This petition is in OPPOSITION to HB340 in its entirety. This proposal requests regulation of medical aesthetic practices (MedSpas) by the Board of Cosmetology in addition to the medical practitioners licensing board.  

As a licensed medical provider experienced in the practice of Medical Aesthetics, we believe these medical practices should not be regulated by the Board of Cosmetology for the following reasons:

• Medical practice is far beyond what cosmetology (a non-medical field) has the authority to regulate.  

• Medical aesthetics practices are already regulated by the practicing providers board (medical, nursing, dental boards) which are all significantly more qualified to provide patient safety and provider scope regulation than the Board of Cosmetology.

• Though medical aesthetic practice are focused on patient beautification, they employ FDA approved and prescription modalities including topical applications, injectable neurotoxins, injectable fillers, and energy devices such as lasers to treat patients which require medical decision making ability which is not taught to a cosmetologist during their formal education.
 
• Many Medical Aesthetic practices have estheticians on staff (licensed by the board of cosmetology) but many modalities the estheticians use for treatment are unable to be ordered/stocked/used outside the supervision of a licensed prescribing provider deeming it inappropriate for the cosmetology licensed individual to operate on their license alone in the medical setting.

While we believe there needs to be careful consideration given to the governance of medical aesthetic practices (MedSpas) as they continue to become more popular, placing it in the hands of the Board of Cosmetology is misdirected.  There is a state non-profit that was established in 2021 called the Kentucky Association of Medical Aesthetic Providers (KAMAP) for this purpose and they are working to act as a liaison between the Nursing, Medical, Dental and Cosmetology boards to establish best safety practices for patients and clinics.  

KAMAP and many others would be pleased to help in anyway with this matter or to be available for consultation services as we understand this may be a topic that may be unfamiliar to most.  We believe together we can find common ground on existent patient safety standards and outcomes without additional regulation.