New Changes to Supervision and Delegation of Laser Hair Removal Services and Potential Implications for LBMD Use in Ohio

A new Ohio law, House Bill 377 (HB 377), that makes significant changes to the delegation and supervision requirements applicable to light-based medical devices (LBMDs) used for hair removal takes effect on Wednesday, August 26, 2026. Currently, Ohio Revised Code § 4731.33 governs the use and delegation of light-based medical devices for hair removal, while the State Medical Board’s rules address the use of light-based medical devices for both hair removal and other medical purposes.

While HB 377 makes substantial revisions to the statutory requirements governing the use of light-based medical devices in Ohio, many of the changes streamline and clarify pre-existing legal requirements. For example, under the current law, a physician may delegate laser hair removal to a physician assistant, a nurse, or an individual who has met certain cosmetic therapy educational course requirements. Under HB 377, the third category of permissible delegate is now defined as a “laser hair removal professional,” but the educational and supervision requirements applicable to those individuals largely remain unchanged. Additionally, the new law defines “nurse” to include registered nurses (RN) or licensed practical nurses (LPN), affirming that both RNs and LPNs are nursing professionals who may perform these services under appropriate supervision.

Of the more significant changes, HB 377 also amends the following:

• Narrows the statutory definition of “light-based medical device.”
  Under the new law, a light-based medical device is a device that emits electromagnetic radiation at wavelengths from 180 nm through 1,064 nm. Previously, the statutory definition included devices emitting electromagnetic radiation through 1,000,000 nm.
• Changes off-site physician supervision requirements.
  Consistent with the existing law, a physician is generally required to provide on-site supervision during the performance of laser hair removal services by nurses or laser hair removal professionals unless the applicable professional satisfies additional education and training requirements. HB 377 now treats nurses and laser hair removal professionals differently for purposes of qualifying for off-site supervision, establishing different training and supervisory standards for each professional category. Notably, the requirements applicable to nurses permit reduced physician involvement once the nurse satisfies the specified training requirements.
• Expands the limit to the number of certain individuals a physician may supervise.
  A physician may now supervise no more than five professionals performing laser hair removal services at one time. This expands the limit from two professionals under the previous law.
• Expressly authorizes advanced practice registered nurses (APRNs) and physician assistants (PAs) to delegate and supervise certain laser hair removal services.
  A common point of confusion under the prior law was whether APRNs and PAs had independent authority to delegate and supervise laser hair removal services performed by nurses or qualifying cosmetic therapists. HB 377 creates new Ohio Revised Code § 4731.331, which expressly permits an APRN or PA to delegate and supervise the application of an LBMD for hair removal by a nurse or laser hair removal professional, subject to the same applicable conditions and requirements governing physician delegation and supervision. An APRN’s authority is also subject to the terms of the APRN’s standard care arrangement, while a PA must satisfy the applicable statutory requirements governing the PA’s supervisory relationship.

HB 377 applies specifically to LBMDs used for hair removal. The State Medical Board’s existing regulations, however, extend beyond hair removal and address the use and delegation of LBMDs for additional medical purposes. To date, the Board has proposed to change the definition of light-based medical device under its regulations to be consistent with HB 377 but has not implemented further changes as a reaction to HB 377.

Nevertheless, HB 377 may provide insight into the direction of future regulation of light-based medical devices in Ohio. In particular, the law’s distinction between on-site and off-site supervision, its establishment of specific training requirements for lower-level professionals performing laser hair removal, and its express recognition of APRN and PA delegation authority may signal a broader effort to clarify and update the supervision structure applicable to LBMDs in general. As the Board considers whether and how to amend its existing rules, medical-aesthetic practices should pay close attention to whether similar changes are extended to other, non-hair removal uses of light-based medical devices.

Should you have questions regarding how these changes may directly impact your business, please reach out directly to Craig Haran, Bradley Reed, Elena Barone, or another member of the Frantz Ward Health Care Practice Group for further information.