In an in interesting turn of events, the Florida Board of Nursing recently issued a Declaratory Statement regarding whether a registered nurse may administer Botox injections. Based on the facts laid out in the nurse’s Petition for Declaratory Statement, the Board determined that the administration of Botox injections did fall within her scope of practice. Specifically, the RN had been practicing under the supervision of a medical doctor and a nurse practitioner for four years, and she had observed aesthetic injections and assisted in the operating room. The RN sought clarification from the Board as to whether she could administer Botox injections in cases where the physician had examined the patient, written an order for the prescribed Botox treatment along with a description of the muscles to be injected and the number of units per injection site, and delegated the task to her. The Board opined that as long as the RN administered Botox injections under the direct supervision of the delegating physician, it did fall within her permissible scope of practice. Note that direct supervision usually means that the supervising physician is in the same building and is immediately physically available.

This Declaratory Statement applies only to the RN/Petitioner in question and does not authorize other RNs to administer Botox injections, but it does offer some helpful guidance regarding the administration of Botox by nurses under the direct supervision of a delegating physician.

So, this is a step forward for RNs in the medspa and aesthetics arena, but it is not carte blanche for RNs to start administering Botox injections.  This Declaratory Statement applies only to this nurse under this specific set of facts.  If you are interested in obtaining a Declaratory Statement, we would be happy to assist you.  The attorneys at Nicholson & Eastin, LLP routinely represent nurses and other healthcare providers in matters before the Board of Nursing, Board of Medicine, and other Florida Department of Health boards. If you have questions regarding Florida nursing scope of practice, Florida Board of Nursing declaratory statements, or any other healthcare regulatory matters in Florida, please contact us.

The entire declaratory statement can be viewed here.