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In Search of Cosmetic Procedure Regulations

Injectables such as Botox necessitate a medical license and hence cannot be administered by estheticians or cosmetologists without the supervision of a doctor.

Injectables such as Botox necessitate a medical license and hence cannot be administered by estheticians or cosmetologists without the supervision of a doctor.

I’m curious as to the frequency with which patients seek your services after having an aesthetic procedure performed elsewhere (i.e., not at a dermatology or plastic surgery clinic). Have you given any thought to who can participate in cosmetic injection training programs like boot camps and other educational programs? Recently, I’ve been, and it’s prompted some reflection.

The beauty industry has exploded in the last two decades. It is anticipated that it will exceed $270 billion by the year 2024. Injecting neuromodulators and fillers is common practice in many fields and is quickly becoming the norm in modern society. Also of note is the fact that the number of Botox injections administered has risen by an incredible 845% from 2000 to 2018. But where should we set limits on who is allowed to inject?

Although the aesthetic industry is regulated by a government body that ensures all practitioners are properly licensed, horror stories continue to circulate. So why are we letting people who should have proper training or foundational skills (i.e., residency, years of practice in dermatology/plastic surgery) carry on with this art form that takes a lot of time and effort to master? 

State laws determine which professions are eligible to inject, but neither dermatology nor plastic surgery training are prerequisites. In addition, injectables like Botox require a medical license and therefore cannot be administered by estheticians or cosmetologists without a doctor’s supervision. Rather than the Texas Department of Licensing and Regulation (TDLR), the Texas Medical Board (TMB) is responsible for enforcing this law.

Since the administration of injections is considered medical practice in all states, only those with appropriate training and/or a valid medical license are legally allowed to do so. Therefore, a medical assistant can only inject under a doctor’s supervision and only if the doctor gives them the go-ahead to do so. It is illegal to inject or examine patients without a valid medical license. This “medical assistant” title is not well defined.

The Food and Drug Administration regulates injectable fillers, neuromodulators, and other types of cosmetic neuromodulation technically as “prescription” drugs. So why are people who can’t legally prescribe drugs doing so in an artistic manner? We are taught to limit our work to the parameters of our degree when we get our license, but who sets those parameters for the cosmetics industry? Who is providing the oversight to make sure only qualified people are giving the injections?

Many dentists, gynecologists, pediatricians, family doctors, and emergency department physicians have run med spas or given injections without sufficient dermatological or cosmetic surgery training.

Many dentists, gynecologists, pediatricians, family doctors, and emergency department physicians have run med spas or given injections without sufficient dermatological or cosmetic surgery training.

There are a plethora of alternatives if you’re looking for a cosmetics course, but how extensive are they in terms of required attendance, credentials of instructors, and scope of participants? Numerous dentists, gynecologists, pediatricians, family doctors, and emergency room physicians have reportedly opened med spas or administered injections despite lacking appropriate training in either dermatology or plastic surgery. Unfortunately, many APPs who have worked in dermatology for a long time are restricted from offering aesthetic services to their patients.

All licensed professionals, including nurses, estheticians, NPs, PAs, MDs, DOs, and dentists, are on an equal footing when it comes to cosmetic procedures thanks to the knowledge we gained while earning our degrees, with the exception of dermatologists and plastic surgeons, of course, who have specialized training in injecting neuromodulators and fillers after completing 4 and 6 years of residency, respectively. 

We have access to training that goes beyond our initial degrees, so anyone can become an expert in their chosen field. Every single one of us should be a fervent supporter of education because it is crucial to the development and evolution of the human soul. If seasoned dermatology APPs aren’t given the opportunity to broaden their medical horizons, it may be to the patient’s detriment, and the patient may end up seeing a doctor who has little to no background in dermatology or plastic surgery. 

This leads me to discuss the education of APPs, which is comparable to that of MDs, NPs, and estheticians in that it covers the fundamentals of medical and nursing practice within the APP’s area of expertise. Nevertheless, it is an issue that needs to be addressed when the opportunity to inject patients varies between the two professions, such as between a dermatology PA and NP, or when it is given to someone with a lower degree or no degree at all. In the end, advanced practice pharmacists have advanced degrees and are able to prescribe medications.

APPs receive additional dermatology training and work under the supervision of a board-certified dermatologist or plastic surgeon. Working closely with a physician and continuing education are crucial for gaining a comprehensive understanding of facial anatomy, which can take years. It is recommended and helpful to become well-versed in the various injectable fillers currently on the market.

A dermatologist or plastic surgeon can help a patient achieve their aesthetic goals by assessing the state of their skin, learning about their expectations for the procedure, and going over the process from beginning to end with them. They learn these fundamental abilities as part of their training. They will be equipped with the knowledge and resources to take corrective action if something goes wrong.

Injecting substances is considered medical practice in many jurisdictions. Therefore, the injector should have the appropriate education and experience, the highest quality product should be used, and the indications, contraindications, aseptic injection techniques, and adequate localization should all be adhered to.

All aesthetic medicine practitioners (APPs) in dermatology and plastic surgery should have access to training in the field; however, we need better regulation regarding the industry’s reach beyond these specialties and the practice of allowing estheticians, medical assistants, or anyone without a medical degree or the requisite foundational knowledge of these fields to inject.

Medical professionals can now receive instruction in Botox administration. Courses can be taken online at https://dentox.com/all-courses/ or in person at https://dentox.com/live-courses/ with actual patients. Learn how to improve patients’ appearance, health, and vision and thereby enhance their quality of life.


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