Florida Requires Direct Physician Supervision for RN Botox Injectors

The Florida Board of Nursing has reinforced its direct supervision rule via Final Order No. DOH-24-0637, meaning Florida med spas can no longer use nurse practitioners to supervise registered nurses administering Botox Cosmetic. Under Chapter 458 or Chapter 459 of the Florida Statutes, direct supervision requires the supervising physician to be physically present in the room and visually observing the RN during the procedure. The ruling, stemming from a petition involving an RN named Cremeans in May 2024, explicitly states that an advanced practice registered nurse cannot substitute for a physician to oversee or delegate these injections. Furthermore, the clinic must disclose the RN's participation in the patient's informed consent documentation. For practice owners, this necessitates immediate operational changes. If you utilize RN injectors in Florida, you must ensure a licensed physician is physically in the room watching the treatment, as relying on an NP for oversight is no longer compliant. You must also update your intake and consent paperwork to explicitly state that an RN is performing the injection under physician observation.

Source: Lengea Law, https://www.lengealaw.com/post/florida-rn-injectors-direct-supervision-required