Hair restoration surgery is the practice of medicine in California and may only be performed by properly trained, licensed physicians and surgeons or licensed allied health care providers authorized to perform such procedures within their scope of practice.
Companies may be marketing surgical devices to physicians indicating that hair restoration surgery is a delegatable procedure, causing confusion about who may use such devices in California.
Physicians may not delegate hair restoration surgery to medical assistants, who are unlicensed individuals with a very limited scope of practice pursuant to Business and Professions Code sections 2069 and 2070 and Title 16 of the California Code of Regulations section 1366. Medical assistants may not perform invasive procedures such as creating holes or slits in a patient’s scalp with a needle, scalpel, or other device.
For more information about the role of medical assistants, please see Is Your Medical Assistant Practicing Beyond His or Her Scope of Training?
No unlicensed person may perform these procedures in California, including those using titles such as hair restoration technician, surgical technician, hair restoration assistant, or any other title. California’s Business and Professions Code section 2052 prohibits the practice of medicine by unlicensed individuals, as well as aiding and abetting the unlicensed practice of medicine. Violation can result in a fine of up to $10,000, imprisonment, or imprisonment in county jail for up to a year or both the fine and either imprisonment.
Medical Board of California News – Summer 2019