If you inject neuromodulators or fillers in the U.S., 2025 brought real changes—and a few high‑profile reminders—that affect how you practice. Here’s a clear, human‑friendly rundown of what actually changed, what’s in flux, and what to do next so you can stay compliant and keep patients safe.
What actually changed in 2025
Texas reorganized its med‑spa rules.
The Texas Medical Board moved its “nonsurgical medical cosmetic procedures” regulations out of the old Rule §193.17 and into a newly structured Chapter 169. The substance is familiar but reorganized: these procedures are the practice of medicine, must be properly delegated, and come with specific supervision, documentation, and signage requirements (e.g., posting the delegating physician’s info and ensuring BLS‑trained staff are on site). American Med Spa AssociationLegal Information Institutetmlt.org
That Texas “Botox Party Bill” you heard about? Vetoed.
SB 378—which would have added explicit penalties for unlicensed injections by cosmetologists/barbers—passed both chambers but was vetoed June 2, 2025. Net result: no new statute from that bill; clinics should keep following the Board’s Chapter 169 rules. LegiScan
Rhode Island now licenses med spas as health‑care facilities.
A new law (signed June 30, 2025) brings licensing under the Department of Health, requires a medical director (physician or CNP) with appropriate training, and sets supervision and documentation standards. DOH must publish detailed licensing rules by July 1, 2026. Plan ahead if you practice there. American Med Spa Association
Telemedicine & controlled substances: the federal extension continues.
DEA and HHS extended COVID‑era telemedicine flexibilities for prescribing Schedules II–V through December 31, 2025. If your practice prescribes controlled meds (e.g., anxiolysis/sedation protocols), the temporary flexibilities are still in place while DEA works on permanent rules. Federal RegisterDEA
Counterfeit Botox remains a live safety issue.
FDA and CDC documented multi‑state incidents and hospitalizations tied to counterfeit toxin and injections by unqualified providers—emphasizing strict sourcing and credential checks. Local health departments continued issuing alerts into 2025. U.S. Food and Drug AdministrationCDCMultnomah County
Employment non‑competes: the federal ban is (still) vacated.
Courts vacated the FTC’s nationwide non‑compete rule; as of mid‑2025 it remains unenforceable, though litigation and policy chatter continue. Treat non‑competes as a state‑law issue for now and lean on confidentiality/non‑solicit provisions drafted by counsel. Davis Polkfaircompetitionlaw.com
“Who can inject?”—quick state snapshots (examples, not legal advice)
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Washington: Competent, appropriately trained RNs may administer neuromodulators with a prescription/order from an authorized prescriber; use the state’s scope‑of‑practice decision tool. nursing.wa.gov
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California: Botox parties aren’t per se illegal—but injections must be performed by a physician or by an RN/PA under physician supervision. California also enforces Corporate Practice of Medicine restrictions, so ownership/control structure matters. Medical Board of California+1
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Florida: Historically murky for RNs, but recent Department of Health declaratory statements approved RN cosmetic injections when a physician has examined the patient, written an order, and delegated the task; these statements apply to the petitioners’ facts and aren’t statutes, but they’re instructive. (APRN/PA authority is clearer.) Florida Department of Health+1American Med Spa Association
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Texas: Under the 2025 reorganization, a physician/PA/APRN must establish the patient relationship and maintain records before delegation; supervising clinicians must be on‑site or immediately available for emergencies, and required notices/name badges must be posted. tmlt.orgLegal Information Institute
Tip: Even within one state, the details can hinge on who orders the drug, who examines the patient, and how supervision is documented. When in doubt, check the medical and nursing boards—and have a health‑law attorney sanity‑check your protocols.
2025 compliance checklist for injectors & medical directors
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Confirm delegation & supervision mechanics.
Make sure your written protocols (or orders) name the delegating physician, define screening criteria, outline complication management, and specify supervision availability. Re‑post required physician identification and complaint notices where mandated (e.g., Texas). tmlt.org -
Require a proper exam and prescription.
For RN‑delivered injections, ensure the prescriber has examined the patient and issued an order consistent with your state’s rules (e.g., WA and Florida examples above). Document it every time. nursing.wa.govFlorida Department of Health -
Lock down your supply chain.
Buy only FDA‑approved products from authorized U.S. distributors; track lot/expiry in the chart. Train staff to spot counterfeit packaging and report suspicious products. U.S. Food and Drug AdministrationCDC -
Mind telemedicine edges.
If you rely on telehealth for consults or prescriptions, the federal flexibilities run through Dec 31, 2025—but you still need to meet state‑law standards of care and any in‑state licensure rules. Federal Register -
Review your employment agreements.
Given the federal non‑compete rule’s status, use state‑compliant alternatives (confidentiality, IP, non‑solicit, training‑repayment where lawful). Davis Polk
How CosmeticInjectors.org can help
Our mission is to pair safe, anatomy‑first training with the state‑by‑state compliance you need to practice confidently. If you’d like, we can generate a quick, customized checklist for your state and role (RN, NP, PA, DDS/DMD, MD/DO) and point you to up‑to‑date board guidance.