The regulatory landscape for medical aesthetic services continues to evolve—and Massachusetts is the latest state to issue clearer, stricter guidance on who can perform what inside MedSpas. In May 2025, the Massachusetts Board of Registration of Cosmetology and Barbering updated its policy on practices outside the scope of licensure, defining boundaries between cosmetic beautification and medical aesthetics.
For MedSpa owners, managers, and injectors, these updates carry major operational and compliance implications. Here’s what’s changed—and what you should be doing now to protect your business.
Why the Updated Policy Matters
The Board’s message is direct:
Working in or near a medical environment does not expand an aesthetician’s legal scope of practice.
Many MedSpas blend cosmetic and medical services under one roof, but Massachusetts now makes it explicitly clear that cosmetic licensure does not authorize medical or invasive procedures—even if a physician is on-site.
This policy aims to reduce patient risk, prevent scope misunderstandings, and reinforce the separation between beauty services and medical care.
What’s Off-Limits for Aestheticians in Massachusetts
Under the clarified policy, cosmetologists, aestheticians, electrologists, manicurists, and barbers may not perform any service considered medical or invasive. Prohibited services include:
- Injectables
- Microneedling beyond the dermis
- Medium or deep chemical peels
- AHA above 30%
- BHA above 2%
- pH below 3.0
- Laser treatments by non-electrologists
- Body contouring technologies
- Radiofrequency devices
- Plasma skin tightening
- Lymphatic drainage outside the head/face/neck
- Tattooing or tattoo removal
- Acupuncture
Even in a medical office—even with physician delegation—these procedures remain outside aesthetic scope and require appropriate medical licensure.
One Exception: IPL (With Strict Conditions)
Intense Pulsed Light (IPL) is the rare exception, but Massachusetts limits its use tightly. Aestheticians may perform IPL only for photofacials and only if they:
- Complete all required IPL training
- Meet specific facility and equipment requirements
- Follow Board-level rules for safety and documentation
All other laser services, including hair removal, remain exclusive to licensed electrologists or medical professionals depending on the technology.
Training Requirements: Clear and Documented
Two popular aesthetic services—microdermabrasion and dermaplaning—remain permissible, but only at the epidermal level. To comply:
- Providers must complete 16 documented training hours per service,
- including 10 hours of hands-on instruction
- Training documentation must be kept on-site and available for Board inspection
This requirement reinforces the need for strong recordkeeping and operational organization.
Licensing and Advertising Rules for MedSpas
One of the biggest clarifications in the updated policy concerns operations inside medical offices. The Board now requires:
1. Salon Licensure for Aesthetic Treatment Rooms
If cosmetology services occur inside a medical practice, the treatment room itself must be licensed as a salon—not just the business as a whole.
2. Clear, Non-Misleading Advertising
Marketing materials must clearly distinguish cosmetology-regulated services from medical procedures. Misleading, blended, or unclear advertising is prohibited.
3. Accurate Professional Titles
The state explicitly rejects hybrid or creative titles including:
- “Medical aesthetician”
- “Clinical aesthetician”
- Or any term suggesting healthcare licensing
Using these titles may constitute misrepresentation and create legal exposure.
What This Means for MedSpa Professionals Moving Forward
With the rules now clearer than ever, MedSpas in Massachusetts should take immediate steps to ensure full compliance.
- Remove aesthetician-listed services involving penetration, tissue alteration, or medical-grade energy; assign to licensed medical providers.
- Separate cosmetic and medical services into different rooms with proper salon licensure and distinct signage/marketing.
- Eliminate wording in titles/branding implying medical licensure for cosmetologists.
- Ensure all training logs are complete, accurate, and accessible.
- Review delegation agreements with legal counsel to ensure compliance and correct task classification.
Massachusetts’ updated policy underscores a message that regulators across the country are increasingly adopting: Cosmetic services and medical procedures must remain clearly differentiated, operationally and legally.
These guidelines aren’t just about compliance; they help strengthen patient safety, reduce liability, and elevate the professionalism of the industry. MedSpas that embrace clear roles, proper staffing, and transparent marketing will be better positioned for long-term success.
How OptiMantra Helps You Stay Compliant and Organized
For MedSpas balancing cosmetic and medical services under one roof, OptiMantra provides the infrastructure to keep everything cleanly separated and compliant:
- Role-based permissions to ensure staff access matches licensure
- Service-specific templates tailored for cosmetic and medical procedures
- Separate menus and workflows for aesthetic vs. medical treatments
- Audit-ready reporting for regulatory inspections
- Clear charting and delegation records when medical providers supervise care
By supporting structured workflows and transparent documentation, OptiMantra helps MedSpas stay aligned with evolving regulations—without slowing down daily operations.
To keep your MedSpa organized, compliant, and aligned with evolving scope-of-practice rules, book a demo or start a free trial with OptiMantra today!
Disclaimer: This article is for informational and educational purposes only and does not constitute legal or regulatory advice. Med spa owners and providers should consult qualified legal counsel and state regulatory authorities to ensure compliance with applicable scope-of-practice laws and licensing requirements.
Source:
Moeller, M. (2025, December 4th). Massachusetts Cosmetology Board Clarifies Rules for Aestheticians in Med Spas. American Med Spa Association. https://americanmedspa.org/news/massachusetts-cosmetology-board-clarifies-rules-for-aestheticians-in-med-spas
