FLORIDA AUTONOMOUS APRNS IN AESTHETIC MEDICINE

Can Florida APRNs Practice Aesthetic Medicine Without Physician Supervision? (2025 Update)

In 2020, Florida made national headlines by granting certain Advanced Practice Registered Nurses (APRNs) the ability to practice independently — but only in very specific circumstances. As we step into 2025, one question continues to surface in the world of medical aesthetics:

Can an APRN in Florida legally provide aesthetic services like Botox or laser treatments without a supervising physician?

The short answer: No. Despite the existence of an autonomous APRN license, Florida law still requires physician supervision and a written protocol for cosmetic medical procedures. Let’s unpack what the law really says and what it means for APRNs practicing (or hoping to practice) aesthetic medicine.

Florida’s APRN Autonomous Practice Law: Primary Care Only

In 2020, Florida passed HB 607, creating a new license category for "Autonomous APRNs." Effective in 2021, this allowed eligible APRNs to practice independently without physician supervision — but only in primary care settings.

To qualify for autonomy, an APRN must:

• Hold a clear and active Florida APRN license

• Have 3,000 hours (2 years) of supervised practice under a physician

• Practice only within primary care fields:▸ General family medicine▸ General internal medicine▸ General pediatrics▸ Health promotion

What is excluded? Dermatology, medical aesthetics, pain management, and other specialty services.

Aesthetic Medicine Is Not Primary Care

Cosmetic procedures like Botox, fillers, microneedling, lasers, and PRP are not included in Florida’s definition of "primary care." That means even an Autonomous APRN cannot perform them without a collaborating physician.

This remains true as of January 2025. There have been no legal changes allowing independent APRN practice in aesthetic medicine.

What Florida Law Requires for APRNs in Aesthetic Medicine

If you are an APRN in Florida planning to offer aesthetic services, you must meet all of the following requirements:

1. Physician Oversight

• You must work under the supervision of a licensed physician.

• If cosmetic services are the primary focus of the practice and you operate at a separate location, the physician must be a:▸ Board-certified or board-eligible plastic surgeon or dermatologist

• The physician must be located within 25 miles of your practice and may only supervise one additional location.

  
  

2. Written Collaborative Protocol

• A formal written protocol is required by law.

• It must:▸ Outline the medical procedures being delegated▸ Be signed by both the APRN and physician▸ Be available upon inspection or audit

• This is mandatory even if you hold an Autonomous APRN license — because cosmetic medicine is outside the autonomous scope.

  
  

3. Scope of Practice Compliance

• Performing aesthetic services without appropriate physician collaboration may be considered the unlicensed practice of medicine — a serious legal and licensing violation.

  
  

Recent Legislative Attempts to Expand APRN Scope (2023–2024)

Over the last two years, Florida lawmakers introduced several bills seeking to expand APRN autonomy — but none became law.

HB 1067 (2023):

Would have allowed autonomous APRNs to practice in their specialty (e.g. dermatology or aesthetics), not just primary care

Status: Died in session

HB 257 / SB 810 (2024):

Focused on CRNAs and broader specialty autonomy

Status: Failed to advance

As of early 2025, no legislation has been passed to grant APRNs full practice authority or independent scope in aesthetic medicine.

What Florida APRNs Need to Know for 2025

Key Issue	2025 Status
Autonomous APRN License	Still limited to primary care only
Aesthetic Procedures	Still require MD supervision & written protocol
Can APRNs be solo medical directors of med spas?	No – must have MD oversight
Recent legislative changes?	None – all expansion efforts failed
Risk of performing aesthetics without MD?	Could face disciplinary action for unlicensed medical practice

Final Takeaway for Florida APRNs in Aesthetics

If you’re an APRN in Florida offering cosmetic services like Botox, lasers, or fillers, autonomy doesn’t apply. You still need a supervising physician and a signed protocol — just like before 2020. Even with an autonomous license, stepping into aesthetics without a collaborating MD could jeopardize your license and your career.

At The Aesthetic Compliance Co., we help APRNs navigate these evolving rules with confidence. From creating state-compliant protocols to ensuring you stay compliant, protected, and ready to grow.

Disclaimer: This blog is for informational purposes only and does not constitute legal advice. For specific legal or regulatory guidance, consult your attorney or state licensing board.