Michigan laser hair removal: the physician supervision rule in MCL 333.16276

In Michigan, a nurse, an esthetician or a trained unlicensed technician may perform laser hair removal, but only under the supervision of a licensed physician. MCL 333.16276(1) says a licensee, registrant, or other individual shall not perform any procedure using a laser for dermatological purposes without that supervision. The patient must also know who is treating them and consent to it.

The section was added by 2004 PA 144 and took effect June 15, 2004. As of October 2026, the Legislature’s history line shows no amendment since. Two newer provisions, both effective April 2, 2025, changed the rules around it.

The statute covers cosmetic laser work, including hair

Operators argue that hair removal is cosmetic and therefore outside the medical rules. The statute closes that door in its definitions. “Dermatological” means of or relating to the practice of dermatology. “Practice of dermatology” means the diagnosis and treatment of medically necessary and cosmetic conditions of the skin, hair, and nails by various surgical, reconstructive, cosmetic, and nonsurgical methods (MCL 333.16276(5)(a) and (b)).

Hair is named. Cosmetic conditions are named. Nonsurgical methods are named. Laser hair removal, laser resurfacing and laser tattoo removal all sit inside the section.

The statute does not define the word laser. If your device is IPL or another light-based system, get the answer in writing from Michigan counsel before you treat it as outside the section.

Supervision has three parts, and none of them is a signature

Section 16276(5)(c) defines supervision the same way the general definition in MCL 333.16109(2) does. It is the overseeing of or participation in the work of another individual by a licensed health professional where at least all of the following exist:

  1. Continuous availability of direct communication between the supervised individual and a licensed health professional, in person or by radio, telephone, or telecommunication.
  2. Regularly scheduled availability of a licensed health professional to review the practice of the supervised individual, provide consultation, review records, and further educate the individual.
  3. Predetermined procedures and drug protocol provided by the supervising licensed health professional.

Read the first item carefully. The text allows communication by telephone or telecommunication. It does not say the physician must be in the building while the laser fires.

Read the other two just as carefully. A physician who can be reached by phone but never reviews charts, never consults and never wrote the protocol has met one condition out of three. The statute says “at least all.”

The department may also promulgate rules to further prohibit or restrict laser use (MCL 333.16276(4)).

The patient consents to the operator by name

Subsection (2) is the part most consent forms miss. A licensee, registrant, or other individual shall not perform a laser procedure for dermatological purposes “unless the patient has knowledge and consents to the procedure being performed by that licensee, registrant, or individual.”

A form that says “I consent to laser hair removal” does not obviously meet it. The patient has to know which person is performing the treatment and agree to that. Put the operator’s name and credential on the consent, and update it when staff change.

Three people are exempt from the supervision rule

Subsection (1) does not apply to:

  • A licensed physician.
  • A licensed physician’s assistant who performs the procedure in a health care facility.
  • A certified nurse practitioner who performs the procedure in a health care facility.

The phrase “health care facility” carries the exemption, and section 16276 does not define it. The Public Health Code defines the term in MCL 333.17210(6)(b), but that definition begins “as used in this section” and belongs to the nurse anesthetist provisions. It lists a physician’s office and “any other office or facility in which diagnostic or therapeutic procedures are provided to a patient.”

That definition is a guide. It is not a ruling on section 16276. If your nurse practitioner runs a laser in a space with no physician attached to it, do not assume the exemption applies. The conservative setup is physician supervision for every operator who is not a physician.

An esthetician license does not reach the laser

Michigan rewrote its esthetician scope in 2024. Under MCL 339.1210, as amended by 2024 PA 78 and 2024 PA 160 (effective April 2, 2025), the listed skin care services include cleansing or stimulating the skin with “noninvasive light,” and temporary hair removal using hands-only techniques with depilatories, waxes, razors, scissors, clippers, thread, or tweezers. Two limits follow:

  • A skin care service must be limited to the stratum corneum, as applicable (MCL 339.1210(3)).
  • Light therapy must be noninvasive, approved by the FDA, and intended to not penetrate into the layers of living skin (MCL 339.1210(5)).

Laser hair removal targets the follicle, which sits below the stratum corneum. It is not on the list.

The cosmetology rules then connect the two codes. Under Mich. Admin. Code R 338.2179g(1)(i), a cosmetology licensee shall not perform services limited to the scope of a licensed health profession unless the service is delegated under MCL 333.16215. So an esthetician may run a laser in Michigan only as a physician’s delegatee, qualified by education, training, or experience, and supervised under section 16276. The cosmetology license adds nothing to that authority.

The 2025 exfoliation rule uses the same template

MCL 333.16276a, added by 2024 PA 159 and effective April 2, 2025, applies the laser structure to “medical exfoliation.” That means dermaplaning or microdermabrasion that exfoliates skin cells in the layers of epidermis below the stratum corneum. It requires physician supervision and patient knowledge and consent to the individual performing it.

The exemption is narrower than the laser one. Only a licensed physician is exempt. A PA or nurse practitioner performing medical exfoliation needs physician supervision under the text.

Who may operate, and on what condition

Operator Laser for dermatological purposes Authority
Physician (MD or DO) Yes, no supervision required MCL 333.16276(3)(a)
PA in a health care facility Yes, exempt from the supervision rule MCL 333.16276(3)(b)
Certified NP in a health care facility Yes, exempt from the supervision rule MCL 333.16276(3)(c)
PA or NP outside a health care facility Only under physician supervision MCL 333.16276(1)
RN, LPN, esthetician, unlicensed technician Only under physician supervision, as a qualified delegatee MCL 333.16276(1); MCL 333.16215(1)
Any operator Patient must know and consent to that individual MCL 333.16276(2)

The file to build for each laser operator

  • A written delegation from the physician naming the individual and the devices.
  • Evidence of the education, training, or experience relied on (MCL 333.16215(1)).
  • The physician’s predetermined procedures: settings by skin type, test spots, contraindications, complication steps.
  • How the operator reaches a licensed health professional during every treatment hour.
  • A schedule of chart review and consultation, with dates kept.
  • A consent form that names the operator.

MDside’s position is stricter than the statute’s minimum. The text permits communication by telephone, but a director who has never seen the device, the room or the operator’s technique cannot write a meaningful protocol. We tie laser delegation to a documented good faith exam, device-specific protocols, and the review cadence in our clinical standards.

What this means for you

If you offer laser services in Michigan, you need a Michigan-licensed physician who supervises in all three statutory senses: reachable, reviewing, and author of the protocol. Rewrite your consent so the patient agrees to the named operator. Do not rely on an esthetician license or a device salesperson’s training certificate as authority. If you also offer dermaplaning or microdermabrasion, check each service against the stratum corneum line. For how supervision is set up in practice, see medical director services in Michigan, aesthetics and injectables, and what MDside provides to med spas.

Frequently asked questions

Who can perform laser hair removal in Michigan?

Any licensee, registrant, or other individual may perform it only under the supervision of a licensed physician, under MCL 333.16276(1). A physician needs no supervision. A physician’s assistant or certified nurse practitioner is exempt from the supervision rule only when performing the procedure in a health care facility. The patient must also consent to the individual operator.

Can an esthetician do laser hair removal in Michigan?

Only as a physician’s delegatee. MCL 339.1210 limits esthetician skin care services to the stratum corneum and to noninvasive light. Rule R 338.2179g bars cosmetology licensees from health profession services unless delegated under MCL 333.16215. The esthetician must be qualified by education, training, or experience and supervised by a physician under MCL 333.16276.

Does the physician have to be on site for laser treatments in Michigan?

The statute’s text does not require it. MCL 333.16276(5)(c) defines supervision as continuous availability of direct communication in person or by radio, telephone, or telecommunication, plus regularly scheduled review and consultation, plus predetermined procedures. All three must exist. Confirm with counsel whether any board rule adds to this for your setup.

Does Michigan require patient consent to the specific laser operator?

Yes. MCL 333.16276(2) says an individual shall not perform a laser procedure for dermatological purposes unless the patient has knowledge and consents to the procedure being performed by that individual. A generic consent to the treatment is not enough on its face. Name the operator and credential on the form.

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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.

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Medical direction. Victor D. Cruz, MD, Systems Medical Director, licensed in Florida (ME117105) and New York, directs structure, corporate practice of medicine, delegation and good faith exams. This states who carries clinical responsibility for this subject area. It is not a page-level review: pages that have been reviewed name the reviewer and show the date. How this site is written and checked.