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Can an Autonomous APRN Practice in Florida Perform Botox or Derma Filler Injections?

A common question asked about the autonomous APRN practice in Florida is whether an autonomous APRN with the requisite education, training and experience in Botox and Derma filler injections is allowed to perform these injections in an autonomous APRN practice.

The answer is No. This is because dermatology is a specialty and such skin care treatments are cosmetic and not primary care health services. In addition, while an autonomous APRN can perform certain treatments that are adjunct to general primary care, beautifying skin care services do not qualify under this limited circumstance.

By way of reference, in a October 2017 final order issued in response to a Petition for Declaratory Statement, the Florida Board of Nursing declared that aesthetic injections such as Derma fillers and Botox are not within the scope of practice for registered nurses in Florida. Since then, the Florida Board of Nursing has not issued any orders stating to the contrary for registered nurses or APRNs. Rather, in their most recent final orders, dated July 7, 2023, October 19, 2023 and October 19, 2023, the Florida Board of Nursing consistently held that, based on the facts presented in each petition and in accordance with the “practice of professional nursing” as defined in Florida Statutes, Section 464.003(19)(b), the petitioners (all registered nurses) had the requisite education, training and experience to have the task of Botox or Derma fillers delegated by and under the direct supervision of their respective supervising physicians. Those “qualified physicians” consisted of a dermatologist and two plastic surgeons.

While the petitioners in those matters were registered nurses and not APRNs, this distinction would not change the outcome given that dermatology is a specialty and the purpose of Botox and Derma filler injections are cosmetic.

For APRNs who may wonder whether autonomously owning a Med Spa, as opposed to a primary care practice, would allow them to perform cosmetic Botox or Derma fillers, the answer remains the same - no. Furthermore, a Med Spa is not a primary care setting and the autonomous APRN practice is limited to providing primary care services.


The information provided in this post is for general informational purposes and not intended as legal advice or legal opinion for any individual matter. Keep in mind that legal developments or changes to law may occur in the future and, as such, the information contained in this post may not be the most up-to-date legal information. Do consult your own attorney for any legal advice you may require. If you do not have an attorney and would like to explore a potential engagement, please reach out to Venus Caruso using the contact submission form or by using the contact information provided in her bio.


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