paper. Nevada answers several questions in writing that other states leave to inference, so an auditor here checks your documents against a fixed text rather than against a general standard.

Three features set Nevada apart: a Board of Nursing grid that gives each nursing license a verdict procedure by procedure, an advanced esthetician license with a statutory distance limit on supervision, and, in our record's reading, a physician ownership requirement that shapes the business before any patient is seen.

The four basis labels

The last column of every table tells you where the requirement comes from, so you know how much weight it carries.

  • Statute: a Nevada statute or regulation in our record, such as NRS 629.086, NRS 644A.545, NRS chapter 89, or NAC 630.810.
  • Nursing Board: the Nevada State Board of Nursing's aesthetic practice decision, including its procedure grids and general requirements.
  • Our reading: a documentation step our Nevada record or our injector guide recommends to prove a legal point, or a cautious reading where the record is ambiguous. It is advice, not a quoted rule.
  • Not addressed: a topic our Nevada record does not specifically address. The line is a house standard built from ordinary compliance practice, and nobody in the practice should describe it as Nevada law.

Who May Own a Nevada Med Spa?

Short answer: A physician, under our record's reading of NRS chapter 89. Nevada follows the corporate practice of medicine doctrine, so the entity that delivers medical services should be physician-owned, and non-physician investors usually come in through a management services agreement.

Our record cites two provisions. NRS 89.070 lets a professional entity organized to practice medicine under chapter 630 or 633 issue ownership interests only to a natural person licensed to render that same professional service. NRS 89.050(2)(b) says a medical professional entity may be composed only of licensed physicians and enumerated practitioners. The record concludes that a med spa practicing medicine must be physician-owned.

The record does not analyze APRN-owned nursing practices or describe Nevada limits on management fees and control. Both go to Nevada counsel.

The facility side has its own rule. Nevada has no med spa license, but if the clinic offers esthetics services, it must hold a cosmetological establishment license under NRS 644A.600, and those services must be performed by appropriately licensed staff. A single Nevada building can therefore need a cosmetology license for its facial rooms and no license at all for its injection rooms.

Audit 1: entity, ownership, and facility
No.RequirementProof on fileSignsBasis
NV 1.1The entity that delivers medical services is organized as a professional entity for the practice of medicine.Articles and organizing documents, with a one-paragraph counsel summary of the NRS 89 structurePhysician owner; Nevada counselStatute
NV 1.2Every ownership interest is held by a natural person licensed to render the same professional service (NRS 89.070).Current ownership ledger listing each holder's Nevada license type and numberPhysician ownerStatute
NV 1.3Non-physician capital sits in a management services company, not in the medical entity.Management services agreement and a chart showing which entity bills patientsPhysician owner; MSO principalOur reading
NV 1.4Management fees and control terms have been reviewed, since our record sets no Nevada standard for them.Dated counsel review memo attached to the management agreementNevada health care counselNot addressed
NV 1.5If the clinic is APRN-led, the ownership structure has a written legal opinion, because the record does not analyze APRN-owned practices.Counsel opinion letter on the entityAPRN; Nevada counselOur reading
NV 1.6A cosmetological establishment license is held if any esthetics services are offered (NRS 644A.600).License displayed and copied to the binder, renewal date on the calendarPractice managerStatute
NV 1.7A one-page memo records that Nevada issues no med spa license and lists the licenses the clinic relies on instead.Authority memo naming each clinician, license, and licensing bodyPhysician ownerOur reading
NV 1.8No owner, investor, or manager without clinical authority chooses patients, products, or doses.Signed acknowledgment from each non-clinical owner and managerEach non-clinical owner; physician ownerOur reading

Is a Medical Director Required for a Nevada Med Spa?

Short answer: Not by statute. Our record finds no Nevada statute requiring a med spa medical director, but it also explains why physician oversight is effectively required anyway. The work a medical director would do still has to be done, and each piece needs a named person.

Our record gives the reasons. Injectable and other medical procedures must be ordered and overseen by a physician or an independent-practice APRN. An advanced esthetician performing nonablative procedures needs a qualifying supervisor under NRS 644A.545. And the Board of Nursing requires aesthetic laser equipment to be FDA-labeled and "approved by medical director." The title has no statutory definition in Nevada, but the board's own laser grids use it.

So the audit asks for a role map rather than one medical director contract. One physician can fill every role, but each needs a name.

The supervision rules, license by license

  • Registered nurses inject only on a qualified practitioner's order and under direct supervision, per the Board of Nursing's cosmetic injectables grid. Our record does not define direct supervision any further: no on-site rule, no response time, no distance.
  • APRNs with independent practice authority may perform aesthetic procedures, including cosmetic injectables, without supervision, according to the Board of Nursing's decision. Our record does not describe how an APRN obtains that status.
  • Physician assistants are licensed under chapter 630 or 633. Our record does not set out how a PA's relationship with a physician must be documented, so the audit asks for whatever the PA's licensing board requires.
  • Advanced estheticians perform nonablative procedures only under a health care professional, defined at NRS 453C.030 as a physician, a PA, or an APRN, who is reachable in real time and stays within 60 miles or 60 minutes. A plain RN or LPN does not qualify, and the statute creates no board-approved collaboration agreement.
  • Medical assistants perform only delegated tasks, may not diagnose, initiate treatment, or prescribe, and need the delegating physician or PA immediately available in person for any invasive task (NAC 630.810).

For how a supervising or collaborating clinician differs from a titled medical director, see our guide to medical directors versus supervising and collaborating physicians.

Audit 2: supervision and delegation
No.RequirementProof on fileSignsBasis
NV 2.1A role map names the ordering practitioner, the RN supervisor, the advanced esthetician supervisor, the drug controller, and the laser equipment approver.Role map, one page, updated whenever a clinician joins or leavesPhysician owner; each named practitioner initials their roleOur reading
NV 2.2Each RN injection session has a named supervising practitioner providing direct supervision.Session supervision log: date, RN, supervisor, and how the supervisor was availableSupervising practitioner; RNNursing Board
NV 2.3Until the Board of Nursing defines direct supervision in writing, the supervisor is present or immediately reachable and able to manage a complication.Written supervision policy stating the clinic's standardPhysician ownerOur reading
NV 2.4Any APRN who injects or orders without a physician has confirmed independent practice authority.Board of Nursing verification or written confirmation, kept in the APRN's fileAPRNNursing Board
NV 2.5Each PA's relationship with a physician is documented in the form the PA's licensing board requires.The PA's documentation, whatever its form, with the board's requirement notedPA; physicianNot addressed
NV 2.6A clinic that relies on PA orders for RN injectables has the Board of Nursing's confirmation, because our record names PAs as ordering practitioners for IV therapy but not in its medical director section.Written board responsePA; physician ownerOur reading
NV 2.7Every advanced esthetician session has a supervisor who is a physician, PA, or APRN, never an RN or LPN (NRS 453C.030).Supervisor roster showing each supervisor's license typeSupervising health care professionalStatute
NV 2.8Medical assistants perform only delegated tasks, with the delegating physician or PA immediately available in person for invasive tasks (NAC 630.810).Signed delegation list per assistant, plus the presence record for invasive tasksDelegating physician or PA; medical assistantStatute

Does Your Advanced Esthetician Schedule Pass the 60/60 Test?

Short answer: Only if every nonablative session has a physician, PA, or APRN who is reachable in real time throughout and who stays within 60 miles or 60 minutes of the treatment room. Our record describes no exceptions and no written agreement that substitutes for it.

NRS 644A.545 is the most mechanical rule in a Nevada med spa, so it gets its own test. The statute, as our record summarizes it, requires the supervising health care professional to satisfy two conditions at all times during the procedure. They must be readily available for immediate consultation with the advanced esthetician by telephone or other technology that allows real-time communication. They must also remain within 60 miles or 60 minutes of the procedure location and be readily available to provide care in person if problems arise.

The test does not require the supervisor to be in the building, and it involves no collaboration agreement; our record says the statute creates none. It does require the right license: a physician, PA, or APRN under NRS 453C.030, so an RN on site never satisfies it.

Four schedules, tested

  • Supervisor in the next suite, phone on. Passes, if the supervisor is a physician, PA, or APRN and the session log shows who it was.
  • Supervisor at a second clinic across town, reachable by phone. Passes, provided the second clinic is within 60 miles or 60 minutes and the supervisor could in fact leave to provide in-person care.
  • Supervisor at home in another Nevada city several hundred miles away, on video. Fails the distance condition, even though the real-time condition is met.
  • RN on site, physician unreachable in surgery. Fails twice: the RN is not a qualifying health care professional, and the physician is not readily available for immediate consultation.

Ablative work never passes the test, because NRS 644A.545 bars advanced estheticians from any ablative esthetic medical procedure. The audit lines for this test sit in Audit 6, with the other device items.

What Must Happen Before a Nevada Patient Is Treated?

Short answer: An assessment by a qualified licensed practitioner and an order for that specific intervention. Our record calls this a good-faith exam requirement, and it allows the assessment by telehealth when the practitioner holds a valid Nevada license.

The Board of Nursing's decision requires "an order for each individual intervention by a qualified licensed practitioner that has assessed the patient and established a bonafide patient/provider relationship," citing NRS 639.235. NRS 629.515, as our record summarizes it, lets a provider at a distant site establish care and write a treatment order or prescription, so long as the provider holds a valid Nevada license.

The assessor must be a physician, an APRN with independent practice authority, or, subject to the caveat in Audit 2, a PA. The injecting RN cannot perform the assessment that authorizes their own treatment, and an esthetician or medical assistant screening does not count. Because the order attaches to "each individual intervention," a protocol letting nurses choose who is treated is not a model our record supports.

A telehealth assessment answers only half the question for RN injections. The remote practitioner may have satisfied the exam requirement and still be unavailable to provide the direct supervision the grid requires during the session. The audit treats those as two separate lines for that reason.

Audit 3: the assessment and the order
No.RequirementProof on fileSignsBasis
NV 3.1A qualified licensed practitioner assessed the patient before the first treatment.Assessment note with history, exam findings, and contraindication screenAssessing practitionerNursing Board
NV 3.2The chart records whether the assessment was in person or by telehealth.Assessment note field for mode and dateAssessing practitionerOur reading
NV 3.3Any telehealth practitioner holds a valid Nevada license (NRS 629.515).Nevada license verification printout, renewal date on the calendarPractice manager; remote practitionerStatute
NV 3.4Each intervention has a patient-specific order, dated before treatment, naming product, areas, and dose.Signed order in the chart for every treatmentOrdering practitionerNursing Board
NV 3.5Returning patients get a new order supported by a current assessment, since the record sets no re-assessment interval.Order and assessment note dated for each visitOrdering practitionerOur reading
NV 3.6The clinic does not run cosmetic injectables from a standing protocol without the Board of Nursing's written approval.Policy statement, or the board's written response if a protocol is usedPhysician ownerOur reading
NV 3.7No RN, esthetician, or medical assistant performs the assessment that authorizes a treatment.Intake workflow showing the assessor's name and license for each new patientPhysician ownerNursing Board
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Which Treatments May Each Nevada License Perform?

Short answer: Physicians, PAs, and APRNs carry their own authority. RNs inject on an order under direct supervision. LPNs may not inject cosmetics. Estheticians, including advanced estheticians, never inject, and medical assistants and owners do not inject either.

The matrix below condenses our injector guide's verdicts and our record's laser, peel, and IV sections. Use it to check the schedule, not to argue an edge case; the Nevada who-can-inject guide explains each row in full.

Nevada procedure matrix, from our record
LicenseNeuromodulators and fillersLasers, IPL, RFMicroneedling and medium-depth peelsIV therapy
Physician (MD or DO)YesYes, within own scopeYes, within own scopeYes; orders and may administer
Physician assistantYesYes, within own scopeYes, within own scopeYes; may order and administer
APRN (incl. nurse practitioner)Yes; no supervision with independent practice authorityYes, within own scopeYes, within own scopeYes; may order and administer
Registered nurseYes, on an order, under direct supervisionMany laser and light procedures, with laser certification, an order, and provider supervision; certain ablative or advanced procedures excludedNot separately addressed in our recordAdministers at a prescriber's direction
Licensed practical nurseNo (grid: Not Within Scope)Many laser and light procedures, with laser certification, an order, and provider supervision; certain ablative or advanced procedures excludedNot separately addressed in our recordAdministers at a prescriber's direction
Advanced estheticianNoNonablative only, under a physician, PA, or APRN meeting the 60/60 rule; never ablativeYes (NRS 644A.012); keep a qualifying supervisor in placeNo
Esthetician or cosmetologistNoNo esthetic medical devicesNo; superficial exfoliation above the stratum corneum onlyNo
Medical assistantNoNot in our record; treat as noNot in our record; treat as noNot in our record; treat as no
Owner or unlicensed staffNoNoNoNo

Three notes. For filler, NRS 629.086 also admits dentists and podiatric physicians with board-prescribed training, within scope and only at a medical facility or licensed provider's office; our record is silent on them for neuromodulators. The RN and LPN laser cells summarize Board of Nursing grids, so check the grid for any specific device. And our record does not treat NAC 630.810 delegation as a route for medical assistants to any of these procedures.

Audit 4: who performs which procedure
No.RequirementProof on fileSignsBasis
NV 4.1Every clinician on the schedule holds a current Nevada license matching the matrix row they work under.License verification for each clinician, with renewal dates on the calendarPractice managerStatute
NV 4.2LPNs are kept off the cosmetic injectables schedule.LPN role description and a monthly schedule checkPhysician owner; each LPNNursing Board
NV 4.3Estheticians, advanced estheticians, cosmetologists, and medical assistants are kept off the injectables schedule.Role descriptions signed by each staff memberPhysician owner; each staff memberStatute
NV 4.4Filler is injected only at a medical facility or a licensed provider's office (NRS 629.086).Location policy and a log of any off-site requests declinedPhysician ownerStatute
NV 4.5Any dentist or podiatric physician who injects filler has the training their board prescribes.Training certificate in the clinician's fileThe dentist or podiatric physicianStatute
NV 4.6A clinician arriving from another state is placed by the Nevada matrix, not by what their former state allowed.Onboarding checklist noting the Nevada row and its limitsPhysician owner; new clinicianOur reading

Which Consent and Chart Records Should a Nevada Med Spa Keep?

Short answer: Our record does not specifically address med spa consent forms or a record retention period. What it does require is documented: an assessment and an order for each intervention. Everything else in this audit is a house standard, labelled as such.

This is where Nevada's written rules run out. The assessment and order requirement from Audit 3 is the only chart content our record makes mandatory. Our injector guide adds a chart standard built around it: the practitioner's name and Nevada license, the date and mode of assessment, the findings, the order, informed consent signed before the injection, the supervising practitioner for RN sessions, and an administration note with the lot number and any adverse event.

Audit 5: consent and patient records
No.RequirementProof on fileSignsBasis
NV 5.1Informed consent for the specific procedure is signed before treatment.Procedure-specific consent form in the chart, dated and timedPatient; treating clinicianNot addressed
NV 5.2Each treatment has an administration note: product, lot number, areas, dose, and any adverse event and response.Treatment note template completed per visitTreating clinicianOur reading
NV 5.3RN treatment notes name the supervising practitioner for that session.Supervisor field on the RN treatment noteRN; supervising practitionerOur reading
NV 5.4A retention schedule for charts and photographs has been set with counsel, since our record names no Nevada period.Written retention policy with counsel's sign-offPhysician owner; Nevada counselNot addressed
NV 5.5Before-and-after photographs have a separate patient consent covering clinical and any marketing use.Photo consent formPatient; practice managerNot addressed
NV 5.6A monthly chart sample confirms that order dates precede treatment dates.Chart audit worksheet, ten charts per monthOrdering practitionerOur reading

Who May Operate Lasers and Energy Devices in a Nevada Med Spa?

Short answer: Physicians, PAs, and APRNs within their own scope; RNs and LPNs for many laser and light procedures with laser certification, a practitioner's order, and provider supervision; advanced estheticians for nonablative work under the 60/60 rule. Basic estheticians and cosmetologists may not use an esthetic medical device at all.

Our record treats lasers, IPL, and RF units as esthetic medical devices. NRS 644A.075 excludes their use from esthetics, and our record notes that SB 249 (2023) revised the cosmetology scope to prohibit estheticians and cosmetologists from using esthetic medical devices. Ablative laser resurfacing is barred to estheticians outright under NRS 644A.545, and the Board of Nursing grids place certain ablative or advanced laser procedures outside RN and LPN scope as well.

The equipment is an audit item too: the Board of Nursing's laser grids require it to be FDA-labeled and approved by the medical director. Our record describes no Nevada laser registration, safety officer, or eye protection rule, so those lines are house standards.

Audit 6: lasers, IPL, and RF devices
No.RequirementProof on fileSignsBasis
NV 6.1Every aesthetic laser, IPL, and RF device is FDA-labeled and approved by the medical director (Board of Nursing grids).Device register: make, model, FDA labeling, approval dateMedical director or approving physicianNursing Board
NV 6.2RN and LPN operators hold laser certification and work on a practitioner's order with provider supervision.Certification copies; order in each chart; supervision logSupervising practitioner; RN or LPNNursing Board
NV 6.3RNs and LPNs are kept off the ablative or advanced laser procedures the grid excludes from their scope.Procedure list checked against the grid, kept with the device registerMedical directorNursing Board
NV 6.4Advanced estheticians perform only nonablative device procedures, each under a qualifying supervisor meeting the 60/60 rule (NRS 644A.545).Session log naming supervisor, license type, location, and real-time contact methodSupervising physician, PA, or APRN; advanced estheticianStatute
NV 6.5No advanced esthetician performs any ablative esthetic medical procedure.Device settings or protocol showing nonablative use only for that operatorMedical directorStatute
NV 6.6Basic estheticians and cosmetologists do not use any esthetic medical device (NRS 644A.075).Device room access list excluding themPractice managerStatute
NV 6.7Laser safety measures, such as eye protection and a safety lead, are set by policy, since our record names no Nevada rule.Laser safety policy and training logMedical directorNot addressed

How Should a Nevada Med Spa Control Drugs, IV Therapy, and Storage?

Short answer: Through the practitioner. Neuromodulators and IV infusions involve dangerous drugs that need a prescriber's order, and the Board of Nursing's decision says only a qualified licensed practitioner may control access to the dangerous drugs used. Storage specifics are not addressed in our record.

The Board of Nursing cites NRS 454.201, 454.213, and 454.316 for that control requirement. Our record summarizes NRS 454.213 as allowing dangerous drugs to be possessed and administered by physicians, PAs, APRNs, and nurses acting at a prescriber's direction. For IV therapy, Nevada has no med-spa-specific statute: a physician, APRN, or PA must establish the patient relationship and order the therapy, and administration may be by physicians, PAs, APRNs, or RNs and LPNs acting at a prescriber's direction.

The test is whose name is on the purchase and who holds the key. A nurse manager or lay owner who controls the supply on their own authority fails this audit. Our record does not address temperature logs, inventory counts, or controlled-substance registration, so those lines are house standards.

Audit 7: drugs, IV therapy, and storage
No.RequirementProof on fileSignsBasis
NV 7.1Neuromodulators, fillers, and IV drugs are purchased under a qualified licensed practitioner's authority.Supplier account records in the practitioner's nameControlling practitionerNursing Board
NV 7.2Only the controlling practitioner, or people they authorize in writing, can access the drug supply.Access list and key or code logControlling practitionerNursing Board
NV 7.3Each IV infusion has a relationship and order from a physician, APRN, or PA.IV assessment and order in the chartOrdering practitionerStatute
NV 7.4IV administration is by a physician, PA, APRN, or an RN or LPN acting at a prescriber's direction (NRS 454.213).Administration note naming the clinician and the prescriberAdministering clinicianStatute
NV 7.5Storage conditions, inventory counts, and expiry checks follow a written policy, since our record sets no Nevada standard.Storage and inventory logControlling practitioner; practice managerNot addressed
NV 7.6Any controlled-substance handling has been reviewed by counsel, since our record does not address it.Counsel memo or a written statement that no controlled substances are stockedPhysician ownerNot addressed

Does Nevada Require a Med Spa Emergency Plan?

Short answer: Our record does not specifically address emergency planning for Nevada med spas. Two of its rules still point at emergencies: RN injectors work under direct supervision, and an advanced esthetician's supervisor must be able to provide care in person if problems arise.

Those two rules set the floor: a supervisor who cannot respond to a complication is not supervising as the grid or NRS 644A.545 describes. Beyond that, the lines below are house standards, centered on vascular occlusion and anaphylaxis, which our injector guide's document file also lists.

For the national version of this audit, with the drills, supplies, and documentation in more detail, work through our med spa emergency protocol checklist.

Audit 8: emergency preparedness
No.RequirementProof on fileSignsBasis
NV 8.1A written complication plan covers vascular occlusion and anaphylaxis, naming who responds and in what order.Complication protocol, reviewed yearlyMedical directorNot addressed
NV 8.2The drugs and supplies the plan calls for are on site and checked.Emergency cart checklist with dated checksPractice manager; medical directorNot addressed
NV 8.3Every RN injection session has a supervisor who can actually manage a complication.Supervision log cross-referenced to the complication planSupervising practitionerNursing Board
NV 8.4Every advanced esthetician session has a supervisor able to provide in-person care if problems arise (NRS 644A.545).Session log showing supervisor location and contact methodSupervising physician, PA, or APRNStatute
NV 8.5Staff have rehearsed the plan.Drill log with date, scenario, and attendeesMedical directorNot addressed
NV 8.6Each adverse event is recorded and reviewed.Adverse event report and follow-up noteTreating clinician; medical directorOur reading

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What Can a Nevada Med Spa Say in Its Advertising?

Short answer: Our record does not address med spa advertising rules as such. It does make holding oneself out as practicing medicine without a license part of the NRS 630.400 offense, so ads that promise medical services from unlicensed staff create real exposure.

An ad calling an LPN a "nurse injector," a post offering Botox with an esthetician, or a "filler party" at a rented venue each advertises something the matrix or NRS 629.086 rules out. Check every campaign against the matrix before it runs.

Our record names no Nevada rule on before-and-after photographs, testimonials, pricing claims, or disclosure of credentials in ads. The lines that cover them are house standards.

Audit 9: advertising and holding out
No.RequirementProof on fileSignsBasis
NV 9.1No ad, post, or listing offers a medical procedure performed by someone the matrix excludes.Pre-publication checklist signed for each campaignMedical director; marketing leadStatute
NV 9.2Staff titles in marketing match their Nevada license type.Staff bio sheet checked against license verificationsPractice managerOur reading
NV 9.3No promotion places filler injection at a venue other than a medical facility or licensed provider's office (NRS 629.086).Event approval formPhysician ownerStatute
NV 9.4Before-and-after photos used in marketing have the patient's marketing consent on file.Photo consent cross-referenced in the marketing archiveMarketing leadNot addressed
NV 9.5Advertised outcomes and claims have been reviewed by a clinician before publication.Claims review note per campaignMedical directorNot addressed

What Happens When a Nevada Board Opens a Complaint Against a Med Spa?

Short answer: Each board examines its own licensees, because Nevada has no med spa regulator. The Board of Medical Examiners can issue cease-and-desist orders, citations, and fines of up to $5,000 per violation, and unlicensed practice of medicine is a felony under NRS 630.400.

Our record states the penalties. Practicing medicine, or holding oneself out as doing so, without a license is a category D felony, or a category C felony if substantial bodily harm results. The Board of Medical Examiners may additionally issue cease-and-desist orders, citations, and administrative fines up to $5,000 per violation. Separately, injecting dermal or soft-tissue fillers by an unauthorized person, outside one's scope, or at an unauthorized location is a misdemeanor under NRS 629.086.

Our record does not list either board's disciplinary grounds or any cosmetology-side penalties under NRS 644A. Assume every clinician named in a chart is exposed to their own board.

Audit 10: inspections, inquiries, and complaints
No.RequirementProof on fileSignsBasis
NV 10.1A board map lists which Nevada body licenses each clinician and the cosmetology establishment.Board map kept with the authority memoPractice managerOur reading
NV 10.2A response binder holds Audits 1 to 9 in order, ready to copy.The binder, with an index dated at each reviewPhysician ownerOur reading
NV 10.3Any inquiry is routed to the physician owner and Nevada counsel the day it arrives.Inquiry log with date received and response deadlinePractice managerNot addressed
NV 10.4For each chart a complaint names, the assessment, order, supervision record, and consent are pulled and checked before a reply.Chart review worksheet per complaintOrdering practitioner; counselOur reading
NV 10.5A licensee named in a complaint has notified their professional liability carrier if the policy requires it.Carrier notice copyNamed licenseeNot addressed
NV 10.6After any finding, the affected audit is re-run and the fix documented.Corrective action note referencing the NV line numbersPhysician ownerOur reading

Which Audit Lines Matter Most for Your Nevada Practice Model?

Every clinic runs all ten audits, but the weak lines depend on staffing. Start with yours.

  • Physician-owned, physician-injected. Ownership and orders are usually clean. Focus on NV 3.4 and NV 5.6 (orders dated before treatment), NV 7.1 and NV 7.2 (drug control), and NV 6.1 if the clinic owns devices.
  • Physician-owned, RN injectors. The supervision lines carry the risk: NV 2.2 and NV 2.3 for direct supervision, NV 3.7 so the RN never performs the authorizing assessment, and NV 2.6 if PAs write the RN orders.
  • Remote telehealth assessments. NV 3.3 for the Nevada license, then NV 2.2 again, because a remote order does not supply direct supervision during the session.
  • APRN-led clinic. NV 2.4 for independent practice authority and NV 1.5 for the ownership opinion. Our record treats the APRN as a full injector and is silent on APRN ownership.
  • Clinic with advanced estheticians. NV 2.7 and NV 6.4, with the 60/60 test applied to every session, and NV 6.5 for the ablative bar.
  • Combined facial and medical clinic. NV 1.6 for the cosmetological establishment license, NV 6.6 to keep basic estheticians away from devices, and NV 4.3 to keep them off the injectables schedule.
  • Investor-funded clinic. NV 1.2 through NV 1.4 and NV 1.8, since the record reads Nevada's corporate practice rules as requiring the medical entity to stay physician-owned.

What Should You Confirm With a Nevada Board Before Relying on It?

These are the points where our Nevada record is silent or its sections do not fully line up. Each appears in an audit line labelled Our reading or Not addressed.

  • Direct supervision for RN injectors. The grid uses the letter D. The record gives no on-site, response-time, or distance rule (NV 2.3).
  • PAs as ordering practitioners for RN injectables. The IV section names physicians, APRNs, and PAs; the medical director section names physicians and independent-practice APRNs (NV 2.6).
  • The PA's physician relationship and how it must be documented (NV 2.5).
  • How an APRN obtains independent practice authority, and what an APRN without it must do (NV 2.4).
  • APRN ownership of a practice offering injectables (NV 1.5).
  • Standing orders and protocols for cosmetic injectables (NV 3.6).
  • How NRS 644A.545 supervision applies to microneedling and medium-depth peels, as distinct from nonablative device work.
  • Consent, retention, storage, emergency planning, and advertising, none of which the record addresses specifically for med spas (Audits 5, 7, 8, and 9).
  • Board disciplinary grounds and cosmetology penalties, which the record does not list (Audit 10).

For any of these, a written question to the relevant board, with Nevada health care counsel reviewing the answer, is the safest step before you build a schedule around it. More Nevada guides are on the Nevada med spa compliance hub.

Nevada Med Spa Checklist FAQ

Is there a Nevada med spa license? + −
No. Our record finds no medical spa license or registration category in Nevada and no Board of Medical Examiners med spa registry. A facility that offers esthetics needs a cosmetological establishment license under NRS 644A.600, and the medical side runs through a physician-owned professional entity under NRS chapter 89.
Can a registered nurse inject in a Nevada med spa without a doctor in the building? + −
Our record does not answer the building question. The Board of Nursing grid puts cosmetic injectables within RN scope only under direct supervision, after a qualified practitioner has assessed the patient and ordered the treatment. The record sets no on-site or response-time rule, so name a supervisor who is present or immediately reachable.
Who can supervise a Nevada advanced esthetician? + −
Only a health care professional as NRS 453C.030 defines it: a physician, a physician assistant, or an APRN. A registered nurse or LPN does not qualify. The supervisor must be reachable in real time and stay within 60 miles or 60 minutes, able to give in-person care if problems arise.
Does a Nevada med spa have to be owned by a physician? + −
Our record says yes for a med spa that practices medicine. Under NRS 89.070 and 89.050(2)(b), a medical professional entity may issue ownership only to licensed professionals rendering that service. Outside capital usually enters through a management services company that does not own the medical entity.
Can a Nevada med spa host a filler event at a hotel or private home? + −
Not for filler. NRS 629.086 allows dermal and soft-tissue filler injection only at a medical facility or a licensed provider's office, and a violation is a misdemeanor. Our record does not extend that location rule to neuromodulators, but a venue unlawful for filler is a poor choice for any injection.
Does Nevada set med spa rules for consent forms, record retention, or advertising? + −
Not specifically. Our Nevada record does not address med spa consent forms, a retention period, or advertising rules. It does make holding oneself out as practicing medicine without a license part of the NRS 630.400 offense. This checklist marks the other items as house standards, not Nevada law.
What is the penalty for unlicensed injections in Nevada? + −
Practicing medicine without a license is a category D felony, or category C if substantial bodily harm results, under NRS 630.400, and the Board of Medical Examiners may add cease-and-desist orders, citations, and fines up to $5,000 per violation. Unauthorized filler injection is also a misdemeanor under NRS 629.086.

MedSpa Standards publishes this checklist as general information, not legal or medical advice. In Nevada, questions about injection scope, orders, supervision, and esthetician practice are decided by the Nevada State Board of Nursing, the Nevada Board of Medical Examiners, and the cosmetology licensing authority under NRS 644A, and statutes and board decisions change. Confirm each clinician's position with their own board, and have a Nevada health care attorney review any ownership structure, management agreement, or staffing model before it goes live.

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