Kentucky does not have a single med spa statute. It has three chapters that each answer part of the question, and a clinic tends to read only one of them.
Medical aesthetics in Kentucky are governed by KRS 311 (the Medical Practice Act), KRS 314 (nursing) and KRS 317A (cosmetology), together with board advisory opinions. Under that framework, injectables, laser and IV therapy are the practice of medicine.
Which chapter answers which question
| Question | Where the answer lives |
|---|---|
| Is this act the practice of medicine at all? | KRS 311 |
| May this nurse or APRN perform it, and on what order? | KRS 314, plus Board of Nursing guidance |
| May an esthetician perform it? | KRS 317A |
| What has the regulator actually said about med spas? | Board advisory opinions, including the Board of Nursing’s APRN med spa resource |
The failure is predictable
A physician-led clinic reads KRS 311 and concludes it is fine. A nurse-led clinic reads KRS 314 and concludes the same. Neither reads KRS 317A, so the esthetician question — which is where most staffing creep happens — is answered by whoever is most confident in the room.
The reverse also happens: a salon adding treatments reads the cosmetology chapter, finds nothing prohibiting it, and never asks whether the act is the practice of medicine under KRS 311.
Start with the act, not the licence
The sequence that works is the opposite of the intuitive one. Do not start with “what may our staff do?” Start with “what is this act?”
- Classify each service on the menu — is it the practice of medicine?
- If it is, establish who may perform it and under what order or protocol.
- Then check the receiving licence’s own chapter for limits the medical chapter does not mention.
- Then check the board advisory opinions, which is where the specifics for this market actually are.
One concrete rule to carry
An RN or LPN may administer an injection only when it is lawfully ordered by a qualified prescriber as part of a documented medical plan of care. That single sentence resolves a large share of Kentucky staffing questions, and it sits at the intersection of all three chapters rather than inside any one of them.
For the prescribing side, Kentucky’s four-year rule for APRN prescriptive authority is the other thing to know before you design the model.
Related reading
Frequently asked questions
Which Kentucky statutes govern med spas?
KRS 311 for medicine, KRS 314 for nursing and KRS 317A for cosmetology, plus board advisory opinions.
Are injectables the practice of medicine in Kentucky?
Yes. Injectables, laser and IV therapy are treated as the practice of medicine.
Can an esthetician perform injectables?
Injection is not within the cosmetology scope. Classify the act first, then check the receiving licence.
When may an RN administer an injection?
Only on a lawful order from a qualified prescriber, as part of a documented medical plan of care.
General information about Kentucky regulation, not legal advice. Confirm your obligations with healthcare counsel licensed in Kentucky.