New York’s Landmark Ruling on Medical Spas and Energy Devices

Background on New York’s Medical Spa Regulation Changes

On March 7, 2025, the New York State Board for Medicine issued a determination that will reshape the landscape of cosmetic and aesthetic services throughout the state. In its ruling, the Board held that the use of energy-based devices-lasers, intense pulsed light (IPL), radiofrequency, ultrasound, and similar technologies-that penetrate beyond the surface of the skin constitutes the practice of medicine. The implications of this shift are profound, both legally and commercially, as medical spas and non-physician operators now face an entirely new regulatory reality.

For years, the medical spa industry has thrived in a regulatory gray zone. Devices once marketed as “non-invasive” or “minimally invasive” blurred the line between cosmetic enhancement and medical treatment. Consumers flocked to spas offering wrinkle reduction, skin tightening, fat sculpting, and tattoo removal without giving much thought to whether these services were truly medical in nature. Many operators relied on aestheticians or technicians to perform the bulk of procedures, often with only nominal oversight from physicians or nurse practitioners. This model proved profitable: the U.S. med spa industry grew to an estimated $15 billion in 2024, with New York as one of the fastest-expanding markets.

The Board’s ruling, however, strikes at the heart of this business model. By declaring that almost all procedures involving energy devices that affect the dermis or deeper tissues fall within the statutory definition of medicine, the Board has eliminated the ambiguity that previously shielded non-licensed providers. The only carveout is laser hair removal, which remains in a unique category that regulators continue to treat as outside the practice of medicine. Beyond this narrow exception, virtually every procedure involving a medical-grade laser, radiofrequency tool, or ultrasound device now requires a licensed professional to conduct the treatment or closely supervise its performance.

The ruling is not simply bureaucratic housekeeping. It reflects an evolving recognition that these technologies, while marketed as safe and consumer-friendly, carry risks that demand medical judgment. Burns, scarring, pigment changes, vascular damage, infections, and even systemic complications are not merely cosmetic side effects-they are medical complications requiring medical expertise.

This introduction of medical classification changes the calculus for everyone involved:

• Medical spa owners must restructure operations to comply with supervision and licensure requirements.
• Aestheticians and technicians face new limits on what services they may perform.
• Physicians and nurse practitioners assume greater responsibility and potential liability.
• Patients gain added safeguards but may also see prices rise as compliance costs increase.

The March 2025 ruling is thus more than a clarification; it is a redefinition of the aesthetic industry in New York. Over the following sections, we will unpack the legal framework that informed the Board’s decision, examine the technical classifications of energy devices, assess the compliance and enforcement landscape, and explore how medical spas can adapt in this new era.

Legal Framework

To understand the significance of the March 2025 ruling, it is essential to place it within the broader legal framework that governs the practice of medicine in New York. The foundation lies in New York Education Law §6521, which defines the practice of medicine as “diagnosing, treating, operating, or prescribing for any human disease, pain, injury, deformity, or physical condition.” At first glance, this definition appears broad, but historically it has been applied in ways that attempt to balance consumer access to aesthetic services with the state’s responsibility to protect public health.

For decades, New York regulators have grappled with how to classify procedures that straddle the line between beauty and medicine. A prime example is the landmark case of People v. Lehrman (1937). In that case, the court examined whether the use of X-ray devices for hair removal constituted the practice of medicine. The court concluded that such use did not fall under medical practice at the time. This decision effectively established a precedent for excluding certain cosmetic treatments from medical regulation, particularly when they were perceived as low-risk.

However, the Board’s 2025 ruling signals a departure from the Lehrman approach. Technological advances over the past 80 years have radically changed the nature of energy-based devices. Today’s Class III and Class IV devices-such as CO₂ lasers for skin resurfacing or radiofrequency tools capable of deep tissue heating-operate at power levels unimaginable in the early 20th century. They penetrate below the epidermis, affect dermal and subcutaneous structures, and carry risks ranging from permanent scarring to systemic complications. To the Board, these characteristics align squarely with the statutory definition of medicine.

It is also important to understand the distinction between regulatory authority and advisory determinations. The Board for Medicine issues interpretations of Education Law, but the New York State Education Department (NYSED) is the entity that formally adopts these determinations. In the March 2025 ruling, NYSED explicitly adopted the Board’s findings with respect to all energy-device treatments other than laser hair removal. This adoption makes the ruling binding and enforceable, not merely advisory.

The ruling effectively draws a bright line:

• Treatments affecting only the stratum corneum or superficial epidermis (such as basic facials or LED light therapies) remain outside the scope of medicine.
• Treatments penetrating into the dermis or deeper layers are now firmly within the practice of medicine, regardless of whether the procedure is marketed as cosmetic.

This clarity is particularly significant given the explosive growth of the medical spa industry. Prior to this ruling, many operators relied on ambiguity to justify delegating procedures to unlicensed personnel. They pointed to the lack of explicit statutory language or prior enforcement actions as evidence that their practices were permissible. With the March 2025 decision, that gray area has been erased.

From a compliance perspective, the ruling reasserts the principle that risk determines regulation. Procedures carrying risks that demand medical judgment must be treated as medical practice, no matter how popular or commercially lucrative they may be. This is a critical shift for spa operators who built their business models around non-physician providers performing services once thought to be cosmetic.

The Board’s Findings

The March 2025 ruling by the New York State Board for Medicine does not merely restate the law; it provides a detailed and practical framework for distinguishing between cosmetic services and medical practice when it comes to energy devices. The Board’s central conclusion is clear: any procedure using energy-based technology that affects the basement membrane or deeper tissues qualifies as the practice of medicine.

This finding addresses longstanding ambiguity in the med spa industry, where procedures were often marketed as “non-invasive” despite involving significant physiological effects beneath the surface of the skin. To eliminate confusion, the Board offered specific guidance, citing a range of procedures that are now considered medical in nature. These include:

• Laser skin rejuvenation: Procedures such as fractional CO₂ resurfacing or erbium lasers, which target wrinkles, scars, and pigmentation by penetrating into the dermis to stimulate collagen remodeling.
• Tattoo removal: High-intensity laser pulses that reach into the dermal layer to fragment pigment particles for immune system clearance.
• Lesion removal: Energy-based treatment of benign growths, vascular malformations, and pigmented lesions, often requiring precision to avoid scarring or recurrence.
• Spider vein treatment: Laser or IPL systems targeting vascular structures beneath the epidermis, necessitating medical knowledge of vascular anatomy.
• Body contouring: Devices such as laser lipolysis tools and deep radiofrequency applicators, which heat subcutaneous fat to induce apoptosis or collagen contraction.

The Board’s reasoning is anchored in risk management and patient safety. Procedures that extend into the dermis or deeper tissues carry risks such as:

• Thermal injury (burns, blistering, necrosis).
• Scarring and keloid formation.
• Dyspigmentation (hyperpigmentation or hypopigmentation).
• Infections, particularly when devices disrupt the skin barrier.
• Vascular or neural injury, depending on device depth and settings.

Such complications, the Board emphasized, require professional medical judgment for both prevention and management. A technician without medical training may be able to operate a machine, but cannot diagnose complications, adjust treatment plans safely, or provide medical interventions if things go wrong.

The ruling also distinguishes laser hair removal as a unique outlier. Although it involves dermal penetration, the Department of Education chose not to act on the Board’s determination in this area, leaving laser hair removal outside the scope of medicine. The decision reflects regulatory caution, recognizing both the procedure’s popularity and the historical precedent of People v. Lehrman. However, the exclusion is narrow. For all other energy-based procedures, the Department fully adopted the Board’s findings, making them legally enforceable.

Another critical element of the findings is the Energy Device Classification Table introduced by the Board. This system categorizes devices from Class I to Class IV based on their depth of action and potential for harm. Class I devices (e.g., LED lights, elastic bandages) are not considered medical. Class II devices (e.g., IPL for hair removal) remain outside the practice of medicine when properly supervised. But Class IIIb and Class IV devices-medium- to high-powered lasers, RF tools, and ablative technologies-are explicitly designated as medical practice. This classification system not only guides practitioners but also provides regulators with a clear enforcement tool.

In essence, the Board’s findings recognize the modern reality: energy devices are not simply beauty tools, they are medical instruments. By acknowledging this, the ruling both elevates patient protection and imposes new obligations on medical spa operators, supervisors, and practitioners.

Practitioner Guidelines and Supervision Requirements

Alongside its reclassification of energy-based aesthetic procedures, the New York State Board for Medicine devoted significant attention to how such treatments must be carried out in practice. Recognizing that many medical spas already employ hybrid teams of physicians, nurses, and aestheticians, the Board set forth detailed practitioner guidelines intended to balance patient safety with operational feasibility.

At the heart of these guidelines is the requirement that every treatment with an energy device begins and ends with a medical assessment. The Board emphasized that an evaluation of the patient’s condition is not optional; it is a prerequisite. This assessment includes the collection of medical history, an examination of the area to be treated, identification of contraindications, and discussion of potential risks. Importantly, the ruling specifies that only licensed medical practitioners-physicians, physician assistants, and nurse practitioners-are authorized to make such determinations. Registered professional nurses (RNs) may also conduct patient assessments, but always under the framework of a medical plan of care established by a supervising practitioner.

The supervision requirements are also carefully delineated. The Board endorsed the concept of general supervision, which means the supervising physician or nurse practitioner does not need to be physically present at the med spa during the procedure. However, the supervisor must be available to provide direction and intervene within a reasonable timeframe should complications arise. This model is designed to accommodate the operational realities of medical spas while ensuring that unlicensed personnel are not operating without oversight.

When it comes to the actual execution of treatments, the ruling draws firm lines:

• Licensed physicians, PAs, and NPs may directly perform treatments with Class IIIb or Class IV devices, or they may delegate execution to RNs.
• Registered nurses may perform treatments, but only pursuant to a specific order and under the general supervision of one of the licensed practitioners noted above.
• Aestheticians and non-licensed personnel are categorically prohibited from using Class IIIb or Class IV devices. They may only use Class I and Class II devices, which include tools like LED lights, elastic bandages, and IPL systems for hair removal. Even then, their work must occur within a supervised structure.

The guidelines also stress the importance of continuous monitoring during and after treatment. Because complications may manifest after the procedure has ended-for example, delayed blistering, infection, or vascular compromise-the supervising medical professional must establish protocols for follow-up and intervention. This may include scheduled check-ins, clear escalation pathways for adverse events, and documentation standards to ensure accountability.

Documentation, in fact, plays a critical role in the supervision framework. The Board expects med spas to maintain thorough records of assessments, orders, procedures, complications, and follow-ups. Failure to document adequately could itself be grounds for regulatory action, as incomplete records undermine both patient safety and the ability to defend against claims.

Taken together, these practitioner guidelines and supervision requirements fundamentally reshape the staffing and operational structure of medical spas. Where many spas previously relied on aestheticians performing a wide range of procedures with little oversight, they must now pivot to models where licensed medical professionals hold central roles. While this transition will impose costs and logistical hurdles, the Board has made clear that patient safety and the proper exercise of medical judgment cannot be compromised for the sake of convenience.

Energy Device Classification Table (Technical Breakdown)

One of the most significant contributions of the March 2025 ruling is the introduction of a classification system for energy devices. This table, issued by the Board for Medicine, categorizes devices into four classes (I through IV) based on the depth of tissue affected and the potential risk of injury. While classification systems are common in medical device regulation at the federal level (e.g., FDA classifications), this framework is unique in that it is tailored specifically to the practice-of-medicine question in New York State. It effectively draws a bright line between what constitutes a cosmetic tool and what must be considered a medical instrument.

Class I Devices

Class I devices are described as low-risk, non-invasive instruments that only affect the outermost layer of skin, the stratum corneum. Examples include elastic bandages, handheld LED light devices, and manual scalpels used for superficial exfoliation. Because these devices operate only on the surface and do not carry significant risk of injury when used properly, their use is not classified as the practice of medicine. As a result, non-licensed professionals, such as aestheticians, may lawfully use these devices in spa settings.

Class II Devices

Class II devices involve non-ablative technologies with safety requirements but limited penetration. These include IPL (intense pulsed light) devices and certain non-ablative lasers used specifically for hair removal. Although they act at the level of the epidermis, their safety profiles are considered acceptable for use by non-licensed personnel, provided they are working under the supervision of a physician or nurse practitioner. Importantly, the ruling clarifies that laser hair removal remains excluded from the definition of medical practice-a carveout that has persisted for decades despite ongoing debate.

Class IIIa Devices

Class IIIa devices represent low-level energy systems that have therapeutic applications but are considered to carry minimal risk under normal usage. A prime example is low-level laser therapy (LLLT) for hair regrowth. Because these devices act primarily on the epidermis and their energy output is limited, they do not rise to the level of medical practice. However, the Board emphasized that even these devices should be used under a framework of supervision to ensure patient safety.

Class IIIb Devices

Here the line into medical practice begins. Class IIIb devices are medium-powered systems designed for therapeutic purposes that extend into the upper dermis. Examples include non-ablative skin lasers (such as Thermage) and therapeutic lasers used for pain management. At this level, the risk of complications-burns, pigment changes, scarring-becomes significant enough that the Board determined their use must fall under the practice of medicine. Only licensed physicians, PAs, or NPs may perform these treatments, or delegate them to RNs under appropriate supervision.

Class IV Devices

At the top of the spectrum are Class IV devices: high-powered systems capable of significant subepidermal tissue damage. This includes CO₂ lasers used for resurfacing, deep radiofrequency devices, and laser lipolysis instruments. These devices penetrate into the dermis and subcutaneous tissue, carrying risks of severe burns, scarring, and structural damage. The ruling is unequivocal: Class IV devices may only be used by licensed medical professionals. No delegation to aestheticians or non-licensed personnel is permitted under any circumstances.

Implications of the Classification

This classification table does more than categorize technology-it creates a compliance roadmap for regulators and providers. Medical spas must now audit every device they use, determine its classification under the Board’s framework, and align staffing accordingly. Misclassification or unauthorized use of a Class IIIb or IV device by an unlicensed person could expose operators to charges of unlicensed practice of medicine, civil liability, and professional discipline.

In practice, this means that services once marketed as “routine” or “non-invasive,” such as laser resurfacing or RF-based body contouring, are now unmistakably medical. The classification table strips away marketing language and evaluates devices on the objective criteria of depth and risk-a shift that prioritizes patient safety over commercial convenience.

Impact on Medical Spas

The ripple effects of the March 2025 ruling will be felt most acutely by New York’s rapidly growing medical spa industry. Once seen as a hybrid space straddling the line between beauty and medicine, med spas must now adapt to a regulatory framework that places most of their high-revenue procedures squarely within the definition of medical practice. For owners, operators, and staff, the consequences are wide-ranging and immediate.

Operational Restructuring

Many spas have relied heavily on aestheticians and other non-licensed technicians to perform treatments such as tattoo removal, laser resurfacing, and body contouring. Under the new rules, these services can no longer be offered without direct physician, nurse practitioner, or physician assistant involvement. Businesses must now decide whether to:

• Hire or contract with licensed professionals to perform and supervise procedures.
• Restrict service offerings to Class I and Class II devices, such as facials, LED therapy, and hair removal.
• Reorganize supervision structures, ensuring that registered nurses carry out orders under appropriate medical oversight.

Each option comes with financial and logistical implications. Hiring medical professionals increases payroll costs significantly, while limiting services reduces revenue potential. Either way, med spas must re-engineer their operating models.

Liability Exposure

The ruling also raises the stakes for liability and enforcement. A spa that allows an unlicensed individual to operate a Class IIIb or IV device is now at risk of being charged with aiding and abetting the unlicensed practice of medicine. Owners could face disciplinary action, civil fines, or even criminal charges in egregious cases. In addition, insurance carriers may deny coverage for claims arising from procedures performed by unauthorized personnel. Patients who suffer burns, scarring, or other complications could leverage the ruling to bolster malpractice or consumer fraud lawsuits.

Financial Impact

Compliance carries costs. Hiring physicians or nurse practitioners to supervise treatments may require restructuring compensation models, such as offering medical directors equity stakes or per-procedure fees. For smaller spas, these expenses could be prohibitive, forcing consolidation or closure. At the same time, med spas that adapt successfully may gain a competitive edge by marketing themselves as fully compliant, medically supervised facilities, appealing to patients who prioritize safety.

Staffing Challenges

Aesthetic professionals face their own career crossroads. Many aestheticians built businesses around performing energy-based treatments that now require medical licensure. While they may still provide lower-risk Class I and II services, their scope of practice has narrowed. Some may choose to pursue additional education, such as nursing or physician assistant programs, to remain competitive in the field. Others may align themselves with physician-led spas that can integrate their skills within a compliant framework.

Patient Experience

For patients, the impact will be mixed. On one hand, safety standards will improve, reducing the risk of poorly managed complications. On the other, prices for treatments may rise as spas pass compliance costs on to consumers. Scheduling may also become more complex, as availability will depend on licensed professionals’ oversight rather than technician-driven volume. Patients accustomed to “quick and easy” procedures may find the process more medicalized, with formal consultations, consent forms, and follow-up visits.

Market Consolidation

Finally, the ruling is likely to drive industry consolidation. Smaller spas unable to absorb compliance costs may sell to larger, physician-backed groups that can achieve economies of scale. This could reshape the competitive landscape, concentrating services among fewer but more medically integrated providers.

In short, the Board’s decision is a turning point. For med spas, compliance is no longer optional-it is existential. Those that adapt will survive and potentially thrive; those that fail to align with the new framework face regulatory sanctions, financial losses, and reputational damage.

Enforcement and Risk Management

The March 2025 ruling is not a theoretical exercise. With the New York State Education Department (NYSED) formally adopting the Board’s findings, the regulatory and enforcement machinery is now fully engaged. For medical spas, this means the margin for error has narrowed dramatically. Compliance failures will not simply be business risks-they will be legal liabilities, potentially triggering investigations, penalties, and professional discipline.

Regulatory Enforcement Pathways

Enforcement of the new rules will flow through multiple channels:

• NYSED Office of the Professions: empowered to investigate unlicensed practice of medicine and discipline licensed professionals who delegate improperly or fail to supervise adequately.
• Department of Health (DOH): may pursue investigations into patient harm and systemic violations of patient safety laws.
• Professional Boards: individual licensing boards for physicians, nurses, and physician assistants may take independent disciplinary action against licensees tied to noncompliant spas.
• Attorney General’s Office: has authority to prosecute cases of consumer fraud or unlicensed medical practice, particularly when advertising misleads patients.

The convergence of these authorities means that enforcement will be multi-layered. A single incident-say, a burn caused by an unlicensed aesthetician using a Class IV laser-could trigger parallel investigations from NYSED, the DOH, and the Attorney General’s Office, while also exposing the supervising physician to discipline.

Liability Beyond Regulation

Legal exposure is not limited to regulators. Civil plaintiffs’ attorneys will use the ruling to their advantage. Any complication arising from a non-compliant procedure now carries a ready-made argument: the procedure was unlawful because it was performed by someone not authorized under state law. This opens the door to malpractice suits, consumer fraud claims, and insurance coverage disputes, as insurers may refuse to defend or indemnify practices engaged in unauthorized medical procedures.

Risk Management Strategies

To navigate this environment, med spas must adopt robust risk management systems. Key strategies include:

1. Device Inventory and Classification: catalog every energy-based device in use, assign it to the correct class under the Board’s framework, and restrict access accordingly.
2. Supervision Protocols: establish clear supervisory arrangements. Written agreements with medical directors or supervising physicians should define responsibilities, response times, and delegation limits.
3. Staff Training: ensure that all staff, licensed and unlicensed, understand the new scope of practice rules. Training should cover both technical competencies and regulatory obligations.
4. Documentation Standards: maintain meticulous records of assessments, physician orders, procedure notes, and follow-up care. Documentation not only supports patient safety but also serves as a critical defense in the event of litigation.
5. Consent and Disclosure: revise informed consent processes to reflect the medical nature of procedures, including disclosure of risks, alternatives, and the identity and licensure of the provider.
6. Insurance Coverage Review: work with insurers to confirm coverage for procedures under the new framework. Policies should be updated to account for the classification of treatments as medical practice.

Proactive Compliance vs. Reactive Defense

Perhaps the most important shift is the need for proactive compliance. Historically, many spas operated under a “don’t ask, don’t tell” philosophy, taking comfort in regulatory ambiguity. That ambiguity has vanished. Waiting until an adverse event triggers an investigation is no longer a viable strategy. Instead, med spas must build compliance into their core business models-an investment that, while costly, is far less expensive than defending against enforcement actions and lawsuits.

In sum, the ruling transforms risk management from a background consideration into a central operational priority. Med spas that fail to internalize this shift are likely to face enforcement, liability, and reputational fallout that could threaten their survival.

Legal Perspectives

From a legal standpoint, the ruling represents a significant expansion of what constitutes the “practice of medicine.” Attorneys specializing in healthcare regulation note that this shift is consistent with broader trends in professional licensing. As technologies evolve, the law adapts to encompass procedures that once seemed cosmetic but now carry medical risk. The ruling also strengthens regulators’ hand in enforcement. By classifying procedures as medical, the state can pursue unauthorized providers for unlicensed practice-a charge that carries more weight than consumer protection statutes alone.

Lawyers representing med spas are already preparing for challenges. Some anticipate constitutional or administrative law arguments, such as whether the Board overstepped its authority or failed to provide adequate notice. However, such challenges face an uphill battle given the Education Department’s formal adoption of the ruling and the longstanding principle that states have broad discretion to regulate the practice of medicine.

National Implications

What happens in New York rarely stays in New York. Other states are closely monitoring this ruling, particularly those with booming med spa industries like California, Florida, and Texas. Already, regulators in several jurisdictions are reevaluating their frameworks for energy devices, and New York’s classification system may serve as a model. If similar rulings spread, the industry could see a nationwide standard emerge, transforming what has been a patchwork of inconsistent rules into a more uniform approach.

Patient Advocacy and Public Perception

Finally, patient advocacy groups have largely applauded the decision. From their perspective, the ruling ensures that individuals undergoing powerful energy-based procedures will be evaluated, treated, and followed up by trained medical professionals rather than technicians with limited education. This aligns with a broader societal trend toward transparency in healthcare and accountability for providers. For the public, the message is simple: treatments that look like medicine, feel like medicine, and carry the risks of medicine should be treated as medicine.

Norman Spencer Law Group’s Role

As the dust settles from the March 2025 ruling, one truth has become clear: medical spa owners, practitioners, and investors will need specialized legal guidance to navigate the new regulatory environment. This is where Norman Spencer Law Group has positioned itself at the forefront. With decades of experience in healthcare law, professional licensing defense, and complex litigation, the firm is uniquely equipped to help providers adapt, defend, and thrive in the wake of heightened scrutiny.

Compliance Counseling

The most immediate need for med spas is compliance realignment. Norman Spencer Law Group advises clients on how to restructure operations so that procedures fall within the new framework. This includes:

• Conducting comprehensive audits of devices and classifying them under the Board’s new system.
• Drafting supervision protocols, including medical director agreements that clearly define roles and responsibilities.
• Developing policies and procedures for assessments, documentation, and follow-up care that satisfy regulatory standards.
• Training staff on the scope of practice limitations that now apply to aestheticians, registered nurses, and other personnel.

By helping spas implement these systems proactively, the firm reduces the risk of enforcement actions and positions its clients as industry leaders in compliance.

Litigation and Defense

Inevitably, some providers will face disciplinary actions, investigations, or lawsuits under the new rules. Norman Spencer Law Group’s litigation team is prepared to mount robust defenses, whether the issue is an allegation of unlicensed practice, patient harm, or supervisory failure. The firm’s attorneys have deep experience defending healthcare professionals before the New York State Education Department, professional boards, and civil courts.

A typical case may involve a patient injury following a laser procedure performed by an unlicensed aesthetician. Under the new ruling, regulators will likely pursue both the aesthetician and the supervising physician. The firm’s attorneys know how to navigate these proceedings, mitigating penalties, protecting licenses, and-when possible-challenging the scope of regulatory claims. Their experience allows them to craft tailored strategies, whether through settlement, negotiation, or litigation.

Risk Management for Growth-Oriented Spas

For larger or growth-oriented med spas, Norman Spencer Law Group also provides strategic risk management services. These include advising on:

• Structuring business models that integrate licensed providers effectively.
• Negotiating medical director contracts that balance compliance with financial sustainability.
• Guiding investors and private equity firms seeking to enter or expand in the med spa market while minimizing regulatory exposure.
• Addressing cross-state operations, as other jurisdictions may adopt similar frameworks in the wake of New York’s ruling.

This forward-looking approach ensures that clients do not merely react to the ruling, but position themselves competitively in a consolidating industry.

Thought Leadership and Advocacy

Finally, Norman Spencer Law Group plays an active role in shaping the conversation around med spa regulation. By publishing articles, participating in industry panels, and engaging with policymakers, the firm advocates for balanced approaches that safeguard patients while supporting responsible business models. In this sense, the firm is not only a legal advisor but also a thought leader helping to shape the future of aesthetic medicine.

For med spa operators, the ruling represents both a challenge and an opportunity. With Norman Spencer Law Group’s guidance, compliance can be transformed from a burden into a strategic advantage. In an industry where reputation and trust are paramount, aligning with experienced legal counsel is not optional-it is essential.