Key Takeaways:
- Ohio Boards are increasing enforcement against nurses involved in IV therapy and aesthetic injections.
- “Certification” courses do not allow independent practice and may mislead nurses about legal requirements.
- Nurses must follow a valid provider order and supervision or risk discipline including fines and reprimands.
In recent years, there has been an influx of wellness-based medical spas providing IV hydration, Botox and dermal fillers to patients. Following this surge, the State Medical Board of Ohio, the Ohio Board of Pharmacy and the Ohio Board of Nursing (collectively the “Boards”) have intensified enforcement efforts, particularly targeting registered nurses (“RNs”) and licensed practical nurses (“LPNs”) involved in IV therapy and aesthetic injections. The Boards released a joint statement in May 2025, warning individuals of these practices and putting them on alert for enforcement actions. Dinsmore also published a legal alert regarding the statement, available here.
As demand for services like Botox, dermal fillers and other aesthetic services rises, nurses are increasingly being marketed expensive “training” and “certification” courses which purport to train them on how to own and operate aesthetic practices with little or no oversight. Simply put, in Ohio, nurses need to be on alert for such marketing schemes.
Many of these nationally offered courses often blur the line between education and authorization, leading nurses to believe they can operate independently or open their own practices immediately after completion of the “training” courses. In reality, “certification” in this context is largely a marketing term and does not override Ohio law or Board regulations, which prohibit RN and LPN licensed nurses from exercising independent judgment when administering Botox, fillers or other injectables to patients.
Further, RNs and LPNs are not permitted to perform injections without a valid order. A physician, physician’s assistant (“PA”), or advanced practice registered nurse (“APRN”) must first evaluate the patient, establish a diagnosis and prescribe a course of treatment. The evaluation includes exact dosages and injection placement. The nurse is then required to follow the recommendation or risk practicing outside of their scope of practice.
The risk inherent in this area is highlighted by several recent Ohio Board of Nursing cases, where nurses were issued Reprimands on their licenses, fined and ordered to undergo continuing education courses. Any nurse interested in injection therapies or completing these Botox/filler “training courses” must ensure there is they are practicing within the scope of their license and with proper oversight or risk discipline by the Boards.
For more information or questions about how you can ensure compliance with Board regulations, contact Beth Collis, Hunter Graffice or any Dinsmore health care attorney.