Med spa charting requirements by state: 6-state guide

Last reviewed September 2026. Laws change. This is not legal advice.

Your medical director is in another city. A board investigator asks for five charts from last month. What do those charts need to show?

Every state answers a little differently, but the core requirement is the same. A prescriber evaluated the patient, wrote an order, a qualified injector carried it out, and the chart captured every step. Here is how six states handle those rules, along with the board to check in each one.

How do California med spa charting laws work?

In California, physicians, NPs, and PAs can evaluate and inject patients, while RNs can inject under a physician's order only after a prescriber completes an initial exam. Medical assistants cannot inject.

Your charts should show the prescriber's exam, a patient-specific order, the injector's name and license, the product and lot number, units per site, and a signed procedure-specific consent. The Medical Board treats prescribing without an appropriate prior exam as unprofessional conduct under Business and Professions Code 2242.

Law firm summaries from Holt Law and Lengea describe SB 351 as effective January 1, 2026. They say it requires a good faith exam by a licensed prescriber before initial treatment, a patient-specific order rather than a standing protocol, and documented medical director chart review. Treat this as "law firm summaries describe," not settled fact.

Check the Medical Board of California and the California Board of Registered Nursing for official updates.

What are the med spa charting rules in Texas?

Texas requires a physician, PA, or APRN to perform an exam before delegating a nonsurgical cosmetic procedure. Delegated staff work under written orders and physician supervision, per AmSpa's summary of Texas Medical Board rules. Trained RNs can inject under these rules. In some cases, unlicensed assistants can too.

A compliant chart should contain the exam, the order, who performed the procedure, the product, and the dose. Weitz Morgan, a Texas firm, lists the patient's history, exam findings, and the medical rationale as the core of a documented good faith exam.

The Texas Medical Board moved Rule 193.17 into 22 TAC 169.25 through 169.29 in 2025. HB 3749 (Jenifer's Law) took effect September 1, 2025 for elective IV therapy. It requires at least a trained RN on staff to offer it, per AmSpa.

Look to the Texas Medical Board for regulation details.

How does Florida regulate med spa charting and supervision?

Florida permits physicians, APRNs, and PAs to evaluate and inject, but RNs face stricter supervision standards. Lengea's summary describes a May 2024 Florida Board of Nursing declaratory statement (DOH-24-0637) saying an RN can inject only with a physician physically present, and that the RN's role must be disclosed in the consent. Declaratory statements are fact-specific, so confirm how yours applies.

Your chart should contain the prescriber's evaluation, the order, a consent form naming who will inject, and the procedure record. Florida law lets the prescriber establish the relationship by telehealth if you meet the standard of care.

The main recent update is the 2024 declaratory statement mentioned above.

Check the Florida Board of Medicine and Florida Board of Nursing for guidance.

What does Arizona require for aesthetic charting?

Arizona allows RNs, LPNs, and APRNs to perform aesthetic procedures with proper training, but Level II and III procedures require an initial face-to-face exam and order from a licensed practitioner. That is the stance taken in the Arizona Board of Nursing's advisory opinion revised in November 2025. Telemedicine may be used for that exam.

The chart should record the practitioner's initial exam, the order, the procedure note, and consent. The opinion also expects training and licensure records on file with the employer.

The opinion was revised in January and November 2025. Read the current version, not a summary.

Refer to the Arizona State Board of Nursing and the Arizona Medical Board.

What are New York's med spa charting rules?

In New York, physicians, NPs, PAs under physician supervision, and RNs carrying out a prescriber's order can inject. NPs need a written practice agreement unless they have more than 3,600 qualifying hours. Unlicensed staff cannot inject, per NYSED guidance.

New York has no statute that uses the term "good faith exam," but the prescriber's evaluation has to exist before an RN carries out an order. Chart the evaluation, the order, everyone involved with license numbers, product and lot, units per site, and any deviation with the prescriber who approved it.

We could not confirm any recent injector-specific law changes here.

Check the NYSED Office of the Professions for nursing and PA rules, and the Office of Professional Medical Conduct for physicians.

How does Nevada regulate med spa charting?

Nevada allows physicians, PAs, APRNs, and RNs to inject, provided an authorized practitioner assesses the patient and writes an order for each intervention. The Nevada State Board of Nursing's practice decision on aesthetic procedures describes LPNs as outside the scope for injectables.

Your documentation needs the practitioner's assessment, the order, the procedure note, product, dose, and consent. Nevada statute allows the practitioner to establish care and write the order by telehealth with a Nevada license.

We found no recent legal changes to report for Nevada.

Consult the Nevada State Board of Medical Examiners and Nevada State Board of Nursing.

Summary table

Retention and recording-consent cells are commonly cited figures from Paubox's retention guide and the Recording Law state guide. Where we could not confirm a cell, it says "confirm."

Across all six states, chart review comes down to the same questions: who evaluated the patient and when, what was ordered for this patient, who carried it out and under what supervision, what product and dose, and whether consent names the procedure and the person doing it.

Frequently asked questions

What if I operate in two states?

Each location follows the state it sits in, but build your charting template to the higher bar so a chart from either office survives review in either state. Confirm with a healthcare attorney in each state.

Does the medical director have to be on site?

It depends on the state and the injector's license. Law firms describe Florida's 2024 declaratory statement as expecting a physician physically present for RN injections, while California summaries describe "immediately available" plus chart review. Confirm with a healthcare attorney in your state.

How long do I have to keep charts?

The commonly cited floor in these six states is 5 to 7 years after the last visit, longer for minors. When in doubt, keep them longer.

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