Beginning August 26, 2026, Ohio providers who offer laser and light-based hair removal services will be subject to a revised legal framework. House Bill 377 amends Ohio Revised Code Section § 4731.33 and enacts a new companion section, § 4731.331, both of which govern the use of “light-based medical devices” for hair removal. At its core, this amendment is about oversight: who is legally permitted to supervise the people performing these procedures, and when that supervision must happen in person versus remotely. This article walks through what the statutory text actually says about those oversight changes, and how they will play out for each type of provider and for practice owners.
The Baseline That Does Not Change
A few foundational requirements carry forward unchanged and are worth stating up front, since everything else builds on them. A “light-based medical device” is any device capable of producing electromagnetic radiation between 180 and 1,064 nanometers that is designed or promoted to affect the structure or function of the body through irradiation. The device must be FDA-cleared or approved for hair removal, its use must fall within the delegating provider’s normal course of practice and expertise, and the underlying education and training standards for non-physician delegatees are unchanged: eight hours of basic education, observation of 15 procedures, and hands-on performance of 20 procedures under a physician’s direct physical oversight, for each specific device type.
The Core Change: Who May Supervise and When Supervision Must Be On Site
A wider group of providers may now serve as the supervising party. Under the law in effect through August 25, 2026, only a “physician” may delegate the application of a light-based device for hair removal and stand as the supervising provider. Starting August 26, new Section 4731.331 extends that authority to advanced practice registered nurses (APRNs) and physician assistants (PAs). An APRN or PA may now delegate the application of a light-based device to a registered nurse, licensed practical nurse or a “laser hair removal professional” and supervise that person directly, without a physician standing in as the delegating and supervising party. An APRN’s authority to do so is limited by whatever their standard care arrangement permits, and a PA must satisfy the same supervision-agreement requirements that already govern PAs under Section 4731.33. Once delegating, an APRN or PA is held to the identical on-site and off-site supervision rules, ratios, and conditions described below that already apply to physicians.
On-site supervision is now more flexible for registered and licensed practical nurses. Under current law, a registered nurse or licensed practical nurse performing hair removal under delegation must always be supervised on site, meaning the supervising physician is physically present in the same office suite, even if not the same room. Only a cosmetic therapist (a category renamed by the new law as a “laser hair removal professional”) could ever work under off-site supervision, meaning the supervisor is not physically present but is continuously available for direct communication (such as via phone). Effective August 26, that option opens up to registered and licensed practical nurses as well. These nurses may work under off-site supervision if they have completed a training and education program, approved by the delegating physician (or now, APRN or PA), consisting of 40 total hours of combined didactic instruction, in-person hands-on training, and performance of laser hair removal procedures. That training may be delivered internally at the practice or through a third-party provider, provided a physician oversees the third-party program. This is a meaningful loosening of the physical-presence requirement for an entire category of delegatee that did not have this option before.
The number of people one supervisor can oversee at once expands substantially. Current law caps a physician at supervising no more than two delegates at a time, combining laser hair removal professionals (cosmetic therapists) and nurses into a single limit. Effective August 26, a supervising physician, APRN, or PA may oversee up to five laser hair removal professionals at a time and, separately, up to five nurses at a time. In practical terms, one supervising provider’s oversight capacity for delegated hair removal services more than doubles, and the caps for the two categories of delegatee no longer compete with each other.
Nurses now carry direct, individual accountability for on-site and off-site compliance. The amended law adds a new provision stating that a nurse who fails to comply with the on-site or off-site supervision requirements, or who fails to report a clinically significant side effect or a treatment not progressing as expected, has committed a failure to practice in accordance with acceptable and prevailing nursing standards, actionable by the Ohio Board of Nursing regardless of whether a patient was actually injured. No comparable provision exists under current law. Because nurses are gaining the ability to work off site, the legislature paired that expanded latitude with a new, direct-enforcement mechanism aimed specifically at supervision and reporting failures.
How House Bill 377 Affects Providers
Physicians keep their existing delegation and supervision authority intact and gain the ability to share that responsibility with APRNs and PAs in the practice. A physician who continues to supervise directly may now oversee up to five laser hair removal professionals and up to five nurses at the same time, rather than two combined.
APRNs gain supervisory authority they did not previously have. Before relying on it, an APRN should confirm that nothing in their standard care arrangement prohibits delegating or supervising light-based hair removal procedures, since the statute expressly conditions this new authority on that document.
Physician assistants likewise gain the ability to delegate and supervise independent of a physician, but only within an effective supervision agreement meeting the same requirements PAs already satisfy under current law.
Registered nurses and licensed practical nurses see the most significant shift. Nurses can now qualify for off-site supervision after completing the 40-hour training program, allowing them to work without a supervisor physically present in the office. That flexibility comes paired with new individual exposure to Board of Nursing discipline for failing to meet the on-site or off-site supervision conditions or the side effect reporting duty.
Laser hair removal professionals (formerly cosmetic therapists) see their on-site and off-site supervision framework carry forward largely as before, but they may now be supervised by an APRN or PA rather than only a physician, and the number of laser hair removal professionals a single supervisor may oversee at once rises from a shared cap of two to a dedicated cap of five.
Practice owners and administrators should treat this as an opportunity to revisit staffing models built around the old two-person supervision cap and physician-only delegation framework. That likely means updating supervision agreements and standard care arrangements to reflect APRN and PA delegation authority, confirming which nurses have completed the 40-hour off-site training before August 26, and revising internal job titles and credentialing files to reflect the “laser hair removal professional” terminology.
Ohio providers and practice owners are encouraged to contact Lengea Law to speak with an attorney about how these oversight and supervision changes affect their specific delegation arrangements, supervision protocols, and staffing plans before the August 26, 2026 effective date.