
Legal
Letter from AmSpa Founder on Texas Med Spa Bill Restricting NPs and PAs
On March 4, 2025 HB 3749 was introduced in the Texas House of Representatives seeking to significantly restrict NPs and ...
Posted By Kate Harper, Friday, January 4, 2019
By Patrick O'Brien, J.D., Legal Coordinator for the American Med Spa Association
This is a continuation of a piece on post on dermaplaning. To read the first part of this blog, click here.
How have other states approached dermaplaning and its perceived duality? Other states have approached this dual nature of dermaplaning as both a cosmetic treatment and a medical procedure by permitting cosmetologists and estheticians to perform dermaplaning but only under the supervision of a physician. Utah is one such state, they allow master estheticians to perform dermaplaning under the direct supervision of a health care practitioner.
The layer of skin affected is not the only area of concern for Dermaplaning. In states such as Texas estheticians and cosmetologists are permitted to perform microdermabrasion procedures as long as they only remove dead skin cells. This is similar to some of the previously listed states. However, Texas estheticians and cosmetologists are not allowed to perform dermaplaning regardless of the layer of skin effected. The reason is that using a bladed implement on the face is considered shaving and only barbers are licensed to shave the face. The similarity to shaving is also at play in New Jersey where barbers and master barbers can perform dermaplaning.
It appears that most states have at least some restriction that limit or prohibit esthetician's and cosmetologist's ability to dermaplane. Some strictly limit the depth of skin that can be affected. Some make it a medical procedure and require that it be performed under medical supervision or by medical practitioners. Medical spas that are considering offering dermaplaning services should certainly review their own state's specific rules on the procedure (AmSpa Members can refer to your state's summary here).
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