Alert: Medical Board of California Issues Warning on Hair Restoration Technicians

Michael S. Byrd | 9.10.19

The Medical Board of California (MBC) warns physicians against using unlicensed persons for hair transplant procedures in the summer issue of their newsletter.  The issue is available here with the article appearing on page 12.  It states that the MBC has become aware of many physicians or clinics that are employing trained but unlicensed persons, referred to as medical assistants (MAs), to perform or assist with hair transplant procedures.  The article gives the example of MAs creating holes or slits in the patient’s scalp using a needle, scalpel, or deceive as being prohibited.  While they do not explicitly state so, their warning would apply equally to harvesting follicles as it would to preparing the follicle implantation sites.


In California MAs have a very limited scope of tasks they are permitted to perform.  They are permitted to perform only “basic administrative, clerical, and technical supportive services” with several procedures specifically authorized in 16 CCR § 1366.  With the exception of puncturing skin or vein, for purposes of drawing blood their other authorized tasks are non-invasive and include things like trimming nails and ear lavage. Likewise the MBC has stated that MAs may not inject fillers nor may they fire lasers.  The article warns that physicians who violate this restriction are aiding the unlicensed practice of medicine, which can carry penalties of fines or imprisonment. If you are employing MAs in your practice, you will want to carefully review what tasks you are assigning to them and ensure that the delegations are legally permitted. If you have any questions or would like to know more about the warning, please schedule a consult at


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