Licensing planning guide

New Mexico med spa
licensing guide.

Medical assistants have a limited cosmetic delegation pathway.

Prepared by Prospyr · Sources checked September 15, 2026

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What to know in New Mexico

Start with these state-specific findings, then use the checklist below to review the rest of your practice. The linked authorities explain the conditions and exceptions behind each point.

01

Aesthetics licensure does not authorize medical procedures

The Board uses alteration of living tissue to distinguish medical procedures from superficial services. An esthetician performing an authorized delegated medical task acts under the medical-assistant framework, not an expanded esthetics license.

Source: New Mexico Medical Board: Medical Spa Practice, revised March 2024
02

Medical-assistant delegation excludes incisive and ablative work

The guidance limits medical assistants to qualifying non-incisive, non-ablative procedures with training, protocols and supervision. It specifically explains that this does not authorize injection into living tissue. PA and nursing pathways must be reviewed separately.

Source: New Mexico Medical Board: Medical Spa Practice, revised March 2024

Your next steps

  1. Match each task to NMAC 16.10.13 and the performer’s role before designing the staffing schedule.
  2. Document training, protocols and the supervising clinician’s required presence or availability for the applicable pathway.

Questions to resolve before opening

  • Is the task non-incisive and non-ablative under the applicable medical-assistant rule?
  • Does a PA-led or nursing-led arrangement use a different lawful supervision pathway?

Bring your actual ownership chart, service menu, devices and staff credentials to the relevant board or healthcare counsel. The same answer may not apply to a different procedure or business model.

A practical licensing checklist

These planning steps complement the New Mexico highlights. They are a workflow for investigation, not a claim that every listed permit applies to every practice.

01

Ownership & clinical control

Identify the owners of the clinical entity, who employs clinicians, who controls medical decisions and how management fees are paid. Ask healthcare counsel to confirm the entity and any professional-ownership or fee-splitting limits before signing agreements.

02

People & procedures

List the person who evaluates, prescribes, performs and supervises each treatment. Verify the actual professional license, restrictions, procedure training and required agreements. A course certificate alone does not establish a legal scope of practice.

03

Premises, devices & products

Check clinic or establishment licensing, local zoning and occupancy, device registration, drug purchasing and storage, and any laboratory or body-art services. Adding a procedure or location can change the applicable requirements.

04

Patient care & opening file

Document consent, assessment, treatment orders, emergency escalation, infection prevention and record access. Assign an owner to every unresolved question and keep the authority supporting the final decision.

Official sources & scope

A source-based planning guide for practice owners, not legal advice or a license approval. The state highlights cover the issues identified below; the workbook helps you resolve additional ownership, scope and facility questions with the relevant boards and qualified counsel. Requirements depend on your services, staff and business structure.

No attorney review is claimed. Report an update.

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