Dual Licenses, Double Trouble: What New Jersey Med Spas Need to Know - Medspa Compliance

Amber Bechthold
Jul 16
2 min read

Updated: Jul 22

If you're overseeing a medspa in New Jersey and possess dual licenses in nursing and esthetics or cosmetology, it's crucial to adhere strictly to medspa compliance. The state of New Jersey demands careful attention to the boundaries of your professional practice, ensuring all operations align with regulatory standards. Stay informed and compliant to maintain the integrity and success of your medspa practice.

You Cannot “Wear Both Hats” at the Same Time

New Jersey is one of the few states where the boards have clearly stated:

If you are acting as a nurse, you may not simultaneously act as a cosmetologist or esthetician.

Let’s break that down. If you’re a Registered Nurse who also holds an esthetician license:

You can perform Botox injections—but only under physician delegation, following Board of Nursing and Medical Examiner regulations.
You can perform facials or lash lifts—but only under your esthetics license, and only if the treatment is non-medical.

But here’s what you cannot do:

Combine both roles in a single session (“inject Botox, then offer a facial”).
Provide medical procedures like microneedling or chemical peels under your esthetician license.
Skip written protocols, proper supervision, or good faith exams just because you’re “dual licensed.”

NJ is very specific—you must operate under one license at a time, and each license comes with its own scope, oversight, and documentation requirements.

Documentation Matters More Than You Think

If you’re operating as a nurse:

You must have written standing orders or delegation protocols in place.
You must be supervised by a physician, APN, or PA, depending on your role.
Your services must be documented in a medical record, including a good faith exam and informed consent.

If you’re operating as an esthetician:

You must only provide non-invasive, non-medical cosmetic services.
You cannot work under physician orders.
You cannot use your esthetics license as a loophole to offer discounted “wellness” or “beauty” injections.

NJ Boards Are Not Sleeping on Enforcement

This isn’t just theory—New Jersey’s regulatory boards are actively investigating and disciplining med spa providers.

Across the:

Board of Medical Examiners
Board of Nursing
Board of Cosmetology and Hairstyling

…you’ll find public records of:

Physicians losing licenses over improper delegation
RNs sanctioned for working beyond scope
Estheticians fined for performing microneedling
Clinics shut down for CPOM violations and missing protocols

If you’re running a med spa in NJ, this is your warning: compliance is not optional.

What Med Spas Should Do Now

Clarify Roles: Every provider should know what license they’re operating under for each treatment.
Update Contracts & Protocols: Make sure you have signed, state-specific delegation agreements for RNs, APNs, and PAs.
Separate Medical from Cosmetic: Use separate appointment types, consent forms, and supervision workflows.
Train Your Team: Everyone—from your injector to your receptionist—should understand scope, documentation, and what to say when patients ask questions.
Get a Compliance Partner: You don’t need to do this alone. At ACE, we specialize in keeping med spas audit-ready and legally protected.

Want to Stay Ahead of NJ’s Rules?

If you need standing orders, good faith exam templates, supervision checklists, or help structuring your MSO to stay CPOM-compliant—we’ve got you covered.