California has clear rules about who may inject, who may operate lasers, and what physician supervision requires. Most patients have never been told what those rules are — or what they don't require.
In California, injectables and lasers are the practice of medicine. A physician may perform them. An RN, NP, or PA may perform them under physician supervision. Medical assistants, estheticians, cosmetologists, and LVNs may not perform them at all — even with a doctor standing beside them. But supervision does not always require the physician to be on site, which is why "we have a medical director" and "a doctor will treat you" are very different statements.
Patients choosing a medical spa are usually comparing before-and-after photos, prices, and Google ratings. Almost nobody asks the question that actually determines their risk: what is the license of the person who will be holding the needle?
That isn't because patients don't care. It's because most don't know the categories exist, or that they carry different legal authority.
What follows is the framework, plainly stated. It's not an argument for any particular practice — plenty of excellent care in California is delivered by nurse injectors. It's the information needed to ask a better question.
*See the 2026 nurse practitioner change below.
Two rows deserve attention. Medical assistants and estheticians cannot inject under any circumstances — not with a physician in the room, not with additional certification, not inside a physician-owned practice. This is reported to be among the most commonly violated rules in California medical spas.
This is the part that surprises people.
California requires physician supervision for delegated medical treatment. It does not universally require the supervising physician to be physically present in the building while treatment happens.
So a practice can accurately say it operates under physician supervision, and have no physician on site on the day you're treated. Both things are true at once, and neither is a lie.
The Board issued this because arrangements had emerged where a physician's name provided regulatory cover for a practice they had little genuine involvement in. California's corporate practice of medicine doctrine exists for related reasons — it restricts non-physicians from owning and controlling medical practices.
A medical director is the physician responsible for supervising delegated medical treatment at a practice.
The title does not mean the physician performs treatments, owns the practice, saw your chart, or is present during your appointment. At some practices the medical director is deeply involved. At others the relationship is considerably thinner.
Patients read "medical director" and hear "a doctor is in charge of my care." Sometimes that's accurate. The title alone doesn't tell you which.
Under AB-890, effective January 1, 2026, a nurse practitioner who has completed California's full-practice authority requirements may perform injectables independently, own a medical spa, and serve as its own medical director — with no physician oversight at all.
Nurse practitioners who haven't yet met those requirements must still maintain a standardized procedure agreement with a collaborating physician.
This is the most significant change to California injectable scope of practice in years, and it means "nurse practitioner" now describes two meaningfully different levels of authority. Worth knowing if that's who is treating you.
Anywhere. Including here.
None of these are hostile questions. Any competent practice expects them and answers plainly. Hesitation is the answer.
Plump Medical Spa is physician-owned. Dr. Amir Mortazavi, MD performs every treatment personally — every injection, every laser, every procedure. Nothing is delegated to a nurse injector, nurse practitioner, physician assistant, or aesthetician.
That isn't a claim that other models are unsafe. Many nurse injectors are excellent, and delegation is legal, common, and often produces very good care.
It's a claim about continuity. The person who assessed your face is the person who treats it and the person who sees how it settled at follow-up. Over one appointment that matters less than people think. Over five years of cumulative treatment, it's the thing that catches the drift toward overfilled — which almost never comes from one bad appointment, but from many reasonable ones with nobody tracking the total.
I'd rather patients ask these questions everywhere than assume the answer here. A patient who knows what to ask makes better decisions regardless of where they end up — and the ones who arrive here having asked elsewhere tend to be the ones I can help most, because they already know what they're comparing.
Can a nurse inject Botox in California?
Yes. Registered nurses, nurse practitioners, and physician assistants may perform cosmetic injections in California under physician supervision. Injectables are legally considered the practice of medicine, so they cannot be performed independently by an RN or PA — a supervising physician relationship is required.
Can a medical assistant or esthetician inject Botox in California?
No. Medical assistants cannot administer injectables under any circumstances, even with a physician physically present. Estheticians and cosmetologists are licensed for non-invasive skincare only and cannot perform injectables even inside a physician-owned practice. Licensed vocational nurses are also prohibited from injecting, regardless of supervision level.
Does a doctor have to be present at a medical spa?
Not necessarily. California requires physician supervision for delegated medical procedures, but supervision does not always mean the physician is physically present in the building. The practical result is that at many medical spas the supervising physician is not on site during treatment. This is why asking who will actually be in the room matters more than asking whether the practice has a physician.
What does "medical director" mean at a med spa?
A medical director is the physician responsible for supervising delegated medical treatment. The title does not indicate the physician performs treatments, owns the practice, or is present during your appointment. The Medical Board of California has stated there is no such thing as a sponsoring physician, and that a nurse may not employ or contract with a physician purely to obtain supervision — but arrangements vary considerably in practice.
Who can operate a laser in California?
Laser and intense pulsed light procedures may be performed by a licensed physician, or by a registered nurse or physician assistant under physician supervision. Medical assistants, estheticians, cosmetologists, and licensed vocational nurses are not authorized to perform them independently.
Can a nurse practitioner own a medical spa in California?
As of January 1, 2026, a nurse practitioner who has met California's full-practice authority requirements under AB-890 may perform injectables independently, own a medical spa, and serve as its medical director without physician oversight. Nurse practitioners who have not yet met those requirements must still maintain a standardized procedure agreement with a collaborating physician.
Who performs treatments at Plump Medical Spa?
Dr. Amir Mortazavi, MD performs every treatment personally. Nothing is delegated to a nurse injector, nurse practitioner, physician assistant, or aesthetician. The physician who assesses you is the physician who treats you and the physician who sees how the result settled.
What should I ask a medical spa before booking?
Ask who will physically be performing your treatment and what their license is. Ask whether a physician will be on site during the appointment. Ask who manages a complication if one occurs, and whether that person is available the same day. These three questions distinguish practices more reliably than any marketing claim.
General information, not legal advice. California scope-of-practice regulation is detailed and changes over time — AB-890 took effect January 1, 2026 and altered nurse practitioner authority meaningfully. This page describes the landscape as it stands to help patients ask better questions. Providers seeking compliance guidance should consult a healthcare attorney, and patients with concerns about a specific practice can contact the Medical Board of California.
Then ask them everywhere else you're considering. The comparison is the point.
4667 MacArthur Blvd, Suite 310 — Newport Beach, CA 92660
(949) 568-7544 — info@plumpmedicalspa.com
Tuesday – Saturday, 10am – 6pm — By Appointment Only