If you run a medspa in Colorado, now is the time to take a close look at your operations. With the passage of House Bill 25-1024 (HB 25-1024), the state is stepping up efforts to increase transparency when unlicensed individuals perform delegated medical-aesthetic services, a common model in many medspa settings.
While the new law doesn’t limit your ability to delegate tasks to trained, unlicensed assistants, it does require you to be transparent about that delegation, through clear disclosures in your signage, marketing materials, and patient documentation.
What HB 1024 Covers
The law applies specifically to medical-aesthetic services (i.e. procedures used for cosmetic or therapeutic aesthetic purposes) when those services are delegated by a licensed physician or advanced practice registered nurse (APRN) to someone who does not hold a medical license.
HB 25-1024 doesn’t change who can delegate or what can be delegated. But it adds three new disclosure obligations that medspas must follow to remain in compliance.
Three Disclosures Required
1. On-Site Signage
You must post a highly visible sign or document in the physical location where delegated services are performed. This must include:
- The name, license number, and contact info of the delegating practitioner
- A link to the Colorado Medical Board’s website, where patients can file complaints
Tip: Place this signage in your reception area, treatment rooms, or anywhere patients check in for services.
2. Website and Advertising Disclosure
Your website, social media, and any advertising involving unlicensed staff must state:
- That medical-aesthetic services are delegated
- The name and license number of the delegating provider
Tip: Include this language clearly on service pages and in bios of any unlicensed team members who perform delegated procedures.
3. Informed Consent
Before treatment, patients must sign an informed consent form acknowledging:
- That they are receiving care from an unlicensed individual under delegation
- All the details included on your in-office signage (practitioner info + Medical Board website)
This signed document must be retained for at least 7 years.
Tip: Review and revise your current consent forms to meet the new requirements now. Don’t wait until the deadline.
When Does This Go Into Effect?
Unless a referendum petition is filed, HB -251024 will take effect on August 5, 2025 (90 days after the General Assembly adjourned on May 7, 2025).
If a referendum is filed, implementation will be delayed until the November 2026 general election, and the law would only take effect if approved by voters.
What Should Medspa Owners Do Now?
To stay ahead of the curve, medspa owners should:
- Audit current marketing materials for appropriate disclosure
- Update informed consent forms and office procedures
- Design and post required signage in treatment locations
- Train your team on how to talk with patients about delegation and licensing
Taking these steps now will not only help you comply with HB 25-1024, it will also demonstrate professionalism and transparency to your clients.