The Massachusetts Board of Registration of Cosmetology and Barbering has issued an important update to its Policy on Practices Outside the Scope of Licensure (amended May 8, 2025).

For med spa owners, medical directors, and licensed aestheticians, this update matters:

It tightens definitions of what aestheticians may and may not do,

Clarifies advertising and business structure requirements, and

Reaffirms that working alongside a medical provider does NOT expand an aesthetician’s legal scope.

As the medical aesthetics industry continues to blend cosmetic and clinical services, the Board is drawing a firm line:

If you are not medically licensed, you cannot perform medical procedures—no matter where you work.

What Massachusetts Now Defines as “Medical or Invasive” Procedures

The Board explicitly prohibits aestheticians, cosmetologists, electrologists, manicurists, and barbers from performing or assisting with any procedure that breaches the dermis or carries medical risk. 

Key examples include:

Injections

• Botox
• Dermal fillers
• PRP or PRF
• Biostimulators
• ANY injectable substance

Microneedling / Nanoneedling Beyond the Epidermis

This clarification is critical:

• SkinPen microneedling and similar medical-grade devices are not within aesthetician scope.
• Only superficial epidermal-only devices may be used.

Medium–Deep Chemical Peels

• Peels > 30% AHA
• Peels > 2% BHA
• Any peel with pH < 3.0

 Laser & Energy Devices

• Laser and RF devices (unless separately licensed)
• IPL is permitted only in extremely narrow circumstances, subject to additional requirements

Body Services Considered Medical or High-Risk

• Body contouring (RF, cavitation, cryolipolysis, etc.)
• Plasma fibroblasting
• Lymphatic drainage beyond head/face/neck
• Tattooing, PMU, tattoo removal (unless separately licensed)
• Acupuncture

If it penetrates the skin, alters tissue, affects body systems, or uses medical-grade energy—it is NOT within aesthetician scope.

What IS Allowed: Beautification-Only Procedures

Aestheticians may provide beautification services, provided they meet three conditions:

They hold any required local/state permits

For example: salon license, city occupational permit, or health department registration.

Services occur in a separate, designated room

The room must be licensed by the Board as a salon—even if located inside a medical office or med spa.

Advertising clearly distinguishes these services

No blending of medical and non-medical language.

Training Requirements Clarified

The Board now requires:

• 16 hours of training for microdermabrasion
• 16 hours for dermaplaning, including 10 hours of hands-on instruction
• Written proof must be kept onsite for inspection.

Additionally, licensees must maintain sanitary conditions meeting Board inspection standards—and they perform these procedures at their own risk.

Working Inside a Medical Office: What Aestheticians Must Know

The Board directly addressed the growing trend of aestheticians working in med spas or dermatology practices. They emphasized:

A salon license is still required

If an aesthetician performs services within a med spa or doctor’s office, the room itself must be licensed as a salon.

“Medical Aesthetician” is not a recognized title

Aesthetic licensees may NOT use terms such as:

• Medical aesthetician
• Advanced aesthetician
• Clinical aesthetician
• Nurse aesthetician (unless they are actually a nurse)

Using these terms may constitute:

• Misrepresentation
• Practicing medicine without a license
• Violating Board advertising rules

Delegated procedures are NOT under the Cosmetology Board’s umbrella

If a physician delegates a medical procedure:

• It is NOT a cosmetology service
• Delegation does NOT expand scope
• The aesthetician may be exposed to separate healthcare regulatory violations

This creates a regulatory gray zone that med spas must carefully navigate.

What Med Spas & Aestheticians Should Do Now

1. Audit Your Service Menu

Anything that breaks the dermis or uses medical-grade energy must be:

• Removed from the aesthetician service list
• Performed only by properly licensed medical personnel

2. Separate Aesthetic & Medical Operations

This may require:

• Distinct rooms
• Distinct licenses
• Clear signage
• Separate pricing menus

3. Update All Advertising

Avoid terms that imply clinical training or medical oversight under cosmetology licensure.

4. Train Staff on Scope-of-Practice Boundaries

Staff should understand:

• What they can safely do
• What they must decline
• When to escalate to a medical provider

5. Review Delegation Practices with Legal Counsel

Delegation is heavily regulated in Massachusetts. Before allowing an aesthetician to assist with any medical procedure, consult a healthcare attorney to avoid:

• Board complaints
• DPH investigations
• Allegations of unlicensed practice

The Bottom Line

Massachusetts has made one thing crystal clear:

Aestheticians and cosmetologists cannot perform medical procedures—no matter where they work or who is supervising.

Med spas, dermatology offices, and aesthetic practices must ensure:

✔ Clear separation between beauty services and medical services

✔ Proper licensing of rooms and business entities

✔ Accurate advertising without medical titles

✔ Strict adherence to scope of practice

As the regulatory scrutiny on medical aesthetics increases nationwide, staying compliant is not optional. It’s essential to patient safety, professional reputation, and business protection.

If you need help reviewing your service menu, delegation structure, or licensing setup, Lengea Law is here to support you.