There has been some confusion online about whether Texas has stopped physicians from delegating injectables or other nonsurgical cosmetic procedures to unlicensed medical assistants. The short answer is that delegation is still allowed in Texas.

In 2025, the Texas Medical Board reviewed and restructured its administrative rules by removing Rule §193.17 and relocating its content into Texas Administrative Code Rule §169.25 - §169.29. This restructuring simplified the language but kept the delegation framework intact. 

Under the reorganized rules, physicians may still delegate to unlicensed individuals as long as the individuals are properly trained, operating under compliant written orders, working within their capabilities, and supervised appropriately. Sections §169.25 through §169.27 outline these requirements, including Good Faith Exams, maintaining medical records, disclosing who will perform the procedure, ensuring basic life support capability on site, and confirming that a physician, PA, or APRN is available for emergency consultation.

The updated Section 169.28 also requires clear signage listing the delegating physician’s name, license number, and complaint notice and requires staff to wear badges showing their names and credentials. This transparency update does not alter delegation, but it strengthens the documentation and identification requirements.

There has also been confusion about Jenifer’s Law, 2025 Texas House Bill 3749, which in its original form would have affected medical spa operations a great deal. AmSpa’s legislative coverage clarified that the final version of HB 3749 applies only to elective IV therapy. It does not affect injectables, lasers, or other medical spa procedures. 

Learn more about the 2025 Texas Med Spa Legislation.

In Texas, minimally invasive aesthetic procedures such as Botox and filler injections are medical acts that can be delegated if proper training, written protocols, Good Faith Exams, documentation, and supervision requirements are met.

Can an esthetician do it?

Texas did not ban delegation. Texas did not prohibit unlicensed but trained individuals from performing delegated tasks. The recent updates reorganized the rules pertaining to medical spas and clarified administration specifically for elective IV therapy. The longstanding ability for physicians to delegate remains fully in place.

If you maintain Good Faith Exams, written protocols, training documentation, correct supervision, and required signage, you remain compliant under Texas law.

Want to learn more? Speak with the Dallas-based national health care law firm powering AmSpa's legal summaries at Medical Spa Show 2026.