The Massachusetts Board of Registration of Cosmetology and Barbering amended its Policy on Practices Outside the Scope of Licensure in May 2025, drawing a clear line between beautification and medical care in med spa settings. The board reiterates that working in, or alongside, a medical practice does not expand an aesthetician’s legal scope. 

What the Policy says

Medical or invasive procedures are off-limits for cosmetologists, aestheticians, electrologists, manicurists, and barbers in Massachusetts. Prohibitions include injections, microneedling beyond the dermis, medium–deep chemical peels (AHA > 30%, BHA > 2%, or pH < 3.0), laser use by non-electrologists, body contouring, radiofrequency, plasma skin tightening, lymphatic drainage beyond the head/face/neck, tattooing and removal, and acupuncture. 

IPL is a narrow exception. Aestheticians may use IPL for photofacials only if they complete required training and follow Board facility and equipment requirements. Laser technology use for hair removal remains limited to electrologists under separate rules.

Training hours clarified. Microdermabrasion and dermaplaning are permitted only at the epidermal level, with documented 16 hours of training for each service, including 10 hours of hands-on instruction kept onsite for inspection. 

Salon licensing and advertising. If services are performed inside a medical office, the treatment room itself must be licensed as a salon, with advertising that clearly distinguishes board-regulated services from any non-board procedures. Misleading or inaccurate advertising is prohibited. 

Titles matter. The board explicitly states that “medical aesthetician,” and similar hybrid titles do not exist under Massachusetts law and may constitute misrepresentation. Delegated medical tasks from a physician are outside the Board’s umbrella and do not expand cosmetology scope.

What med spas and aestheticians should do now

Audit service menus. Remove any service that penetrates the skin, alters tissue, or uses medical-grade energy from the aesthetician list. Reserve these for medically licensed personnel. 

Separate operations. Use distinct rooms, obtain board salon licensure for those rooms in medical facilities, and keep signage and pricing menus separate. 

Update advertising and titles. Avoid medical or clinical language and non-recognized titles that imply healthcare licensure.

Verify training documentation. Maintain proof of required training hours for microdermabrasion, dermaplaning, and licensed services onsite.

Review delegation with counsel. Physician delegation does not convert a procedure into a cosmetology service and may trigger separate healthcare regulations. 

Bottom line for AmSpa readers: In Massachusetts, beautification stays within aesthetic licensure, medical procedures require medical licensure, and med spa operators must keep regulatory walls intact between the two.