VCAT confirms cosmetic nurse meets nurse practitioner standard: what Tzimas v NMBA means for advanced practice
On 4 February 2026, the Victorian Civil and Administrative Tribunal (VCAT) handed down an important decision in Tzimas v Nursing and Midwifery Board of Australia VCAT 60, overturning the Board’s refusal to endorse a cosmetic nurse as a nurse practitioner. The ruling will be of particular interest to nurses working in non‑surgical cosmetic practice, nurse practitioner candidates, and clinic owners navigating the Health Practitioner Regulation National Law (Victoria).
Background- a cosmetic nurse’s path to endorsement
Ms Nektaria (Nicky) Tzimas is a registered nurse who has worked in non‑surgical cosmetic procedures since 2008 and completed a Master of Nursing Practice (Nurse Practitioner) at Deakin University between 2016 and 2020. She owns and works clinically in cosmetic clinics and runs the CPD Institute of Australia, a training business for cosmetic injectors.
In 2021 she applied to the Nursing and Midwifery Board of Australia (NMBA) for endorsement as a nurse practitioner under s 95 of the National Law. Although one branch of the Board initially approved her application, that decision was revoked, and the Victorian Board ultimately refused endorsement on the basis that she had not shown 5,000 hours of “advanced nursing practice” within the previous six years and had not met the nurse practitioner standards for practice.
The legal test for nurse practitioner endorsement
Under the Registration Standard, Endorsement as a Nurse Practitioner, a nurse must demonstrate four key things to be endorsed:
Current general registration with no relevant conditions or undertakings.
The equivalent of three years’ full‑time experience (5,000 hours) at the advanced nursing practice level in the last six years.
Successful completion of an NMBA‑approved program of study leading to nurse practitioner endorsement.
Compliance with the NMBA Nurse Practitioner Standards for Practice, including advanced assessment, diagnosis, prescribing and clinical leadership.
“Advanced nursing practice” is defined as a higher level of capability in knowledge, clinical reasoning, judgement, skills and behaviours, incorporating leadership, education and research, and accountability for people with complex healthcare needs. The definition expressly recognises that advanced practice can occur in a generalist or specialist context.
The Board’s stance and why VCAT disagreed
The Board relied heavily on its 2022 position statement “Nurses and cosmetic medical procedures”, which says nurses working solely in cosmetic medical procedures are “unlikely” to meet the nurse practitioner endorsement standard, and that cosmetic injecting is “not working at the advanced practice level”. It argued that Ms Tzimas’ work was too narrow, too focused on cosmetic procedures, and lacked sufficient management of complex health conditions to qualify as advanced practice for 5,000 hours.
VCAT accepted that the Board can issue guidance, but held that the position statement cannot override the Registration Standard approved under the National Law. The Tribunal found that saying cosmetic practice “is not” advanced practice is an inflexible policy that conflicts with the legislation, which expressly allows advanced practice within specialist contexts. In other words, cosmetic practice can amount to advanced nursing practice if, in the particular case, the nurse truly meets the advanced capability and complexity requirements.
Evidence that cosmetic practice can be advanced nursing practice
To decide whether Ms Tzimas met the advanced practice standard, VCAT examined detailed evidence, including:
Case studies of patients with complex presentations, autoimmune disease, polymyalgia, suspected vascular occlusion, delayed inflammatory nodules, abscesses, severe allergic reactions and body dysmorphic symptoms.
Evidence that she identified psychological risks, refused inappropriate cosmetic treatment, coordinated referrals to GPs, specialists and psychologists, and followed patients through complications.
Clinical supervision assessments from her supervising doctors (including Dr Rob Weiss) rating her as practising independently at nurse practitioner level.
Expert evidence from radiologist and cosmetic practitioner Dr Chau Nguyen, who described Ms Tzimas as managing patients like a medical registrar by taking histories, forming differentials, ordering imaging, interpreting results and formulating management plans in collaboration with her.
Her development and use of tools such as the CANSAT psychological screening tool, and her leadership and education roles through the CPD Institute.
The Board’s expert, nurse practitioner Ms Leanne Boase, argued that the case studies did not prove consistent advanced practice and emphasised that cosmetic practice was too narrow and insufficiently generalist. However, she had never observed Ms Tzimas in clinical practice, had no specific experience in cosmetic medicine, and assessed only a subset of the material. VCAT therefore gave greater weight to the clinicians who had directly supervised and worked with Ms Tzimas over many years.
5,000 hours of advanced practice
One of the most practically important aspects of the decision is how VCAT interpreted the 5,000‑hour requirement. The Tribunal accepted that:
The Registration Standard does not require every single clinical minute to be at advanced level.
In reality, routine and advanced tasks are “seamlessly integrated” within episodes of care; even nurse practitioners do some basic tasks as part of advanced practice.
What matters is whether, in the overall period, the nurse is practising at an advanced level across their clinical work, not that every discrete task is advanced.
VCAT accepted evidence that Ms Tzimas worked clinically 35–42 hours per week across her cosmetic clinics, with back‑to‑back patient appointments demonstrating substantial direct clinical care over multiple years. It rejected the suggestion that most of this time was business or administrative work, noting that she had staff to manage operations and that her training hours were separately accounted for.
Even taking into account a previous finding of unsatisfactory professional performance in 2020 and a mentoring condition, the Tribunal held that this did not disqualify those hours from counting towards advanced practice. It viewed the mentoring and further education as part of the expected development “continuum” for nurse practitioner candidates.
Meeting the Nurse Practitioner Standards for Practice
VCAT found that Ms Tzimas’ evidence and the corroborating expert material showed compliance with the NMBA Nurse Practitioner Standards for Practice, including:
Advanced health assessment, including complex histories, comorbidities and psychological factors.
Formulation of differential diagnoses and recognition of urgent or rare complications (for example, vascular occlusion, abscesses, severe allergic reactions).
Use and interpretation of investigations such as ultrasound, and appropriate referral to plastic surgeons, ENT specialists, rheumatologists and psychologists.
Safe prescribing and management planning via collaboration with prescribing doctors, pending her own endorsement.
Clinical leadership in designing protocols, educating other clinicians, and contributing to research and publications in cosmetic medicine safety.
The Tribunal also emphasised her “thought leadership” in developing structured tools and protocols for psychological screening and complication management, and in sharing these through her training organisation.
The outcome- endorsement granted
Ultimately, VCAT held that Ms Tzimas:
Had completed at least 5,000 hours of clinical practice at an advanced nursing practice level in the six years prior to her application.
Complied with the Nurse Practitioner Standards for Practice.
Met all four elements of the Registration Standard for endorsement as a nurse practitioner.
Exercising its powers on review, the Tribunal set aside the Board’s 13 July 2022 refusal and substituted a decision that she be endorsed as a nurse practitioner under s 95 of the National Law. It considered and rejected imposing conditions on her endorsement, noting both parties had run the case on a “yes or no” basis and that it lacked submissions on suitable conditions.
Why this decision matters for cosmetic nurses
This ruling has wider implications for advanced practice nurses in Australia, especially those in specialist fields such as cosmetic medicine, aesthetics and other niche clinical areas:
It confirms that specialist non‑surgical cosmetic practice is not automatically excluded from counting as advanced nursing practice.
It clarifies that the 5,000‑hour requirement is about overall advanced‑level practice, not every minute of clinical time.
It highlights the importance of detailed case studies, robust supervision evidence and clear documentation of leadership, education and research in supporting an endorsement application.
It signals that policy statements cannot narrow the scope of advanced practice beyond what the Registration Standard and the National Law allow.
For cosmetic nurses aiming for nurse practitioner endorsement, Tzimas v NMBA underscores the value of building strong clinical collaborations, documenting complex case management, and integrating education and research into everyday clinical work to demonstrate genuine advanced practice.
