By Patrick O’Brien, Legal Coordinator, American Med Spa Association

Rhode Island has passed a law regulating medical spas after several years of unsuccessful attempts. The companion bills, Senate Bill 976 and House Bill 5351, were signed into law on June 30, 2025. Both bills were amended during the legislative process and will require Rhode Island medical spas to make several changes to remain compliant. This post will review the elements and changes of this new law. 

The biggest change introduced by this law is that medical spas will now be licensed healthcare facilities under the Rhode Island Department of Health. Previously, Rhode Island medical spas were governed by the same regulations as other medical offices or physicians’ practices. But, under the new law, medical spas will need to apply and be licensed, similar to nursing facilities, ambulatory surgical centers and dialysis centers. Importantly, medical spas are exempt from needing to obtain a “determination of need,” as other facilities do. The exact requirements of the application are not yet available; the department has until July 1, 2026, to release rules governing licensing requirements and for other areas of this law. 

In addition to licensing, medical spas will also need to follow new training and supervision requirements. The law defines medical spas as licensed establishments that perform “cosmetic medical procedures,” which are broadly defined to include any procedure directed at improving appearance that does not meaningfully promote function or treat a disease and does not require sedation. The definition goes on to list a number of procedures that are included, such as hair transplants, cosmetic injections, dermabrasion beyond the stratum corneum, laser treatments, platelet-rich plasma (PRP), permanent fat removal and radio frequency. 

Every medical spa must employ or contract with a physician or certified nurse practitioner who assumes the role of a medical director. This medical director must be trained in the indications and performance of the cosmetic medical procedures that are offered in the medical spa; the training cannot solely be from manufacturer- or vendor-provided programs. The medical director must also implement policies and procedures to ensure quality of care. They are responsible for the delegation and supervision of the cosmetic procedures and the oversight and training of those who perform them.

Cosmetic medical procedures can only be provided by or under the supervision of a physician, physician assistant (PA) or advanced practice registered nurse (APRN). Supervision can be onsite or offsite, but the supervisor must be able to directly observe the treatment being performed. Prior to treatment, a supervising physician, PA or APRN must: 

1. Perform an initial patient assessment;
2. Create a written treatment plan for each patient;
3. Obtain patient consent; and
4. Create medical records for the patient. 

In order for non-physicians, non-PAs or non-APRNs to perform cosmetic medical procedures, the treatment must be delegated the treatment by a supervising physician, PA or APRN and be properly trained in the safe and effective performance of all cosmetic medical procedures. Ablative energy procedures may only be performed by physicians, PAs or certified nurse practitioners. In performing any cosmetic medical procedures, all providers must: 

1. Review and follow the written protocols;
2. Verify that the patient has been assessed and given a written treatment instruction by a physician, PA or APRN;
3. Review the procedure with the patient;
4. Notify the medical director and the supervising person of any adverse events or complications;
5. Document all details in the medical records; and
6. Satisfy any requirements of their licensing board.

This new law contains many new provisions that Rhode Island medical spas will need to adopt to maintain compliance—chief among them is obtaining a facility license. Previously, practitioner-owned medical spas were exempt, but now, all will need to apply for the license. The other training and supervision changes are similar to previous Rhode Island medical spa practices and, therefore, may not require huge adjustments or changes for medical spas to stay compliant. But every Rhode Island medical spa should take this opportunity to review their policies, procedures and training to come into line with this law. Information about the medical spa license is not yet available but eventually will be through the Center for Health Facilities Regulation. 

Rhode Island is merely the latest state to take action on aesthetic and wellness practices. Many other states are taking a closer look at regulating these practices, with several bills introduced this year. Given the fast-changing nature of this industry, many medical spas may benefit from reviewing their policies and procedures and performing a compliance review.

Keep up with the latest movements in med spa regulation with AmSpa's state-by-state legal resources. AmSpa Members can take advantage of an annual consultation with national health care law firm ByrdAdatto for a personalized look at their practice's legal compliance. Learn more about becoming a member to access the community, tools and education you need to succeed in medical aesthetics.