AGO 2025-03_10.22.25

AARON D. FORD Attorney General CRAIG A. NEWBY First Assistant Attorney General CHRISTINE JONES BRADY Second Assistant Attorney General STATE OF NEVADA OFFICE OF THE ATTORNEY GENERAL 100 North Carson Street Carson City, Nevada 89701 TERESA BENITEZ- THOMPSON Chief of Staff LESLIE NINO PIRO General Counsel HEIDI PARRY STERN Solicitor General October 22, 2025 OPINION NO. 2025-03 ANATOMY; BOARDS AND COMMISSIONS; CHIROPRACTIC; HEALTH; HOMEOPATHIC MEDICINE; LICENSES; MASSAGE THERAPY, BOARD OF; NAPRAPATHY; PHYSICAL THERAPY: Stretching services offered by individuals not licensed as massage therapists may fall within the definition of “massage therapy” under NRS 640C.060 and “structural integration” under NRS 640C.085 if they involve manual application to the muscular structure and soft tissues, or are intended to improve the functional relationship of the parts of the human body to each other within the influences of gravity. Such services require a massage therapy license under Nevada law. Elisabeth Barnard Executive Director Nevada State Board of Massage Therapy 1755 E. Plumb Lane Suite 252 Reno, Nevada 89502 Dear Director Barnard, Pursuant to NRS 228.150, you have requested an opinion from this office as to whether businesses offering “stretching” or “assisted stretching” (collec- tively, “stretching services”) to clients in a studio environment—by employees who are not otherwise licensed as massage therapists but who touch clients as they are engaging in the stretching by applying an external force to help elon- gate and stretch a client’s muscles as the client engages in the stretch—require a massage license. This letter addresses that question. 1 Elisabeth Barnard, Executive Director Page 2 October 20, 2025 ## QUESTION Whether engaging in “stretching services” with clients in a studio environment—by unlicensed employees who touch clients as they are engaging in the stretching by applying an external force to help elongate and stretch a client’s muscles as the client engages in the stretch—fits within the definition of “massage therapy” in NRS 640C.060 or “structural integration” in NRS 640C.085, therefore requiring a massage license. ## SHORT ANSWER It depends upon the specific circumstances. In Nevada, stretching services offered by individuals who are not licensed as massage therapists may fall within the definition of “massage therapy” under NRS 640C.060 and “structural integration” under NRS 640C.085, depending on how the services are provided. ## ANALYSIS ### I. Massage Therapy in NRS 640C.060 NRS 640C.060 defines “massage therapy” as: “The application of a system of pressure to the muscular structure and soft tissues of the human body for therapeutic purpose . . . .” This includes, but is not limited to, techniques such as effleurage, petrissage, tapotement, compression, vibration, friction, and movements applied manually, with or without superficial heat, cold, water, or lubricants, for the purposes of maintaining good health and establishing and maintaining good physical condition. NRS 640C.060(1)(a)-(g). Stretching, when performed manually and applied to the muscular structure and soft tissues, can be considered a form of “movement applied manually” as described in the statute. NRS 640C.(1)(g). Therefore, if an individual provides assisted stretching services that involve manual application to the muscles and soft tissues, these services may be classified as “massage therapy” under Nevada law. NRS 640C.060(2)(b). ### II. Structural Integration in NRS 640C.085 NRS 640C.085 defines “structural integration” as: “The application of a system of manual therapy, movement education and embodiment education 2 Elisabeth Barnard, Executive Director Page 3 October 20, 2025 that is intended to improve the functional relationship of the parts of the human body to each other within the influences of gravity.” The statute specifically excludes practices such as physical therapy, chiropractic and naprapathy from this definition. NRS 640C.085(2)(a)-(c). Stretching, when performed manually and applied to the muscular structure and soft tissues, can be considered a form of manual therapy. If the stretching services are intended to improve the “functional relationship of the parts of the human body to each other within the influences of gravity,” they may be classified as “structural integration” under Nevada law. ### III. Stretching Without Application of Pressure to Muscles or Soft Tissue If stretching services are offered outside the context of massage therapy, *i.e.* in a fitness or wellness setting without the application of pressure to the muscular structure and soft tissues, then a massage therapy license is not necessary. For instance, some establishments offering assisted stretching services provided by individuals who are not licensed massage therapists offer guided stretching sessions without application of pressure to the muscular structure and soft tissues. This type of service would not fall within the definition of “massage therapy” or “structural integration.” ### IV. Other Legal Considerations The legislative history of both AB 250 in 2005, and AB 179 in 2017, reveals that the Legislature’s primary focus in enacting the statutes was enforcement against prostitution and sex trafficking problems. The Legislature also made several changes to the statutes governing the Massage Board itself, including definitions (with no mention of stretching). Some other states have addressed this issue by specifically listing “stretching” as a massage technique. Ohio (Ohio Administrative Code 4731-1-05) and Indiana (Indiana Code 25-21.8-1-4). This approach seems to indicate that, at least in some circumstances, “stretching” can be considered a form of “massage therapy”. ### CONCLUSION As discussed above, stretching services offered by individuals not licensed as massage therapists may fall within the definition of “massage therapy” under NRS 640C.060 and “structural integration” under NRS 3 Elisabeth Barnard, Executive Director Page 4 October 20, 2025 640C.085 if they involve manual application to the muscular structure and soft tissues, or are intended to improve the functional relationship of the parts of the human body to each other within the influences of gravity. Such services require a massage therapy license under Nevada law. NRS 640C.060(1)(g) and NRS 640C.085(1). Stretching services provided by individuals who are not licensed massage therapists, however, that involve guided stretching sessions without application of pressure to the muscular structure and soft tissues would not fall within the definition of “massage therapy” or “structural integration”. These services are not subject to Nevada’s massage therapy licensing requirement. AARON D. FORD Attorney General By: HENNA RASUL Senior Deputy Attorney General 4