Who Can Inject Botox in Texas? 2026 Delegation Rules

"Who can inject Botox in Texas?" is a question where the wrong answer circulates faster than the right one — largely because Texas rewrote the governing rules in January 2025 and most guidance online still cites the repealed version. This guide works through the framework licence by licence, and flags the four places where Texas genuinely has not settled the point.

Three agencies matter: the Texas Medical Board (TMB), which owns the delegation framework; the Texas Board of Nursing (BON), which governs what a nurse may accept; and the Texas Department of Licensing and Regulation (TDLR), which licenses estheticians and cosmetologists. See also who can inject Botox across the United States and the Texas med spa compliance hub.

Injecting Botox Is the Practice of Medicine in Texas

Everything downstream depends on this classification, so start here rather than with job titles.

What 22 TAC §169.25 actually says

The operative rule is 22 Texas Administrative Code §169.25, "Other Delegation." In accordance with §157.001 of the Medical Practice Act, the board has determined the following to be the practice of medicine and capable of being properly delegated and supervised: nonsurgical medical cosmetic procedures, including but not limited to the injection of medication or substances for cosmetic purposes, colonic irrigation, and the use of a prescription medical device for cosmetic purposes.

Two consequences follow. No non-medical licence reaches an injection. And because these acts are delegable, the question is not who holds which credential; it is whether a valid delegation stands behind this injection, for this patient, today.

The rule most Texas guides still cite was repealed in January 2025

If a compliance binder or competitor blog post cites 22 TAC §193.17, it is describing a rule that no longer exists. Chapter 193 was repealed effective January 9, 2025 in a legislatively mandated rule review, and the nonsurgical cosmetic content moved to Chapter 169, Subchapter E — §§169.25 through 169.28. This is not a cosmetic renumbering; one substantive requirement changed, covered below.

What the 2025 Legislature did — and did not — change

Three bills from the 2025 regular session get quoted as though they govern injectables. Two do not, and the third is not law.

• HB 3749, "Jenifer's Law" — signed June 20, 2025, effective September 1, 2025, adding Occupations Code Chapter 172. It was introduced as a broad med spa bill covering cosmetic treatments, but the committee substitute stripped that out. As enacted it governs elective intravenous therapy only and says nothing about Botox or fillers.
• SB 378 — would have barred barbers and cosmetologists from incising the dermis or injecting. It passed both chambers and was vetoed on June 2, 2025. Any page presenting it as the 2026 rule is wrong.
• SB 2696 — would have required an occupational certificate for cosmetic injections. It passed the Senate and died in House committee.

So the Texas rules are the TMB's delegation rules, not a med spa statute. There is no Texas med spa licence and no med spa registration — TMB guidance confirms it registers pain management clinics, office-based anaesthesia and physician–PA jointly owned clinics, but not med spas. See our Texas med spa regulatory changes guide.

The Texas Delegation Framework: Where Non-Physician Authority Comes From

Texas non-physician injectors hold delegated authority, not independent authority — and delegation is a defined structure with named preconditions.

Occupations Code §157.001: the statutory hook

The enabling statute permits a physician to delegate a medical act to a qualified and properly trained person acting under the physician's supervision, provided the act can be safely performed in its customary manner. Subsection (b) is the sentence to memorise: the delegating physician remains responsible for the medical acts of the person performing the delegated act. Note what the statute conditions delegation on — training and supervision, not any particular licence. That is the source of two of the four unsettled questions below.

The four preconditions in §169.26

22 TAC §169.26, "General Standards," puts operational teeth on the statute. Before any delegated cosmetic injection, four things must be true.

1. Delegate training. Under §169.26(a)(1) the physician must ensure the individual is trained in techniques for the delegated act including pre-procedural care, post-procedural care and infection control; contraindications; and recognition and acute management of potential complications.
2. A signed protocol. Under §169.26(a)(2) the individual performing the act must sign and date a written protocol. Note who signs: the delegate. The physician's written order is a separate document.
3. Physician competence. Under §169.26(b) the physician must be appropriately trained in the act, or familiar with it and able to perform it to the standard of care.
4. A patient-specific evaluation. Under §169.26(c) a physician — or a PA or APRN acting under a physician's delegation — must establish a practitioner-patient relationship, maintain an adequate record under Chapter 163, disclose the identity and title of whoever will perform the act, and ensure a person trained in basic life support is present while the patient is onsite.

The written order under §169.27 and the notices under §169.28

§169.27 gives the physician a separate duty: either approve the facility's written order in writing, or develop their own. It must contain the identity of the delegating physician, patient selection criteria, a description of appropriate care, and procedures for common complications, serious injuries or emergencies including feedback to the delegating provider.

One myth to retire: it is often said that a Texas protocol must specify the delegate's qualifications and credentials. No Texas rule requires that — not §169.26, not §169.27(b), and not the repealed §193.17. What Texas does require is §169.28: every public area and treatment room must post the board's complaint notice and each delegating physician's name and Texas licence number, and everyone performing a delegated act must wear a name tag delineating their identity and credentials.

Quick Reference: Who May Inject Botox in Texas

Scan this, then read the section that applies to you.

Notice what the middle column omits: who evaluated the patient. That is what Texas investigators look at first.

Physicians and Physician Assistants

One role is the origin of all delegated authority; the other is the advanced practice role with the cleanest supervisory paperwork.

Physicians (MD / DO): the source of every delegation

Verdict: yes, on their own licence. A Texas-licensed physician may perform any injectable procedure within their training and the standard of care, and needs no delegation to do so. In most med spas the physician's real function is owning the clinical decisions — approving the §169.27 order, confirming each delegate's training, carrying or delegating the evaluation, and staying reachable. See Texas med spa medical director requirements.

Can a physician assistant inject Botox in Texas?

Verdict: yes, under a supervising physician. PA practice is governed by Occupations Code Chapter 204 and, since the January 2025 reorganisation, by 22 TAC Chapter 183 — not Chapter 185, which is now Surgical Assistants. Under §204.204 supervision must be continuous but does not require constant physical presence: if the physician is absent, the two must be able to reach each other easily by telephone or other telecommunication device.

Three requirements are frequently missed. The supervising physician must notify the TMB of intent to supervise, accept legal responsibility in writing, and receive board approval under §204.205 — a registration, not a handshake. Under 22 TAC §169.5 the delegation must be registered with the TMB within 30 days, and termination reported within 30 days. And because botulinum toxin is a dangerous drug, a PA who wants to order it needs a prescriptive authority agreement.

APRNs and Nurse Practitioners: Texas Runs on Prescriptive Authority Agreements

This is where Texas diverges most sharply from the states nurse injectors tend to move from. If you are relocating from Arizona, Colorado or Washington, assume nothing.

Can a nurse practitioner inject Botox in Texas?

Verdict: yes — but not independently. Texas is a restricted-practice state under the American Association of Nurse Practitioners' 2026 classification: state law requires career-long supervision, delegation or team management by another provider. There is no independent-practice pathway, however experienced the NP. An APRN may perform the pre-treatment evaluation and order the neurotoxin — §169.26(c) names PAs and APRNs alongside physicians for that step — but that authority comes through a prescriptive authority agreement, not the nursing licence. Every 2025 bill that would have loosened this died in committee.

What a prescriptive authority agreement must contain

Occupations Code §157.0512(e) requires the agreement to be in writing, signed and dated; to state the parties' names, addresses and professional licence numbers; to describe the practice and its locations; to identify the categories of drugs or devices that may or may not be prescribed; to set out plans for consultation, referral and patient emergencies; to describe the communication process; to designate any alternate supervising physicians; and to include a quality assurance and improvement plan with methods for documenting implementation. It must be reviewed annually, dated and signed — a rule, not a nicety, and the item practices most often skip.

Monthly meetings, chart review, and the seven-provider cap

The quality-assurance plan has two named components: chart review, with the number of charts determined by the physician and the APRN or PA, and periodic meetings that must cover patient care, changes in care plans and referral issues, must be documented, and must happen at least once a month.

Two clarifications, because both are commonly got wrong. There is no required chart-review percentage in Texas — a vendor quoting a fixed ten or twenty percent is inventing it, so set your own number and evidence it. And the monthly cadence does not step down; the old monthly-then-quarterly scheme was repealed by HB 278 in 2019, which also removed the face-to-face requirement. §157.0512(c) caps a physician at seven advanced practice providers, or the full-time equivalent. Our Texas nurse practitioner med spa playbook covers what this means for a nurse-led practice.

Registered Nurses: What Delegation Must Look Like — and What an RN May Not Do

RNs are the most common injector in Texas med spas, and the role most often documented badly. The nursing licence is real authority to administer; it is not authority to decide.

Can an RN inject Botox in Texas?

Verdict: yes, as a delegate. A Texas RN may administer botulinum toxin and dermal filler when a physician has delegated the act under §157.001, the RN meets the §169.26(a)(1) training conditions and has signed and dated a written protocol, and a physician, PA or APRN has evaluated that specific patient and ordered the treatment. Then the file has to prove it: documented training in facial and neck anatomy, product-specific technique, contraindications, infection control, and management of complications — vascular occlusion above all. See our references on neurotoxin dosing and reconstitution and Botox complications management.

What an RN may not do in Texas

• Perform the pre-treatment evaluation. The §169.26(c) list is closed at physician, PA and APRN. An RN who assesses the patient, decides they are a candidate and injects has removed the step that makes the injection lawful.
• Select the product or set the dose. Those are prescribing judgments; the order comes from the evaluating provider and is patient-specific.
• Hide behind the order. The Board of Nursing is explicit that nurses do not practise under a physician's licence, and that no order, policy or directive supersedes the nurse's own duty under the Nursing Practice Act. Accepting an unsafe assignment is independently disciplinable, and actual injury need not be established.

Licensed Vocational Nurses: Can an LVN Inject Botox in Texas?

This is the most-searched sub-question in Texas after the headline one, and the one where nearly every published answer — including our own earlier version of this page — has been more confident than the source material supports.

Can an LVN inject Botox in Texas?

Verdict: almost never defensible in practice — but there is no rule that says "no." That distinction matters, because a practice built on a misquoted prohibition is as exposed as one ignoring a real rule. The Texas Board of Nursing has not issued a categorical prohibition on LVN cosmetic injection. No position statement and no rule names botulinum toxin, dermal filler or cosmetic injection and forbids it to LVNs. What constrains the LVN is the structure of the licence and the delegation chain — genuinely severe, but a different argument from the one usually made.

What the Texas Board of Nursing does and does not say

The BON declines to publish task lists at all. Its guidance states that because each nurse has different background, knowledge and competence, the board maintains no all-purpose list of tasks every nurse can or cannot perform, and that the Nursing Practice Act and board rules do not specifically address cosmetic procedures. Nurses are directed to the Scope of Practice Decision-Making Model, an eight-question framework that replaced the six-step model in April 2019 and whose final question is LVN-specific: if you are an LVN, will adequate supervision be available?

The BON's stated limit is conditional: an LVN should not perform a cosmetic procedure if the LVN lacks the necessary preparation, knowledge, competency or skill; lacks an order; or lacks appropriate supervision. Two things make that absence meaningful rather than accidental. The BON does issue categorical prohibitions when it means to — LVNs cannot determine death, and medical screening exams are outside LVN scope. And in explaining supervision it uses an LVN administering Botox as its own worked example of a delegated medical act, an odd choice for something it considered prohibited.

Directed scope: the structural problem with an LVN injector

The real constraint is 22 TAC §217.11(2), which defines LVN practice as a directed scope under the supervision of an RN, APRN, PA, physician, podiatrist or dentist. The BON does not specify required physical proximity, but a licensed supervisor must be accessible at all times, at minimum telephonically. Position Statement 15.11 adds the test for a delegated medical act: demonstrated competence including the ability to respond to complications, documented education in the personnel file, jointly developed written policies reviewed annually, an order from a licensed practitioner, and available support.

Stack that on the TMB requirements and the LVN model needs two supervisory relationships running at once, one nursing and one medical, both evidenced — and an LVN can never perform the evaluation. Position Statement 15.11 also bars sub-delegation, so an NP-led practice cannot hand the injection down to an LVN. Our recommendation is unchanged even though the reasoning is: build your Texas injector roster from RNs, APRNs and PAs. If a specific LVN arrangement is genuinely under consideration, get a written scope determination from a Texas healthcare attorney.

Estheticians and Cosmetologists: The Two Most-Asked Questions in Texas

These are separate licences and separate questions. Texas answers both the same way, with one genuinely open flank operators should understand before someone else exploits it.

Can an esthetician inject Botox in Texas?

Verdict: no, not on the esthetician licence. TDLR's published Medspas at a Glance guidance is unambiguous: an esthetician, barber or cosmetology operator licence does not authorise the holder to use hypodermic needles to inject botulinum toxin — Botox is its named example — or other substances, even for cosmetic procedures. Its services table assigns Botox to the Texas Medical Board, and it closes the workaround: a physician cannot delegate cosmetology or barbering procedures, only medical ones. Our Texas esthetician and advanced skin scope guide maps that line for peels, microneedling and device work.

Can a cosmetologist do Botox in Texas?

Verdict: no, not on the cosmetology licence. The analysis is the same, because TDLR addresses both in one sentence: a cosmetology operator licence does not authorise using hypodermic needles to inject botulinum toxin or other substances. Nothing in the TDLR cosmetology rules creates an injectable privilege, and the Medical Board's classification of cosmetic injection as the practice of medicine sits above the cosmetology scheme entirely. The licence grants nothing — which does not make the conduct consequence-free. A cosmetologist injecting without a valid physician delegation is practising medicine without a licence, which Texas treats as a felony.

The unsettled part: the delegation door and the SB 378 veto

Here is the open flank, stated plainly because pretending it is closed helps nobody. Neither Occupations Code §157.001 nor 22 TAC §169.26 imposes a licensure floor on the delegate. The statute says "qualified and properly trained person"; the rule imposes training, protocol and supervision conditions. On the face of the text, a physician delegating to an esthetician is delegating to a person, not to a cosmetology licence — and the TDLR prohibition speaks to what the licence authorises, a different proposition.

The Legislature noticed. SB 378 was written to close exactly this, and its bill analysis observed that Texas statute is silent on both the TMB's and TDLR's authority to pursue a licensed esthetician or cosmetologist who crosses the boundary. The bill passed both chambers and was vetoed on June 2, 2025. The gap therefore remains open, and Texas has published no interpretive guidance resolving it. We are not suggesting you walk through that door — a physician delegating to someone unqualified is disciplinable under §164.053(a)(9) regardless, and carriers exclude out-of-scope acts. But treat any page claiming SB 378 "closed the Texas med spa loophole" as describing a bill that never became law.

Medical Assistants and Unlicensed Staff

The MA question deserves the same precision as the LVN one, and for the same reason: the popular answer is right in outcome and wrong in reasoning, which makes it fragile.

Can a medical assistant inject Botox in Texas?

Verdict: no as a practical matter — but again, not because a rule names medical assistants. Texas has no medical assistant licensure scheme and no rule listing MAs as prohibited injectors. What is true is stronger: the MA credential confers no authority whatsoever. Any authority an MA has is borrowed from a physician's delegation, which collapses the analysis back into §157.001 and §169.26 — and back onto the physician. The same is true of any unlicensed staff member, including the practice owner.

Three things sit between the statute and an MA holding a syringe, and any one is enough. The physician remains responsible under §157.001(b), so the act is legally the physician's. §164.053(a)(9) makes it disciplinable to delegate to someone not qualified by training, experience, or licensure — licensure is named there even though it is absent from §157.001. And the MA can never perform the §169.26(c) evaluation, so the workflow has no lawful order behind it.

The delegate's own exposure under §157.005

Delegation does not make the delegate personally untouchable. Occupations Code §157.005 is a limited safe harbour: a person performing a delegated act is not practising medicine without a licence unless the person acts with knowledge that the delegation, and the action taken under it, is a violation. The protection evaporates the moment the delegate knows the arrangement is improper — and unlicensed practice of medicine in Texas is a third-degree felony.

The Good-Faith Exam and Who May Perform It in Texas

This is the step practices compress for throughput and the step regulators most want documented. It is also the one the January 2025 rewrite changed most.

Texas does not use the phrase "good-faith exam"

Search the governing Texas provisions for "good faith exam" and you will not find it. It is industry shorthand; the Texas term is establish a practitioner-patient relationship, in §169.26(c)(1). The requirement is real — only the vocabulary is borrowed.

Here is the change worth knowing, stated honestly. The repealed §193.17 spelled the step out: take a history, perform an appropriate physical examination, make a diagnosis. The replacement substitutes the undefined phrase "establish a practitioner-patient relationship," which is not defined in §169.1 or Chapter 163. Whether that narrows the substantive obligation is genuinely unsettled, and the TMB has published no guidance on it. Our read is that it does not: §169.26(c)(2) requires a Chapter 163 record, and 22 TAC §163.1 requires that record to contain relevant history, physical examination findings, an assessment, a clinical impression and a diagnosis. You cannot produce a compliant chart without a compliant exam.

The closed list: physician, PA, or APRN only

Whatever it is called, §169.26(c) names exactly three roles that may perform it: a physician, or a physician assistant or advanced practice registered nurse acting under the delegation of a physician. The list is closed. An RN may not establish the practitioner-patient relationship, and neither may an LVN, an esthetician, a medical assistant or a practice owner. This is the most common structural failure in Texas med spas, and what the TMB's disciplinary orders describe.

Telemedicine, and why a standing order will not substitute

The evaluation may be performed by telemedicine, and Texas is more permissive here than operators expect. Under Occupations Code §111.005(a)(3) a valid practitioner-patient relationship may be established through synchronous audiovisual interaction, or asynchronous store-and-forward technology combined with synchronous audio. A prior in-person visit is not required: §111.006(b) directs the boards to allow relationships established this way, and §111.007 bars a higher standard of care for telemedicine. A PA or APRN under delegation can carry the televisit.

What Texas will not accept is a blanket standing order in place of a patient-specific evaluation, and the rules foreclose it three ways. Section 169.26(c)(1) requires the relationship to be established prior to performance of the delegated act, without exception. The §169.1 definition of a standing delegation order closes the drug list to a narrow set — oral contraceptives, certain topicals and anti-parasitics, antibiotics for venereal disease, immunisations — and neither botulinum toxin nor dermal filler is on it. And "standing medical orders" are defined as being used after patients have been evaluated.

Supervision in Texas: On-Site, Off-Site, Documentation and Chart Review

"Supervision" does a lot of unexamined work in med spa conversations. In Texas it has a specific, testable meaning — and one very common misreading.

On-site or immediately available: the §169.26(d) standard

For a delegated cosmetic injection, 22 TAC §169.26(d) gives the practice a choice: a physician, PA or APRN must either be onsite during the procedure, or be immediately available for emergency consultation in the event of an adverse outcome, and if necessary the physician must be able to conduct an emergency appointment with the patient.

On-site physician presence is not required in Texas. That is the most misquoted point in this area, and the misquote runs both ways. Off-site oversight is permitted; absentee oversight is not. The rule sets no distance or response time, so the standard is judged after the fact: can the provider be reached during treatment hours, is there a named alternate, and is the arrangement written into the protocol? A physician covering fourteen locations on paper is not immediately available, and inadequate supervision is a stand-alone disciplinary ground under §164.053(a)(8). Note too that §169.26(c)(4) separately requires a person trained in basic life support onsite. See our guides to remote and telehealth medical director arrangements and medical director duties and responsibilities.

Chart review, quality assurance, and the §169.25(b) carve-out

Chart review in Texas is not a general med spa requirement — it attaches to the prescriptive authority agreement under §157.0512, alongside the documented monthly meetings. If your practice has an APRN or a prescribing PA, you owe a documented chart-review programme and a meeting log, with an explicit number set in the PAA.

One further ambiguity to flag rather than paper over. Section 169.25(b) says the subchapter does not include delegations specifically authorised and described in Chapter 157 of the Act, or procedures performed at a physician's practice by the physician, PA or APRN acting under the physician's supervision. The drafting is awkward and the TMB has published no interpretive guidance on how far that carve-out reaches. We do not think a Texas practice should rely on it. TMB's own med spa guidance describes the on-site-or-immediately-available standard as applying to med spa services generally, so satisfy §§169.26 to 169.28 regardless.

What the Delegating Physician Is Liable For

Texas physicians occasionally sign a med spa delegation the way one signs a gym waiver. The statute is not built that way, and the disciplinary record proves it.

Responsibility does not transfer — it accumulates

Section 157.001(b) is one sentence: the delegating physician remains responsible for the medical acts of the person performing the delegated acts. There is no proportionality, no carve-out for absence, and no reduction for a modest retainer. For PAs, §204.207 adds that the employing entity shares the responsibility, so the business does not shield the physician. See med spa medical director liability.

The disciplinary hooks: §164.053 and aiding unlicensed practice

Three provisions do most of the work when the TMB acts against a med spa physician. §164.053(a)(8) — failure to adequately supervise those acting under the physician's supervision. §164.053(a)(9) — delegating professional medical responsibility to a person the physician knows or has reason to know is not qualified by training, experience or licensure. Both feed §164.052(a)(5), unprofessional conduct. Then there is §164.052(a)(17): aiding or abetting the practice of medicine by a person or corporation not licensed to practise medicine — the reason a name-only medical director role is not low-risk side income, and the doctrinal core of Texas's corporate practice of medicine position.

Texas Enforcement Patterns and Penalties for Out-of-Scope Injection

You do not have to speculate about what gets enforced in Texas. The TMB publishes its disciplinary actions, and the med spa fact patterns repeat.

What the Texas Medical Board has actually disciplined physicians for

The pattern is the §169.26(c) failure almost every time. In March 2024 the board publicly reprimanded a Frisco physician who, acting as a med spa medical director, improperly delegated patient examinations and follow-up care to a registered nurse not qualified to provide that level of care, with no meaningful oversight over roughly two years — 24 hours of continuing education, the medical jurisprudence exam, and a $5,000 administrative penalty. In June 2024 it reprimanded a physician who failed to supervise her delegates and aided unlicensed practice by allowing a registered nurse to prescribe independently. In August 2024 a Dallas physician's licence was restricted and he was barred from supervising PAs and APRNs after failing to supervise a med spa owner who was neither licensed nor qualified to make treatment decisions, in a case where a patient died.

Cease-and-desist orders, and criminal and civil exposure

The board also acts against unlicensed operators directly. Recent Texas cease-and-desist orders have named unlicensed operators for cosmetic procedures performed without a physician having evaluated the patient; for Botox services without adequate supervision by a medical director or midlevel practitioner; for offering microneedling and Botox without a physician licence. Every entry maps to a named provision — no §169.26(c) evaluation, no adequate §169.26(d) availability, no valid §157.001 delegation. See our guide to common med spa compliance violations.

Texas stacks three penalty tracks. Criminal: under §165.152, practising medicine in violation of the subtitle is an offence, each day is a separate offence, and it is a felony of the third degree, with forfeiture of all licence rights on conviction. Civil: under §165.101 the attorney general may sue for $1,000 per violation, each day separate. Administrative: under §165.003 the board may impose up to $5,000 per violation, and under §§165.051–165.052 it may seek an injunction or issue a cease-and-desist order. Then there is insurance: carriers commonly exclude out-of-scope acts, so the injection can be both the claim and the reason it is uncovered.

The Delegation File: Documentation a Texas Practice Should Hold

Compliance in Texas is evidentiary. Every requirement above is provable or it is not, and "we always do that" is not evidence.

The practice-level and per-provider file

• The written order under §169.27 — approved in writing by the delegating physician, or the physician's own, containing all four required elements.
• Signed and dated protocols from each individual performing delegated acts per §169.26(a)(2), dated before their first treated patient.
• Prescriptive authority agreements for each APRN and prescribing PA, with the annual review dated and signed, the QA plan, the monthly meeting log, the chart-review record, and a count confirming you are inside the seven-provider cap.
• TMB registrations — supervising physician approval for PAs under §204.205, and delegation registration and termination notices within 30 days under §169.5.
• Training and competency records for every injector, mapped to the three §169.26(a)(1) categories rather than to a generic course title.
• Current licence verifications, BLS certification for whoever covers the treatment day, and the posted §169.28 notices and name tags.

The per-patient chart, and what auditors find missing first

Per patient, the chart must satisfy §163.1: reason for the encounter, relevant history, physical examination findings, an assessment, clinical impression and diagnosis, and a plan of care with the medication and dose. Add the identity and title of the injector, disclosed beforehand under §169.26(c)(3), and consent naming both the injector and the delegating physician — our med spa consent forms guide covers that disclosure.

Four things go missing before anything else: evidence that a physician, PA or APRN evaluated this patient before this treatment; the monthly PAA meeting log; training records mapped to complication management rather than a generic certificate; and a written order naming the products actually in the fridge.

This article is for informational purposes only and does not constitute legal or medical advice. Texas delegation, scope-of-practice and licensing rules are administered by several agencies, changed materially in January 2025, and can change again. Confirm current requirements with the Texas Medical Board, the Texas Board of Nursing and the Texas Department of Licensing and Regulation, and consult a Texas healthcare attorney before making staffing decisions.