Appearance Enhancement Service vs. Med Spa Service

Med spa service providers generally offer a range of spa and appearance enhancement services, as well as medical procedures.

Appearance enhancement services are non-medical procedures, such as facials and eyelash extensions, that can be performed by individuals with a cosmetology license issued by the Department of State.

Medspa services are more invasive and riskier than traditional spa offerings, although there are several well-known cosmetic procedures that require a medical license to perform.   

Who Licenses Med Spas?

Depending on the type of services provided, providers may be regulated by the Department of State, the State Education Department and/or the Department of Health.  It is highly recommended that consumers check with the appropriate agency to ensure that such providers are appropriately licensed prior to services being performed.

Is a Medical License Required?

Medical procedures cannot not be provided by appearance enhancement licensees, including cosmetologists and estheticians. Common medical procedures include, but are not limited to:

  • Injections of any drugs (including Botox) or any fillers (including as Restylane) whether by needle or pressure pen
  • Cool Sculpting
  • Cryotherapy
  • Microneedling
  • Ear Candling
  • Laser procedures (except for laser hair removal)
  • Peels
  • Pen Treatments
  • Plasma Treatments
  • Radiofrequency Procedures (e.g., Facials and Body Treatments)
  • Skin Tag Removal
  • Ultrasound
  • Hormone replacement therapy
  • GLP-1 (weight loss injections, either name brand or compound)
  • Vitamin infusions

Med Spa Procedures

 

Any business offering these procedures or promoting “med spa” services must be licensed as a medical facility or a medical practice. These medical facilities must employ licensed physicians to serve as medical directors, who ensure that patients receive safe and effective medical care from qualified staff. The business must be owned and operated by licensed physicians responsible for providing safe and effective care to patients

Providers offering med spa services must be formed as a professional entity, such as a professional corporation (PC) or a professional limited liability company (PLLC) and must obtain a Certificate of Authorization from the New York State Education Department.  Providers organized as a “PC” or “PLLC” cannot have “spa” in their name. For more information, please contact the NYS Department of Education. (Provide link and contact information).