Colorado’s House Bill 25-1024 (HB25-1024), signed into law on April 7, 2025, adds critical obligations for medical professionals who delegate medical-aesthetic procedures to unlicensed staff. If you’re a Colorado physician or advanced practice registered nurse (APRN) working with aestheticians, laser techs, or other individuals who do not have a healthcare license, this new law requires specific disclosures to patients across signage, marketing and consent forms.
Here’s what you need to know to stay compliant:
I. Who Does the Law Apply To?
HB25-1024 applies to:
- physicians licensed pursuant to Article 240 of the Colorado Revised Statutes (MDs and DOs); and
- APRNs licensed pursuant to Article 255 of the Colorado Revised Statutes.
These licensed professionals may delegate medical-aesthetic services to unlicensed individuals, such as aestheticians, laser technicians, or other staff who do not hold a Colorado healthcare license.
“Medical-aesthetic services” are defined as therapeutic procedures used in aesthetics.
II. Required Disclosures at the Physical Location
You must post a notice in a highly visible area at the site where delegated services occur. The notice must include:
- The name of the licensed delegator (physician or APRN);
- The delegating provider’s Colorado license number;
- Contact information for the delegating licensee; and
- Address where a patient can file a complaint.
III. Required Website and Advertising Disclosures
The public website and all advertising materials must include:
- A statement that medical-aesthetic services are delegated
- The name and Colorado license number of the delegating physician or APRN
IV. Informed Consent Requirements
Each patient must review and sign a written informed consent form before receiving services. The form must:
- State that the patient is receiving medical-aesthetic services delegated to an unlicensed individual by a licensed individual;
- Include the same licensee details required in the physical notice (see section II, above);
- Be signed by the patient before treatment begins; and
- Be retained on file and accessible by the licensed healthcare provider for at least seven years.
V. Telemedicine and Medical Records
HB25-1024 also amends definitions and recordkeeping requirements related to telemedicine, clarifying that any medical information shared during or in relation to a telemedicine encounter becomes part of the patient’s official medical record, whether handled by a facility or individual provider.
VI. Are There Any Exemptions?
Yes. HB25-1024 does not apply to facilities regulated under Title 25 of the Colorado Revised Statutes, such as hospitals and certain outpatient facilities. However, most independent medical-aesthetic businesses and med spas do not fit into those facility categories and are, therefore, generally not exempt.
Protect Your License, Your Practice, and Your Patients
Colorado’s HB25-1024 emphasizes the importance of transparency and accountability when delegating medical-aesthetic procedures. Whether you’re a physician medical director or an APRN overseeing aesthetic staff, it’s time to review your:
- Supervisory/delegatory relationships, practices and contracts;
- Patient consent forms;
- Marketing and advertising materials; and
- Record-retention processes.
If you’re unsure how these requirements apply to your practice or how to update your materials, we’re here to help.