Do I need a medical director or supervising physician to run a med spa?

In most states, yes. Aesthetic procedures like injectables and lasers are considered the practice of medicine, which typically requires a physician owner, a medical director, or a supervising/delegating physician relationship. The specifics — ownership rules, delegation, chart review, and how often the physician must be involved — vary by state and change through legislation, which is exactly what Med Spa Radar tracks.

What is a good-faith exam requirement for med spas?

A good-faith exam (GFE) is a clinical evaluation required before a patient is treated — for example before Botox or filler — to establish a valid provider-patient relationship and a treatment order. States increasingly regulate who may perform the GFE and whether it can be done over telehealth. New GFE rules are one of the most common scope-of-practice changes we surface.

Can a nurse, NP, or PA inject Botox or filler without a doctor present?

It varies widely by state. Some states grant nurse practitioners broad independent authority; others require a delegating or supervising physician, an established good-faith exam, or physician availability. Because these scope-of-practice rules change through state legislation and licensing-board action, the safe answer is state-specific — and it moves. Med Spa Radar monitors all 50 states and DC for exactly these changes.

Can med spas legally compound or sell semaglutide and tirzepatide?

It depends on two things that change frequently: whether the drug is on the FDA shortage list, and your state’s rules. Under federal law (sections 503A and 503B), a compounder generally may not make a copy of a commercially available drug — being on the FDA shortage list has been the main exception that allowed compounded semaglutide and tirzepatide. When the FDA declared those shortages resolved, the basis for compounded versions narrowed sharply. Med Spa Radar tracks FDA shortage status and state action daily so you know when it changes. This is regulatory monitoring, not legal advice.

Can med spas compound peptides like BPC-157, KPV, or TB-500?

It depends on whether the peptide is on the FDA’s 503A Bulks List — and as of the July 2026 Pharmacy Compounding Advisory Committee (PCAC) meetings, none of the headline peptides are. PCAC recommended further review of BPC-157, KPV, TB-500, and MOTS-c, but a recommendation is not a legal status change: FDA is not bound by it, and actually permitting 503A compounding requires notice-and-comment rulemaking, commonly 8–12 months. So these remain not compoundable under 503A today. FDA has separately scheduled a further PCAC meeting by the end of February 2027 for five more peptides (GHK-Cu, Melanotan II, LL-37, Dihexa, PEG-MGF). We track each substance’s current standing, with its government source and date, on the Med Spa Radar substance tracker. This is regulatory monitoring, not legal advice.

How does a med spa stay compliant with constantly changing regulations?

The practical challenge is awareness: rules change through hundreds of state bills plus FDA and Federal Register activity every session, and a single missed change can put a license or the business at risk. Med Spa Radar monitors all of those sources daily, scores each change for impact, and tells you in plain language what changed and what to do — so compliance starts with knowing first.

Is Med Spa Radar legal or compliance advice?

No. Med Spa Radar is regulatory monitoring, not legal, medical, or compliance advice. We surface relevant changes early and link you to the primary source so you and your counsel can act on them. Always verify against the primary source and consult qualified counsel before making compliance decisions.

How to open a med spa: what the rules actually require

Opening a med spa is governed less by business licensing than by medical law. In most states, injecting a neuromodulator or filler is the practice of medicine, which means four things decide whether — and how — you can open: who may own the business, which physician must supervise it, what exam must happen before a patient is treated, and who is allowed to hold the syringe. Each is set by state law and each changes through legislation and licensing-board action.

Below is what each of those four requires, in the states where we have verified the rules against the primary source. Every statement is linked to the statute, rule, or board document it came from, and dated. This is regulatory monitoring and reference — not legal advice.

What this page covers. 77 rules, each cited to a primary source, across 5 states: Arizona, California, Florida, Indiana, Texas. We monitor all 50 state legislatures daily, but we only publish a rule here once we have verified it against the source document — so this list grows as states are verified, and it never claims a state we have not read. Most recent verification: Jul 26, 2026.

1. Can you own a med spa?

Who is allowed to own the business, and in what corporate form?

Arizona

Ownership & corporate practice of medicine

Unlike strict-CPOM states, Arizona’s Medical Practice Act regulates individual licensees rather than business ownership.

Arizona has no statute prohibiting non-physician ownership of a medical practice; the Medical Practice Act regulates individual licensees, and clinical decision-making must stay with licensees under the standard-of-care rules.
A.R.S. §32-1401 · verified Jul 26, 2026
If a practice organizes as a professional corporation, non-licensed persons may hold up to 49% of the voting shares (unless the licensing authority prescribes a different percentage).
A.R.S. §10-2220(A)(4) · verified Jul 26, 2026

California

Ownership & corporate practice of medicine

California strongly bars the corporate practice of medicine. This is the opposite of a permissive-ownership state.

Corporations and other artificial legal entities have no professional rights, privileges, or powers — laypersons and lay entities may not own any part of a medical practice or control clinical decisions.
Cal. Bus. & Prof. Code §2400 · verified Jul 26, 2026
The compliant structure is a professional medical corporation under the Moscone-Knox Act: a majority of shares must be held by California-licensed physicians, only enumerated licensed health professionals may hold shares (up to 49% in aggregate), and no lay person may hold any stock.
Cal. Corp. Code §13401.5(a) · verified Jul 26, 2026

all 4 California rules on this →

Florida

Ownership & corporate practice of medicine

Florida has no strict corporate-practice-of-medicine ban. Non-physician ownership is instead gated by the Health Care Clinic Act.

Unlike some states, Florida does not broadly prohibit non-physician ownership of a medical practice or med spa; ownership is governed by the Health Care Clinic Act rather than a corporate-practice-of-medicine prohibition.
Fla. Stat. §400.990 · verified Jul 26, 2026
An entity that provides health-care services and bills for reimbursement is a “clinic” that must be licensed by AHCA to operate — each location licensed separately — unless it qualifies for an exemption.
Fla. Stat. §400.991(1)(a) · verified Jul 26, 2026

all 4 Florida rules on this →

Indiana

Ownership & corporate practice of medicine

Indiana is comparatively permissive and does not impose a strict corporate-practice-of-medicine ban.

An employment or other contractual relationship between an entity and a licensed physician is not the unlawful practice of medicine, as long as the entity does not direct or control the physician’s independent medical acts, decisions, or judgment. So a non-physician-owned entity may employ physicians without controlling their clinical judgment.
Ind. Code §25-22.5-1-2(c) · verified Jul 26, 2026

Texas

Ownership & corporate practice of medicine

Texas follows the corporate-practice-of-medicine doctrine, derived from the Medical Practice Act’s licensure requirement rather than a single titled statute.

A person may not practice medicine in Texas unless licensed by the Board. As a result, a general business corporation or an unlicensed individual cannot practice medicine or employ physicians in a way that controls their medical judgment.
Tex. Occ. Code §155.001 · verified Jul 26, 2026
One recognized structure is a Board-certified nonprofit health organization (a “5.01(a)” corporation) that is organized solely by Board-licensed physicians.
Tex. Occ. Code §162.001 · verified Jul 26, 2026

all 3 Texas rules on this →