May an esthetician or laser technician perform microneedling in Ohio?

The rest of what Ohio says on this

Every other rule we have verified under physician supervision & delegation, each linked to its primary source.

• Applying a light-based medical device to the human body is itself the practice of medicine and surgery, osteopathic medicine and surgery, or podiatric medicine and surgery. Everything a non-physician does with one of these devices in Ohio is therefore a delegation from a physician, and is lawful only to the extent a specific rule permits it.

  Ohio Admin. Code 4731-18-02(A) · verified Sep 1, 2026

• A physician shall not delegate the application of light based medical devices for ablative procedures. This is the one absolute in the chapter: there is no training, certification or supervision arrangement that makes an ablative treatment delegable to anyone, and none of the carve-outs for vascular lasers, hair removal or phototherapy reaches ablative work.

  Ohio Admin. Code 4731-18-02(B) · verified Sep 1, 2026

• And the line is drawn by depth. An “ablative dermatologic procedure” is one expected to excise, burn, or vaporize the skin BELOW the dermo-epidermal junction; a “non-ablative” procedure is one not expected or intended to excise, burn or vaporize the epidermal surface. Which side of that boundary a device is set to work on decides whether the treatment may be delegated at all.

  Ohio Admin. Code 4731-18-01(D) and (E) · verified Sep 1, 2026

• Delegating an ablative procedure is charged two ways at once: it is a departure from minimal standards of care under §4731.22(B)(6) whether or not the patient was injured, and it is aiding the unauthorized practice of medicine under §4731.22(B)(20) by reference to §4731.41.

  Ohio Admin. Code 4731-18-02(G) · verified Sep 1, 2026

• For a VASCULAR laser used non-ablatively, the delegate may only be a physician assistant with whom the physician has an effective supervision agreement, or a registered nurse or licensed practical nurse licensed under Chapter 4723. In this lane — and only this lane — a person holding none of those three licenses is ineligible however well trained. A “vascular laser” is one whose primary cutaneous targets are telangiectasia, venulectasia and superficial cutaneous vascular structures.

  Ohio Admin. Code 4731-18-03(A)(5), defined at 4731-18-01(J) · verified Sep 1, 2026

• Before a nurse may apply a vascular laser, the physician must ensure they have completed eight hours of basic education covering light-based procedure physics, tissue interaction, safety and proper safety equipment, clinical application, pre- and post-operative care and adverse event reporting; observed fifteen procedures of that specific type; and performed twenty procedures of that type under the physician’s direct physical oversight — meaning the physician in the same room, observing.

  Ohio Admin. Code 4731-18-03(A)(7) · verified Sep 1, 2026

• The eight hours of basic education need be completed only once by the delegate, regardless of how many types of vascular laser procedure are delegated or how many physicians delegate them. The fifteen observations and twenty supervised procedures must be completed once for each specific type of vascular laser procedure delegated — again regardless of the number of delegating physicians. Moving to a new device restarts the count; moving to a new supervising physician does not.

  Ohio Admin. Code 4731-18-03(A)(7)(d) · verified Sep 1, 2026

• For a vascular laser the physician must provide on-site supervision at all times the nurse is applying it, and may supervise no more than TWO such people at the same time. This is the cap that applies to vascular work only — hair removal has its own, and it is higher.

  Ohio Admin. Code 4731-18-03(A)(8) and (A)(9) · verified Sep 1, 2026

• HAIR REMOVAL is governed by statute rather than by the vascular rule, and its list of eligible delegates is wider: a physician assistant under an effective supervision agreement, a LASER HAIR REMOVAL PROFESSIONAL, or a nurse. The laser hair removal professional is not a licensed health professional, which is the point — in this lane, and unlike the vascular lane, a trained non-licensee may lawfully operate the device.

  Ohio Rev. Code §4731.33(B)(3) · verified Sep 1, 2026

• A “laser hair removal professional” is an individual who either held a cosmetic therapist license under Chapter 4731 on 11 April 2021, or has completed a cosmetic therapy course of instruction of at least seven hundred fifty clock hours and passed the certified laser hair removal professional examination administered by the Society for Clinical and Medical Hair Removal. The delegating physician must also confirm the device is FDA-cleared for hair removal and that hair removal is within their own normal course of practice and expertise.

  Ohio Rev. Code §4731.33(B)(1), (B)(2) and (B)(3)(b) · verified Sep 1, 2026

• A laser hair removal professional must, before working under delegation, complete the same eight hours of basic education, observe fifteen procedures for each specific device procedure, and perform twenty under the physician’s direct physical oversight — unless they are exempt as someone who was lawfully delegated hair removal for at least two years before 30 September 2021, or held the pre-2021 cosmetic therapist license.

  Ohio Rev. Code §4731.33(D)(1) and (E) · verified Sep 1, 2026

• For hair removal the default is on-site supervision — the physician physically in the same location, though not necessarily the same room. Since HB 377 took effect on 26 August 2026 there is an OFF-SITE pathway: the physician need only be continuously available for direct communication, but only for an ESTABLISHED patient, and only where the delegate has qualified for it.

  Ohio Rev. Code §4731.33(F)(1), (F)(2), (G)(1), (G)(2); definitions at (A)(6) and (A)(7) · verified Sep 1, 2026

• Qualifying for off-site supervision differs by delegate. A laser hair removal professional must have completed a physician-approved course of at least fifty hours, of which at least thirty were clinical, and must have worked under that physician’s on-site supervision long enough for the physician to be satisfied they are competent unsupervised. A nurse must have completed a physician-approved training program of forty total hours, which may be run internally at the facility or by a third party overseen by a physician. Both must keep the documentation.

  Ohio Rev. Code §4731.33(F)(2) and (G)(2) · verified Sep 1, 2026

• In the hair-removal lane a physician may supervise no more than FIVE laser hair removal professionals at the same time, and separately no more than five nurses — whether the supervision is on-site or off-site. This is the staffing number for hair removal; applying the vascular rule’s cap of two here understates lawful capacity by more than half.

  Ohio Rev. Code §4731.33(F)(3) and (G)(3) · verified Sep 1, 2026

• The delegating physician must see and evaluate the patient before the device is first applied to determine the proposed application is appropriate, and must see and evaluate them again after that first application, before any continuation of treatment, to confirm they responded well. The off-site pathway does not remove either visit; it applies only once the patient is established.

  Ohio Rev. Code §4731.33(D)(2) and (D)(3) · verified Sep 1, 2026

• Delegating hair removal to anyone outside the statutory list is charged as aiding the unauthorized practice of medicine under §4731.22(B)(20) and §4731.41. The delegate is exposed too, on their own footing: a laser hair removal professional who breaches the supervision rules is himself practicing medicine without authority, and a nurse who does is charged under §4723.28(B)(19) for failing to meet prevailing standards of safe nursing care — in both cases whether or not a patient was injured.

  Ohio Rev. Code §4731.33(I), (J), (K) and (L) · verified Sep 1, 2026

• Whichever lane applies, the delegate must immediately report to the supervising physician any clinically significant side effect or any failure of treatment to progress as expected, and the physician must then evaluate that patient as soon as practicable. Ohio does not permit the complication to be managed at a distance by the person who caused it.

  Ohio Rev. Code §4731.33(H); Ohio Admin. Code 4731-18-03(C) · verified Sep 1, 2026

• Injecting is a different question from operating a device, and Ohio answers it from a different chapter. OAC Chapter 4731-23 governs a physician’s delegation of a medical task to an UNLICENSED PERSON — defined as someone not licensed or otherwise specifically authorized by the Revised Code to perform the task. Ohio licenses no medical assistant, so a medical assistant is an unlicensed person here and this is the chapter that decides what they may be handed.

  Ohio Admin. Code 4731-23-01(B) and (F); Ohio Rev. Code §4731.053(B) · verified Sep 1, 2026

• The chapter reaches injections by name: “administer” means the direct application of a drug, whether by injection, inhalation, ingestion, or any other means, to a person. Handing a syringe to an unlicensed person is delegating the administration of a drug, and every rule below applies to it.

  Ohio Admin. Code 4731-23-01(A) · verified Sep 1, 2026

• Before delegating anything to an unlicensed person the physician must determine the task is within their own authority, is indicated for this patient, that no law prohibits the delegation, that the person is competent to perform it, and that the task is one that SHOULD be delegated — judged on six factors: it can be performed without exercising judgment based on medical knowledge; its results are reasonably predictable; it can be performed safely according to exact, unchanging directions; it needs no complex observations or critical decisions; it needs no repeated medical assessments; and performed improperly it would not present life-threatening consequences or the danger of immediate and serious harm.

  Ohio Admin. Code 4731-23-02(B) · verified Sep 1, 2026

• Three categories are barred outright: a physician shall not delegate to an unlicensed person the administration of anesthesia, of controlled substances, or of drugs administered INTRAVENOUSLY. The bar is in the statute as well as the rule, as a limit on what the Board is permitted to authorize — so it cannot be rule-changed away. An IV therapy drip is squarely inside it.

  Ohio Admin. Code 4731-23-03(F); Ohio Rev. Code §4731.053(D)(3) · verified Sep 1, 2026

• A physician shall not delegate the practice of medicine as defined in §4731.34 unless the Revised Code, or a rule effective before 10 April 2001, specifically authorizes it. This is the provision that does the work for cosmetic injectables: the light-based device rules are such a specific authorization, and there is no counterpart authorizing an unlicensed person to inject a prescription drug.

  Ohio Admin. Code 4731-23-03(A) · verified Sep 1, 2026

• ⚠️ Ohio publishes NO list of drugs a medical assistant may or may not inject, and names neither botulinum toxin nor dermal filler anywhere in Chapter 4731-23. What the state supplies is the test above, applied by the delegating physician, who answers to the Board for the answer. Any source telling you Ohio has a per-drug list for cosmetic injectables is describing a document the Revised Code and Administrative Code do not contain.

  Ohio Admin. Code Chapter 4731-23 (surveyed in full); Ohio Rev. Code §4731.053 · verified Sep 1, 2026

• Where a physician delegates the administration of a drug, on-site supervision is required. The only exceptions are a hand-off knowingly accepted by another physician patient-by-patient, the routine administration of a topical drug such as a medicated shampoo, and written policies for distributing drugs in correctional settings. None of those describes a med spa.

  Ohio Admin. Code 4731-23-02(C) · verified Sep 1, 2026

• And “on-site supervision” has a physical threshold: the physician must be present in the same location as the unlicensed person — the rule’s own example is the physician’s office suite — while the delegated task is performed. It does not require the physician to be in the same room, and being reachable by phone is not on-site.

  Ohio Admin. Code 4731-23-01(C) · verified Sep 1, 2026

• Two structural limits close the common workarounds. A physician may not transfer responsibility for supervising an unlicensed person to anyone but another physician who has knowingly accepted it — so a nurse cannot be made the supervisor of record. And the unlicensed person may not re-delegate the task to a third person. The supervising physician retains responsibility for the manner in which the task is carried out.

  Ohio Admin. Code 4731-23-03(D), (E) and (G); Ohio Rev. Code §4731.053(D)(1) and (D)(2) · verified Sep 1, 2026

• Breaching any rule in the delegation chapter is a departure from minimal standards of care under §4731.22(B)(6) whether or not the patient was injured; where the breach concerns administering drugs it is additionally charged as a failure to maintain minimal standards applicable to the selection or administration of drugs under §4731.22(B)(2). A bad injectable delegation is therefore two findings against the physician, not one.

  Ohio Admin. Code 4731-23-04(A) and (B) · verified Sep 1, 2026

• And the board’s competence rule ties the esthetician to that definition rather than to training: an esthetician “SHALL PROVIDE COSMETOLOGY SERVICES WITHIN A SALON WHERE THE LICENSE IS CURRENT, ACTIVE, AND APPROPRIATE TO THE SCOPE OF PRACTICE OF ESTHETICS FOR AN ESTHETICIAN AS SET FORTH IN SECTION 4713.01 OF THE REVISED CODE AND THE RULES OF THE BOARD.”

  Ohio Admin. Code 4713-8-04(A) (eff. 2025-01-02) · verified Sep 2, 2026

How other states answer this

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Related Ohio questions

• Does a med spa in Ohio need a medical director?
• What must the supervising physician actually do in Ohio?
• Who may operate a cosmetic laser in Ohio?
• Can a medical assistant give injections in Ohio?