Med spa regulations by state, at a glance

Nothing contained in this chapter shall prevent any licensed practitioner of the healing arts from personally compounding, dispensing, administering, or supplying to his or her patient drugs and medicines for their use.

(6) Level 2 Delegate - A Level 2 Delegate is a licensed practicing nurse (LPN) or medical assistant to include Medical Examiners Chapter 540-X-11 Revised 3/16/26 11-3 aestheticians, cosmetologists, and laser technicians authorized in a written job description or protocol to use a specific laser/pulsed light device or other energy source, chemical or other modality for non-ablative procedures, as designated in the written job description or protocol, and who has met the educational requirements for a Level 2 Delegate as stated in these rules.

⛔ ALABAMA PUBLISHES ACTUAL AMOUNTS RATHER THAN A CEILING, SO THIS IS THE PRICE AND NOT A CAP. Fees shall be the following: (a) Written Examination or Reexamination $75 (b) Practical Examination or Reexamination $130 (c) Original License $50 (d) Personal Renewal $100 (e) New Shop $200 (f) Shop Renewal $150 Opening a shop costs $200 and renewing it $150, while the individual practitioner pays $50 to be licensed and $100 to renew — premises and practitioner billed separately, as in most states.

⛔ COMPOUNDED SEMAGLUTIDE IN ALASKA IS BOUNDED BY THE DEFINITION OF COMPOUNDING, WHICH HAS ONLY TWO LIMBS AND ONE OF THEM FORBIDS SALE. “compounding” means the preparation, mixing, assembling, packaging, or labeling of a drug or device (A) as the result of a practitioner's prescription drug order or initiative based on the relationship of the practitioner, patient, and pharmacist in the course of professional practice or (B) for the purpose of, or as an incident to, research, teaching, or chemical analysis and not for sale or dispensing Limb (A) requires a prescription order resting on a practitioner-patient-pharmacist relationship; limb (B) is research and is expressly not for sale or dispensing. A clinic buying compounded stock reaches neither on the face of the definition.

⚠️ Alaska states no corporate-practice-of-medicine doctrine in its professions statutes or the medical board’s regulations. A survey of the Medical Board chapter (AS 08.64), the Nursing chapter (AS 08.68), the Barbers and Hairdressers chapter (AS 08.13), the centralized licensing chapter (AS 08.01) and the corresponding regulations (12 AAC 40, 12 AAC 02, 12 AAC 09) returns no provision on corporate practice, business-entity ownership of a practice, fee-splitting, dividing a fee, or rebates. Alaska regulates WHO may perform an act and under whose supervision, not who may own the business that employs them. Anyone citing you an Alaska corporate-practice rule is describing a document these chapters do not contain.

For the purposes of AS 08.13.220 (5), (1) "appliances" in the field of esthetics means only those devices used to stimulate natural physiological processes intended to improve the health and appearance of a person's skin; a device (A) operates within the manufacturer's guidelines; (B) does not directly ablate or destroy live tissue; (C) does not involve an incision into skin beyond the epidermis;

⛔ ALASKA PUBLISHES THE COST OF ENTRY AS A FEE RULE, SO THIS IS AN ANSWER RATHER THAN AN ESTIMATE. 12 AAC 02.140. Board of Barbers and Hairdressers. (a) The following fees are established: (1) nonrefundable application fee for (A) initial license, $150 The application fee is charged before any license issues and is not returned if the application fails.

⚠️ COMPOUNDING IS A PHARMACIST ACT BY DEFINITION IN ARIZONA — AND THE DEFINITION EXPRESSLY COVERS OFFICE STOCK. “Compounding” means preparing, mixing, assembling, packaging or labeling a drug “BY A PHARMACIST OR AN INTERN OR PHARMACY TECHNICIAN UNDER THE PHARMACIST’S SUPERVISION, for the purpose of dispensing to a patient based on a valid prescription order”, and it INCLUDES preparing drugs “FOR ADMINISTRATION BY A MEDICAL PRACTITIONER TO THE MEDICAL PRACTITIONER’S PATIENT AND NOT FOR SALE OR DISPENSING”. Office stock to ADMINISTER is contemplated; office stock to SELL is not.

⚠️ ARIZONA CATCHES THE ARRANGEMENT BY ITS EFFECT, NOT ITS LABEL. Unprofessional conduct includes “CHARGING A FEE FOR SERVICES NOT RENDERED OR DIVIDING A PROFESSIONAL FEE FOR PATIENT REFERRALS AMONG HEALTH CARE PROVIDERS OR HEALTH CARE INSTITUTIONS OR BETWEEN THESE PROVIDERS AND INSTITUTIONS OR A CONTRACTUAL ARRANGEMENT THAT HAS THE SAME EFFECT.” That closing clause is the point — a management or marketing contract structured to do what a fee split does is inside the ground.

ARIZONA’S DEFINITION OF AESTHETICS WAS READ IN FULL AND IS A CLOSED LIST OF THREE SURFACE PRACTICES. “AESTHETICS” MEANS “MASSAGING, CLEANSING, STIMULATING, MANIPULATING, EXERCISING, BEAUTIFYING OR APPLYING OILS, CREAMS, ANTISEPTICS, CLAYS, LOTIONS OR OTHER PREPARATIONS, EITHER BY HAND OR BY MECHANICAL OR ELECTRICAL APPLIANCES”; “ARCHING EYEBROWS OR TINTING EYEBROWS AND EYELASHES”; and “REMOVING SUPERFLUOUS HAIR BY MEANS OTHER THAN ELECTROLYSIS OR THREADING” — each qualified as performed “FOR COSMETIC PURPOSES”. Nothing in the definition describes puncturing skin. An absence in this definition, not a finding that Arizona prohibits microneedling.

💰 ARIZONA PUBLISHES ONE SCHEDULE AND IT IS ALL CEILINGS: “THE BOARD SHALL ESTABLISH AND COLLECT FEES NOT TO EXCEED THE FOLLOWING”. For a med spa the operative lines are “APPLICATION FOR ESTABLISHMENT LICENSE, INCLUDING CHANGE OF OWNERSHIP, $250”, “ESTABLISHMENT LICENSE RENEWAL, $100” and “APPLICATION FOR INITIAL PERSONAL LICENSE, A ONETIME FEE OF $100”, with the personal renewal “$100 TO BE PAID ONCE EVERY TWO YEARS”. Note the two traps priced into the list: a CHANGE OF OWNERSHIP costs the full $250, and moving the business is its own charge — “ESTABLISHMENT LICENSE AFTER A CHANGE OF LOCATION, $150”.

⛔ ARKANSAS GENERALLY PROHIBITS COMPOUNDING A COPY OF A COMMERCIALLY AVAILABLE DRUG, AND SEMAGLUTIDE AND TIRZEPATIDE ARE COMMERCIALLY AVAILABLE PRODUCTS. Compounding a drug product that is commercially available in the marketplace or that is essentially a copy of a commercially available Food and Drug Administration-approved drug product is generally prohibited. (2) However, in special circumstances a pharmacist may compound an appropriate quantity of a drug that is only slightly different than a Food and Drug Administration-approved drug that is commercially available: (A) Based on documentation provided by the prescribing physician of a patient-specific medical need (e.g., the physician requests an alternate product due to hypersensitivity to excipients or preservative in the Food and Drug Administration-approved product, or the physician requests an effective alternate dosage form); or (B) If the drug product is not commercially available.

“Aesthetician” means any person who engages in the practice of beautifying the body by cleaning, waxing, externally manipulating, or stimulating the body by means of the hands, devices, apparatus, or appliances with or without the use of cosmetic: (A) Preparations; (B) Antiseptics; (C) Tonics; (D) Lotions; and (E) Creams;

All fees are nonrefundable upon submission: New establishment or mobile salon $100 one-time fee Renewal of an establishment or mobile salon $50.00 annually Relocation of establishment $50.00 one-time fee Renewal of a cosmetology, manicure, aesthetics, electrology, or instructor license $50.00 biennially

THE STANDARD ITSELF REACHES ANY COMPOUNDING DESTINED FOR THIS STATE. “The compounding of drug preparations by a pharmacy FOR FURNISHING, DISTRIBUTION, OR USE IN THIS STATE SHALL BE CONSISTENT WITH STANDARDS ESTABLISHED IN THE PHARMACY COMPOUNDING CHAPTERS OF THE CURRENT VERSION OF THE UNITED STATES PHARMACOPEIA-NATIONAL FORMULARY, INCLUDING RELEVANT TESTING AND QUALITY ASSURANCE.” “For … use in this state” is what carries the duty across a state line to an out-of-state compounder.

⚠️ CALIFORNIA’S BAN IS BROAD AND EXPRESSLY SURVIVES CO-OWNERSHIP. The offer, delivery, receipt or acceptance by a licensee of “ANY REBATE, REFUND, COMMISSION, PREFERENCE, PATRONAGE DIVIDEND, DISCOUNT, OR OTHER CONSIDERATION, WHETHER IN THE FORM OF MONEY OR OTHERWISE, AS COMPENSATION OR INDUCEMENT FOR REFERRING PATIENTS, CLIENTS, OR CUSTOMERS” is unlawful — “IRRESPECTIVE OF ANY MEMBERSHIP, PROPRIETARY INTEREST, OR COOWNERSHIP IN OR WITH ANY PERSON TO WHOM THESE PATIENTS … ARE REFERRED”. Shared ownership is not a defense.

✅ CALIFORNIA WRITES THE LIMIT INTO THE DEFINITION OF SKIN CARE, IN TISSUE TERMS. The practice of skin care is “GIVING FACIALS, MASSAGING, STIMULATING, EXFOLIATING, CLEANSING, OR BEAUTIFYING THE FACE, SCALP, NECK, HANDS, ARMS, FEET, LEGS, OR UPPER PART OF THE HUMAN BODY BY THE USE OF HANDS, ESTHETIC DEVICES, COSMETIC PRODUCTS, ANTISEPTICS, LOTIONS, TONICS, OR CREAMS FOR THE PURPOSE OF IMPROVING THE APPEARANCE OR WELL-BEING OF THE SKIN THAT DO NOT RESULT IN THE ABLATION OR DESTRUCTION OF THE LIVE TISSUE.” California permits esthetic DEVICES by name — and then bounds every one of them by what it does to live tissue.

💰 CALIFORNIA’S FEE SCHEDULE IS PUBLISHED IN DOLLARS WITHOUT DOLLAR SIGNS, AND THE PREMISES ARE THE CHEAP PART. “The following fees (in dollars) shall be charged by the Board”: for “Estheticians”, “Application and examination fee 75”, “Initial license fee 40”, “License renewal fee 50” and “License renewal delinquency fee 25”; for “Establishments”, “Application and initial license fee 50”, “License renewal fee 40” and “License renewal delinquency fee 20”. A mobile unit costs more than a fixed one — “Initial inspection and license fee 100” — because it is inspected.

⚠️ WHO MAY COMPOUND OR DISPENSE AT ALL, WHICH IS THE FIRST GATE ON A COMPOUNDED GLP-1. “ONLY A REGISTERED PRESCRIPTION DRUG OUTLET or other outlet registered pursuant to section 12-280-119 (1)(d) MAY COMPOUND OR DISPENSE A PRESCRIPTION.” A med spa is not a prescription drug outlet, so the default position is that it may do neither.

⚠️ COLORADO’S FEE-DIVISION RULE IS BOTH CRIMINAL AND DISCIPLINARY, AND THE SECOND HALF IS EASY TO MISS. Dividing a fee for sending or bringing a patient is a class 2 misdemeanor under § 12-240-132(1)(a) — and separately, “VIOLATION OF THE PROVISIONS OF THIS SECTION SHALL CONSTITUTE GROUNDS FOR THE SUSPENSION OR REVOCATION OF A LICENSE OR THE PLACING OF THE HOLDER THEREOF ON PROBATION.” One arrangement, two forums: a criminal charge and a license action.

⚠️ AND THE SAME SENTENCE CLOSES TWO LOOPHOLES. “NOTHING IN THIS EXEMPTION SHALL BE DEEMED TO EXTEND OR LIMIT THE SCOPE OF ANY LICENSE” — delegation cannot enlarge what a nurse or esthetician may already do. And the exemption “SHALL NOT APPLY TO PERSONS OTHERWISE QUALIFIED TO PRACTICE MEDICINE BUT NOT LICENSED TO PRACTICE IN THIS STATE” — a physician unlicensed in Colorado cannot work as somebody’s delegate.

⚠️ COLORADO FIXES NO FEE AMOUNT IN STATUTE — ITS FEES FLOAT TO COVER THE REGULATOR’S COSTS. Section 12-20-105 applies “to all activities of the division and all regulators”, and the mechanism is annual: “The director shall propose, as part of the division’s annual budget request, an adjustment in the amount of each fee that each regulator is authorized by law to collect”, and then “each regulator shall adjust the fees the regulator is authorized by law to collect so that the revenue generated from the fees approximates its direct and indirect costs.” A Colorado operator therefore has no statutory figure to plan against, and the number can move every budget year.

⛔ CONNECTICUT LIMITS WHAT A STERILE COMPOUNDING PHARMACY MAY DISPENSE WITHOUT A PATIENT-SPECIFIC ORDER. A sterile compounding pharmacy may only provide patient-specific sterile pharmaceuticals to patients, to practitioners of medicine, osteopathy, podiatry, dentistry or veterinary medicine, or to an acute care or long-term care hospital or health care facility licensed by the Department of Public Health. If a sterile compounding pharmacy provides sterile pharmaceuticals without a patient-specific prescription or medical order, the sterile compounding pharmacy shall also obtain a certificate of registration from the Department of Consumer Protection pursuant to section 21a-70 and any required federal license or registration. A sterile compounding pharmacy may prepare and maintain on-site inventory of sterile pharmaceuticals no greater than a thirty-day supply, calculated from the completion of compounding

“Esthetics” means services related to skin care treatments, (A) including, but not limited to, cleansing, toning, stimulating, exfoliating or performing any similar procedure on the human body while using cosmetic preparations, hands, devices, apparatus or appliances to enhance or improve the appearance of the skin; makeup application; beautifying lashes and brows; or removing unwanted hair using manual and mechanical means, and (B) excluding the use of a prescriptive laser device; the performance of a cosmetic medical procedure, as defined in section 19a-903c ; any practice, activity or treatment that constitutes the practice of medicine;

On and after July 1, 2020, except as provided in subsection (g) of this section, no person may practice as an esthetician without obtaining a license or temporary permit from the Department of Public Health under this section or section 20-265f. On and after January 1, 2020, each person seeking an initial license as an esthetician shall apply to the department on a form prescribed by the department, accompanied by an application fee of one hundred dollars.

⛔ DELAWARE IS ONE OF THE STATES THAT SAYS OFFICE USE OUT LOUD, WHICH MAKES ITS ANSWER ON COMPOUNDED SEMAGLUTIDE DIFFERENT FROM MOST. Nothing in this title is meant to limit a prescriber’s ability under pre-existing law to order a compounded medication for use in the prescriber’s practice, as permitted by State of Delaware and federal law. A prescriber may order compounded product FOR USE IN THE PRACTICE rather than against a named patient — but only so far as other Delaware and federal law already allow, so this preserves an existing ability and creates none.

Delaware’s fee-splitting rule sits among the Board of Medical Licensure and Discipline’s enumerated unprofessional conduct: 8.1.9 Payment of a fee by a physician to another physician who has referred the patient to him, unless the fee is in proportion to work actually performed by the referring physician.

An aesthetician is not authorized to prescribe medication or provide medical treatment in the same manner as a dermatologist.

⛔ DELAWARE DOES NOT PUBLISH A DOLLAR FIGURE, AND THE HONEST ANSWER IS THE MECHANISM RATHER THAN A NUMBER. The amount to be charged for each fee imposed under this chapter shall approximate and reasonably reflect all costs necessary to defray the expenses of the Board, as well as the proportional expenses incurred by the Division of Professional Regulation in its services on behalf of the Board. There shall be a separate fee charged for each service or activity; but no fee shall be charged for an activity not specified in this chapter. The application fee shall not be combined with any other fee or charge. Fees are recomputed each licensure biennium to match the Board’s costs, so an operator budgeting to open should expect a separate charge per service and should read the current biennium’s figure from the Division rather than from the statute.

Anticipatory compounding for later dispensing is inside the District's definition. Compounding - the preparation, mixing, assembling, packaging, or labeling of a drug or device as the result of a practitioner's prescription drug order or for the purpose of, or as an incident to, research, teaching, or chemical analysis and not for sale or dispensing. Compounding also includes the preparation of drugs or devices in anticipation of prescription drug orders based on routine, regularly observed prescribing patterns.

A disciplinary action may be taken against a person who pays or agrees to pay anything of value to, or splits or divides fees for professional services with, any person for bringing or referring a patient.

Esthetics – the application of creams, lotions, scrubs, polishes, waxes, cosmetics, eyelashes, and other beauty treatments directly onto the skin to bring about a temporary improvement in appearance, excluding peels and microdermabrasion; and the removal of superfluous hair from the face and neck area of any person by the use of depilatories, waxing or tweezers. Master esthetics - esthetics and more specialized skincare treatments, including microdermabrasion, resurfacing, and chemical peel.

The examination, annual license fees and criminal background check fees for each class of license issued by the Department of Health shall be as follows: COSMETOLOGISTS: Application $65.00; License $110.00 (up to 2 years); Renewal $110.00 (up to 2 years); Renewal (Managers & Instructors) $155.00; Late Renewal Fee $50.00; Reinstated License $110.00 (up to 2 years). BARBERS: Application $65.00; License: (1) Barber $110.00 (up to 2 years) (2) Manager $110.00 (up to 2 years) (3) Instructor $110.00 (up to 2 years) (4) Owner $110.00 (up to 2 years).

⚠️ THE SUPPLIER OF A COMPOUNDED INJECTABLE NEEDS A FLORIDA PERMIT, AND THIS IS CHECKABLE. “IN ORDER TO SHIP, MAIL, DELIVER, OR DISPENSE, IN ANY MANNER, A COMPOUNDED STERILE PRODUCT INTO THIS STATE, a nonresident pharmacy registered under s. 465.0156, OR AN OUTSOURCING FACILITY, MUST HOLD A NONRESIDENT STERILE COMPOUNDING PERMIT.” Compounded semaglutide is a sterile product; a Florida practice buying it from out of state should ask to see this permit before the first delivery.

⚠️ FLORIDA’S KICKBACK BAN IS BROAD AND IT IS CRIMINAL IN FORM. “It is UNLAWFUL for any health care provider or any provider of health care services TO OFFER, PAY, SOLICIT, OR RECEIVE A KICKBACK, DIRECTLY OR INDIRECTLY, OVERTLY OR COVERTLY, IN CASH OR IN KIND, FOR REFERRING OR SOLICITING PATIENTS.” Four verbs and four adverbial pairs — the drafting is designed to catch arrangements dressed up as something else.

⚠️ FLORIDA WRITES THE MEDICAL EXCLUSION INTO THE DEFINITION OF COSMETOLOGY ITSELF. “COSMETOLOGY” MEANS “THE MECHANICAL OR CHEMICAL TREATMENT OF THE HEAD, FACE, AND SCALP FOR AESTHETIC RATHER THAN MEDICAL PURPOSES”. The facial specialty is no wider: “FACIALS, OR THE MASSAGING OR TREATING OF THE FACE OR SCALP WITH OILS, CREAMS, LOTIONS, OR OTHER PREPARATIONS, AND SKIN CARE SERVICES.” So in Florida the question is not whether microneedling is listed — it is whether the treatment is for a medical purpose, which the license does not reach either way.

⚠️ AND TAKING ANY MONEY FOR IT TRIGGERS A REGISTRATION MOST PRACTICES DO NOT HOLD. “A practitioner who dispenses medicinal drugs for human consumption FOR FEE OR REMUNERATION OF ANY KIND, WHETHER DIRECT OR INDIRECT, MUST … REGISTER WITH HER OR HIS PROFESSIONAL LICENSING BOARD AS A DISPENSING PRACTITIONER and pay A FEE NOT TO EXCEED $100 at the time of such registration and upon each renewal.” “Indirect” reaches a drug bundled into the price of a treatment package.

⚠️ GEORGIA PROHIBITS OFFICE-USE COMPOUNDING FOR HUMAN PRACTITIONERS IN ONE SENTENCE. “THE DISTRIBUTION OF NON-PATIENT SPECIFIC COMPOUNDED PREPARATIONS FOR OFFICE USE BY A PRACTITIONER, EXCLUDING VETERINARIANS, IS PROHIBITED.” A Georgia med spa cannot lawfully receive compounded stock from a pharmacy to hold and use.

⚠️ GEORGIA PUTS FEE DIVISION IN THE SAME GROUND AS AIDING UNLICENSED PRACTICE, AND IT NAMES CORPORATIONS. The board may discipline a licensee who has “DIVIDED FEES OR AGREED TO DIVIDE FEES RECEIVED FOR PROFESSIONAL SERVICES WITH ANY PERSON, FIRM, ASSOCIATION, CORPORATION, OR OTHER ENTITY FOR BRINGING OR REFERRING A PATIENT.” The trigger is what the payment is FOR — bringing or referring — not who receives it.

✅ GEORGIA EXCLUDES MEDICAL AESTHETICS FROM THE ESTHETICS LICENSE BY NAME, IN THE DEFINITION ITSELF. After listing the four practices an esthetician may perform, the statute closes: “SUCH PRACTICES OF ESTHETICS SHALL NOT INCLUDE THE DIAGNOSIS, TREATMENT, OR THERAPY OF ANY DERMATOLOGICAL CONDITION OR MEDICAL AESTHETICS OR THE USE OF LASERS.” Few states name “medical aesthetics” as a category and put it outside the license; Georgia does.

⚠️ GEORGIA PUBLISHES NO FEE AMOUNT IN ITS RULES AT ALL, AND SAYS SO EXPRESSLY. “ALL LICENSE/PERMIT FEES FOR RENEWAL AND REINSTATEMENT SHALL BE ESTABLISHED BY THE BOARD PERIODICALLY AS SET FORTH ON A FEE SCHEDULE”, and “THE FEE SCHEDULE IS AVAILABLE FROM THE BOARD OFFICE AND AT THE BOARD’S WEBSITE. FEES MAY BE REVIEWED AND CHANGED AT THE DISCRETION OF THE BOARD.” Unlike Minnesota or Arizona, which fix the numbers in law, a Georgia operator has no published legal figure to plan against — and the rule warns of two surcharges without pricing either: the Board “MAY ASSESS A PAPER APPLICATION PROCESSING FEE THAT IS GREATER THAN OR IN ADDITION TO AN ELECTRONIC APPLICATION FEE”, and “MAY ASSESS A LATE RENEWAL FEE”.

"Practice of pharmacy" means: (1) The interpretation and evaluation of prescription orders; the compounding, dispensing, and labeling of drugs and devices (except labeling by a manufacturer, packer, or distributor of nonprescription drugs and commercially legend drugs and devices); the participation in drug selection and drug utilization reviews; the proper and safe storage of drugs and devices and the maintenance of proper records therefor;

"Esthetician" means a person licensed in the State who, with hands or nonmedically prescribed mechanical or electrical apparatus or devices or by use of cosmetic preparations, antiseptics, tonics, lotions, or creams, engages for compensation in any of the following practices: (1) Massaging, cleansing, stimulating, manipulating, exercising, beautifying, or doing similar work on the scalp, face, neck, hands, arms, bust, upper part of the body, legs, or feet; (2) Cleansing, exfoliating, wrapping, or doing similar work upon the entire body, without direct contact by the hands and utilizing gloves, loofah mitts, or brushes; or (3) Removing superfluous hair about the body of any person by means other than electrolysis.

The department’s fee rule sets the license fees for the board of barbering and cosmetology as dollar amounts. Its application fees are listed as Operator or instructor $ 20; Beauty shop $ 50; Beauty school $ 500; Apprentice $ 20.

⛔ COMPOUNDED SEMAGLUTIDE OR TIRZEPATIDE EXISTS IN IDAHO ONLY AS A PREPARATION FOR ONE NAMED PATIENT, AND THE DEFINITION OF COMPOUNDING IS WHERE THE LAW SAYS SO. "Compounding" means the practice in which a pharmacist, a prescriber, or, in the case of an outsourcing facility, a person under the supervision of a pharmacist combines, mixes or alters ingredients of a drug to create a medication tailored to the needs of an individual patient. A prescriber is named in the definition, so compounding is not a pharmacist-only act here — but the preparation must be tailored to an individual patient, and this definition describes no office stock.

Dividing fees or gifts or agreeing to split or divide fees or gifts received for professional services with any person, institution or corporation in exchange for referral is a ground for medical discipline.

"Esthetics" means noninvasive care of the skin by application of cosmetic preparations, antiseptics, tonics, lotions, creams and essential oils to cleanse, massage, exfoliate, hydrate and stimulate; makeup application; pore extraction; use of chemical exfoliants approved for professional esthetic use; particle exfoliation; use of any class I medical device, as classified by the United States food and drug administration, designed for care of the skin, except that a class II medical device designed for care of the skin may be used as directed and supervised by an authorized and licensed health care practitioner.

400. FEES. All fees are non-refundable. Annual fees ma y be aggregated for biennial licensure. FEE TYPE AMOUNT (Not to Exceed) ANNUAL RENEWALFEE (Not to Exceed) Individual Original License or Certificate $30 $30 Application $30 Instructor License $35 $35 License/Registration $25 $25 School License $360 $100 Apprentice Registration $30 Endorsement License $45 Reinstatement $35 — the establishment, dealer and facility license or registration is the $25 line, and each figure is stated as an amount NOT TO EXCEED.

⚠️ ILLINOIS PUTS TWO CONDITIONS ON COMPOUNDING A DRUG YOU COULD SIMPLY BUY, AND BOTH MUST HOLD. “COMMERCIALLY AVAILABLE PRODUCTS MAY BE COMPOUNDED FOR DISPENSING TO INDIVIDUAL PATIENTS ONLY IF ALL OF THE FOLLOWING CONDITIONS ARE MET: (i) THE COMMERCIAL PRODUCT IS NOT REASONABLY AVAILABLE FROM NORMAL DISTRIBUTION CHANNELS IN A TIMELY MANNER TO MEET THE PATIENT’S NEEDS and (ii) THE PRESCRIBING PRACTITIONER HAS REQUESTED THAT THE DRUG BE COMPOUNDED.” Availability is a SUPPLY-CHAIN test, not a price test — and the request must come from the prescriber.

⚠️ ILLINOIS HAS A DEDICATED FEE-SPLITTING SECTION AND ITS BAN IS NOT LIMITED TO REFERRALS. “A licensee under this Act MAY NOT DIRECTLY OR INDIRECTLY DIVIDE, SHARE OR SPLIT ANY PROFESSIONAL FEE OR OTHER FORM OF COMPENSATION FOR PROFESSIONAL SERVICES WITH ANYONE IN EXCHANGE FOR A REFERRAL OR OTHERWISE, other than as provided in this Section 22.2.” The words “OR OTHERWISE” do the work — an arrangement with no referral in it is still inside the section unless an exception applies.

✅ ILLINOIS NAMES MICRONEEDLING AS THE PRACTICE OF MEDICINE, AND SETS NO DEPTH THAT MAKES IT LAWFUL. IDFPR has stated that the following are the practice of medicine and outside the scope of a cosmetologist or esthetician: botulinum toxin, chemical peels other than superficial peels, collagen injections, colonics, liposuction, microblading, microneedling and radiofrequency. Unlike the states that draw a depth line, Illinois puts the procedure itself on the far side of the license.

💰 ILLINOIS IS THE CHEAPEST COSMETOLOGY REGISTRATION IN THIS CORPUS, AND ITS RENEWALS ARE PRICED PER YEAR. “The fee for registration of a barber shop or cosmetology, nail technician, hair braiding or esthetics salon (salon) is $40”, renewal “calculated at $20 per year”, and “The fee for changing the name or address of a registered barber shop or salon is $20.” On the individual side, “The fee for a license is $30” with renewal “calculated at the rate of $25 per year”. Let one lapse and restoration is “$50 plus payment of all lapsed renewal fees not to exceed $200.”

IN INDIANA, COMPOUNDING IS PHARMACY PRACTICE BY DEFINITION. The practice of pharmacy is performed by a pharmacist — or by a pharmacist intern or an unlicensed person the pharmacist SUPERVISES under section 18.5 — and it includes “THE COMPOUNDING, LABELING, ADMINISTERING, DISPENSING, OR SELLING OF DRUGS AND DEVICES … WHETHER DISPENSED UNDER A PRACTITIONER’S PRESCRIPTION OR DRUG ORDER OR SOLD OR GIVEN DIRECTLY TO THE ULTIMATE CONSUMER”, together with their proper and safe STORAGE AND DISTRIBUTION and the maintenance of records of receipt, storage, sale and dispensing.

INDIANA’S STANDARDS-OF-PRACTICE CHAPTER WAS SURVEYED AND CONTAINS NO FEE-DIVISION GROUND. IC 25-1-9 is the chapter that supplies the grounds for disciplining a health practitioner, and it contains no prohibition on dividing or sharing a professional fee, and no use of “rebate”, “kickback” or “remuneration”. An absence in this chapter, not in Indiana law as a whole.

INDIANA’S ESTHETICIAN DEFINITION WAS READ IN FULL AND IS A CLOSED LIST WITH A MEDICAL CARVE-OUT. An esthetician is “A PERSON WHO ENGAGES SOLELY IN ONE (1) OR MORE OF THE FOLLOWING PRACTICES”: “GIVING FACIALS, APPLYING MAKEUP, AND GIVING SKIN CARE”; “BEAUTIFYING, MASSAGING, OR CLEANING THE BODY WITH THE USE OF COSMETIC PREPARATIONS, ANTISEPTICS, TONICS, LOTIONS, OR CREAMS”; and removing superfluous hair “BY THE USE OF DEPILATORIES, WAXING, OR TWEEZERS”. The term expressly “DOES NOT INCLUDE PERFORMING ANY OF THE ACTS DESCRIBED IN SUBSECTION (A)… IN TREATING AN ILLNESS OR A DISEASE” No act of puncturing appears — an absence in this definition.

💰 INDIANA CHARGES ONE PRICE FOR ALMOST EVERYTHING, AND THE EXCEPTIONS ARE THE INTERESTING PART. “The board shall charge and collect the following application/issuance fees for licenses”, and the list is flat: “Cosmetologist: 40”, “Esthetician: 40”, “Esthetic salon: 40”, “Cosmetology salon: 40”, “Mobile salon: 40”. Only two rows break the pattern — “Cosmetology school: 400” and “Tanning facility: 200”. A med spa that adds a tanning bed therefore pays five times what its esthetics license costs.

⛔ IOWA LICENSES THE EXACT ARRANGEMENT A MED SPA USES TO HOLD COMPOUNDED SEMAGLUTIDE, AND NAMES IT. Any compounding facility that is registered as an outsourcing facility, as defined in 21 U.S.C. §353b, that distributes sterile compounded human drug products without a patient-specific prescription to an authorized agent or practitioner in this state shall obtain an outsourcing facility license from the board prior to engaging in such distribution. Buying compounded semaglutide as office stock — that is, without a prescription naming the patient — is distribution the supplier must hold an Iowa outsourcing facility license to make.

Acceptance of remuneration for referral of a patient to other health professionals in violation of the law or medical ethics.

Provide on-site review of medical aesthetic services performed by qualified licensed or certified nonphysician persons or qualified laser technicians each week and review at least 10 percent of patient charts for medical aesthetic services performed by qualified licensed or certified nonphysician persons or qualified laser technicians;

Barbering and cosmetology arts and sciences license fees. All fees are nonrefundable. 507.5(1) License fee for license to practice barbering and cosmetology arts and sciences, license by endorsement, license by reciprocity, or an instructor’s license is $60. 507.5(2) Biennial license renewal fee for each license for each biennium is $60.

⛔ THIS IS THE COMPOUNDED-SEMAGLUTIDE QUESTION ANSWERED INSIDE THE DEFINITION ITSELF, AND KANSAS SETS A TEST THE DRUG’S OWN AVAILABILITY DECIDES. Compounding is the combining of components into a compounded preparation "Compounding" means the combining of components into a compounded preparation under either of the following conditions: (A) As the result of a practitioner's prescription drug order or initiative based on the practitioner-patient-pharmacist relationship in the course of professional practice to meet the specialized medical need of an individual patient of the practitioner that cannot be filled by an FDA-approved drug Semaglutide and tirzepatide ARE available as FDA-approved drugs, so in Kansas a compounded version has to answer a specialized medical need of an identified patient that the approved product cannot meet — commercial preference or price is not that need.

Unprofessional conduct means directly or indirectly giving or receiving any fee, commission, rebate or other compensation for professional services not actually and personally rendered, other than through the legal functioning of lawful professional partnerships, corporations, limited liability companies or associations.

"Esthetician" means any person who, for compensation practices the profession of cosmetology only to the following extent: Eyebrow and eyelash services, cleansing, stimulating or performing any other noninvasive beautifying process on any skin surface by means of hands or mechanical or electrical appliances, other than electric needles, provided for esthetic rather than medical purposes; temporary hair removal from the face or any part of the body by use of the hands or mechanical or electrical appliances other than electric needles; or using cosmetic preparations, antiseptics, lotions, creams or other preparations in performing any of the practices described in this subsection.

Unless revoked for cause, all licenses of cosmetologists, cosmetology technicians, estheticians, electrologists and manicurists issued or renewed by the board shall expire on the expiration dates established by rules and regulations adopted by the board under this section. Each such license shall be renewable on a biennial basis upon the filing of a renewal application prior to the expiration of the license, payment of the nonrefundable license renewal fee established under this section and the filing of a successfully completed written renewal examination prescribed by the board under this subsection.

⛔ KENTUCKY BARS COMPOUNDING AN ESSENTIAL COPY OF A COMMERCIALLY AVAILABLE DRUG UNLESS FEDERAL LAW ALLOWS IT — AND A COMPOUNDED SEMAGLUTIDE OR TIRZEPATIDE PREPARATION IS SUCH A COPY WHILE THE APPROVED PRODUCT IS AVAILABLE. Non-sterile and sterile preparations compounded for human use shall: Not be essential copies of a commercially available drug product unless authorized by 21 U.S.C. 353(a).

⛔ KENTUCKY BANS THE KICKBACK AND THEN NAMES WHO MAY DIVIDE A FEE, WHICH IS WHAT ANSWERS A NON-CLINICAL OWNER. It is a ground for discipline to have Given or received, directly or indirectly, from any person, firm, or corporation, any fee, commission, rebate, or other form of compensation for sending, referring, or otherwise inducing a person to communicate with a person licensed under KRS 311.530 in his or her professional capacity or for any professional services not actually and personally rendered. The carve-out that follows reaches LICENSED practitioners only, permitting those who hold valid licenses and practice together under KRS Chapter 274 from pooling, sharing, dividing, or apportioning the fees and moneys received by them. A share of revenue is therefore something licensees may divide among themselves, not something a lay owner may be paid out of.

No person shall engage in the practice of cosmetology, esthetic practices, or nail technology for other than cosmetic purposes nor shall any person engage in the practice of cosmetology, esthetic practices, or nail technology for the treatment of physical or mental ailments. This chapter does not apply to persons authorized by the law of this state to practice medicine, podiatry, optometry, dentistry, chiropractic, nursing, or embalming who perform incidental practices of cosmetology, esthetic practices, and nail technology in the normal course of the practice of their profession.

⛔ KENTUCKY PUBLISHES THE COST OF ENTRY AS A FEE REGULATION, SO THIS IS THE PRICE RATHER THAN AN ESTIMATE. Section 1. The initial license fees shall be as follows: (3) Esthetician - fifty (50) dollars; and Esthetic salon - $100. On renewal the same two are $100 and $200 respectively. The premises and the practitioner are licensed and priced separately, and the schedule states the practitioner fees IN WORDS and the premises fees in digits within the same section.

⛔ LOUISIANA EXCLUDES COPIES OF A COMMERCIAL PRODUCT FROM COMPOUNDING BY DEFINITION, AND SEMAGLUTIDE AND TIRZEPATIDE ARE COMMERCIALLY AVAILABLE PRODUCTS. Compounding does not include the compounding of drug products that are essentially copies of a commercially available product.

Soliciting, accepting, or receiving anything of economic value in return for and based on the referral of patients to another person, firm, or corporation or in return for the prescription of medications or medical devices is a cause for which the board may refuse to issue, or may suspend or revoke any license or permit.

No license or permit issued by the board authorizes the performance of any of the following services in a salon licensed by the board: micro-needling; micro-blading; services or procedures which penetrate or invade the live tissue or dermis by any means including but not limited to the use of instruments or product insertion, puncturing, cutting, needling or chemical exfoliation.

The following fees shall be assessed by the board for each initial certificate of registration and each annual renewal of such certificate: (a) Cosmetologist, esthetician, manicurist, teacher/instructor, or manager $35.00 (b) Beauty shop or salon, mobile salon, or home care $55.00 (c) Initial inspection fee for salon, mobile salon, or booth rental $50.00 (d) Booth rental permit, special permit, or temporary permit $50.00

⛔ MAINE ENUMERATES WHAT COMPOUNDING MAY BE FOR, AND THE ONLY NON-PATIENT-SPECIFIC LIMB IS VETERINARY. "Compounding" means the preparation, mixing, assembling, packaging or labeling of a drug or device by a pharmacist: A. For the pharmacist's patient for dispensing as the result of a practitioner's prescription drug order; The act is a pharmacist's to begin with, and limb A ties it to that pharmacist's own patient against a prescription order.

The practice of aesthetics under this subsection does not include the diagnosis, treatment or therapy of any dermatological condition.

⛔ MAINE CAPS THE COST OF ENTRY IN STATUTE AND THE CEILING IS LOW. The Director of the Office of Professional and Occupational Regulation within the department may establish by rule fees for purposes authorized under this chapter in amounts that are reasonable and necessary for their respective purposes, except that the fee for licensure of a school may not exceed $500 and the fee for any other purpose may not exceed $100. Every barbering and cosmetology license fee other than a school is capped at $100, with the actual figure set by rule beneath that ceiling — so an operator should treat $100 as the most any single license can cost, not the price.

Anticipatory compounding for later dispensing is inside Maryland's definition. “Compounding” means the preparation, mixing, assembling, packaging, or labeling of a drug: (a) As the result of a practitioner’s prescription drug order or initiative based on the practitioner/patient relationship in the course of professional practice; (b) For the purpose of, or incidental to, research, teaching, or chemical analysis and not for the sale or dispensing of the drug or device; or (c) In anticipation of a prescription drug order based on routine, regularly observed prescribing patterns.

Under Maryland’s self-referral law, a health care practitioner may not refer a patient, or direct an employee of or person under contract with the health care practitioner to refer a patient to a health care entity: (1) In which the health care practitioner or the practitioner in combination with the practitioner’s immediate family owns a beneficial interest; (2) In which the practitioner’s immediate family owns a beneficial interest of 3 percent or greater; or (3) With which the health care practitioner, the practitioner’s immediate family, or the practitioner in combination with the practitioner’s immediate family has a compensation arrangement. The section opens with an exception clause: “Except as provided in subsection (d) of this section”.

“Provide esthetic services” means to provide to an individual, for compensation, the service of: (i) cleansing, exercising, exfoliating, massaging, cosmetic microneedling, stimulating, toning, or performing any other similar procedure on the skin or scalp by electrical, mechanical, or any other means; “Provide esthetic services” does not include: (i) the diagnosis of illness, disease, or injury; or (ii) performing ablation of the dermis or hypodermis.

The Board of Cosmetologists’ published schedule: Fees are set by Law and Regulation and are subject to change with public notice given. All fees are nonrefundable. COSMETOLOGIST LICENSE FEE Type of License Cat Original Renew Late SHOP LIMITED SERVICE 01 $225 $ 56 $ 112 after 45 days $225 SHOP FULL SERVICE 02 $225 $ 56 $ 112 after 45 days $225 SENIOR COSMETOLOGIST 04 $ 28 $ 28 $56 COSMETOLOGIST 08 $ 28 $ 28 $56 LIMITED ESTHETICIAN 15 $ 28 $ 28 $56

⚠️ MASSACHUSETTS LICENSES STERILE COMPOUNDING SEPARATELY, AND THE LICENSE STACKS. “The board SHALL ESTABLISH A CATEGORY OF PHARMACY LICENSURE FOR RETAIL PHARMACIES ENGAGED IN STERILE COMPOUNDING. A retail sterile compounding pharmacy license issued by the board SHALL BE OBTAINED IN ADDITION TO AND NOT IN PLACE OF ANY OTHER PERMIT OR LICENSE A PHARMACY HOLDS.” Compounded semaglutide is a sterile preparation, so a Massachusetts practice’s supplier needs this license on top of its pharmacy permit.

⚠️ MASSACHUSETTS’ KICKBACK STATUTE IS BROAD IN CONDUCT AND NARROW IN SCOPE, AND THE SCOPE IS WHAT DECIDES A MED SPA. It punishes “ANY PERSON WHO SOLICITS OR RECEIVES ANY REMUNERATION, DIRECTLY OR INDIRECTLY, OVERTLY OR COVERTLY, IN CASH OR IN KIND IN RETURN FOR PURCHASING, LEASING, ORDERING OR ARRANGING FOR OR RECOMMENDING PURCHASING, LEASING, OR ORDERING OF ANY GOOD, FACILITY, SERVICE, OR ITEM FOR WHICH PAYMENT IS OR MAY BE MADE IN WHOLE OR IN PART BY A HEALTH CARE INSURER.” Cash-pay cosmetic work sits outside that last clause; the moment a service is billed to insurance — botulinum toxin for hyperhidrosis, say — it does not.

⚠️ MASSACHUSETTS PUTS A CEILING ON AESTHETICS WITHOUT SAYING WHERE IT SITS. The defined acts are “CLEANSING, STIMULATING, MANIPULATING AND BEAUTIFYING OF THE SKIN USING HANDS, MECHANICAL OR ELECTRICAL APPARATUS OR APPLIANCES, COSMETIC PREPARATIONS, TONICS, LOTIONS OR CREAMS” — and then the limit: “PROVIDED HOWEVER, THAT AESTHETICS ONLY INCLUDES METHODS THAT ARE MINIMALLY INVASIVE AND POSE A MINIMAL RISK TO THE PUBLIC’S HEALTH AS DEFINED BY THE BOARD.” The statute does not itself say whether a needling device clears that bar; it hands that judgment to the board.

⚠️ MASSACHUSETTS PUTS ITS LICENSING FEES OUTSIDE THE LICENSING STATUTE ENTIRELY. “The fees for a license issued by the board, or for any renewal thereof, shall be determined by the secretary of administration and finance under section 3B of chapter 7”, and renewal applications must be “accompanied by payment of a renewal fee, as determined by the secretary of administration and finance under said section 3B of said chapter 7.” The licensing chapter fixes no amount, and the cycle itself is administrative too: “The commissioner of occupational licensure shall determine the renewal cycle and renewal period for all licenses issued by the board.”

⚠️ MICHIGAN REQUIRES A LICENSE TO COMPOUND AT ALL, AND A SECOND AUTHORIZATION ON TOP OF IT. “To do business in this state, A PERSON THAT PROVIDES COMPOUNDING SERVICES MUST BE LICENSED AS A PHARMACY OR MANUFACTURER under this part AND, IF A PHARMACY, AUTHORIZED TO PROVIDE COMPOUNDING SERVICES under this section and sections 17748a and 17748b.” The same subsection opens by requiring that “A PHARMACY, MANUFACTURER, WHOLESALE DISTRIBUTOR, OR WHOLESALE DISTRIBUTOR-BROKER, WHETHER OR NOT LOCATED IN THIS STATE, MUST BE LICENSED under this part” — so every link in the chain that distributes a compounded drug into Michigan is licensed here. A pharmacy license alone does not by itself carry compounding authority.

⚠️ MICHIGAN FILES FEE-SPLITTING UNDER “UNETHICAL BUSINESS PRACTICES”, AND NAMES THE DRUG MARK-UP. The department shall investigate and the board may sanction “UNETHICAL BUSINESS PRACTICES, CONSISTING OF 1 OR MORE OF THE FOLLOWING: (i) FALSE OR MISLEADING ADVERTISING. (ii) DIVIDING FEES FOR REFERRAL OF PATIENTS OR ACCEPTING KICKBACKS ON MEDICAL OR SURGICAL SERVICES, APPLIANCES, OR MEDICATIONS PURCHASED BY OR IN BEHALF OF PATIENTS.” A rebate on medications bought for patients sits in the same clause as paying for referrals.

✅ MICHIGAN ANSWERS THIS WITH A HARD DEPTH CEILING, IN ONE SENTENCE. Having listed the skin care services an esthetician or cosmetologist may perform, the statute closes: “AS APPLICABLE, A SKIN CARE SERVICE DESCRIBED IN SUBSECTION (2) MUST BE LIMITED TO AN INDIVIDUAL’S STRATUM CORNEUM.” Microneedling is designed to puncture past that layer, and it appears nowhere in the list of permitted services.

💰 MICHIGAN’S FEES ARE IN A SEPARATE ACT FROM ITS LICENSING RULES, AND THEY ARE CHARGED PER YEAR. The State License Fee Act sets “Fees for a person licensed or seeking licensure as a cosmetologist, manicurist, natural hair culturist, esthetician, electrologist, or instructor or a person licensed or seeking licensure to operate a cosmetology establishment or school of cosmetology”. Under “Application processing fees” a cosmetology establishment is 25.00 and an esthetician 15.00 through September 30, 2027 (falling to 10.00 after). Under “License fees, per year” an establishment is 25.00 and an esthetician 24.00 through the same date (falling to 12.00). ⚠️ NOTE THE SCHEDULED STEP-DOWN — the statute already carries the post-2027 numbers, so a figure quoted today has an expiry date written into it.

⚠️ COMPOUNDED SEMAGLUTIDE IS PATIENT-SPECIFIC BY DEFINITION IN MINNESOTA. “Compounding” means preparing, mixing, assembling, packaging, and labeling a drug FOR AN IDENTIFIED INDIVIDUAL PATIENT AS A RESULT OF A PRACTITIONER’S PRESCRIPTION DRUG ORDER — and the definition closes with the general rule: “ALL COMPOUNDING, REGARDLESS OF THE TYPE OF PRODUCT, MUST BE DONE PURSUANT TO A PRESCRIPTION DRUG ORDER unless otherwise permitted in this chapter or by the rules of the board.” A med spa cannot lawfully stock generic compounded vials against future demand.

⚠️ MINNESOTA NAMES THE MED SPA BUSINESS MODEL AS FEE SPLITTING. “FEE SPLITTING” is unprofessional conduct “including without limitation … (4) DISPENSING FOR PROFIT ANY DRUG OR DEVICE, UNLESS THE PHYSICIAN HAS DISCLOSED THE PHYSICIAN’S OWN PROFIT INTEREST.” Selling a drug or a device at a mark-up is inside the fee-splitting ground unless the profit interest is disclosed — which is a different and larger duty than the § 151.37 filing.

The exemption that a med spa would reach for is SCOPE-LIMITED. Section 147.081 does not restrict “any person licensed by a health-related licensing board … PROVIDED THAT THE PERSON CONFINES ACTIVITIES WITHIN THE SCOPE OF THE LICENSE.” Holding a nursing or esthetics license is therefore not itself an answer — the question is whether the act is inside THAT license’s scope.

💰 MINNESOTA PUBLISHES THE ACTUAL NUMBERS, AND THEY RUN ON A THREE-YEAR CYCLE. The statutory schedule sets “$350 INITIAL SALON LICENSE, DIVIDED AS FOLLOWS: (I) $250 FOR EACH INITIAL LICENSE; AND (II) $100 FOR EACH INITIAL LICENSE APPLICATION FEE” and “$195 INITIAL PRACTITIONER, MANAGER, OR INSTRUCTOR LICENSE”, with renewals at “$225 RENEWAL OF SALON LICENSE” and “$115 RENEWAL OF PRACTITIONER LICENSE”. These are cosmetology licenses — the medical side of a med spa is licensed separately and is not in this schedule.

Mississippi’s pharmacy act defines the practice of pharmacy to include compounding and dispensing: it means a health care service that includes, but is not limited to, the compounding, dispensing, and labeling of drugs or devices; interpreting and evaluating prescriptions; administering and distributing drugs and devices;

“Esthetics” means any one (1) or a combination of the following practices: (i) Massaging the face or neck of a person. (ii) Arching eyebrows to include trimming, tweezing, waxing, threading or any other method of epilation. (iii) Tinting eyelashes or eyebrows. (iv) Waxing. (v) Stimulating, cleaning or beautifying the face, neck, arms or legs of a person by any method with the aid of the hands or any mechanical or electrical apparatus, or by the use of a cosmetic preparation. The terms “cosmetology,” barbering,” “esthetics” and “nail technology” shall not include the diagnosis, treatment or therapy of any dermatological condition.

The cosmetology board’s fee rule sets its license fees in dollars: A. Practitioner license/renewal $50.00; G. Salon/barber shop application and initial inspection $85.00; I. Salon/barber shop renewal $60.00.

⛔ MISSOURI ALLOWS COMPOUNDED STOCK AHEAD OF THE ORDER AND TIES IT TO A RELATIONSHIP THAT ALREADY EXISTS, WHICH IS WHERE COMPOUNDED SEMAGLUTIDE FOR A NEW CLINIC FAILS. Pharmacists may compound preparations in limited quantities prior to receiving a valid prescription based on a history of receiving valid prescriptions that have been generated solely with an established pharmacist/patient/ prescriber relationship. The justification is a history of real prescriptions inside an established pharmacist/patient/prescriber relationship — not projected demand, and not a clinic’s intention to sell.

"Class E - estheticians" includes the use of mechanical, electrical apparatuses or appliances, or by the use of cosmetic preparations, antiseptics, tonics, lotions or creams, not to exceed ten percent phenol, engages for compensation, either directly or indirectly, in any one, or any combination, of the following practices: massaging, cleansing, stimulating, manipulating, exercising, beautifying or similar work upon the scalp, face, neck, ears, arms, hands, bust, torso, legs or feet and removing superfluous hair by means other than electric needle or any other means of arching or tinting eyebrows or tinting eyelashes, of any person.

⛔ MISSOURI PUBLISHES THE ACTUAL AMOUNTS IN THE BOARD’S FEE RULE, SO THIS IS A PRICE AND NOT A CEILING. (C) Cosmetology Establishments (up to and including three (3) operators) 1. Application/License (Full Service and Rental Station) $100 Opening a cosmetology establishment of up to three operators costs $100, with renewal at $75 and reinstatement at $105. Note the bracket: the $100 figure is scoped to establishments of three operators or fewer.

"Compounding" means the preparation, mixing, assembling, packaging, or labeling of a drug or device based on: (a) a practitioner's prescription drug order; (b) a professional practice relationship between a practitioner, pharmacist, and patient; (c) research, instruction, or chemical analysis, but not for sale or dispensing; (d) the preparation of drugs or devices based on routine, regularly observed prescribing patterns; or (e) the preparation of drugs based on a facility being registered as an outsourcing facility with the FDA.

"Esthetics" means skin care of the body, including but not limited to hot compresses or the use of safety-approved electrical appliances or chemical compounds formulated for professional application only and the temporary removal of superfluous hair by means of lotions, creams, or mechanical or electrical apparatus or appliances on another person.

The Board of Barbers and Cosmetologists sets its license fees in a rule, in dollars. (1) Original and renewal license to practice barbering, barbering nonchemical, cosmetology, electrology, esthetics, and manicuring $100. (2) Original and renewal teacher license $115. (3) Original and renewal school license $220. (4) Additional courses within a cosmetology school $70. (5) School/course inspection $200. (6) Original and renewal salon or shop license $125. (7) Salon or shop inspection $150. (8) Original and renewal booth rental license $95.

⛔ NEBRASKA ALLOWS COMPOUNDING FOR OFFICE USE BUT NOT A COPY OF AN APPROVED DRUG, WHICH IS WHAT A COMPOUNDED SEMAGLUTIDE OR TIRZEPATIDE PRODUCT IS OUTSIDE A SHORTAGE. No person shall compound: (a) A drug that has been identified by the federal Food and Drug Administration as withdrawn or removed from the market because the drug was found to be unsafe or ineffective; (b) A drug that is essentially a copy of an approved drug unless there is a drug shortage as determined by the board or unless a patient has an allergic reaction to the approved drug; or (c) A drug that has been identified by the federal Food and Drug Administration or the board as a product which may not be compounded.

Unprofessional conduct includes division of fees, or agreeing to split or divide the fees, received for professional services with any person for bringing or referring a consumer, other than with a partner or employee of the credential holder, with a landlord under a written agreement providing for rent based on gross receipts, or with a former partner or employee under a retirement plan or separation agreement.

⛔ THE BOARD BOUNDS ESTHETICS TO THE SURFACE, WHICH IS WHERE A MICRONEEDLING QUESTION IS ANSWERED. 002.02 ESTHETICS . The definition of esthetics is set out in Neb. Rev. Stat. § 38-1026. The practice of esthetics is upon the skin or epidermis. The rule bounds the license to the epidermis and does not name microneedling.

⛔ NEBRASKA SETS THE COST OF ENTRY BY RULE, NOT BY STATUTE, SO THIS IS THE PRICE AND § 38-155 IS ONLY THE AUTHORITY. 001. SCOPE AND AUTHORITY . These regulations establish fees related to the credentialing of individuals and businesses under the Uniform Credentialing Act (UCA), Nebraska Revised Statutes (Neb. Rev. Stat.) §§ 38-101 to 38-1,142. 002. CREDENTIALING FEES . Credentials are renewed biennially unless otherwise noted. The schedule sets Esthetics Salon $150 $150 $50 for re-inspection if required, and Esthetician $95 $118. The premises and the practitioner are licensed separately and priced separately: an esthetics salon pays $150 to open and $150 on each biennial renewal, and an esthetician working in it pays $95 then $118.

Except as otherwise provided in subsection 2, an outsourcing facility is not required to be licensed as a pharmacy. An outsourcing facility may dispense dangerous drugs or controlled substances for identified individual patients pursuant to a prescription only if the outsourcing facility is licensed by the Board as a pharmacy in accordance with NRS 639.230 or 639.2328.

Directly or indirectly receiving from any person, corporation or other business organization any fee, commission, rebate or other form of compensation which is intended or tends to influence the physician’s objective evaluation or treatment of a patient is among the acts that constitute grounds for initiating disciplinary action or denying licensure.

Except as otherwise provided in this section, a licensee shall not perform any invasive procedure that includes, without limitation: (c) The penetration of the skin by needles; The provisions of paragraph (c) of subsection 1 do not apply to the use of needles by a licensed advanced esthetician for the purpose of microneedling, microchanneling or dermarolling if: (a) The gauge and penetration of the needles do not exceed 1.5 mm, unless the advanced esthetician is being directly supervised by a health care professional; and (b) The needles are not used for an ablative esthetic medical procedure, to remove blood or to inject any substance, including, without limitation, a controlled substance.

The fee for issuance of a license for a cosmetological establishment is: (a) For 2 years, $200. (b) For 4 years, $400. The fee for the initial inspection is $15. If an additional inspection is necessary, the fee is $25.

⛔ NEW HAMPSHIRE BARS COMPOUNDING A STERILE COPY OF A COMMERCIALLY AVAILABLE FDA-APPROVED PRODUCT, WHICH IS WHAT A COMPOUNDED SEMAGLUTIDE OR TIRZEPATIDE INJECTION IS WHILE THE APPROVED PRODUCT IS ON THE MARKET. A compounder shall not compound a sterile product of an FDA-approved product when the product is commercially available. (f) When no commercial source of a sterile product exists, such as being listed on the FDA backorder list, the compounder shall only use USP or other USP recognized grades such as BP, JP, EP, bulk ingredients obtained from a good manufacturing practice compliant supplier.

Esthetics means giving facials, applying makeup, giving therapeutic skin care treatments, removing superfluous hair, or applying eyelashes to any person; beautifying the face, neck, arms, and shoulders, by use of cosmetic preparations, antiseptics, tonics, lotions, or creams; massaging, cleansing, or stimulating the face, neck, arms, and shoulders, by means of the hands, devices, apparatus, or appliances, with the use of cosmetic preparations, antiseptics, tonics, lotions, or creams; or providing pedicure and manicure services.

The application processing and licensing fees found in Table 1002.7, below, shall apply to the professions regulated by the board of barbering, cosmetology, and esthetics under RSA 313-A: Barber, cosmetologist, esthetician, manicurist, or master barber personal license application processing and licensing: Initial, renewal, or reinstatement after expiration of license 2 years $55; Shop license application processing and licensing: Initial, renewal, or reinstatement after expiration of license 2 years $110; School license application processing and licensing: Initial, renewal, or reinstatement after expiration of license 2 years $346.

⚠️ NEW JERSEY BARS COMPOUNDED STERILE STOCK FOR HUMAN PRACTICE, AND PERMITS IT FOR ANIMALS. “IN THE ABSENCE OF A VALID PATIENT-SPECIFIC PRESCRIPTION OR MEDICATION ORDER, pharmacists, pharmacy technicians, pharmacy interns, and pharmacy externs SHALL NOT PREPARE COMPOUNDED STERILE PREPARATIONS FOR HUMAN USE FOR A LICENSED PRESCRIBER TO USE IN HIS OR HER PRACTICE, EXCEPT TO THE EXTENT PERMITTED BY FEDERAL LAW.” The very next sentence lets a pharmacy prepare them for a prescriber “FOR NON-HUMAN USE … WITHOUT A PRESCRIPTION”. The federal exception is the 503B door.

⚠️ NEW JERSEY’S RULE IS A SELF-REFERRAL BAN WITH A 1991 CUT-OFF. “A PRACTITIONER SHALL NOT REFER A PATIENT OR DIRECT AN EMPLOYEE OF THE PRACTITIONER TO REFER A PATIENT TO A HEALTH CARE SERVICE IN WHICH THE PRACTITIONER OR THE PRACTITIONER’S IMMEDIATE FAMILY, OR THE PRACTITIONER IN COMBINATION WITH THE PRACTITIONER’S IMMEDIATE FAMILY, HAS A SIGNIFICANT BENEFICIAL INTEREST, UNLESS THE PRACTITIONER HELD THE INTEREST PRIOR TO JULY 31, 1991” and discloses it. Interests taken after that date are not curable by disclosure — they bar the referral.

✅ NEW JERSEY DRAWS THE LINE AT THE STRATUM CORNEUM, WHICH IS THE LAYER MICRONEEDLING IS DESIGNED TO CROSS. A cosmetology licensee shall not “PERFORM OR OFFER TO PERFORM MASSAGING, CLEANSING OR STIMULATING OF THE SKIN, WITH OR WITHOUT COSMETIC PREPARATIONS, BY HAND, MECHANICAL OR ELECTRICAL APPLIANCES, BELOW THE STRATUM CORNEUM, THEREBY AFFECTING THE LIVING CELLS OF THE EPIDERMIS.” Doing so “SHALL BE DEEMED TO BE ENGAGED IN UNLAWFUL PRACTICE PURSUANT TO N.J.S.A. 45:5B-13(E)”.

💰 NEW JERSEY PRORATES THE FIRST LICENSE BY WHERE YOU LAND IN THE RENEWAL CYCLE, WHICH IS UNUSUAL AND WORTH TIMING. “The following fees will be charged by the Board”: “Shop license application fee (includes shop inspection fee) 150.00”, then “Initial license fee (shop) i. If paid during the first year of a renewal cycle 200.00 ii. If paid during the second year of a renewal cycle 100.00”, and “Biennial license renewal (shop) 200.00”. The individual side runs “Biennial license renewal (individual) $ 90.00” with the same first-year / second-year split on the initial fee. Opening in the second year of the cycle halves the initial license fee.

⛔ NEW MEXICO LETS A PHARMACY COMPOUND A COMMERCIALLY AVAILABLE PRODUCT FOR DISPENSING ONLY ON STATED CONDITIONS, WHICH IS THE COMPOUNDED-SEMAGLUTIDE QUESTION IN ONE PARAGRAPH. Commercially available product may be compounded for dispensing to individual patients provided the following conditions are met: (a) the commercial product is not reasonably available from normal distribution channels in a timely manner to meet patient’s needs; and (b) the prescribing practitioner has requested that the drug be compounded; or (c) if the compounded product is changed to produce for that patient a significant difference, as authorized by the prescriber, between the compounded drug and the comparable commercially available drug product, or if use of the compounded product is in the best interest of the patient; when a compounded product is to be dispensed in place of a commercially available product, the prescriber and patient shall be informed that the product will be compounded.

(16) fee splitting;

⛔ NEW MEXICO CLOSES THE ESTHETICIAN LIST, WHICH IS HOW THE MICRONEEDLING QUESTION IS ANSWERED. 16.34.5.12 ESTHETICIAN LICENSE: an esthetician license permits the practitioner to use cosmetic preparations on the skin for cleansing and stimulating, apply massage and manipulation techniques using the hands or mechanical apparatus, use specialized skin care and facial machines in applying facial treatments, apply cosmetic makeup preparations, and remove superfluous or unwanted hair from the body of a person by any means except electrolysis or other invasive techniques and shaving. An esthetician shall not perform any services other than those listed above. To do so may lead to revocation of the license or other disciplinary action by the board.

⛔ NEW MEXICO PUBLISHES THE COST OF ENTRY AS A FEE RULE, SO THIS IS THE PRICE RATHER THAN AN ESTIMATE. 16.34.14.8 FEES: The board or department, where applicable, may charge the following fees: A. Enterprise or establishment license (original): $200.00 B. Enterprise or establishment license (renewal): $50.00. A School license (original and renewal) is $500.00. Part 14 exists to set fees; the civil penalties in Part 15 are a different instrument and are not what it costs to open.

THE BASELINE IS A PHARMACIST AND A PRESCRIPTION. “No drug for which a prescription is required … shall be distributed or dispensed to any person EXCEPT UPON A PRESCRIPTION written by a person legally authorized to issue such prescription. SUCH DRUG SHALL BE COMPOUNDED OR DISPENSED BY A LICENSED PHARMACIST”, labeled with the dispensing establishment owner’s name and address, THE DATE COMPOUNDED, the prescription number, the prescriber, the patient’s name and address, and the directions for use.

⚠️ NEW YORK’S FEE RULE IS WRITTEN AS A LIST OF WHO MAY SHARE, AND A NON-CLINICAL OWNER IS NOT ON IT. Professional misconduct includes “PERMITTING ANY PERSON TO SHARE IN THE FEES FOR PROFESSIONAL SERVICES, OTHER THAN: A PARTNER, EMPLOYEE, ASSOCIATE IN A PROFESSIONAL FIRM OR CORPORATION, PROFESSIONAL SUBCONTRACTOR OR CONSULTANT AUTHORIZED TO PRACTICE MEDICINE, OR A LEGALLY AUTHORIZED TRAINEE PRACTICING UNDER THE SUPERVISION OF A LICENSEE.” Every permitted sharer is inside the practice or licensed to practice medicine.

The Board grades energy devices by how deep they act and who may therefore operate them. Class I (surface only — e.g. handheld LED) is not the practice of medicine and may be performed by trained non-licensed professionals such as aestheticians. Class II (non-ablative devices including IPL and non-ablative hair-removal lasers) and Class IIIa (low-risk devices such as low-level laser therapy) are also not the practice of medicine, but require trained non-licensed personnel to work under supervision. Class IIIb (medium-powered, upper dermis — e.g. Thermage) and Class IV (high-powered, dermis and deeper — e.g. CO2 resurfacing, deep RF, laser lipolysis) ARE the practice of medicine; Class IIIb requires licensed medical professionals or supervised personnel, and Class IV is restricted to licensed medical professionals exclusively.

💰 NEW YORK’S BUSINESS LICENSE IS CHEAP, AND THE STATUTE SAYS SO IN WORDS. “THE FEE FOR AN APPEARANCE ENHANCEMENT BUSINESS LICENSE SHALL BE SIXTY DOLLARS INITIALLY AND SIXTY DOLLARS FOR EACH RENEWAL THEREOF”, and the individual practitioner license — “NAIL SPECIALTY, WAXING, NATURAL HAIR STYLING, ESTHETICS OR COSMETOLOGY” — is “FORTY DOLLARS INITIALLY AND FOR EACH RENEWAL THEREOF THE FEE SHALL BE FORTY DOLLARS”. These are the cosmetology-side costs only; nothing here licenses the medical services a med spa sells.

NORTH CAROLINA DEFINES COMPOUNDING BROADLY ENOUGH TO CATCH A DILUTION. “Compounding” means “TAKING TWO OR MORE INGREDIENTS AND COMBINING THEM INTO A DOSAGE FORM OF A DRUG, EXCLUSIVE OF COMPOUNDING BY A DRUG MANUFACTURER, DISTRIBUTOR, OR PACKER.” No exception for reconstitution to the label, and no minimum quantity — two ingredients into a dosage form is the whole test.

⚠️ NORTH CAROLINA GIVES REFERRAL FEES THEIR OWN ARTICLE, AND IT REACHES CORPORATIONS BY NAME. “A HEALTH CARE PROVIDER SHALL NOT FINANCIALLY COMPENSATE IN ANY MANNER A PERSON, FIRM, OR CORPORATION FOR RECOMMENDING OR SECURING THE HEALTH CARE PROVIDER’S EMPLOYMENT BY A PATIENT, OR AS A REWARD FOR HAVING MADE A RECOMMENDATION RESULTING IN THE HEALTH CARE PROVIDER’S EMPLOYMENT BY A PATIENT.” “IN ANY MANNER” is the operative phrase — the form of the payment does not matter.

NORTH CAROLINA’S STATUTORY DEFINITION OF ESTHETICS WAS READ IN FULL AND REACHES THE SURFACE ONLY. It covers “GIVING FACIALS; APPLYING MAKEUP; PERFORMING SKIN CARE”, hair removal “BY USE OF CREAMS, TWEEZERS, OR WAXING”, eyelash work, beautifying “BY USE OF COSMETIC PREPARATIONS, ANTISEPTICS, TONICS, LOTIONS, OR CREAMS”, “SURFACE MANIPULATION IN RELATION TO SKIN CARE”, and “CLEANING OR STIMULATING” the body “BY MEANS OF HANDS, DEVICES, APPARATUS, OR APPLIANCES ALONG WITH THE USE OF COSMETIC PREPARATIONS, ANTISEPTICS, TONICS, LOTIONS, OR CREAMS.” Every device use in the definition is paired with a topical preparation; no act of puncturing appears. An absence in the definition.

💰 NORTH CAROLINA’S COSMETIC ART FEES ARE LOW AND STATUTORY. The Board may charge application fees of “INSPECTION OF A NEWLY ESTABLISHED COSMETIC ART SHOP $25.00” and “RECIPROCITY APPLICANT UNDER G.S. 88B-13 $15.00”, and license fees including “ESTHETICIAN $10.00 PER YEAR” and “COSMETOLOGIST $39.00 EVERY 3 YEARS”. The Board may also charge “THE ACTUAL COST OF PREPARATION, ADMINISTRATION, AND GRADING OF EXAMINATIONS … IN ADDITION TO ITS OTHER FEES”, so the examination cost is not fixed by the statute.

⛔ NORTH DAKOTA ANSWERS THE COMPOUNDED-SEMAGLUTIDE QUESTION IN THE DEFINITION, AND NEITHER LIMB REACHES A CLINIC BUYING STOCK. "Compounding" means the preparation, mixing, assembling, packaging, or labeling of a drug or device: a. As the result of a practitioner's prescription drug order or initiative based on the practitioner, patient, and pharmacist relationship in the course of professional practice; or b. For the purpose of, or as an incident to, research, teaching, or chemical analysis and not for sale or dispensing. Limb (a) needs a prescription order resting on the practitioner-patient-pharmacist relationship; limb (b) is research and is expressly not for sale or dispensing.

The payment or receipt, directly or indirectly, of any fee, commission, rebate, or other compensation for medical services not actually or personally rendered, or for patient referrals;

"Advanced esthetics" means the practice of advanced cosmetic preparations or procedures using the hands or a mechanical or electronic apparatus for esthetic purposes. a. The term includes: (1) Advanced chemical peels; (2) Microneedling; (3) Nonablative procedures; and (4) Extractions using lancets. b. The term does not include: (1) Procedures to treat a medical, physical, or mental ailment; or (2) Ablative esthetic procedures.

⛔ NORTH DAKOTA CAPS THE COST OF ENTRY IN STATUTE RATHER THAN SETTING IT, WHICH IS A DIFFERENT ANSWER AND HAS TO BE READ AS ONE. Fees to be paid by applicants as required under this chapter may not exceed the following amounts: a. Fees: MAXIMUM FEE: (1) Establishment, original license $150.00 (2) Establishment, annual renewal $100.00 per year These are ceilings the board may not exceed, not the amounts actually charged — the board sets the real figure beneath them by rule, so an operator should treat $150.00 as the most an establishment license can cost, not the price.

⚠️ OHIO DOES LICENSE THE PREMISES — JUST NOT THROUGH THE MEDICAL BOARD. A manufacturer, OUTSOURCING FACILITY, third-party logistics provider, repackager or wholesale distributor may sell or distribute dangerous drugs only to A LICENSED TERMINAL DISTRIBUTOR OF DANGEROUS DRUGS, or to a person exempt from that licensure under § 4729.541. Whether a med spa may take delivery of a drug at all turns on which of those two it is.

⚠️ OHIO MAKES THE DIVISION OF FEES FOR REFERRAL A DISCIPLINARY GROUND, AND REACHES BEYOND MONEY. It is grounds for discipline to engage in “THE DIVISION OF FEES FOR REFERRAL OF PATIENTS, OR THE RECEIVING OF A THING OF VALUE IN RETURN FOR A SPECIFIC REFERRAL OF A PATIENT TO UTILIZE A PARTICULAR SERVICE OR BUSINESS”. “A thing of value” and “a particular service or business” together catch reciprocal arrangements that never involve a fee at all.

OHIO’S STATUTORY DEFINITION OF ESTHETICS WAS READ IN FULL AND AUTHORIZES NOTHING THAT BREAKS THE SKIN. “PRACTICE OF ESTHETICS” MEANS “THE APPLICATION OF COSMETICS, TONICS, ANTISEPTICS, CREAMS, LOTIONS, OR OTHER PREPARATIONS FOR THE PURPOSE OF SKIN BEAUTIFICATION AND INCLUDES PREPARATION OF THE SKIN BY MANUAL MASSAGE TECHNIQUES OR BY USE OF ELECTRICAL, MECHANICAL, OR OTHER APPARATUS; ENHANCEMENT OF THE SKIN BY SKIN CARE, FACIALS, BODY TREATMENTS, HAIR REMOVAL, AND OTHER TREATMENTS; AND EYE LASH EXTENSION SERVICES.” Microneedling is not named, and neither is any act of puncturing. This is an absence in the definition, not a finding that Ohio prohibits it.

💰 OHIO SETS ITS COSMETOLOGY FEES AS CEILINGS, NOT FIXED PRICES. The board “SHALL CHARGE AND COLLECT THE FOLLOWING NONREFUNDABLE FEES”, each written as a maximum: “FOR THE ISSUANCE OF A NEW SALON LICENSE OR THE CHANGE OF NAME OR OWNERSHIP OF A SALON LICENSE … NOT MORE THAN ONE HUNDRED DOLLARS”; “FOR THE RENEWAL OF A SALON LICENSE … NOT MORE THAN NINETY DOLLARS”; “FOR THE ISSUANCE OF A LICENSE BY EXAMINATION … NOT MORE THAN SEVENTY-FIVE DOLLARS”; and “FOR INITIAL APPLICATION TO TAKE AN EXAMINATION … NOT MORE THAN FORTY DOLLARS”. A change of OWNERSHIP is priced the same as a new salon license — buying an existing spa is not the cheaper paperwork it looks like.

⛔ OKLAHOMA ANSWERS THE COMPOUNDED-SEMAGLUTIDE QUESTION IN THE PHARMACY ACT’S DEFINITIONS, AND ITS DEFINITION IS BROADER THAN MOST. "Compounding" means the combining, admixing, mixing, diluting, pooling, reconstituting or otherwise altering of a drug or bulk drug substance to create a drug. Compounding includes the preparation of drugs or devices in anticipation of prescription drug orders based on routine, regularly observed prescribing patterns The definition does not turn on an individual patient’s specialized need, and it expressly reaches stock prepared ahead of the order — but the anticipation must rest on prescribing already observed, not on expected demand.

The obtaining of any fee or offering to accept any fee, present or other form of remuneration whatsoever, on the assurance or promise that a manifestly incurable disease can or will be cured;

Scope of practice for Cosmetologists and Facialists/Estheticians: cosmetology expressly does not include services that puncture the skin or that are within the scope of practice of the healing arts pursuant to 59 O.S., § 199.1 and OAC 175:1 - 1 - 2. “puncturing the skin” is defined as perforating the skin by any means, including, but not limited to: (C) Microneedling or “collagen induction treatment or therapy,” which is a procedure that uses a multi - needled device to create microchannels in the skin at a depth greater than 0.25 mm to stimulate the body’s natural healing process while minimizing cellular damage;

⛔ OKLAHOMA PUBLISHES THE WHOLE COST OF ENTRY AS A STATUTORY FEE SCHEDULE, SO THIS IS AN ANSWER RATHER THAN AN ESTIMATE. SECTION 199.14 FEES A. The following fees shall be charged by the State Board of Cosmetology and Barbering: The schedule that follows sets a Cosmetology establishment license at $120.00 biennially and $90.00 on biennial renewal, a Cosmetic Studio license at the same $120.00 and $90.00, and the individual Facial/Esthetics operator license at $80.00 biennially. Premises and practitioner are billed separately, so a single-operator studio pays both.

“Manufacture” means the production, preparation, propagation, compounding, conversion or processing of a device or a drug, either directly or indirectly by extraction from substances of natural origin or independently by means of chemical synthesis or by a combination of extraction and chemical synthesis and includes any packaging or repackaging of the substances or labeling or relabeling of its container, except that this term does not include the preparation or compounding of a drug by an individual for their own use or the preparation, compounding, packaging or labeling of a drug: (a) By a practitioner as an incident to administering or dispensing of a drug in the course of professional practice.

An esthetician is limited to performing services with mechanical or electric apparatuses, appliances, or devices that do not penetrate beyond the epidermis except through natural physiological effects as defined in OAR 817-015-0045. An esthetician may use mechanical or electrical apparatuses, appliances, or devices that include, but are not limited to, the following: (f) Mechanical or electrical apparatuses, appliances, or devices used for nanoneedling, microneedling, and similar procedures;

Fees established by the Office, in consultation with the Board, are as follows: (a) Application: (A) Practitioner certificate: $30 per field of practice. (E) Facility license: $140. (c) Original issuance of authorization to practice: (A) Practitioner certificate: $35 for two years. (E) Facility license: $155 for one year.

⚠️ AND THE PROHIBITION IS THE WHOLE GLP-1 QUESTION IN ONE CLAUSE. “Pharmacists MAY NOT COMPOUND … DRUGS THAT ARE ESSENTIALLY COPIES OF A COMMERCIALLY AVAILABLE DRUG PRODUCT, except as provided in section 503a(b)(1)(D) of the Federal Food, Drug, and Cosmetic Act.” Where the branded GLP-1 can be obtained, a compounded version of it is an essential copy and Pennsylvania forbids compounding it — no quantity limit or supervision arrangement cures that.

⚠️ THE MEDICAL PRACTICE ACT OF 1985 WAS READ IN FULL AND CONTAINS NO FEE-SPLITTING PROHIBITION. Section 41 lists the reasons the board may discipline a practitioner, and neither that list nor any other section of the Act uses the words “fee splitting”, “division of fees”, “rebate”, “kickback” or “remuneration” — in a document that says “fee” 34 times, all of them about license and application fees. This is an absence in the Act; it is not a statement that no Pennsylvania law reaches the arrangement.

PENNSYLVANIA’S DEFINITION OF ESTHETICS WAS READ IN FULL AND DESCRIBES SURFACE WORK ONLY. It is “THE PRACTICE OF MASSAGING THE FACE, APPLYING COSMETIC PREPARATIONS, ANTISEPTICS, TONICS, LOTIONS OR CREAMS TO THE FACE, REMOVING SUPERFLUOUS HAIR BY TWEEZERS, DEPILATORIES OR WAXES, EYELASH PERMING AND THE DYEING OF EYELASHES AND EYEBROWS”, and “THE TERM INCLUDES THE USE OF INDUSTRY STANDARD MECHANICAL AND ELECTRICAL APPARATUS AND APPLIANCES IN THE PRACTICE OF ESTHETICS.” The apparatus clause carries no depth or penetration language, and nothing in the definition describes puncturing skin. An absence in this definition.

💰 PENNSYLVANIA’S COSMETOLOGY FEES ARE PUBLISHED AS A TWO-COLUMN TABLE — “EFFECTIVE NOVEMBER 5, 2022” and “EFFECTIVE JULY 1, 2024” — so the second figure in each row is the one now charged. On initial application the rows read “Esthetician $25 $26” and “Cosmetology salon or limited practice salon $135 $142”; on biennial renewal, “Esthetician $82 $97” and “Cosmetology salon or limited practice salon $129 $144”. Changing the salon is charged separately: “Change in cosmetology salon or limited practice salon (inspection required) $100 $105”.

⛔ RHODE ISLAND ANSWERS THE COMPOUNDED-SEMAGLUTIDE QUESTION WITH A SENTENCE ABOUT COPIES. Compounding does not mean the routine preparation, mixing, or assembling of drug products that are essentially copies of a commercially available product. Semaglutide and tirzepatide are commercially available products, so a compounded version prepared as a routine copy of one falls outside what Rhode Island calls compounding at all.

Unprofessional conduct includes dividing fees or agreeing to split or divide the fees received for professional services for any person for bringing to or referring a patient.

“Esthetics” means the practice of cleansing, stimulating, manipulating, and beautifying skin, including, but not limited to, the treatment of such skin problems as dehydration, temporary capillary dilation, excessive oiliness, and clogged pores.

Fees payable to the department shall be as follows: Barbers/hairdressers 5-10-10(a) Renewal application $25.00; Barbers/hairdressers 5-10-11[c] Application fee $25.00; Barbers/hairdressers 5-10-15 Shop license: initial $170.00 Barbers/hairdressers 5-10-15 Shop license: renewal $170.00.

"Outsourcing facility" means a facility registered with the United States Food and Drug Administration to operate under Section 503B of the federal Food and Cosmetic Act.

⚠️ SOUTH CAROLINA STATES NO FEE-SPLITTING PROHIBITION IN THE CHAPTERS THAT WOULD CARRY ONE. A survey of the Board of Medical Examiners' enumerated misconduct grounds (§40-47-110(B), read in full), the definitions section of the Medical Practice Act (§40-47-20), the Professional Association Act (Chapter 19 of Title 33) and the Cosmetology chapter (Chapter 13 of Title 40) returns no provision on fee-splitting, dividing a fee, rebates, kickbacks, or paying a commission for a referral. South Carolina restricts WHO MAY OWN a professional corporation and does not separately regulate how revenue is shared with a non-clinical manager. An operator should read this as an absence in these four chapters, not as permission: §40-47-110(B)(9) still reaches "dishonorable, unethical, or unprofessional conduct", which the board applies case by case.

⚠️ SOUTH CAROLINA DEFINES THE ESTHETICIAN BY PURPOSE, AND THE PURPOSE IS THE SURFACE OF THE SKIN. "Esthetician" means a person including, but not limited to, an independent contractor, who is licensed to practice skin care, make-up, or similar work. Skin care is for the sole purpose of beautifying the skin. Nothing in that definition reaches puncturing the skin, and microneedling is not named anywhere in Chapter 13. An operator should read this as the limit of the COSMETOLOGY license, not as a statewide ban — the medical side of the line is §40-47-20(36).

The Board of Cosmetology’s published fee schedule: License Type Examination Endorsement Renewal Reinstatement Registered Cosmetologist $45 $60 $52 $152 Nail Technician $45 $60 $52 $152 Esthetician $45 $60 $52 $152 License Type Initial Application Fee Renewal Fee Reinstatement Fee Salon $100 $72 #122 Booth Renter $100 $72 #122 School $300 $122 $172 Initial applications and reinstatements applications require an inspection.

⛔ SOUTH DAKOTA ANSWERS THE COMPOUNDED-SEMAGLUTIDE QUESTION IN THE DEFINITION, AND THE SECOND LIMB RULES OUT THE COMMERCIAL ROUTE ON ITS FACE. "Compounding," the preparation, mixing, assembling, packaging, or labeling of a drug or drug device, as the result of a practitioner's prescription drug order or an initiative based on the pharmacist, patient, and practitioner relationship in the course of professional practice, or for the purpose of or as an incident to research, teaching, or chemical analysis, and not for sale or dispensing. A compounded preparation must answer a prescription drug order resting on the pharmacist-patient-practitioner relationship; the only alternative limb is research, and it excludes sale and dispensing.

The term, unprofessional or dishonorable conduct, as used in this chapter includes: Splitting fees or giving to any person furnishing a patient any portion of the fees received from the patient or paying or giving to any person consideration of any kind for furnishing a patient.

A person is engaged in the practice of esthetics if that person, for compensation, a fee, or any valuable consideration, engages in beautifying, massaging, cleansing, exfoliating, stimulating, or applying oils, creams, cosmetic preparations, make-up, facial treatments, body treatments, body wraps, antiseptics, scrubs, clays, lotions, masks, waxes, or other preparations for the noninvasive care of the skin. For purposes of this subdivision, noninvasive means confined to the nonliving cells of the stratum corneum of the epidermis. Such practices shall be in a superficial mode and not for the treatment of medical disorders, and living cells may never be altered, cut, or damaged.

⛔ SOUTH DAKOTA WRITES ITS FEES IN WORDS RATHER THAN FIGURES, WHICH IS WHY A SEARCH FOR DOLLAR SIGNS FINDS NOTHING AND THE SCHEDULE LOOKS ABSENT. (12) Salon or booth initial license fee, seventy-five dollars ; (13) Salon or booth license renewal fee, fifty-five dollars Opening a salon or booth costs seventy-five dollars and renewing it fifty-five — the premises charge, separate from the practitioner’s own license.

TENNESSEE BINDS STERILE COMPOUNDING TO USP AND SAYS SO TWICE. “ALL STERILE PRODUCTS SHALL BE PREPARED IN COMPLIANCE WITH APPLICABLE USP STANDARDS FOR PHARMACEUTICAL COMPOUNDING”, and separately “ANY FACILITY THAT COMPOUNDS STERILE PRODUCTS SHALL COMPLY WITH APPLICABLE USP STANDARDS.” Compounded injectables are sterile products, so USP is the operative standard behind any compounded GLP-1 a Tennessee practice administers.

⚠️ TENNESSEE’S FEE GROUND IS ONE LINE, AND ITS BREADTH IS THE POINT. Grounds for discipline include “GIVING OR RECEIVING, OR AIDING OR ABETTING THE GIVING OR RECEIVING, OF REBATES, EITHER DIRECTLY OR INDIRECTLY.” The statute does not define “rebate”, does not limit it to referrals, and reaches the party who merely assists — so a marketing or management arrangement that returns part of a treatment price is judged against a term with no stated boundary.

TENNESSEE’S DEFINITION OF AESTHETICS WAS READ IN FULL AND IS THREE SURFACE PRACTICES. “AESTHETICS” MEANS “MASSAGING, CLEANSING, STIMULATING, MANIPULATING, EXERCISING, BEAUTIFYING OR SIMILAR WORK WITH HANDS OR MECHANICAL OR ELECTRICAL APPARATUS OR BY THE USE OF COSMETIC PREPARATIONS, ANTISEPTICS, TONICS, LOTIONS OR CREAMS”; “PLACING OR APPLYING ARTIFICIAL EYELASHES”; or “GIVING FACIALS, APPLYING MAKEUP, GIVING SKIN CARE OR REMOVING SUPERFLUOUS HAIR BY TWEEZING, DEPILATORIES OR WAXING”. No act of puncturing appears, and the apparatus clause sets no depth. An absence in this definition, not a finding that Tennessee prohibits microneedling.

Any medical spa offering cosmetic medical services in Tennessee MUST REGISTER with the Board of Medical Examiners, before operation or within sixty calendar days of the rule taking effect. Registration is by application to Board staff with a non-refundable Medical Spa Registration Fee.

⚠️ TEXAS PERMITS OFFICE-USE COMPOUNDING OUTRIGHT, WHICH FEW STATES DO. “A PHARMACY MAY DISPENSE AND DELIVER A REASONABLE QUANTITY OF A COMPOUNDED DRUG TO A PRACTITIONER FOR OFFICE USE BY THE PRACTITIONER in accordance with this chapter.” There is no commercial-availability condition and no patient-specific prescription requirement — the limit is the phrase “reasonable quantity”.

⚠️ IN TEXAS PAYING FOR PATIENTS IS A CRIME, NOT A BOARD MATTER. “A PERSON COMMITS AN OFFENSE if the person knowingly OFFERS TO PAY OR AGREES TO ACCEPT, DIRECTLY OR INDIRECTLY, OVERTLY OR COVERTLY ANY REMUNERATION IN CASH OR IN KIND OR ANY BENEFIT OR COMMISSION TO OR FROM ANOTHER FOR SECURING OR SOLICITING A PATIENT OR PATRONAGE” for or from a person licensed by a state health care regulatory agency. “PATRONAGE” is wider than patients, and “any benefit” is wider than money.

⚠️ TEXAS DRAWS THE ESTHETICIAN LINE AT LIVING TISSUE, AND MICRONEEDLING IS A DEVICE THAT PUNCTURES IT. TDLR states the test twice. On exfoliation: a treatment that “DOES NOT PIERCE THE DERMAL LAYER OF SKIN” is within scope, while treatments that “CONTACT OR PENETRATE THE DERMIS (LIVING TISSUE) DO NOT FALL WITHIN THE SCOPE OF AN ESTHETICIAN OR COSMETOLOGY OPERATOR LICENSE AND MUST BE ADMINISTERED OR DELEGATED BY A PHYSICIAN.” On peels, the same line: those that “PENETRATE THE DERMIS (LIVING TISSUE) AND ARE CONSIDERED MEDICAL PROCEDURES REGULATED BY THE TEXAS MEDICAL BOARD.” TDLR’S GUIDANCE DOES NOT NAME MICRONEEDLING — it states a depth test, and a needle depth is the operator’s setting.

💰 TEXAS PRICES THE PREMISES BY TYPE, AND LATE RENEWAL IS THE EXPENSIVE PART. TDLR publishes “Initial Application Fees” of “$50 for Practitioners (Class A Barbers, Cosmetology Operators & Specialty license holders)”, “$70 for Mini-Establishments” and “$78 for Barbering & Cosmetology (“Full-Service”) Establishment, Mobile & Specialty Establishments”. Practitioner renewal runs “$50 for On-time Renewals”, “$75 for Late Renewals (expired less than 18 months)”.

⛔ UTAH ANSWERS THE COMPOUNDED-SEMAGLUTIDE QUESTION BY EXCLUSION, AND THE EXCLUSION IS THE SHARPEST ON THIS PASS. "Compounding" does not include the preparation by a pharmacist or pharmacy intern of any prescription drug in a dosage form which is regularly and commonly available from a manufacturer in quantities and strengths prescribed by a practitioner Semaglutide and tirzepatide are regularly and commonly available from their manufacturers, so preparing them in the marketed dosage form is not compounding in Utah at all — it falls outside the definition rather than inside it on conditions.

directly or indirectly giving or receiving any fee, commission, rebate, or other compensation for professional services not actually and personally provided or supervised; however, nothing in this section shall preclude the legal relationships within lawful professional partnerships, corporations, or associations or the relationship between an approved supervising physician and physician assistants or advanced practice nurses supervised by them;

the supervisor supervising the procedure shall: (i) have an unrestricted license to practice medicine or advanced practice registered nursing; (ii) personally perform the nonablative cosmetic medical procedure or: (A) authorize and provide general cosmetic medical procedure supervision for the nonablative cosmetic medical procedure that is performed by a registered nurse or a master esthetician; or (B) authorize and provide supervision as provided in Chapter 70a, Utah Physician Assistant Act, for the nonablative cosmetic medical procedure that is performed by a physician assistant; and (C) authorize and provide direct cosmetic medical procedure supervision for the nonablative cosmetic medical procedure that is performed by an esthetician or a practical nurse;

The Division of Occupational and Professional Licensing’s fee schedule (initial application, then renewal): Esthetician N/A $60.00 $52.00 Esthetician Esthetician Apprentice $20.00 $20.00 Esthetician Esthetician Instructor $60.00 N/A Esthetician Esthetician School $110.00 $110.00 Esthetician Basic Esthetics Permit $60.00 $52.00 Esthetician Master Esthetician $85.00 $68.00; Cosmetology N/A $60.00 $52.00

Vermont licenses compounding and 503B outsourcing as classes of drug outlet: Each drug outlet shall apply for a license in one or more of the following classifications: (1) Retail. (2) Institutional. (3) Manufacturer. (4) Wholesale distributor. (5) Investigative and research projects. (6) Compounding. (7) Outsourcing. (8) Home infusion. (9) Nuclear. (10) Third-party logistics provider.

The Board shall find that the following constitutes unprofessional conduct: division of fees or agreeing to split or divide the fees received for professional services for any person for bringing to or referring a patient

Esthetics means services related to skin-care treatments to enhance or improve the appearance of the skin, including cleansing, toning, stimulating, manipulating, beautifying, exfoliating, or performing any similar procedure on the human body using only cosmetic preparations, hands, mechanical or electrical apparatus or appliances, tonics, lotions, creams, or makeup; beautifying lashes and brows; and removing unwanted hair using manual and mechanical means.

Unless otherwise provided by law, the following fees shall apply to all professions regulated by the Director in consultation with advisor appointees under Title 26: Application for licensure or certification, $115.00, except application for: (A) Barbering or cosmetology schools and shops, $355.00. (L) Barbers, cosmetologists, nail technicians, and estheticians, $120.00.

VIRGINIA COMPOUNDS PATIENT BY PATIENT, AND TIES IT BACK TO THE EXAMINATION DUTY. A pharmacist may compound when dispensing is “(i) PURSUANT TO VALID PRESCRIPTIONS FOR SPECIFIC PATIENTS and (ii) CONSISTENT WITH THE PROVISIONS OF § 54.1-3303 relating to the issuance of prescriptions and the dispensing of drugs” — which is the bona fide practitioner-patient relationship, examination included. The two questions are one question in Virginia.

⚠️ VIRGINIA’S REMUNERATION BAN IS REAL BUT NARROWLY TARGETED — READ THE OBJECT OF THE REFERRAL. “No practitioner of the healing arts shall KNOWINGLY AND WILLFULLY SOLICIT OR RECEIVE ANY REMUNERATION DIRECTLY OR INDIRECTLY, IN CASH OR IN KIND, IN RETURN FOR REFERRING AN INDIVIDUAL OR INDIVIDUALS TO A FACILITY OR INSTITUTION as defined in § 37.2-100 OR A HOSPITAL as defined in § 32.1-123.” It reaches referrals to those defined places, not every payment between a practice and a marketer.

⚠️ VIRGINIA SETTLES THIS BY DEFINITION RATHER THAN BY NAMING THE PROCEDURE. “ESTHETICS IS NOT A HEALING ART AND SHALL NOT INCLUDE ANY PRACTICE, ACTIVITY, OR TREATMENT THAT CONSTITUTES THE PRACTICE OF MEDICINE, OSTEOPATHIC MEDICINE, OR CHIROPRACTIC.” The licensed acts are surface acts — “CLEANSING, TONING, PERFORMING EFFLEURAGE OR OTHER RELATED MOVEMENTS, STIMULATING, EXFOLIATING, OR PERFORMING ANY OTHER SIMILAR PROCEDURE ON THE SKIN” — and every device permitted is qualified as “ANY NONLASER DEVICE.” Microneedling is nowhere in the definition, so the question in Virginia is whether puncturing skin is the practice of medicine, not whether an esthetics license lists it.

💰 VIRGINIA’S ESTHETICS FEES ARE FLAT, NONREFUNDABLE, AND DOUBLE IF YOU LET THE LICENSE LAPSE. “All fees are nonrefundable and will not be prorated.” For “Individuals”, Application $120, Renewal $120, and Reinstatement $240 — the schedule spells out that this “includes $120 renewal fee and $120 reinstatement fee”. For “Spas” the premises license is Application $220, Renewal $220, Reinstatement $440. Letting either lapse costs exactly twice the renewal, which is the cheapest avoidable expense in this corpus.

⚠️ AND WASHINGTON EXPRESSLY CONTEMPLATES OFFICE STOCK, THEN BINDS IT TO USP. “Any medicinal products that are compounded FOR PATIENT ADMINISTRATION OR DISTRIBUTION TO A LICENSED PRACTITIONER FOR PATIENT USE OR ADMINISTRATION shall, AT A MINIMUM, MEET THE STANDARDS OF THE OFFICIAL UNITED STATES PHARMACOPEIA as it applies to nonsterile products and STERILE ADMINISTERED PRODUCTS.” Distribution to a practitioner for office use is assumed lawful by the text; what the statute regulates is the standard it must meet.

⚠️ WASHINGTON’S REBATE BAN REACHES THE SALE OF THE DRUG ITSELF, NOT JUST REFERRALS. It is unlawful to pay or allow, or for a licensee to request or receive, “DIRECTLY OR INDIRECTLY, A REBATE, REFUND, COMMISSION, UNEARNED DISCOUNT OR PROFIT BY MEANS OF A CREDIT OR OTHER VALUABLE CONSIDERATION IN CONNECTION WITH THE REFERRAL OF PATIENTS … OR … ON THE SALE, RENTAL, FURNISHING OR SUPPLYING OF … DRUGS, MEDICATION, OR MEDICAL SUPPLIES, OR ANY OTHER GOODS, SERVICES OR SUPPLIES PRESCRIBED FOR MEDICAL DIAGNOSIS, CARE OR TREATMENT.”

⚠️ WASHINGTON HAS TWO ESTHETICS LICENSES, AND THE ANSWER DIFFERS BETWEEN THEM. The ordinary “PRACTICE OF ESTHETICS” is surface work — “SUPERFICIAL AND LIGHT PEELS”, “SUPERFICIAL SKIN STIMULATION”, “PORE EXTRACTION”, by any device “EXCEPT LASER” — and it closes with a flat exclusion: “UNDER NO CIRCUMSTANCES DOES THE PRACTICE OF ESTHETICS INCLUDE THE ADMINISTRATION OF INJECTIONS.”

💰 WASHINGTON’S LICENSING AGENCY PUBLISHES ITS FEES AS A TABLE, AND THE PREMISES COST MORE THAN THE PERSON. Under “Professional license fees” the columns are Get a license / Reciprocity / Renew / Late renewal, and the rows read “Esthetician $35 $60 $66 $131” and “Master esthetics $35 $60 $66 $131” — identical for both tiers. The premises row is “Salon/Shop $121 N/A $121 $181”, with “Personal Service $121 N/A $121 $181” for work done at a client’s location. Late renewal roughly doubles each figure.

⛔ WEST VIRGINIA PUTS THE SALE CONDITION INSIDE THE FIRST LIMB RATHER THAN LEAVING IT TO INFERENCE. “Compounding” means: (A) The preparation, mixing, assembling, packaging, or labeling of a drug or device: (i) As the result of a practitioner’s prescription drug order or initiative based on the practitioner/patient/pharmacist relationship in the course of professional practice for sale or dispensing; or (ii) For the purpose of, or as an incident to, research, teaching, or chemical analysis and not for sale or dispensing Compounding may be for sale or dispensing ONLY on limb (i) — which requires a prescription drug order resting on the practitioner/patient/pharmacist relationship. The research limb (ii) is expressly not for sale or dispensing, so it is no route to stock.

The board may discipline a physician or podiatrist adjudged unqualified due to requesting, receiving, or paying directly or indirectly a payment, rebate, refund, commission, credit, or other form of profit or valuable consideration for the referral of patients to any person or entity in connection with providing medical or other health care services or clinical laboratory services, supplies of any kind, drugs, medication, or any other medical goods, services, or devices used in connection with medical or other health care services.

⛔ WEST VIRGINIA ENUMERATES WHAT AESTHETICS IS, SO THE MICRONEEDLING ANSWER IS READ OFF THE LIST RATHER THAN INFERRED. “Aesthetics” or “esthetics” means any one or any combination of the following acts when done on the human body for compensation and not for the treatment of disease: (1) Administering cosmetic treatments to enhance or improve the appearance of the skin, including cleansing, toning, performing effleurage or other related movements, stimulating, exfoliating, or performing any other similar procedure on the skin of the human body or scalp; The list is closed — "any one or any combination of the following acts" — and every act on it is worked ON the skin. Microneedling punctures it. Nothing in this definition describes penetrating the skin, and the whole definition is bounded by "not for the treatment of disease".

This legislative rule establishes the various fees that are to be submitted to the Board of Barbers and Cosmetologists by students, instructors, and owners and operators of schools of barbering and cosmetology and owners of barber, cosmetology, nail technology, hair styling, waxing, and aesthetic salons. 2.13 Salon or school opening inspection fee $50.00; 2.15 Initial license fee for cosmetology, barber, nail technology, hair styling, waxing, and aesthetic salon $40.00 2.16 Annual renewal fee for cosmetology, barber, nail technology, hair styling, waxing, and aesthetic salon $40.00.

WISCONSIN LETS THE PRACTITIONER COMPOUND, WHICH MANY STATES DO NOT. “No person other than A PHARMACIST OR PRACTITIONER OR THEIR AGENTS AND EMPLOYEES AS DIRECTED, SUPERVISED, AND INSPECTED BY THE PHARMACIST OR PRACTITIONER, including pharmacy technicians, MAY PREPARE, COMPOUND, DISPENSE, OR PREPARE FOR DELIVERY FOR A PATIENT ANY PRESCRIPTION DRUG.” Three verbs govern the delegate — directed, supervised AND inspected — so an unsupervised staff member preparing an injectable is outside the statute.

⚠️ WISCONSIN’S FEE-SPLITTING BAN HAS TWO LIMBS AND THE SECOND IS THE ONE A MED SPA TRIPS OVER. No licensee “may GIVE OR RECEIVE, DIRECTLY OR INDIRECTLY, to or from any person, firm or corporation ANY FEE, COMMISSION, REBATE OR OTHER FORM OF COMPENSATION OR ANYTHING OF VALUE FOR SENDING, REFERRING OR OTHERWISE INDUCING A PERSON TO COMMUNICATE WITH A LICENSEE IN A PROFESSIONAL CAPACITY, OR FOR ANY PROFESSIONAL SERVICES NOT ACTUALLY RENDERED PERSONALLY OR AT HIS OR HER DIRECTION.” Paying anyone out of professional fees for work the licensee neither performed nor directed is fee splitting, referral or no referral.

✅ WISCONSIN ANSWERS THIS DIRECTLY — AND IT IS ONE OF THE FEW THAT DOES. Microneedling is listed by name as a DELEGATED MEDICAL PROCEDURE, and the rule that governs those says licensees “MAY PROVIDE CLIENT SERVICES CONSTITUTING MEDICAL PROCEDURES ONLY AS DIRECTED, SUPERVISED AND INSPECTED BY A PHYSICIAN WHO HAS THE POWER TO DIRECT, DECIDE AND OVERSEE THE IMPLEMENTATION OF THE CLIENT SERVICES PROVIDED IN LICENSED ESTABLISHMENTS.” So an esthetician may perform it, but only under that physician relationship — not on an esthetics license alone.

💰 WISCONSIN’S RENEWAL FEES ARE THE LOWEST IN THIS CORPUS, AND THE LATE PENALTY IS MORE THAN TRIPLE THE FEE. The Department’s schedule of “Renewal Dates and Fees” has columns “Renewal Date”, “*Renewal Fee” and “With Late Fee”, and the three rows a med spa needs are identical: “Aesthetician 03/31/odd year $11 $36”, “Aesthetics Establishment 03/31/odd year $11 $36” and “Aesthetics School 03/31/odd year $11 $36”. Note the common renewal date — every aesthetics credential in the state expires on the same day of the same odd year, so a lapse hits the practitioner and the premises at once.

⛔ WYOMING'S PHARMACY RULES REFUSE THE ORDER A MED SPA WOULD USE TO STOCK COMPOUNDED SEMAGLUTIDE. A prescription may not be dispensed to a practitioner based on an order that is not issued for one specific patient. A prescription order for "office use" is not a valid order.

Within the esthetics scope of practice: (v) Procedures which pierce the epidermal or dermal layer of the skin are considered invasive and are prohibited. (vi) Using the term or title of "Medical Esthetician" is not allowed.

The Board has established the following schedule of non-refundable fees: (a) Hands on practical examination fee $50.00 (b) Personal license fee to include: Cosmetologist, Nail Technician, Esthetician, Hairstylist, and Instructors $ 48.00 per year (c) Independent contractor license $ 75.00 per year (d) Salon license $ 75.00 per year (e) Salon application fee $225.00 (f) Salon relocation fee $225.00