Montana Med Spa Regulations
Montana has no medical-spa-specific statute; med spas run under the general Medical Practice Act and Nurse Practice Act, so only physicians, PAs, APRNs, and RNs (under a prescriber's order) may perform injections and other medical cosmetic procedures, non-physicians may own the facility, and estheticians are confined to noninvasive skin care.
Last reviewed: 2026-07-21
Who can inject Botox and dermal fillers in Montana?
Montana has no med-spa-specific injectables statute; administering neurotoxins or dermal fillers is the practice of medicine or nursing, so it may be performed only by a physician (MD/DO), a physician assistant, or an advanced practice registered nurse, or by a registered nurse administering the drug under an authorized prescriber's order. The Board of Barbers and Cosmetologists confirms that injectables fall outside every cosmetology and esthetics license and that a qualified health care provider must prescribe the product and either provide or appropriately supervise the injection.
Source: Montana Board of Barbers & Cosmetologists — Medical Spa FAQ (2024), Q5 (injectables outside cosmetology scope; provider must prescribe), MCA 37-3-102 (definition of 'practice of medicine'), MCA 37-8-102 (practice of professional nursing includes administering prescribed medications)
Does Montana require a good-faith exam before treatment?
Montana has no cosmetic-specific 'good faith exam' statute, but because injectables and other cosmetic medical services must be prescribed and provided within the standard of care, the general prescribing rule applies: a provider must establish a provider-patient relationship and obtain a medical history and examination sufficient for diagnosis and treatment before treating or issuing prescriptions (ARM 24.156.813). That relationship may be established through telemedicine when the standard of care does not require an in-person encounter, so a properly conducted telehealth evaluation is permitted.
Source: ARM 24.156.813 (Board of Medical Examiners — telemedicine practice requirements; establish relationship and obtain history before treating/prescribing), MCA 37-3-102 ('practice of medicine' expressly includes telemedicine)
Does a med spa in Montana need a medical director?
Montana imposes no statutory 'medical director' requirement for medical spas, and med spas as facilities are not licensed by any professional board. However, any medical or injectable service must be provided or appropriately supervised by a qualified health care provider who also prescribes the injectable, so a physician (or other authorized prescriber such as an APRN or PA) must stand behind the medical services even though no formal medical-director designation is mandated by statute or rule.
Can a non-physician own a med spa in Montana?
Montana does not bar lay ownership of a medical spa — the Board of Barbers and Cosmetologists expressly states that 'a person not licensed by a professional licensing board may own a medical spa.' There is no strict corporate-practice-of-medicine ownership prohibition applied to med spas; the operative limits are that only appropriately licensed professionals may perform or supervise the medical services and that no one may impersonate or falsely advertise as a licensed physician or nurse.
What supervision does Montana require for med-spa procedures?
Supervision in Montana is provider-type-specific rather than med-spa-specific. A physician assistant with fewer than 8,000 hours of postgraduate clinical experience must practice under a written collaborative agreement with a collaborating physician (or an experienced PA), who gives direction and guidance (MCA 37-20-203). APRNs are not required to have a collaborative agreement or physician supervision to practice — the 2025 recodification removed the brief 2023 two-year collaborative-agreement requirement, and the term no longer appears in the nursing definitions. Registered nurses and medical assistants act under an authorized prescriber's orders/delegation, and the Board's med-spa FAQ requires a qualified health care provider to provide or appropriately supervise all medical procedures.
Source: MCA 37-20-203 (PA licensing — collaborative agreements; <8,000-hour threshold), MCA 37-8-409 (APRN — when a professional nurse may practice; no supervision mandate), Montana Board of Barbers & Cosmetologists — Medical Spa FAQ (2024) (provider must provide/appropriately supervise medical procedures)
What can an esthetician legally do in Montana?
Estheticians and all other Board of Barbers and Cosmetologists licensees are limited to noninvasive procedures confined to the nonliving stratum corneum. They may perform facials, exfoliation, waxing/epilation, light therapies, and — with proper training — microdermabrasion and chemical peels, but they may not administer injectables, perform laser hair removal (deemed surgery), or perform any procedure that compromises the germinative or basal layers of the skin.
Who can operate a cosmetic laser in Montana?
Montana treats laser hair removal as 'surgery' — defined as any procedure in which human tissue is cut or altered by mechanical or energy forms, including electrical or laser energy — and ARM 24.121.1509(7) prohibits Board of Barbers and Cosmetologists licensees from performing it. There is no dedicated laser-operator license; energy-based cosmetic procedures are the practice of medicine/nursing and must be performed by, or delegated and supervised by, a qualified health care provider (physician, PA, or APRN), with RNs or technicians operating only under a provider's direction and supervision.
What are the rules for IV therapy and vitamin drips in Montana?
IV therapy (for example vitamin or hydration drips) is not addressed by a med-spa-specific statute; it is the practice of nursing and medicine. It must be ordered by an authorized prescriber (physician, PA, or APRN) and is administered by a registered nurse within the practice of professional nursing (MCA 37-8-102). It falls outside every esthetics/cosmetology license; medical assistants may administer IV medications or blood products only under a physician's onsite/direct supervision.
Source: MCA 37-8-102 (practice of professional nursing includes administration of prescribed medications/treatments), Montana Board of Barbers & Cosmetologists — Medical Spa FAQ (2024) (medical procedures require a qualified health care provider; outside cosmetology scope)
Does a med spa have to register or hold a license in Montana?
Montana has no medical-spa license or registration — the Board states that 'medical spas, as facilities, are not regulated by professional licensing boards.' Depending on the procedures offered, the Department of Public Health and Human Services may have jurisdiction, and any portion of the premises where cosmetology or esthetics is practiced must be licensed as a salon/shop and physically separated from the medical treatment area by a full-length partition.
What are the penalties for practicing outside scope in Montana?
Practicing medicine or nursing without the required license is enforced under MCA 37-1-109: the Department of Labor and Industry may issue a cease-and-desist order for practicing without the required license, a board screening panel or the Department may assess a civil penalty of up to $1,000 per day for each day the order is violated, and the state may seek a district-court injunction. Knowingly or purposely violating such an injunction is a felony under 46-18-213. (The former misdemeanor unlicensed-practice statutes — 37-3-325 and 37-1-317 — were repealed in the 2023 professional-licensing recodification.)
Source: MCA 37-1-109 (cease and desist -- injunction -- criminal penalties)
Cite this page
Build a compliant med spa faster
Board-ready SOPs and compliance checklists mapped to these requirements.
SOP kits by topic: Injectables · Skin & Laser · Operations & Compliance · Body & Wellness · Weight Loss · Hormone Therapy · Emergency Protocols
This information is provided for general educational purposes only and is not legal advice. Regulations change — verify current requirements with your state medical/nursing board before acting.