The Rhode Island Department of Health (RIDOH) is proposing a clarification to its physician licensure regulations (216‑RICR‑40‑05-1) to amend the definition of “surgery,” stating that injection of the following medications and autologous plasma products for cosmetic purposes is not considered surgery:

• OnabotulinumtoxinA (e.g., Botox)
• Hyaluronic acid fillers
• Platelet‑Rich Fibrin (PRF)
• Platelet‑Rich Plasma (PRP)

The amendment simply codifies that these injectable aesthetic treatments, which are already routinely understood to be minimally invasive nonsurgical procedures, will be officially excluded from the regulatory definition of surgery in Rhode Island.

RIDOH’s existing definition of surgery is very broad and includes any use of instruments (including needles) that alter human tissue. Without clarification, this could technically be interpreted to include cosmetic injections.

For licensed medical professionals already performing these aesthetic treatments, nothing about your scope of practice changes. The amendment does not restrict, expand, or modify who can inject botox and fillers in Rhode Island.

Interested in learning more about the state of med spa legislation? Join your colleagues at Medical Spa Show, April 9 - 12, 2026.