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RN Scope of Practice and Prescribed Injectable Aesthetic Agents Interpretive Statement


On January 18, 2018, the ND Board of Nursing (NDBON) approved the following Interpretive Statement to provide clarification of current law and rules pertaining to RN scope of practice and prescribed/injectable aesthetic agents:

A Registered Nurse, with evidence of comprehensive, specialized, and accredited training; Certification; and competencies, may inject FDA approved medical aesthetic/cosmetic agents, as part of a medically prescribed treatment plan, which includes a documented initial assessment/evaluation for each individual client by the prescriber. (NDAC 54-05-02-04; NDAC 54-05-02-05).

A Registered Nurse cannot medically diagnose; determine medical treatment; or prescribe or dispense legend pharmaceuticals (NDCC 43-12.1-02 (5); NDAC 61-04-02-01; Board of Pharmacy Administrative Guidelines for Practitioner dispensing in ND).


  • Over the past 6-8 months, the NDBON received several public concerns/complaints related to RNs scope of practice and injecting prescribed aesthetics agents with minimal or no prescriber/provider involvement.
  • November 2017, the NDBON directed further research, exploration of other state nursing boards positions, and discussion with other ND boards to explore the public safety concern.
  • The ND Tri-Regulator Collaborative (ND Board of Nursing, ND Board of Pharmacy, and ND Board of Medicine) discussed the current laws and rules related to the public safety concern.
  • Dec. 2017, ND TRC minutes excerpt:

Medi-Spas and RNs administering Botox, fillers, etc. NCSBN Aesthetics Document and other states nursing boards position statements reviewed and discussed. ND TRC discussed the ND rules and laws which require the practitioner/prescriber be involved in dispensing legend medications and medical diagnosis/medical treatment. The RN cannot medically diagnose or prescribe. Recommended referring to BOP dispensing statement.” 

  • The Board reviewed positions statements from 16 other state nursing boards.
  • The Board reviewed related information and surveys from the National Council of State Boards of Nursing (NCSBN).


  • According to ND law, rules, and educational training in nursing programs, it is within scope of practice for the RN to inject prescribed medications as part of a medical treatment plan.
  • According to ND law and rules, it is not within the RN scope of practice to prescribe, dispense, medically diagnose, or medically treat.
  • The NDAC 54-05-02-04 declares, “each registered nurse is responsible and accountable to practice according to the standards of practice prescribed by the board and the profession”.  Therefore, the RN or APRN has the ultimate accountability for their practice and must make practice decisions accordingly.

Excerpt November 2017 minutes

Excerpt January 2018 minutes