Utah GLP-1 Med Spa Compliance Rules 2026

Search Utah Code for semaglutide, tirzepatide or GLP-1 and you will find nothing. That is not a gap, and it is not permission. It means a Utah weight-loss programme is governed by four ordinary bodies of law at once: the Medical Practice Act, the Nurse Practice Act, DOPL's cosmetic supervision provisions, and federal drug law.

This guide is Utah only. The general mechanics — what a GLP-1 programme is, why the good faith exam exists, how titration and monitoring work as a clinical matter — belong to our national GLP-1 med spa compliance guide, and we will not restate it here. Everything below is about what Utah law does with those mechanics, and the primary sources sit on our Utah med spa regulations reference.

Utah Has No GLP-1 Rule — Which Makes the General Law Do All the Work

What Utah actually regulates

Utah regulates people and premises, not molecules. There is no weight-management rule, no obesity-treatment licence, and no DOPL bulletin naming a GLP-1 agonist. We looked and could not find one, and we would rather tell you the state is silent than manufacture a requirement.

Every question a weight-loss programme raises therefore resolves against general law. Prescribing a GLP-1 is prescribing a prescription drug, which is the practice of medicine under Chapter 67 unless another practice act authorises it. Administering it by injection is a nursing act under Chapter 31b unless the person doing it holds some other licence that reaches. Buying it is a pharmacy question under Chapter 17b and a federal question under the Food, Drug, and Cosmetic Act.

Who the regulators are

One division does almost all of the work. The Utah Division of Professional Licensing — DOPL — sits inside the Utah Department of Commerce and licenses physicians, nurses, physician assistants, pharmacists and pharmacies alike. Note the name: it was renamed from the Division of Occupational and Professional Licensing effective 4 May 2022, and a great deal of still-current material carries the old title. That is not evidence you are reading a superseded document.

Underneath DOPL sit the profession boards that will actually hear a complaint about your programme. The Utah Physicians Licensing Board is created at 58-67-201 and the Utah Board of Nursing at 58-31b-201. For sourcing, the relevant body is the Utah State Board of Pharmacy, created at 58-17b-201: Utah's Pharmacy Practice Act defines the practice of pharmacy to include compounding, and DOPL licenses pharmacies — including out-of-state mail-service pharmacies — in collaboration with that board. If your compounded vials arrive by courier from another state, that board's licensing regime is the one that decides whether the sender was allowed to send them.

Who Can Prescribe a GLP-1 in Utah: The Direct Verdicts

Three licence types, and no others. Each row is explained below.

Physicians — yes, on their own authority

Verdict: yes. An MD licensed under the Utah Medical Practice Act at Chapter 67, or a DO under the Utah Osteopathic Medical Practice Act at Chapter 68, may evaluate, diagnose and prescribe a GLP-1 for an appropriate indication. Utah imposes no obesity-medicine credential, no additional certification and no minimum training hours before a physician does so. The constraint is the standard of care, not a licensing box.

Physician assistants — yes, on a collaboration ladder

Verdict: yes, with a collaboration duty that shrinks as experience grows. Utah's framework at 58-70a-307 is graduated rather than fixed. Below 4,000 hours of post-graduate clinical experience, a PA must collaborate with a physician under written practice-level policies. Between 4,000 and 10,000 hours, the PA must enter a written collaborative agreement with a physician or with a PA holding over 10,000 hours in the same speciality. Above 10,000 hours, the written agreement requirement falls away entirely.

Two things practices get wrong. The ladder is measured in hours of post-graduate practice, not years employed, so it has to be evidenced rather than asserted. And a PA who has cleared 10,000 hours is free of the collaboration requirement while still not being a supervisor for any purpose Utah recognises — different statutes, different questions.

Registered nurses — no, and the line is bright

Verdict: no. Prescribing is not in the registered nursing scope in Utah. An RN who selects the drug, sets the starting dose, or decides that this month's dose goes up is prescribing, whatever the internal job title says. The full RN verdict — what they may do, which is a great deal — has its own section below.

Utah's APRN Practice Authority, Verified Rather Than Assumed

This is the hinge of the whole article, and it is worth doing precisely rather than repeating a headline.

What Senate Bill 36 actually did

Governor Spencer Cox signed Senate Bill 36 in March 2023, making Utah the 27th state to adopt full practice authority for nurse practitioners. The operative change was the elimination of the state-mandated contract with a physician that had been a condition of APRN licensure, together with the removal of the pre-conditions that 58-31b-803 had previously attached to prescribing or administering a Schedule II controlled substance.

Describe it carefully. Section 58-31b-803 was not deleted; it survives under the heading Advanced practice registered nurse prescriptive authority, with the restrictions stripped out. An APRN practising within their population focus needs no collaborative agreement, supervising physician or chart-review arrangement to evaluate a patient, diagnose obesity or a related metabolic condition, prescribe a GLP-1 and manage the titration. A vendor telling you a Utah nurse practitioner needs a collaborating physician is quoting law repealed three years ago.

Controlled substances — a real condition that does not reach a GLP-1

A residual controlled-substance layer remains, worth stating accurately so nobody over-reads it. An APRN prescribing controlled substances still needs a separate Utah controlled substance licence and carries additional continuing-education obligations tied to opioid prescribing and substance use disorder treatment under 58-37-6.5. Certified registered nurse anaesthetists are expressly outside the prescriptive authority section.

None of it touches a weight-loss programme. Semaglutide and tirzepatide are not controlled substances, so the controlled substance licence, the opioid CE requirement and the CRNA carve-out are all beside the point for a GLP-1 clinic. We flag them only because operators researching Utah APRN authority meet these provisions first and conclude, wrongly, that some extra credential is needed.

The post-licensure hours question — where the requirement really lives

Utah does impose a post-licensure supervised-practice framework on some APRNs, and it is regularly misquoted as applying to all of them. Under the Nurse Practice Act Rule at R156-31b-302e, the substantial hours requirement — 4,000 hours in total, of which DOPL credits 1,000 for an approved graduate programme and the remaining 3,000 must be completed after the national certification examination, including supervised clinical practice — attaches to the psychiatric mental health nursing specialty.

Verdict: a family, adult-gerontology or women's health nurse practitioner running a Utah weight-loss programme is not subject to that framework. Outside the psychiatric specialty, no generally applicable post-licensure supervised-hours condition stands between a newly licensed Utah APRN and independent prescribing. Hour allocations in R156-31b are amended from time to time, so confirm the current rule with DOPL if a specific licensee's status matters to a hiring decision.

The word that quietly does the work: unrestricted

Full practice authority describes what a clean licence permits. It says nothing about a licence carrying probationary terms or a stipulated limitation — and that distinction is decisive next, because Utah's supervisor definition turns on the word unrestricted. A nurse practitioner may lawfully prescribe while being ineligible to supervise anybody. Verify status on DOPL's public licence lookup rather than accepting a number on a CV.

Why One Person Can Hold Both Ends of a Utah Weight-Loss Programme

Here is the commercially important consequence, and the reason Utah is a genuinely different market.

The supervisor definition at 58-1-505

Utah Code 58-1-505 defines a cosmetic medical procedure supervisor narrowly, and there are exactly two ways to qualify. The first is a physician holding an unrestricted licence under Chapter 67 or Chapter 68, acting within the scope of the practice of medicine. The second is an advanced practice registered nurse holding an unrestricted licence under the Nurse Practice Act at Chapter 31b. Nobody else qualifies — not a physician assistant however senior, not a registered nurse, not an owner. The statute also forecloses the obvious workaround: the supervisory role may be delegated only to another individual who is themselves qualified as a supervisor.

The org-chart consequence

Put the two provisions side by side. The Nurse Practice Act, post-SB 36, lets a Utah APRN prescribe a GLP-1 independently. Section 58-1-505 lets an APRN with an unrestricted licence stand as the supervisor behind delegated procedures. The same individual can therefore both write the prescription and hold the supervisory role that any delegated administration depends on.

Most states force you to buy two relationships: a prescriber, and a separately contracted medical director whose only real function is to satisfy a supervision statute. Utah does not. An APRN-led Utah weight-loss practice needs no physician in the structure at all — no collaborative agreement, no chart-review retainer, no medical director fee. That is a material difference in fixed cost and in launch speed, and it is the fact most worth verifying before signing a director contract someone has told you Utah requires. Our Utah injectables and delegation guide works the same two statutes through the neurotoxin side of the business.

The advertising provision that is narrower than the supervisor rule

One catch, and it is easy to miss because it lives in a different section. Utah Code 58-1-507 provides that, from 1 July 2013, a facility performing a cosmetic medical procedure may not advertise or hold itself out to the public as a medical spa, medical facility or medical clinic unless it has an individual on the premises while the procedure is performed who is licensed under Chapter 67, Chapter 68, or as an APRN under Chapter 31b practising as a nurse practitioner.

Read that against 58-1-505. The supervisor definition accepts any APRN with an unrestricted licence; the advertising provision names the nurse practitioner role specifically and adds a presence requirement tied to the moment of treatment. A practice calling itself a med spa, performing cosmetic procedures alongside weight loss, and running afternoons on remote oversight has an advertising problem even where its supervision is otherwise sound.

The Good Faith Exam: Utah Puts It in the Telehealth Statute

No Utah statute uses the phrase

Search Utah Code for good faith exam and you will not find it. The requirement is real anyway, arriving from two directions. A GLP-1 is a prescription drug, so a prescriber must establish the patient relationship and evaluate the patient to the ordinary standard of care before an order exists. And where the cosmetic supervision provisions apply, 58-1-506 independently requires the supervisor to have authorised the specific procedure for the specific patient.

Who may perform it

Verdict: a prescriber, and only a prescriber. A physician, an osteopathic physician, an APRN, or a PA working within 58-70a-307. Not an RN, an LPN, a medical assistant, a master esthetician, or a sales coordinator with a checklist. An RN may gather history, take vitals and record what the patient reports — useful nursing data collection, but not the evaluation. A chart showing only nursing data before a first dose shows a prescription written without one.

Telehealth: Utah writes a pre-prescribing duty into statute

Verdict: telehealth satisfies the requirement in Utah, subject to a statutory condition most states leave implicit. Utah Code 26B-4-704, in the Utah Telehealth Act, holds telehealth providers to the same standards of practice as traditional in-person settings, and requires a provider without an existing relationship to establish one during the encounter consistent with DOPL's standards, including disclosing licensure and credentials. DOPL's telehealth rule at R156-1-602 sits alongside it.

The provision worth pinning to the wall is this one: before providing treatment or prescribing a prescription drug, the provider must establish a diagnosis and identify underlying conditions and contraindications to the recommended treatment. Utah has legislated the substance of the good faith exam rather than leaving it to be inferred from the standard of care. For a GLP-1 that means a documented indication, and a documented consideration of the contraindications that actually matter for this drug class — personal or family history of medullary thyroid carcinoma or MEN 2, pancreatitis history, pregnancy or intent to conceive, gallbladder disease, severe gastrointestinal disease, and interacting therapy.

What an intake questionnaire is not

An asynchronous form that collects height, weight and a tick-list of denials, auto-approves against a rule and generates a prescription is not an encounter in which a diagnosis was established. It may be an efficient way to collect information a prescriber then uses — but the prescriber has to use it, and the chart has to show a clinician's judgement rather than a rule's output. A standing order pre-approving everyone who books is a record that no evaluation happened: standing orders authorise nursing tasks, they do not manufacture a patient-specific prescription.

What an RN May and May Not Do With a GLP-1 in Utah

This question decides your staffing model, and it has a cleaner answer than most operators expect — provided you notice which statute you are standing in.

The verdict under nursing law

Verdict: yes, an RN may administer a GLP-1 on a valid prescriber's order. The Nurse Practice Act defines administering as the direct application of a prescription drug to the body of a patient by another person, whether by injection or otherwise, and registered nursing acts expressly include implementing a strategy of care and evaluating responses to interventions. Administering a prescribed subcutaneous injection is core registered nursing. It requires no special credential and no delegation-group analysis — this authority comes from Chapter 31b directly.

Where delegation group A does and does not reach

Now the Utah-specific wrinkle, which we would rather flag than paper over. The delegation architecture at 58-1-506 — group A comprising the PA, the RN, the master esthetician and the electrologist for laser hair removal; group B the practical nurse, the esthetician and the medical assistant — governs cosmetic medical procedures. And 58-67-102 defines that term as the use of cosmetic medical devices for ablative or nonablative procedures, or the injection of medication or substance, including a neurotoxin or a filler, for cosmetic purposes.

Whether a weekly GLP-1 injection is an injection of medication for cosmetic purposes is genuinely unsettled, and we could not find a DOPL determination resolving it. A programme documenting a BMI-based indication and comorbidity management looks like ordinary medical treatment, in which case 58-1-506 is not the governing frame and the RN's authority rests on nursing law alone. A programme marketed on appearance, sold beside injectables and charted thinly looks far more like the cosmetic frame — and if that frame attaches, the RN must be a qualified group A member, which pulls in the supervisor's duty to verify training, an unrestricted licence and at least 80 hours of documented education under Subsection 58-1-506(2)(f)(iii) and R156-1-506.

Operating verdict: build to the stricter frame. The cosmetic requirements are a superset of the medical ones and cheap to satisfy. Verify the 80 hours, record the delegation-group determination in writing, and map the supervision tier service by service. Then the classification question never has to be answered under pressure.

The three things an RN may not do

Whichever frame applies, these do not move:

• Assess for the purpose of deciding treatment. Nursing assessment is real and belongs to the RN; deciding that this patient is a candidate for this drug is a prescriber's diagnostic act.
• Prescribe. Selecting the agent, the compounding source, or the starting dose is prescribing regardless of who signs afterwards.
• Independently adjust the dose. This is where good programmes actually fail. A patient tolerating 0.5 mg badly does not get held at 0.5 mg by the nurse's decision; a patient sailing through does not get moved to 1.0 mg because the calendar says so. Titration is a prescribing act. What an RN can lawfully work from is a prescriber-authorised, patient-specific titration plan written in advance with the decision points and the parameters spelled out — the difference between executing a clinician's plan and substituting your own.

Group B: LPNs, Estheticians and the Medical Assistant Question

The licensed practical nurse

Verdict: narrower than the RN, and narrower than group B membership suggests. The practical nurse is named in group B, which is more than several states allow, but two constraints bite. Group B carries indirect supervision: the supervisor must have authorised the procedure, given written instructions, and be present within the facility. Presence, not availability — covering from another location does not satisfy it. And the LPN scope is narrower than the RN's on precisely the independent-assessment dimension a GLP-1 follow-up depends on.

Estheticians, and the route list that settles it

Verdict: no, at either tier. An esthetician appears in group B and a master esthetician in group A, and neither listing is permission. Every group member must be acting within their respective scope of practice, and the practice of master esthetics at 58-11a-302.18 enumerates chemical exfoliation, microdermabrasion, dermaplaning, lymphatic massage and cosmetic medical devices for nonablative procedures. No drug therapy of any kind appears in it. Group membership sets the supervision tier for tasks the licensee could already perform; it does not enlarge a licence.

Nursing law supplies a supporting signal. The Nurse Practice Act framework defines routine medications by a closed list of routes — oral, sublingual, buccal, eye, ear, nasal, rectal and vaginal. Injection is not on it. Utah's drafters have declined to treat administration by injection as the low-risk category that lighter-touch personnel provisions are built around.

The medical assistant — genuinely unsettled, and we will not guess

Verdict: do not staff this model without written DOPL confirmation. The medical assistant is expressly named in group B, and 58-1-506 expressly contemplates that a delegate may satisfy the credential test by performing under the licence of the supervising physician and surgeon rather than by holding a Title 58 licence — which it has to, since Utah issues no medical assistant licence.

Read literally, that appears to permit delegating a cosmetic medical procedure to a qualified medical assistant under indirect supervision. The reading may well be wrong for an injectable drug: administering a prescription drug engages the Nurse Practice Act and pharmacy law independently of 58-1-506, and a weight-loss GLP-1 may not be a cosmetic medical procedure at all, in which case group B never enters the analysis and the medical assistant has no route. We could not verify DOPL's position against a primary source, and we will not assert a requirement we cannot cite. The downside of guessing wrong is a felony charge. Get it in writing.

Charting and Monitoring: What a Utah Chart Has to Answer

Utah publishes no GLP-1 charting rule. What it publishes are duties — the telehealth diagnosis duty at 26B-4-704, the patient-specific authorisation duty in every 58-1-506 supervision definition, and the ordinary standard of care — and each is proved or disproved by a document.

The prescriber's record

Every chart should answer four questions on its face: who evaluated, who prescribed, who administered, and under whose authority. Concretely: the prescriber's identity and licence type on the encounter; the indication and the measurements it rests on; the contraindications considered and excluded, named individually rather than as a blanket denial; consent covering off-label use and the class risks; and the order itself, naming product, strength, dose, route and frequency.

Titration and dose changes

Every dose change is a prescribing decision and needs a prescriber's fingerprint on it: who authorised the change, on what date, on the basis of which reported tolerance and which measured response. Where an RN executes a pre-authorised plan, the plan belongs in the chart — patient-specific, signed, decision points and hold criteria visible. A titration recorded only as a sequence of increasing numbers cannot show that a clinician decided anything.

The monitoring schedule

Decide the cadence in advance and write it down rather than reconstructing it from whatever the visits happened to capture: weight and BMI trajectory, blood pressure and pulse, gastrointestinal tolerance, hypoglycaemia risk where the patient is on other glucose-lowering therapy, gallbladder and pancreatitis red flags, injection-site findings, and the review point at which a non-responder is reassessed rather than escalated indefinitely. Our GLP-1 monitoring schedule template sets out an interval-by-interval structure, and the tirzepatide protocol guide covers where the dual agonist differs from semaglutide.

Adverse events and the call at 7pm

The commonest real-world failure is not a wrong dose — it is an unanswered call. Persistent vomiting, severe abdominal pain radiating to the back and signs of biliary disease each need a defined path to a prescriber within a defined time, and whoever answers the phone needs a written protocol naming the symptoms that escalate immediately. Record the event, the advice, who gave it and the outcome. Consent deserves the same discipline; our med spa consent forms guide covers what a defensible consent contains.

Sourcing: Compounded Semaglutide and Tirzepatide in 2026

This section is federal law. Utah adds a licensing layer on top, but whether a compounded GLP-1 may lawfully exist is answered in Washington, not Salt Lake City — and the answer has moved several times, so check the date on anything you read about it, including this.

The federal position as it actually stands

The shortages that made large-scale GLP-1 compounding lawful are over and have been for some time. The FDA declared the tirzepatide shortage resolved in December 2024 and the semaglutide shortage resolved in February 2025. The agency then wound down enforcement discretion on a published timetable: for tirzepatide, 18 February 2025 for 503A state-licensed pharmacies and 19 March 2025 for 503B outsourcing facilities; for semaglutide, 22 April 2025 for 503A and 22 May 2025 for 503B. The Outsourcing Facilities Association challenged both shortage determinations in federal court; preliminary injunctions were denied in each case and the deadlines held.

Enforcement followed: more than 55 FDA warning letters to online sellers of compounded GLP-1 products in September 2025, and a further 30 aimed at telehealth companies selling compounded semaglutide and tirzepatide in March 2026.

Then, on 30 April 2026, the agency proposed to exclude semaglutide, tirzepatide and liraglutide from the 503B bulk drug substances list, on the basis that there is no clinical need for outsourcing facilities to compound them from bulk substances absent a shortage. The comment period closed at the end of June 2026. As of this writing no final determination has been announced — the exclusion is a proposal, not yet a rule, and we will not describe it as one. If you are reading this later, that is the first thing to re-check.

503A versus 503B — what each may still supply

The distinction still matters and is still widely misdescribed. A 503A pharmacy compounds pursuant to a valid prescription for an identified individual patient. That has not been abolished; it has been returned to its narrow statutory basis, which requires a documented clinical need for that patient that the commercially available product cannot meet — a genuine excipient intolerance, or a strength no approved product provides. What 503A never permitted, and certainly does not now the shortages are resolved, is producing essentially a copy of an approved drug as a cheaper routine alternative, or supplying office stock.

A 503B outsourcing facility registers with the FDA, operates to CGMP standards, and may supply office stock without patient-specific prescriptions. That is the only lawful route to vials sitting in your fridge with nobody's name on them. Its ability to compound these three molecules from bulk substances is precisely what the April 2026 proposal targets. Our 503A versus 503B sourcing guide works through the diligence questions to put to a supplier.

The Utah layer: the Board of Pharmacy and the Class D licence

Federal compliance is necessary and not sufficient. Utah's Pharmacy Practice Act at Chapter 17b, administered by DOPL with the Utah State Board of Pharmacy, defines the practice of pharmacy to include compounding and requires pharmacies operating into Utah to be licensed here. Under the pharmacy rule at R156-17b, an out-of-state mail-service pharmacy shipping into Utah falls within the Class D classification, with a pharmacist-in-charge licensed where the pharmacy sits; applicants engaged in compounding must submit a recent inspection report as part of licensure.

Practical verdict: verify two licences, not one. Ask any out-of-state compounder for its Utah pharmacy licence number and its FDA registration status, and confirm both against the issuing regulators rather than a PDF the vendor emailed you.

The two traps that end careers rather than contracts

First, research use only. A grey market sells semaglutide, tirzepatide, retatrutide and assorted peptides labelled for research use only or not for human consumption, at prices that make the reason obvious. The FDA has issued warning letters to sellers whose advertising showed the products were intended for human use, and the labelling defeats nothing: administering an RUO substance to a patient is administering an unapproved drug. No Utah licence covers it.

Second, patient-supplied and personally imported product. A patient arriving with a vial bought online or brought back from abroad is not a sourcing solution. Personal importation of an unapproved drug is a federal question with narrow and largely inapplicable exceptions, and a clinician administering product of unverified provenance owns the outcome entirely — chain of custody is what makes an adverse event defensible, and there is none. Decline it, and document why.

Advertising a Utah Weight-Loss Programme Without Buying an Enforcement File

The label on the door

Return to 58-1-507. If your facility performs cosmetic medical procedures and calls itself a medical spa, medical facility or medical clinic, someone licensed under Chapter 67 or 68, or as an APRN practising as a nurse practitioner, must be on the premises while those procedures are performed. It is a marketing-copy problem with a staffing-rota answer, and the two are usually owned by different people who never compare notes.

Claims about the drug

The commonest exposure is not the licence on the wall but the language on the website. Guaranteed pound-loss figures, medically supervised where nobody supervises anything, FDA approved attached to a compounded preparation — that last one is both false and the exact claim the FDA has been writing letters about. A compounded drug is not an approved drug; it is one the FDA has not evaluated. Describing branded semaglutide and then quietly dispensing a compounded preparation is a bait-and-switch that adds a consumer-protection problem on top of the licensing one.

Before-and-afters, testimonials and staff titles

Use only your own patients' images, with specific written consent for the specific use, and make representative outcomes representative. Do not let a job title do work a licence cannot: weight-loss specialist and metabolic coach are marketing words, and DOPL reads the licence underneath rather than the business card.

Penalties, Enforcement, and the Build Order

What the exposure actually is

Utah grades unlicensed practice seriously. Under 58-67-503, a person who violates the unlawful conduct provisions of 58-67-501, or Subsection 58-1-501(1)(a) or (1)(c), is guilty of a third degree felony — and practising a profession that requires licensure without holding that licence sits squarely within 58-1-501. Administratively, 58-1-502 makes a violation a class A misdemeanour unless otherwise specified, and DOPL's director or designee may assess a fine of up to $1,000 for each instance of unlawful or unprofessional conduct.

Enforcement rarely stops with the person who pushed the plunger. The prescriber faces board discipline for an order written without an evaluation; a supervisor faces it for delegating outside the groups. And liability carriers commonly exclude acts outside the insured's scope, so an out-of-scope administration can be both the event causing a claim and the reason it is denied.

The build order for a Utah programme

In sequence: identify your prescriber and confirm the licence is current and unrestricted; if that prescriber is an APRN, recognise they can also hold the supervisor role and stop shopping for a physician you do not need; put the evaluation in a prescriber's hands and make 26B-4-704's diagnosis-and-contraindications duty visible in the chart; write patient-specific titration plans so the RN executes rather than decides; assign every staff member to a delegation group in writing and build to the stricter frame; document the 80 hours; verify your compounder's FDA status and its Utah pharmacy licence separately; audit your advertising against 58-1-507; and get written DOPL confirmation for anything genuinely unsettled.

None of that is exotic. Most of it is paperwork that either exists or does not on the day someone asks. If you would rather not assemble the protocols, screening checklists, consent forms and monitoring schedules from scratch, our library of med spa SOP and protocol templates covers the documentation behind every step above.

For more Utah-specific compliance guides as this cluster grows, browse the Utah med spa compliance hub.

This article is for informational purposes only and does not constitute legal or medical advice. Utah scope-of-practice, prescribing, delegation and pharmacy rules are administered by the Utah Division of Professional Licensing within the Department of Commerce, advised by the Physicians Licensing Board, the Board of Nursing and the Board of Pharmacy, and they change over time. Federal compounding policy for GLP-1 drugs has changed repeatedly since 2024 and the FDA's April 2026 proposal to exclude semaglutide, tirzepatide and liraglutide from the 503B bulks list had not been finalised when this was written. Where Utah's position is genuinely unsettled — most notably whether a weight-loss injection is a cosmetic medical procedure, and the medical assistant delegation question — we have said so rather than guessed. Confirm current requirements with DOPL and the FDA, and consult a Utah healthcare attorney before making staffing or sourcing decisions.

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