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Who Can Inject Botox in Colorado? Understanding the Laws and Regulations

In the world of aesthetics, treatments like Botox and Xeomin have become popular choices for those seeking to enhance their natural beauty. These neurotoxins, when administered correctly, can smooth out wrinkles, prevent new ones from forming, and give your skin a youthful, rejuvenated appearance. However, it’s crucial to remember that these are medical procedures, and choosing the right practitioner is key to achieving the best and safest results. So who can inject Botox in Colorado? The answer might surprise you.

Understanding Medical Spas and the Practice of Medicine in Colorado

Medical spas were developed to offer certain aesthetic skin care procedures developed by dermatologists and plastic surgeons in an environment thought to be more pleasing to clients. While these procedures may be referred to as ‘cosmetic treatments,’ they are actually medical procedures. According to the Colorado Medical Board, “Medical services” are defined to include suggesting, recommending, prescribing, or administering any form of treatment, operation, or healing for the intended palliation, relief, or cure of any physical or mental disease, ailment, injury, condition or defect of any person.

In addition, “Medical-Aesthetic Services” are medical services in the cosmetic or aesthetic field and constitute the practice of medicine. Such Medical-Aesthetic Services include, but are not limited to: [1] the use of a Class IIIb or higher laser, radio-frequency device, IPL, or other technique that results in the revision, destruction, incision or other structural alteration of human tissue and/or for hair removal and [2] the performance of injection of any substance into the human body.

Who Can Legally Inject Botox in Colorado?

Colorado considers the injection of botox to be the practice of medicine and as such must be administered by licensed physicians. However, the physician may delegate the procedure to a physician assistant, nurse practitioner, registered nurse, licensed practical nurse or even an unlicensed person, under appropriate physician supervision, if they are qualified by education, training or experience to competently and safely perform the procedure. Further, any delegation must comply with the requirements of Rule 800. Yes, that’s an unlicensed person. Legally they must be supervised in some way, but how do you know what level of supervision that person has received?

Different legal Models

While delegation is state specific and each state has its own nuances, there are two basic ways the laws are set up. We refer to these two constructs as the (1) dictator model and the (2) deference model (Americanmedspa.org, 2023).

In the dictator model, the state will specifically define who can perform medical treatments (including Botox). For example, California allows a RN, a PA, or APRN to be delegated medical treatments, including Botox. The dictator model is both clear and rigid. There is not compliant utility for using someone who does not have specific authority to be delegated treatment in a state that has the dictator model.

Other states use the deference model and place the burden on the doctor who is delegating the procedure to determine who may perform medical treatments. The doctor is held to the standard of care and puts their license on the line when deciding who they think is appropriate to provide a treatment like Botox. The doctor has discretion to delegate the procedure to anyone they feel is safe and has the appropriate level of training and experience. However, just because you are allowed to delegate, does not mean you always should.

The Advantage of a Medical Physician

While many spas and clinics offer these treatments, it’s a rare and valuable find to have a medical physician performing the procedure. A medical physician has extensive training and understanding of the human body, which goes beyond what is typically required for aesthetic treatments.

Dr. Degurse, the owner of Pearl Skin & Body Rejuvenation, is one such rare find. As a medical physician, she brings a level of expertise and credibility that sets her apart in the field of medical aesthetics.

What Sets Dr. Degurse Apart

Dr. Degurse‘s medical background allows her to understand the science behind the treatments she offers. She knows how these neurotoxins work, where they should be administered for the best results, and how to do so safely. This knowledge allows her to provide treatments that are tailored to each individual’s needs and goals, ensuring the best possible results.

Moreover, as a physician, Dr. Degurse is equipped to handle any potential complications. While these are rare, knowing that your practitioner can swiftly and effectively address any issues that may arise provides an added layer of security and peace of mind.


When it comes to neurotoxin treatments like Botox and Xeomin, choosing the right practitioner is crucial. Having a medical physician like Dr. Degurse administer your treatment offers a level of expertise and safety that is truly exceptional.

At Pearl Skin & Body Rejuvenation, we believe in providing the highest level of care for our clients. We invite you to experience the difference that a physician-led treatment can make.

Remember, your beauty is unique, and you deserve to entrust it to the best. Choose wisely, choose safety, choose expertise. Choose Pearl Skin & Body Rejuvenation.

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