The word "medical" does a lot of quiet work on a storefront. It suggests a physician somewhere in the building, a chart with your name on it, someone qualified to notice if something goes wrong. Sometimes all of that is true. Sometimes the word is doing the work by itself.
This is an awkward subject for us to write about, so let us be plain about our own position up front: we offer aesthetic treatments, so we are not neutral. Plenty of med spas in Texas are run carefully by people who take the rules seriously, and the label on the door tells you very little either way. What actually varies from one place to the next is who is responsible for you, and that is worth understanding before you book anything, including with us.
So here is what Texas actually requires, taken from the state's own documents rather than from anybody's marketing.
In Texas, these are medical procedures
The clearest way to see this is the Texas Department of Licensing and Regulation's own guide for consumers, which sorts med spa services by which agency regulates them. TDLR handles cosmetology, massage therapy, and laser hair removal. It says directly that it does not have jurisdiction over everything offered at a med spa.
Look at where the individual services land in that chart and the line becomes obvious. Facials, waxing, tweezing, eyelash extensions: TDLR, under a cosmetology or esthetician license. Botox: Texas Medical Board. Microneedling with platelet-rich plasma: Texas Medical Board. IV hydration: Texas Medical Board. CoolSculpting: Texas Medical Board. Dermaplaning with a medical scalpel: Texas Medical Board, while dermaplaning with an ordinary razor stays with TDLR.
That is not a technicality about paperwork. It is the state saying that a category of things sold in the same building as a facial are the practice of medicine, and are therefore subject to a physician's responsibility rather than a cosmetology license.
What an esthetician's license does not cover
Estheticians are skilled professionals doing real work, and this is not a knock on the license. It is about where the license stops, which TDLR spells out in unusually direct language.
An esthetician, cosmetologist, or barber license does not authorize the holder to use hypodermic needles to inject botulinum toxin or other substances, even for cosmetic purposes. It does not authorize the use of lasers for hair removal, skin resurfacing, or teeth whitening. And TDLR is explicit that the facials within that scope "do NOT include injectables, fillers and other types of medical-type procedures that require the use of needles."
Two of the finer lines are worth knowing because they come up constantly. Superficial or light chemical peels that work on dead cells in the epidermis are within an esthetician's scope. Medium and deep peels penetrate the dermis, the living tissue, and are medical procedures regulated by the Medical Board. Microdermabrasion follows the same logic: fine when it removes dead cells from the surface, a medical procedure once the device reaches the dermis.
TDLR adds a point that cuts the other way too, and it is a good sign the agency is drawing lines rather than picking sides: a physician cannot delegate cosmetology or barbering procedures. Doctors may delegate medical acts only. The boundary runs in both directions.
One more line from that guide is worth quoting because it is the whole principle in a sentence. Anyone offering services at a med spa must have the appropriate license and training for what they are providing, "or be under the delegation of a licensed physician, when providing medical treatments."
Why the state has been tightening this
Texas did not arrive at this out of nowhere.
In 2025 the legislature passed House Bill 3749, which regulates elective intravenous therapy. It was signed in June 2025 and took effect on September 1, 2025. Under it, a physician may delegate the administration of IV therapy to a physician assistant, an advanced practice registered nurse, or a registered nurse, each acting under adequate physician supervision.
The official analysis of that bill is blunt about why it existed. A patient died after receiving IV therapy at a med spa in Wortham, Texas in July 2023. The same analysis cites a CDC investigation of presumptive HIV transmission among former clients of a spa in New Mexico that had offered platelet-rich plasma microneedling, the treatment sometimes marketed as a vampire facial, with cases diagnosed between 2018 and 2023. The CDC described it as the first investigation to associate HIV transmission with cosmetic injection services of this kind.
The analysis also reports that dermatologic surgeons told the legislature that between 61 and 100 percent of the complications they were seeing in their own practices traced back to medical spas. Read that carefully, because it is easy to overstate: it describes the share of complications arriving in those particular doctors' offices, not a rate of harm across all med spa visits. It is still a striking thing for a group of physicians to tell a legislature.
None of that means an IV drip or a microneedling session is inherently dangerous. It means these are medical procedures with medical risks, and the state has concluded that they need someone medically accountable attached to them.
Oversight is not a signature on a wall
Here is where the practical difference lives, and it is not really about statutes.
A physician's name can appear on a document without that physician ever seeing you, knowing what was recommended to you, or being reachable when something looks wrong three days later. The rules contemplate real involvement: proper training before a procedure is performed or delegated, appropriate delegation with someone qualified available if there is an adverse outcome, and someone who can actually respond. The gap between meeting that on paper and meaning it is where patients get hurt.
Meaningful oversight looks fairly ordinary from the outside. Someone qualified examines you before anything is decided, rather than after you have chosen from a menu. The person treating you is working from a plan a physician actually made for your face. If a complication starts, there is a specific physician who knows your history and will pick up the phone. And someone in the building is willing to tell you no.
That last one is the tell. A practice that will decline to treat you is a practice with judgment in the loop.
The questions Texas itself suggests you ask
The nice thing about the TDLR guide is that it does not leave consumers to guess. It lists the questions to ask when deciding whether to go to a med spa, and they are these three:
- Who owns and operates the med spa?
- Who will administer the treatment, and what credentials does that person have?
- Is a licensed medical practitioner on site in case there are complications?
We would add two more. Who specifically do I call if something goes wrong at nine o'clock at night, and will that person have my chart? And who examined me before this was recommended?
Any practice worth your money will answer all five without getting defensive. The answers matter more than the décor, and considerably more than the word on the sign.
What this means for you, here in Lubbock
Picture someone in Lubbock who has been offered a package deal on injectables at a place she found through an ad. The price is good. The before-and-after photos look fine. She has no idea who the physician of record is, whether anyone will examine her first, or who she would call on a Saturday if her lip swelled in a way that did not seem normal.
She does not need to become an expert in Texas administrative law. She needs to ask five questions and pay attention to how they are answered. If the reply is vague about who the physician is, or defensive about why she is asking, that is the answer.
For our part, we would rather you ask us those questions than assume. Aesthetic treatments here sit inside a physician's practice, alongside concierge primary care and the rest of your skin health, which is simply how we think regenerative aesthetics ought to work. It is also why we are comfortable telling people that a treatment is not right for them.
Ask us anything on this list
If you are weighing an aesthetic treatment anywhere in Lubbock, including here, you are welcome to bring these questions to us and get straight answers, with no expectation that you book anything. Dr. Sima Shahbandar is happy to explain what oversight actually looks like in this practice and what she would and would not recommend for you.
Reach us through our contact page or call (806) 778-4395.
Sources
- Which agency regulates which med spa service, the limits of an esthetician, cosmetologist, or barber license including the prohibition on using hypodermic needles to inject botulinum toxin, the superficial versus medium and deep peel distinction, the microdermabrasion line at the dermis, the rule that a physician cannot delegate cosmetology procedures, and the three questions to ask before booking: Texas Department of Licensing and Regulation, "Medspas at a Glance"
- The passage and effective date of the elective intravenous therapy law, signed 20 June 2025 and effective 1 September 2025: Texas Legislature Online, HB 3749, 89th Legislature
- The background to that law, including the July 2023 death after IV therapy at a med spa in Wortham, the CDC investigation in New Mexico, the reports from dermatologic surgeons about complications, and who may administer IV therapy under physician supervision: Texas Legislature Online, HB 3749 bill analysis
- The CDC investigation of presumptive HIV transmission among former clients of a spa offering platelet-rich plasma microneedling, New Mexico, 2018 to 2023: Investigation of Presumptive HIV Transmission Associated with Receipt of Platelet-Rich Plasma Microneedling Facials at a Spa Among Former Spa Clients, Morbidity and Mortality Weekly Report, 2024
- The Texas Medical Board's rules on delegation and on nonsurgical medical cosmetic procedures, which the board reorganized in 2025: Texas Medical Board, laws and board rules
This article is for general educational purposes and is not medical advice, diagnosis, or treatment, and it does not create a physician-patient relationship. It is also not legal advice, and it is not a description of any particular business other than our own. Regulations change, so confirm current requirements with the relevant Texas agency. Individual results vary, and no outcome is guaranteed. Treatment decisions should be made with a qualified physician who knows your full medical history. Omri Med is a private-pay concierge practice; membership is limited and does not replace health insurance.