Question 1

Does a med spa in Alabama need a medical director?

Accepted Answer

ALABAMA HAS A CHAPTER FOR THIS AND IT TIERS THE DELEGATE. 540-X-11 governs lasers and light/energy-based devices — any energy source, chemical or modality affecting living tissue below the stratum corneum, for surgical, therapeutic OR COSMETIC purposes — and says outright that using them is the practice of medicine. A physician may delegate only NON-ABLATIVE treatments, only through written protocols, and only to a properly trained LEVEL 1 OR LEVEL 2 DELEGATE — and Alabama counts the training in hours: THIRTY for a physician, FORTY for a delegate, before either may use a device. The written protocol is a physician’s order kept ON SITE and producible to the Board on request. The delegating physician must formulate or approve the protocol, review and authorize it at least ANNUALLY, and provide on-site or locally remote supervision. (Ala. Admin. Code r. 540-X-11-.06(1) (Initial training requirements for physicians and delegates); verified 2026-09-04) This is regulatory monitoring, not legal advice.

Question 2

Does a med spa in Alaska need a medical director?

Accepted Answer

Alaska’s Medical Board sets the delegation standard in regulation, and it is unusually specific about the paperwork. Under 12 AAC 40.920 a physician, podiatrist, osteopath or physician assistant may delegate a routine medical duty only if it is within the delegator’s own scope, a licensee has assessed the patient, the patient’s condition is STABLE AND PREDICTABLE, the delegate’s training is DOCUMENTED, and the duty would not require the delegate to exercise professional medical judgment. The delegator must give WRITTEN INSTRUCTIONS covering the procedure, the predicted outcomes, how to respond to complications, and how to document the task. Delegation is specific to that person AND that patient — it authorizes nobody else — the delegator must remain readily available in person or by telecommunication, and remains responsible for the quality of care. AS 08.64.106 supplies the statutory basis, and among the requirements it sets for those regulations is an absolute bar: duties related to pain management and opioid use and addiction may not be delegated at all. The Board of Barbers and Hairdressers’ regulations answer the microneedling question through the definition of the esthetician’s tools: for the statutory definition of esthetics, an “appliance” means only a device used to stimulate natural physiological processes to improve the health and appearance of the skin, which operates within the manufacturer’s guidelines, does NOT directly ablate or destroy live tissue, does NOT involve an incision into skin beyond the epidermis, and is not a Class III or Class IV laser. (12 AAC 40.920(a)(1)-(3) (Standards for delegation of routine duties); verified 2026-09-05) This is regulatory monitoring, not legal advice.

Question 3

Does a med spa in Arizona need a medical director?

Accepted Answer

Arizona’s delegation rules here are about the UNLICENSED MEDICAL ASSISTANT: what one may do, that injections require DIRECT supervision, and what direct supervision physically means. (A.R.S. §32-1401; verified 2026-07-26) This is regulatory monitoring, not legal advice.

Question 4

Does a med spa in Arkansas need a medical director?

Accepted Answer

ARKANSAS SAYS THE COSMETIC LASER IS THE PRACTICE OF MEDICINE, AND WRITES THE DELEGATION PROTOCOL AROUND IT. 17 CAR § 140-1601 finds that using medical lasers on human beings, for therapeutic OR COSMETIC purposes, constitutes the practice of medicine, and lets a physician delegate a minor procedure only on a protocol. The delegation rule adds a factor test before any task reaches an unlicensed employee, two of which are that the practice can be performed without requiring the exercise of judgment based on medical knowledge and that its results are reasonably predictable. The delegating physician remains responsible for the employee’s acts throughout, and may not hand that supervisory responsibility to anyone but another physician who knowingly accepts it, nor delegate anesthesia to an unlicensed person at all. The Department of Health’s cosmetology rules define the aesthetician by EXTERNAL work: any person who engages in the practice of beautifying the body by cleaning, waxing, externally manipulating or stimulating the body by means of the hands, devices, apparatus or appliances, with or without cosmetic preparations, antiseptics, tonics, lotions and creams — a definition that stops at the surface and names no procedure that penetrates it. (17 CAR § 140-1601(b)(2) (Laser surgery guidelines — protocol); verified 2026-09-04) This is regulatory monitoring, not legal advice.

Question 5

Does a med spa in California need a medical director?

Accepted Answer

THE BOARD WROTE THIS ABOUT A REAL SOLICITATION IT RECEIVED, AND ITS ANSWER RUNS TO ONE WORD. A business had offered physicians “up to $400 per month per spa” to serve as a medical director. The Medical Board describes that as “offering the opportunity for physicians, for a fee, to rent their license to a business so that the business may engage in the practice of medicine”, asks whether a physician can sign on, lend their name on paper to a salon or spa, collect the fee and escape liability for the patients the business treats, and answers “NO!”. The standards for informed consent, delegation to allied health professionals, confidentiality and boundaries and medical records, “as well as responsibility and liability apply to physicians” — “even those denominated “medical director.”” (Medical Board of California — Medical Spas guidance (the medical-director role); verified 2026-09-08) This is regulatory monitoring, not legal advice.

Question 6

Does a med spa in Colorado need a medical director?

Accepted Answer

⚠️ THERE IS NO MED SPA REGISTRATION, LICENSE OR FACILITY PERMIT, AND NO MEDICAL DIRECTOR IS REQUIRED. Article 240 — the Colorado Medical Practice Act — was surveyed in full for this entry and creates no facility license, registration, permit or fee for a cosmetic practice. Its ONLY use of the phrase “medical director” is an exemption from licensure for a person “PRACTICING AS A MEDICAL DIRECTOR PURSUANT TO THE ‘RECOGNITION OF EMERGENCY MEDICAL SERVICES PERSONNEL LICENSURE INTERSTATE COMPACT ACT’” — an EMS role, not a cosmetic one. The wider Title 12 never uses the phrase “medical spa” at all. Colorado is the opposite of Tennessee, which registers the facility, charges $175 and requires a named medical director to sign for it. The Colorado gate is the professional service corporation and the individual license behind it. (Colo. Rev. Stat. art. 240 of tit. 12, surveyed in full; the sole medical-director reference is § 12-240-107(3)(y); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 7

Does a med spa in Connecticut need a medical director?

Accepted Answer

Connecticut names, by statute, exactly who may perform a cosmetic medical procedure in a medical spa: the physician, physician assistant or advanced practice registered nurse the spa employs or contracts with, or a registered nurse. The active-practice and training-plus-experience requirements attach to the physician, physician assistant and advanced practice registered nurse the spa engages — the statute adds the registered nurse separately, without restating those conditions. Failing to supervise a physician assistant adequately is a separate ground for restricting a physician’s license. The cosmetology chapter then says what an ESTHETICIAN may not do: esthetics means skin-care services — cleansing, toning, stimulating, exfoliating or similar procedures using cosmetic preparations, hands, devices, apparatus or appliances to enhance or improve the appearance of the skin, makeup application, lash and brow work, and manual or mechanical hair removal — and EXCLUDES the use of a prescriptive laser device, the performance of a cosmetic medical procedure as defined in the medical spa statute, and any practice, activity or treatment that constitutes the practice of medicine. The medical spa statute’s non-exhaustive list of cosmetic medical procedures names dermaplaning, dermastamping, dermarolling and dermabrasion that removes cells beyond the stratum corneum, as well as class II devices designed to induce deep skin tissue alteration. (Conn. Gen. Stat. §19a-903c(b) (Medical spas); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 8

Does a med spa in Delaware need a medical director?

Accepted Answer

Delaware writes two supervision regimes and a med spa can sit under either. The one that reaches a non-physician directly is 24 DAC 1700 § 11: the delegating physician is responsible for that individual’s medical activities, may not delegate a function the delegate is barred from performing, and may not be involved in patient care in name only — with direct supervision meaning physically on the premises, and indirect supervision meaning present or reachable electronically and able to be physically present within 30 minutes. The regime Delaware writes for PHYSICIAN ASSOCIATES is the more detailed of the two: the collaborating physician may not be involved in patient care in name only, must be involved in active patient care on a regular basis, and may not assign medical acts exceeding the physician’s own license. Unless a Board regulation changes the number — and except where both work in the same physical office or facility building — that physician may collaborate with no more than 4 physician associates at a time, with the PA’s scope identified in a written collaborative agreement kept on file where care is given; a physician associate above 6,000 postgraduate clinical practice hours may be released from the regime on application. Two disciplinary grounds reach supervision directly: failing to supervise a person working under a physician’s supervision, and knowingly assisting unauthorized practice. A physician practice with multiple offices must have a physician member visit each at least monthly. The Act’s own exceptions section states that its practice-of-medicine provisions do not apply to the business of cosmetology, and the cosmetology chapter states that an aesthetician is not authorized to prescribe medication or provide medical treatment in the same manner as a dermatologist. (24 Del. C. §5124(1); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 9

Does a med spa in District of Columbia need a medical director?

Accepted Answer

The District draws its line at the stratum corneum and does it inside the definition of practicing medicine: offering or performing any invasive procedure of the body, or otherwise affecting the layer of skin BELOW THE STRATUM CORNEUM for surgical, therapeutic or COSMETIC purposes, is the practice of medicine — excluding, by the statute’s own terms, procedures known as body tattooing or body piercing. Other health professionals may still perform such a procedure, but only if a licensed physician has authorized it or the performer is one of the named clinicians who has the necessary training and experience. The Barber and Cosmetology Board’s rules then say the same from the esthetician’s side: esthetics is the application of creams, lotions, scrubs, polishes, waxes, cosmetics, eyelashes and other beauty treatments directly onto the skin for a TEMPORARY improvement in appearance, EXCLUDING peels and microdermabrasion, plus facial and neck hair removal by depilatories, waxing or tweezers; master esthetics adds microdermabrasion, resurfacing and chemical peel. Licensees are prohibited from procedures using cosmetic exfoliating substances or devices that affect more than the top layer of the epidermis — a device is not intended to remove viable skin below the stratum corneum, and such use is beyond the scope of every person and establishment the Board licenses — while FDA-registered devices intended for cosmetic skin care remain permitted. (D.C. Code §3-1201.02(7)(A)(iv); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 10

Does a med spa in Florida need a medical director?

Accepted Answer

Florida regulates cosmetic procedures through the physician’s duty to supervise and to delegate only to qualified people. (Fla. Stat. §458.331(1)(w); verified 2026-07-26) This is regulatory monitoring, not legal advice.

Question 11

Does a med spa in Georgia need a medical director?

Accepted Answer

Georgia licenses the people who operate cosmetic lasers, in two tiers, and requires the facility to have a consulting physician behind them. Separately, a physician delegates medical acts to a nurse by written protocol or to a physician assistant by a board-approved job description. (Ga. Comp. R. & Regs. 360-35-.05; verified 2026-08-17) This is regulatory monitoring, not legal advice.

Question 12

Does a med spa in Hawaii need a medical director?

Accepted Answer

HAWAII DEFINES THE PRACTICE OF MEDICINE BY ANY MEANS, METHOD, OR AGENT, AND THE SECTIONS CITED HERE PUT THE SUPERVISION LINE IN THE STATUTE RATHER THAN IN A RULE ABOUT MEDICAL ASSISTANTS. The practice of medicine includes the use of drugs, surgery, electricity, telehealth, and any means to diagnose, treat, prescribe for, or correct any human condition, and no person may practice or offer to practice medicine without a license from the Hawaii medical board. A physician assistant or emergency medical services licensee may render services under the direction and control of a licensed physician, that direction and control does not in every case require the physician’s personal presence, and the employing physician retains full professional and personal responsibility for any act that constitutes the practice of medicine. Anyone practicing medicine under a physician’s supervision must be licensed as a physician assistant, except a person trained to do only a very limited number of diagnostic or therapeutic procedures under a physician’s direction, who is not deemed a practitioner of medicine; the board sets the degree of supervision, and a physician who supervises below it commits professional misconduct. The Board’s rule makes the physician assistant the supervising physician’s agent. A registered nurse may delegate nursing tasks to unlicensed assistive personnel but never assessment, evaluation, or nursing judgment. On the cosmetology side, an esthetician is defined by the work of massaging, cleansing, stimulating, manipulating, exercising, or beautifying the skin with hands or nonmedically prescribed apparatus, cosmetic preparations, and hair removal by means other than electrolysis; the practice of cosmetology is beauty care of the skin, hair, scalp, and nails for cosmetic purposes; and the chapter does not restrict licensed professionals acting within their own scope. None of the sections cited here names microneedling, lasers, or a medical director. (Haw. Rev. Stat. § 453-1; verified 2026-09-08) This is regulatory monitoring, not legal advice.

Question 13

Does a med spa in Idaho need a medical director?

Accepted Answer

IDAHO DEFINES THE SUPERVISING PHYSICIAN AS REACHING UNLICENSED PERSONNEL, AND THAT IS THE PROVISION A MED SPA TURNS ON. A “supervising physician” is a physician responsible for the direction and supervision of the activities of, and patient services provided by, LICENSED OR UNLICENSED medical personnel — so the statute contemplates unlicensed staff working under a physician and puts the physician on the hook for what they do. Failing to supervise the activities of interns, residents, nurse practitioners, certified nurse-midwives, clinical nurse specialists or physician assistants is a ground for medical discipline, and so is knowingly aiding or abetting any person to practice medicine who is not authorized to. The practice of medicine itself is defined broadly, reaching investigation, diagnosis, treatment, correction, prevention of, or prescription for any human condition by any means or instrumentality involving the application of principles or techniques of medical science — and, separately, offering or holding oneself out as able to do those acts. (Idaho Code §54-1803(4); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 14

Does a med spa in Illinois need a medical director?

Accepted Answer

Illinois treats energy devices that disrupt the skin as the practice of medicine, then grades the supervision by whether the procedure is ablative. Ablative means the physician is on site. Non-ablative means the physician can be at the end of a phone. That distinction is the one an Illinois operator has to get right. (68 Ill. Adm. Code 1285.336 (as stated in the IDFPR/IDPH med spa memo); verified 2026-08-17) This is regulatory monitoring, not legal advice.

Question 15

Does a med spa in Indiana need a medical director?

Accepted Answer

Indiana defines the practice of medicine broadly enough to reach injectables and energy procedures: prescribing or administering treatment, and procedures that cut, burn or vaporize tissue, are the practice of medicine. (Ind. Code §25-22.5-1-1.1; verified 2026-07-26) This is regulatory monitoring, not legal advice.

Question 16

Does a med spa in Iowa need a medical director?

Accepted Answer

A medical aesthetic service shall only be performed by qualified licensed or certified nonphysician persons or qualified laser technicians if the service has been delegated by a medical director who is responsible for supervision of the services performed at a medical spa in Iowa. (Iowa Admin. Code r. 481—655.6(2) (Delegation by a medical director); verified 2026-09-04) This is regulatory monitoring, not legal advice.

Question 17

Does a med spa in Kansas need a medical director?

Accepted Answer

KANSAS BOUNDS THE COSMETOLOGY LICENSE TWICE OVER, AND BOTH LIMITS MATTER TO A MED SPA. An esthetician practices the profession of cosmetology ONLY to the listed extent, and the skin work on that list must be both NONINVASIVE and “provided for esthetic rather than medical purposes” — two independent conditions, either of which a cosmetic medical procedure can fail. On the medical side the Act sweeps in by function rather than title: persons who prescribe, recommend or furnish medicine or drugs, or perform any surgical operation of whatever nature by the use of any surgical instrument, procedure, equipment or mechanical device for the diagnosis, cure or relief of any wound, injury, infirmity or disease, are DEEMED to be engaged in the practice of medicine and surgery. Delegating professional responsibilities to a person the licensee knows or has reason to know is not qualified by training, experience or licensure is unprofessional conduct. (Kan. Stat. Ann. §65-1901(f); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 18

Does a med spa in Kentucky need a medical director?

Accepted Answer

KENTUCKY'S COSMETOLOGY CHAPTER DRAWS THE MED SPA LINE ITSELF, IN ONE SENTENCE. No person shall engage in the practice of cosmetology, esthetic practices or nail technology FOR OTHER THAN COSMETIC PURPOSES, nor engage in them FOR THE TREATMENT OF PHYSICAL OR MENTAL AILMENTS — and the chapter does not apply to persons authorized by Kentucky law to practice medicine, nursing and the other named professions who perform incidental practices of cosmetology in the normal course of their own profession. The esthetic-practices definition then contemplates the medical setting expressly: it includes providing PREOPERATIVE AND POSTOPERATIVE ESTHETIC SKIN CARE, either referred by or SUPERVISED BY A MEDICAL PROFESSIONAL, unless the acts are performed incident to treatment of an illness or a disease. On the medical side the practice of medicine is defined as the diagnosis, treatment or correction of any and all human conditions, ailments, diseases, injuries or infirmities BY ANY AND ALL MEANS, METHODS, DEVICES, OR INSTRUMENTALITIES; and employing an unlicensed person as a practitioner of medicine, or otherwise aiding, assisting or abetting the unlawful practice of medicine or any other healing art, is a ground for discipline. (Ky. Rev. Stat. §317A.020(1); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 19

Does a med spa in Louisiana need a medical director?

Accepted Answer

LOUISIANA NAMES THE MED SPA FAILURE MODES INSIDE ONE DEFINITION OF UNPROFESSIONAL CONDUCT. R.S. 37:1285(A)(13) makes unprofessional conduct a cause for refusing, suspending or revoking a license, and its enumerated examples read like a list of how a cosmetic practice goes wrong: FAILING TO MAINTAIN INDEPENDENT MEDICAL JUDGMENT, IMPROPERLY DELEGATING OR SUPERVISING, exercising undue influence, ENABLING THE UNAUTHORIZED PRACTICE OF MEDICINE, practicing or enabling practice by an impaired provider, and failing to practice within the scope of education, training and experience. A separate cause reaches the arrangement rather than the act: knowingly performing any act which in any way assists an unlicensed person to practice medicine, or HAVING PROFESSIONAL CONNECTION WITH OR LENDING ONE'S NAME TO AN ILLEGAL PRACTITIONER. Physician assistants have their own cause — utilizing one without approval and recordation as required by law, or permitting one within the physician's employment to conduct activities OUTSIDE THE DESIGNATED SCOPE of the assistant's approval and registration. The practice of medicine is defined broadly enough to catch cosmetic work: holding oneself out as engaged in, or actually engaging in, the diagnosing, treating, curing or relieving of any bodily condition, defect or injury in another person, BY ANY DRUG, INSTRUMENT OR FORCE, or any other agency or means. THE COSMETOLOGY BOARD’S RULES THEN NAME THE PROCEDURES A SALON LICENSE DOES NOT REACH. No license or permit issued by the Board of Cosmetology authorizes, in a salon it licenses, the use of lasers, MICRO-NEEDLING, micro-blading, any service or procedure which penetrates or invades the live tissue or dermis by any means — instruments, product insertion, puncturing, cutting, needling or chemical exfoliation — or the use of any mechanical or electrical apparatus classified as a medical device by the FDA. Estheticians shall not perform any procedure which will affect the dermis or skin below the epidermis; esthetic services are the work performed ON THE EPIDERMIS, and the board’s definition of nano-needling is a non-invasive technique that does not penetrate beyond the epidermis by more than .25 mm. (La. Rev. Stat. §37:1285(A)(13); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 20

Does a med spa in Maine need a medical director?

Accepted Answer

Maine writes the delegation rule a med spa actually operates under, and it is CONDITIONAL rather than open: a physician may delegate activities relating to medical care to employees or support staff only where the activities are carried out by custom and usage under the physician’s control, do not themselves require a license, and the physician has ensured the staff have the appropriate training, education and experience AND that they perform the activities competently and safely. The physician remains legally liable and the delegate is treated as the physician’s agent. The section expressly does not reach registered nurses or licensed physician associates, who are governed by their own chapters — and for physician associates the dividing line is 4,000 documented hours of clinical practice, below which a filed collaborative agreement is required and above which a physician associate may be the principal clinical provider in a practice with no physician partner, under a practice agreement. The practice of aesthetics defined by the barbering and cosmetology chapter does not include the diagnosis, treatment or therapy of any dermatological condition. (32 M.R.S. §14202(7); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 21

Does a med spa in Maryland need a medical director?

Accepted Answer

Maryland attaches its delegation duties to the licensed physician who actually delegates. That physician must evaluate the risk to the patient, delegate only technical acts customary to their own practice and for which the assistant has been trained, remain responsible for the act, and supervise it — and responsibility cannot be handed to another physician without that physician’s express consent. Maryland sets the required presence by tier rather than by one nonsurgical rule: patient preparation, history interviews, specimen collection, tuberculin skin tests, electrocardiography, prescription transmittal, oral drugs and microdermabrasion may be delegated without on-site supervision; injections and peripheral intravenous lines require on-site supervision; and a surgical technical act requires the delegating physician present, scrubbed and personally performing the surgery in the same surgical field. An act that is exclusively limited to a licensed, certified or registered occupation may not be delegated TO AN ASSISTANT — a limit on who may receive the act, not a bar on delegating it to someone whose own license covers it. The cosmetology statute answers the microneedling question in its own definition: “provide esthetic services” means cleansing, exercising, exfoliating, massaging, COSMETIC MICRONEEDLING, stimulating, toning or any similar procedure on the skin or scalp by electrical, mechanical or any other means, and includes superficial exfoliation of the epidermis and nonablative skin rejuvenation — but it does not include the diagnosis of illness, disease or injury, or performing ABLATION OF THE DERMIS OR HYPODERMIS; hair removal under that definition is by any means other than a laser light-based device. (Md. Code Regs. 10.32.12.03(A) (Standards for the Licensed Physician Delegating to an Assistant); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 22

Does a med spa in Massachusetts need a medical director?

Accepted Answer

What chapter 112 creates behind a physician assistant is a SUPERVISING PHYSICIAN, in one unusually direct sentence: supervision must be CONTINUOUS, and it expressly does not require the physician to be present. The absence of a presence requirement is paid for in liability — and what the assistant may do is set by their own training rather than by a list. (Mass. Gen. Laws ch. 112, § 9E; verified 2026-09-01) This is regulatory monitoring, not legal advice.

Question 23

Does a med spa in Michigan need a medical director?

Accepted Answer

Michigan is a delegation-permissive state with real limits inside it. A licensee may delegate to a LICENSED OR UNLICENSED individual qualified by education, training or experience — but only where the act is WITHIN THE SCOPE OF THE LICENSEE’S OWN PROFESSION and is performed UNDER THE LICENSEE’S SUPERVISION — and may not delegate at all where the act requires the education, skill and judgment of the licensee. Separately, the esthetics license is capped by statute at the stratum corneum, so what may be delegated to a licensee is not the same question as what that license itself reaches. (Mich. Comp. Laws § 333.16215(1); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 24

Does a med spa in Minnesota need a medical director?

Accepted Answer

⚠️ THERE IS NO MED SPA REGISTRATION AND NO MEDICAL DIRECTOR REQUIREMENT. Chapter 147 was surveyed in full for this entry: it contains no occurrence of “medical director” and no facility license, registration, permit or fee of any kind for a cosmetic practice. Minnesota regulates the PERSON performing the act, never the premises — so there is no register a Minnesota consumer can check, and no filing a Minnesota operator must make. (Minn. Stat. ch. 147 (surveyed in full via the chapter text); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 25

Does a med spa in Mississippi need a medical director?

Accepted Answer

MISSISSIPPI PUTS ITS SUPERVISION LINES IN THE MEDICAL BOARD’S RULES, AND THE ONE THAT REACHES A MED SPA MOST DIRECTLY IS THE LASER RULE. The statute defines the practice of medicine as suggesting, recommending, prescribing, or directing any drug, medicine, appliance, or other agency for the cure, relief, or palliation of any ailment for compensation, and requires a license from the State Board of Medical Licensure before practicing. The Board’s laser rule declares the use of laser, pulsed light, or similar devices for invasive or cosmetic procedures to be the practice of medicine, limited to physicians and those directly supervised by physicians, with a physician on the premises and directly involved in the treatment if required. Physician assistants practice with physician supervision, may perform any delegated medical service within their training that forms part of the physician’s scope, are the agents of their supervising physicians, and supervision means overseeing and accepting responsibility for the services rendered. The Board of Nursing lets a registered nurse assign the administration of patient medications to other licensed nurses only, except as its Part 2860 sets out. On the cosmetology side, esthetics is defined as massaging the face or neck, brow work, lash and brow tinting, waxing, and stimulating, cleaning, or beautifying the face, neck, arms, or legs by hand, apparatus, or cosmetic preparation, and excludes the diagnosis, treatment, or therapy of any dermatological condition; the cosmetology board’s rules forbid any service or tool that penetrates the skin below the epidermis, forbid practicing medicine or surgery and excising moles or skin tags, and allow dermaplaning only with a disposable, non-surgical 10R rounded edge butterblade. None of the sections cited here names microneedling or a medical director. (Miss. Code Ann. § 73-25-33(1); verified 2026-09-08) This is regulatory monitoring, not legal advice.

Question 26

Does a med spa in Missouri need a medical director?

Accepted Answer

MISSOURI FIXES THE SUPERVISION BURDEN IN NUMBERS, AND IT COUNTS CHARTS. A physician may enter collaborative practice arrangements with registered professional nurses, in the form of written agreements, jointly agreed-upon protocols or standing orders, and those arrangements may delegate authority to administer or dispense drugs and provide treatment — but only within the nurse’s scope of practice and consistent with that nurse’s skill, training and competence. The statute then fixes the review burden in numbers: the APRN must submit at least TEN PERCENT of the charts documenting their delivery of health care services for physician review EVERY FOURTEEN DAYS, and the collaborating physician must review every fourteen days at least TWENTY PERCENT of the charts in which the APRN prescribes controlled substances. Where the arrangement covers diagnosis and initiation of treatment for acutely or chronically ill or injured persons, the collaborating physician must be present for sufficient periods of time at least once every two weeks. Geographic proximity is required, subject to the exceptions the section itself sets out. Separately, delegating professional responsibilities to a person not qualified by training, skill, competency, age, experience or licensure is a ground for discipline. On the cosmetology side the licensed practice is enumerated: the Class E esthetician occupation is defined by a list of manual and apparatus-based skin practices, with cosmetic preparations not to exceed ten percent phenol. (Mo. Rev. Stat. §329.010(5)(d); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 27

Does a med spa in Montana need a medical director?

Accepted Answer

"Medical director" means a physician or physician assistant who holds a current unrestricted Montana license and is professionally and legally responsible for training, providing medical direction, and oversight of licensed ECPs under the medical director's supervision. That is the only medical director defined anywhere in Title 37, chapter 3 of the Montana Code Annotated or in the Board of Medical Examiners’ rules in Title 24, chapter 156 of the Administrative Rules of Montana, and it concerns emergency care providers; neither the chapter nor the rules requires a medical spa or any other office practice to designate a medical director. (Mont. Admin. R. 24.156.403(1)(h) (Title 37, ch. 3 and ARM Title 24, ch. 156 surveyed); verified 2026-09-08) This is regulatory monitoring, not legal advice.

Question 28

Does a med spa in Nebraska need a medical director?

Accepted Answer

Nebraska defines delegation in nursing terms — transferring the authority, responsibility AND accountability to perform nursing interventions — and places delegating, directing and assigning within the registered nurse’s own practice, bounded by the Nurse Practice Act. It also puts an affirmative duty on every credential holder to report anyone they have reason to believe is practicing without a credential. Separately, the Board’s own rules bound the cosmetology licenses: the practice of esthetics is UPON THE SKIN OR EPIDERMIS, and neither esthetics nor cosmetology includes using injectables and lasers. That rule names those two modalities and does not name microneedling. (Neb. Rev. Stat. §38-2205 (“Delegating” defined); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 29

Does a med spa in Nevada need a medical director?

Accepted Answer

Nevada’s Medical Practice Act contains no med-spa “medical director” designation. The full text of NRS chapter 630 was surveyed and the phrase “medical director” does not appear in it, nor do “medical spa” or “med spa”; the chapter regulates supervision through the named supervising-physician relationship and the medical-assistant supervision ground instead. (Nev. Rev. Stat. ch. 630 (Physicians and Physician Assistants — full chapter surveyed); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 30

Does a med spa in New Hampshire need a medical director?

Accepted Answer

New Hampshire makes the licensee answerable for who works in their office: employing or ALLOWING an unlicensed person to practice there is itself a disciplinary ground. It also treats regular or frequent consultation by an unlicensed person as the practice of medicine without a license, so a consultation exception cannot be used as a standing arrangement. The cosmetology chapter defines esthetics by an enumerated list of surface treatments — giving facials, applying makeup, giving therapeutic skin care treatments, removing superfluous hair, applying eyelashes, beautifying, massaging, cleansing or stimulating the face, neck, arms and shoulders with cosmetic preparations, devices or appliances, and providing pedicure and manicure services — a list on which no procedure that punctures the skin appears. (N.H. Rev. Stat. §329:17, VI(e); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 31

Does a med spa in New Jersey need a medical director?

Accepted Answer

Two rules meet here and they must not be confused. Lasers are swept into the definition of SURGERY for the office-surgery rules. The separate delegation rule addresses physical modalities, and it gives an unlicensed aide a list of exactly five — hot packs, cold packs, paraffin baths, contrast baths and whirlpool baths. Nothing on that list is a cosmetic device. (N.J.A.C. 13:35-4A.3; verified 2026-08-17) This is regulatory monitoring, not legal advice.

Question 32

Does a med spa in New Mexico need a medical director?

Accepted Answer

NEW MEXICO WROTE A RULE FOR THIS EXACT BUSINESS, AND IT IS RECENT. 16.12.14 NMAC — "Nursing Practice in Aesthetic Healthcare Facilities", effective 2024-05-21 — defines an AESTHETIC HEALTHCARE FACILITY and requires it to employ a CLINICAL SUPERVISOR who is an APRN or other licensed independent practitioner with the training to perform every procedure the facility offers. That supervisor must develop or approve WRITTEN PROTOCOLS for all procedures, detailed enough that making independent healthcare decisions never falls to someone without the scope to make them. On the physician side, the medical board treats the use of medical therapeutic and cosmetic devices as the practice of medicine, and a MEDICAL ASSISTANT may use one only if certified on that device, only if it is non-incisive and non-ablative, and only when the supervising physician is IMMEDIATELY AVAILABLE ON THE PREMISES. (16.12.14.8(B) NMAC (Nursing Practice in Aesthetic Healthcare Facilities, eff. 2024-05-21); verified 2026-09-04) This is regulatory monitoring, not legal advice.

Question 33

Does a med spa in New York need a medical director?

Accepted Answer

New York reaches cosmetic procedures through the definition of the PRACTICE OF MEDICINE, plus the physician’s own duties not to delegate to the unqualified and not to permit unlicensed practice. On 7 March 2025 the State Board for Medicine determined that using an energy device WHICH AFFECTS THE BASEMENT MEMBRANE OR DEEPER TISSUE is the practice of medicine — grading devices by depth. The Education Department adopted that determination for every physical condition EXCEPT LASER HAIR REMOVAL, on which it has not acted. Inside it, only a licensed practitioner or a REGISTERED PROFESSIONAL NURSE under a physician’s general supervision may carry out the treatment. (N.Y. Educ. Law §6521; verified 2026-08-17) This is regulatory monitoring, not legal advice.

Question 34

Does a med spa in North Carolina need a medical director?

Accepted Answer

The Medical Board treats an aesthetic laser as a surgical instrument: altering human tissue with one is surgery, and therefore the practice of medicine. Everything about who may hold the handpiece follows from that. (NCMB Position Statement 5.1.2 (adopted July 1999, amended May 2021); verified 2026-08-17) This is regulatory monitoring, not legal advice.

Question 35

Does a med spa in North Dakota need a medical director?

Accepted Answer

The Medical Practice Act itself sets the terms on which a physician assistant may practice. A PA serving a patient located in the state must hold an active North Dakota PA license or be privileged under chapter 43-17.5, and the Board of Medicine sets the rules governing a PA’s conduct, licensure, qualifications and discipline. The hard limit is negative rather than positive: a PA is NOT authorized to perform any service that must be performed by someone licensed under chapters 43-12.1, 43-13, 43-15 and 43-28. On the nursing side, a nurse may supervise and delegate nursing interventions, to an individual the nursing chapter exempts under a named subsection. The cosmetology chapter answers the microneedling question in its definitions: esthetics excludes any procedure invading living tissue below the stratum corneum and excludes advanced esthetic procedures; ADVANCED ESTHETICS includes microneedling, nonablative procedures, advanced chemical peels and lancet extractions but not treatment of a medical ailment or ablative procedures; and an advanced esthetician must file proof of board-approved additional training before using microneedling pens, rollers or devices. (N.D.C.C. § 43-17-02.1(1) (Physician assistant — scope of practice); verified 2026-09-05) This is regulatory monitoring, not legal advice.

Question 36

Does a med spa in Ohio need a medical director?

Accepted Answer

Across the acts these chapters cover — light-based devices and the administration of drugs — Ohio puts a DELEGATING PHYSICIAN behind the act, answerable to the Board for it, and the esthetics license itself authorizes nothing that breaks the skin. Which rules that physician is held to turns on the act, not the job title: an injection delegated to an UNLICENSED PERSON runs through chapter 4731-23, and light-based devices split into four separate lanes that disagree with each other. Ablative may never be delegated at all; a vascular laser may go to a nurse under an on-site physician watching at most two people; hair removal may go to a certified non-licensee under a physician watching up to five, who need not always be in the building. (Ohio Admin. Code 4731-18-02(A); verified 2026-09-01) This is regulatory monitoring, not legal advice.

Question 37

Does a med spa in Oklahoma need a medical director?

Accepted Answer

Oklahoma writes the supervision duty as a list the SUPERVISING PHYSICIAN must satisfy, and it is unusually concrete about orders. In all patient care settings that physician must provide appropriate methods of supervising the physician assistant’s services, and § 519.6 names them: being responsible for the FORMULATION OR APPROVAL OF ALL ORDERS AND PROTOCOLS — standing, direct or otherwise — and periodically reviewing them; regularly reviewing the services provided and any problems or complications; being available physically or by telemedicine or direct telecommunication for consultation, emergencies or referral; and reviewing a sample of outpatient medical records. The Cosmetology and Barbering Board’s scope rule then draws the esthetician’s line by DEPTH: cosmetology expressly does not include services that puncture the skin or that fall within the healing arts, and “puncturing the skin” is defined to include microneedling — a multi-needled device creating microchannels at a depth greater than 0.25 mm — as well as laser, ultrasound and HIFU, plasma pen, injections including needle-free devices, FDA Class 3 devices and dermabrasion. (Okla. Stat. tit. 59, § 519.6 (Supervision in all patient care settings); verified 2026-09-05) This is regulatory monitoring, not legal advice.

Question 38

Does a med spa in Oregon need a medical director?

Accepted Answer

Oregon does not let a physician associate practice on an informal understanding: a written collaboration agreement signed by a physician, podiatric physician or employer is a precondition of practicing at all, and the degree of collaboration is set at the associate’s primary location of practice by reference to the patient’s condition, the standard of care and the associate’s own education, experience and competence. The cosmetology chapter draws its own line inside the definition of esthetics: the listed skin and facial care practices — cleansing, stimulating, manipulating, exfoliating and applying lotions or creams with the hands or apparatuses, temporary hair removal including dermaplaning, makeup artistry, eyebrow and eyelash services, and facial and body treatments — count as esthetics only when performed to keep the skin healthy and attractive and NOT for medical diagnosis or treatment of disease or physical or mental ailments. The Board’s device rules then answer the microneedling question by DEPTH rather than by name: an esthetician is limited to mechanical or electric apparatuses, appliances or devices that do not penetrate beyond the epidermis except through natural physiological effects, and the devices an esthetician may use expressly include those used for nanoneedling, microneedling and similar procedures — within that limit. The epidermis is the outermost layer only; an esthetician is presumed to be working below it on exfoliating or removing skin below the epidermal layer or destroying or damaging the dermis or muscle; an esthetic device is not a laser, intense pulsed light or a needle-free filler injector; and an esthetician may not use any device for medical diagnosis or treatment of disease or physical or mental ailments. (Or. Rev. Stat. §677.510(2)(a); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 39

Does a med spa in Pennsylvania need a medical director?

Accepted Answer

On the medical side Pennsylvania delegates by TEST rather than by list: seven conditions, all of which must hold before a physician delegates a medical service TO A HEALTH CARE PRACTITIONER OR A TECHNICIAN — with a separate standing-protocol route for emergencies. The cosmetology side is the opposite shape, and it is a list: the board’s definition of esthetics names massaging, applying preparations, hair removal by tweezers or wax, and eyelash work, with no depth or penetration language anywhere in it. (49 Pa. Code §18.402(a); verified 2026-08-17) This is regulatory monitoring, not legal advice.

Question 40

Does a med spa in Rhode Island need a medical director?

Accepted Answer

Rhode Island’s practice-of-medicine definition reaches HOLDING OUT as well as doing: a person is regarded as practicing medicine who holds themself out as able to diagnose, treat, operate or prescribe for anyone ill or alleged to be ill, or who professes to heal or undertakes by ANY MEANS OR METHOD to do those things — and attaching M.D., D.O. or a similar abbreviation indicating engagement in treatment or diagnosis is itself practicing medicine. The delegation ground is stated as unprofessional conduct: practicing medicine with an unlicensed physician, except in an accredited preceptorship or residency training program, OR AIDING OR ABETTING UNLICENSED PERSONS IN THE PRACTICE OF MEDICINE. On the cosmetology side, esthetics is defined as cleansing, stimulating, manipulating and beautifying skin, including the treatment of skin problems such as dehydration, temporary capillary dilation, excessive oiliness and clogged pores. (R.I. Gen. Laws §5-37-1(a)(22); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 41

Does a med spa in South Carolina need a medical director?

Accepted Answer

South Carolina reaches supervision and delegation failures through the Board of Medical Examiners’ misconduct grounds: knowingly performing an act that in any way assists an UNLICENSED person to practice is itself misconduct, as is being convicted of or sanctioned for illegal or unauthorized practice, and so is assisting or abetting a violation of the medical practice laws. The exposure therefore runs to the licensee who lets an unlicensed person perform, not only to that person. (S.C. Code §40-47-110(B)(7); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 42

Does a med spa in South Dakota need a medical director?

Accepted Answer

SOUTH DAKOTA DEFINES THE ESTHETICIAN'S LIMIT ANATOMICALLY, WHICH IS RARE AND WORTH READING TWICE. The practice of esthetics is confined to the NONINVASIVE care of the skin, and the statute says what noninvasive means: CONFINED TO THE NONLIVING CELLS OF THE STRATUM CORNEUM OF THE EPIDERMIS. It adds two limits in the same breath — the practices must be in a SUPERFICIAL MODE and NOT FOR THE TREATMENT OF MEDICAL DISORDERS, and LIVING CELLS MAY NEVER BE ALTERED, CUT, OR DAMAGED. On the medical side the practice of medicine includes, without limitation, recommending, prescribing or directing for the use of any person any drug, medicine, APPARATUS, or other agency for the cure, relief or palliation of any ailment or disease of the mind or body. And within a medical corporation, medical or surgical treatment, consultation or advice may be given by employees of the corporation ONLY IF THEY ARE LICENSED under the Medical Practice Act. (S.D. Codified Laws §36-15-2.2(1); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 43

Does a med spa in Tennessee need a medical director?

Accepted Answer

The application must give the name and physical address of the medical spa; the NAME AND TENNESSEE LICENSE NUMBER of the medical director or supervising physician responsible for services; the name and physical address of THAT PHYSICIAN’S PRIMARY PRACTICE; their certification information; and AN ATTESTATION that the medical director or supervising physician registering the spa ASSUMES AND ACCEPTS RESPONSIBILITY for the cosmetic medical services provided there. (Tenn. Comp. R. & Regs. 0880-02-.24(1)(a)–(f); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 44

Does a med spa in Texas need a medical director?

Accepted Answer

Cosmetic injections, dermal fillers and cosmetic laser use are medical acts a Texas physician may delegate to a QUALIFIED, PROPERLY TRAINED person under supervision — with a written order that identifies the physician and sets patient-screening criteria. ⚠️ LASER HAIR REMOVAL SITS OUTSIDE THAT ROUTE ENTIRELY: it is separately licensed under the Health & Safety Code, on a tiered certificate. (Tex. Occ. Code §157.001; verified 2026-07-26) This is regulatory monitoring, not legal advice.

Question 45

Does a med spa in Utah need a medical director?

Accepted Answer

UTAH LEGISLATES THIS IN GROUPS AND IN MILES. Section 58-1-506 sorts who may be delegated a cosmetic medical procedure into DELEGATION GROUP A (physician assistant, registered nurse, master esthetician, and an electrologist for laser hair removal) and GROUP B (practical nurse, esthetician, medical assistant), then grades supervision — GENERAL supervision requires the supervisor to be available in person to evaluate a suspected adverse reaction and LOCATED WITHIN 60 MINUTES OR 60 MILES of the cosmetic medical facility. For a NONABLATIVE cosmetic medical procedure the supervisor may perform it personally, authorize GENERAL supervision where a registered nurse or master esthetician performs it, or authorize DIRECT supervision where an esthetician or practical nurse performs it. And Utah answers the medical-assistant question flatly: a medical assistant under the indirect supervision of a physician MAY NOT diagnose, MAY NOT establish a treatment plan, and MAY NOT inject a medication or substance — INCLUDING A NEUROTOXIN OR FILLER — for cosmetic purposes. The nursing rules define delegation as transferring authority to another nurse, or to an unlicensed individual only a task that does not require a nursing assessment. (Utah Code § 58-1-506(1)(a)-(b) (Supervision of cosmetic medical procedures); verified 2026-09-04) This is regulatory monitoring, not legal advice.

Question 46

Does a med spa in Vermont need a medical director?

Accepted Answer

Vermont names the delegation failure directly: handing health care services to someone the licensee knows, or has reason to know, is not qualified by training, experience, education or licensing credentials is unprofessional conduct. Practicing medicine with a physician who is not legally practicing in the State, or aiding such a physician, is a separate ground. The cosmetology chapter draws the esthetics line from both directions: esthetics MEANS skin-care services to enhance or improve the appearance of the skin — cleansing, toning, stimulating, manipulating, beautifying, exfoliating or similar procedures using only cosmetic preparations, hands, mechanical or electrical apparatus, tonics, lotions, creams or makeup, plus lash and brow work and manual or mechanical hair removal — and esthetics DOES NOT INCLUDE any practice that constitutes the practice of medicine, including injections of any substance and the use of lasers. (Vt. Stat. tit. 26, §1354(a)(29); verified 2026-09-03) This is regulatory monitoring, not legal advice.

Question 47

Does a med spa in Virginia need a medical director?

Accepted Answer

Virginia’s procedure-specific rule here is about LASER HAIR REMOVAL. It requires a named training curriculum including TEN PROCTORED CASES, lets the physician delegate to a properly trained person, and defines supervision as “readily available” rather than physically present — with one duty the physician cannot delegate at all. (18 Va. Admin. Code § 85-20-91(A); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 48

Does a med spa in Washington need a medical director?

Accepted Answer

Washington answers the supervision question twice, because it has two rules and they disagree on purpose. For a delegated LLRP DEVICE — a laser, noncoherent light, IPL, radiofrequency or plasma device that topically penetrates and alters tissue — the physician must be ON THE PREMISES for the patient’s first treatment. For a cosmetic INJECTION it turns on the label: on-site for the whole procedure if the substance is used off-label, and merely reachable within thirty minutes if it is FDA-approved for that use. (Wash. Admin. Code 246-919-605(1) and (2); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 49

Does a med spa in West Virginia need a medical director?

Accepted Answer

WEST VIRGINIA PUTS ENERGY DEVICES INSIDE THE DEFINITION OF SURGERY, AND THAT IS THE FIRST THING A MED SPA HERE NEEDS TO KNOW. The Medical Practice Act defines the practice of medicine and surgery as the diagnosis or treatment of, or operation or prescription for, any human disease, pain, injury, deformity or other physical or mental condition — and says in terms that “surgery” includes the use on humans of lasers, ionizing radiation, pulsed light and radiofrequency devices. The same section carries an exception for a person who is a duly licensed health care provider under other provisions of the code and who is acting within the scope of that license. On the delegation side the statute is unusually blunt: a physician assistant may not practice independent of a collaborating physician, and may perform medical acts in collaboration with physicians only within their own education, training and experience AND the collaborating physician’s scope of practice. Aiding, assisting, procuring or advising any unauthorized person to practice medicine is a ground for discipline. (W. Va. Code § 30-27-3(a) (aesthetics is a CLOSED list of surface acts, and none of them break skin); verified 2026-09-07) This is regulatory monitoring, not legal advice.

Question 50

Does a med spa in Wisconsin need a medical director?

Accepted Answer

Wisconsin works from both ends. The medical board defines ADEQUATE SUPERVISION as a two-sided competence test — the physician must be competent to do the delegated act, and must have reasonable evidence the delegate is minimally competent to do it — and failing to supervise adequately is unprofessional conduct, expressly including delegation to UNLICENSED personnel. The cosmetology board comes at it from the other side and names procedures: microneedling is listed as a DELEGATED MEDICAL PROCEDURE, alongside a catch-all for any treatment reaching below the stratum corneum, so an esthetician may perform it only under a physician’s direction. (Wis. Admin. Code Med § 10.02(1); verified 2026-09-02) This is regulatory monitoring, not legal advice.

Question 51

Does a med spa in Wyoming need a medical director?

Accepted Answer

WYOMING DEFINES “PRACTICING MEDICINE” BROADLY, AND IT REACHES CONDUCT A MED SPA DOES DAILY. A person is practicing medicine who advertises, holds out or represents to the public that they are authorized to practice medicine; who offers or undertakes to prevent, diagnose, correct or treat, IN ANY MANNER, BY ANY MEANS, METHOD OR DEVICE, any human disease, illness, pain, wound, infirmity, defect or abnormal condition; who offers or undertakes to prescribe, order, give or administer drugs obtainable only by prescription; or who RENDERS A DETERMINATION OF MEDICAL NECESSITY OR APPROPRIATENESS of proposed treatment. Aiding or abetting the practice of medicine by a person not licensed by the board is a ground for discipline. On the cosmetology side the practice of esthetics is defined by purpose — the improvement and beautification of the skin FOR COSMETIC PURPOSES — and the Cosmetology Act does not prohibit services rendered by licensed physicians, nurses, dentists, podiatrists, chiropractors, physical therapists, morticians or barbers when exclusively engaged in the practice of their respective professions. The cosmetology board’s own scope rule then closes the esthetics question the statute leaves open: the rule enumerates the esthetics scope — massaging, cleansing, exfoliating, stimulating, manipulating, beautifying and applying preparations to the skin, brow and lash work, and extractions of the face are among the acts it lists — and then states that PROCEDURES WHICH PIERCE THE EPIDERMAL OR DERMAL LAYER OF THE SKIN ARE CONSIDERED INVASIVE AND ARE PROHIBITED; the same rule says that using the term or title “Medical Esthetician” is not allowed. (Wyo. Stat. Ann. §33-26-102(a)(xi)(A)-(B); verified 2026-09-03) This is regulatory monitoring, not legal advice.

State	What its rule says	Cited to
Alabama	The cited rules do not settle this — none names a "medical director"; they establish that a physician who delegates non-ablative treatments to a Level 1 or 2 Delegate must have 30 hours of training and must supervise the work under a written protocol.	Ala. Admin. Code r. 540-X-11-.06(1) (Initial training requirements for physicians and delegates) Sep 4, 2026
Alaska	The cited rules do not settle this — none names a medical director. What they do set: when a physician, PA, podiatrist or osteopath delegates a duty, it must be within their own scope, they must assess the patient first, then supervise and stay available.	12 AAC 40.920(a)(1)-(3) (Standards for delegation of routine duties) Sep 5, 2026
Arizona	The cited rules do not settle this — none requires a named medical director, and Arizona has no dedicated med-spa statute or license; they do require clinical decisions to stay with licensees and medical assistants to be adequately supervised.	A.R.S. §32-1401 Jul 26, 2026
Arkansas	Not directly — the cited rules require no titled "medical director," but laser treatment is the practice of medicine, so a physician must personally diagnose and prescribe each case, delegate only to trained staff, and stay reachable for complications.	17 CAR § 140-1601(b)(2) (Laser surgery guidelines — protocol) Sep 4, 2026
California	The cited rules do not settle this — they impose no "medical director" title, but they do make a med spa a physician's own medical practice, and a physician who lends their name to one for a fee remains fully responsible and liable for its patients.	Medical Board of California — Medical Spas guidance (the medical-director role) Sep 8, 2026
Colorado	No — the Medical Practice Act creates no med spa license, registration or medical director requirement; its only "medical director" mention is an EMS compact exemption. The gate is the professional service corporation and the individual licenses behind it.	Colo. Rev. Stat. art. 240 of tit. 12, surveyed in full; the sole medical-director reference is § 12-240-107(3)(y) Sep 2, 2026
Connecticut	Not a titled "medical director" — but every Connecticut med spa must employ or contract with a licensed physician, physician assistant, or APRN who is actively practicing in the state and has training and experience in cosmetic medical procedures.	Conn. Gen. Stat. §19a-903c(b) (Medical spas) Sep 3, 2026
Delaware	The cited rules do not settle this — no medical director title is named, but aestheticians may not prescribe or provide medical treatment, and any physician who delegates medical acts to a non-physician must actively supervise, not be involved in name only.	24 Del. C. §5124(1) Sep 3, 2026
District of Columbia	The cited rules do not settle this — no named medical director requirement appears, but any procedure below the stratum corneum is the practice of medicine and must be physician-authorized or performed by a listed licensed practitioner trained for it.	D.C. Code §3-1201.02(7)(A)(iv) Sep 3, 2026
Florida	Florida regulates cosmetic procedures through the physician’s duty to supervise and to delegate only to qualified people.	Fla. Stat. §458.331(1)(w) Jul 26, 2026
Georgia	The cited rules do not settle this generally — they require only that a non-physician-office facility offering cosmetic laser services other than hair removal hold a consulting physician agreement and file that physician's details with the Board.	Ga. Comp. R. & Regs. 360-35-.05 Aug 17, 2026
Hawaii	Not directly — no cited rule requires a med spa to name a medical director, and Hawaii licenses no med spa facility; but diagnosing or treating is the practice of medicine, so each service must sit within a licensee's scope or permitted supervision.	Haw. Rev. Stat. § 453-1 Sep 8, 2026
Idaho	The cited rules do not settle this — Idaho defines a "supervising physician" as the person responsible for directing and supervising medical personnel and the patient services they provide, but they impose no medical director requirement on a med spa itself.	Idaho Code §54-1803(4) Sep 3, 2026
Illinois	Not directly — no cited rule names a "medical director," but a med spa must be owned and operated by a physician (or an APRN for some services), and Class 3b/4 laser, IPL, RF and microwave treatments disrupting the epidermis need a physician or delegation.	68 Ill. Adm. Code 1285.336 (as stated in the IDFPR/IDPH med spa memo) Aug 17, 2026
Indiana	Yes — from July 1, 2026 each med spa must have a responsible practitioner (a physician, qualifying APRN, or PA with delegated prescriptive authority), physically present enough to ensure compliance; injectables and energy-device work are practicing medicine.	Ind. Code §25-22.5-1-1.1 Jul 26, 2026
Iowa	A medical aesthetic service shall only be performed by qualified licensed or certified nonphysician persons or qualified laser technicians if the service has been delegated by a medical director who is responsible for supervision of the services performed at a medical spa in Iowa.	Iowa Admin. Code r. 481—655.6(2) (Delegation by a medical director) Sep 4, 2026
Kansas	The cited rules do not settle this — no med spa medical director requirement appears; estheticians are limited to noninvasive, non-medical skin work, and anything amounting to practice of medicine must be done or properly supervised by a licensed physician.	Kan. Stat. Ann. §65-1901(f) Sep 3, 2026
Kentucky	The cited rules do not settle this — Kentucky names no med spa "medical director." They do establish that esthetics licenses stop at cosmetic work, and that diagnosis or treatment of any condition is practicing medicine and needs a medical license.	Ky. Rev. Stat. §317A.020(1) Sep 3, 2026
Louisiana	The cited rules do not settle this — none names a medical director; they only require a Louisiana license to practice medicine and make improper delegation or supervision, or enabling unlicensed practice, grounds for board discipline against the physician.	La. Rev. Stat. §37:1285(A)(13) Sep 3, 2026
Maine	The cited rules do not settle this — none requires a med spa to have a medical director; the only mention is as an alternative to supervision for a certified nurse practitioner's first 24 months. Aesthetics licensure itself excludes treating skin conditions.	32 M.R.S. §14202(7) Sep 3, 2026
Maryland	The cited rules do not settle this — no medical director title appears in them; they require only that a physician delegating a technical act to an assistant supervise that assistant, delegate only acts the assistant is trained for, and stay responsible.	Md. Code Regs. 10.32.12.03(A) (Standards for the Licensed Physician Delegating to an Assistant) Sep 3, 2026
Massachusetts	The cited rules do not settle this — no statute requires a med spa medical director; PAs do need continuous physician supervision (not necessarily on-site), while NPs with 2 years' supervised practice prescribe independently.	Mass. Gen. Laws ch. 112, § 9E Sep 1, 2026
Michigan	Not directly — no cited rule requires a medical director title, and Michigan licenses no med spa as such. But delegated acts must be supervised by the delegating licensee, and laser dermatological procedures must be under a licensed physician's supervision.	Mich. Comp. Laws § 333.16215(1) Sep 2, 2026
Minnesota	No — chapter 147 has no medical director requirement and no facility license, registration or permit for a cosmetic practice; Minnesota regulates the person performing each act, so medical acts must still be done by someone licensed to do them.	Minn. Stat. ch. 147 (surveyed in full via the chapter text) Sep 2, 2026
Mississippi	The cited rules do not settle this — they name no "medical director" and Mississippi issues no med-spa-specific license; they do require a physician's license to prescribe or direct drugs or appliances for pay, and a physician on the premises for laser use.	Miss. Code Ann. § 73-25-33(1) Sep 8, 2026
Missouri	The cited rules do not settle this — none require a med spa to name a medical director. They only limit Class E estheticians to surface cosmetic work and require medical practice to be by a licensed physician or delegated under a collaborative arrangement.	Mo. Rev. Stat. §329.010(5)(d) Sep 3, 2026
Montana	No — the only "medical director" in Montana's medical practice chapter and Board of Medical Examiners rules is the physician or PA overseeing emergency care providers; nothing there requires a med spa or other office practice to name one.	Mont. Admin. R. 24.156.403(1)(h) (Title 37, ch. 3 and ARM Title 24, ch. 156 surveyed) Sep 8, 2026
Nebraska	The cited rules do not settle this — they only define delegating as transferring the authority, responsibility, and accountability for nursing interventions, and let an RN delegate them; no cited rule requires a med spa to have a medical director.	Neb. Rev. Stat. §38-2205 (“Delegating” defined) Sep 3, 2026
Nevada	Not as a titled role — chapter 630 has no "medical director" designation, but supervision duties apply: a named supervising physician for PAs, adequate medical-assistant supervision, and readily available supervision for nonablative esthetic procedures.	Nev. Rev. Stat. ch. 630 (Physicians and Physician Assistants — full chapter surveyed) Sep 3, 2026
New Hampshire	The cited rules do not settle this — none of them require a med spa to name a medical director, but a physician can be disciplined for allowing an unlicensed person to practice in their office, and unlicensed practice of medicine is itself unlawful.	N.H. Rev. Stat. §329:17, VI(e) Sep 3, 2026
New Jersey	The cited rules do not settle this — no med spa medical director role is named; they treat lasers as surgery and require a director, investing licensee, or other independent licensee on site during services, except mobile care like house calls.	N.J.A.C. 13:35-4A.3 Aug 17, 2026
New Mexico	Not directly — no "medical director" by name, but a facility where nurses perform aesthetic procedures must employ a clinical supervisor who is an APRN or other licensed independent practitioner qualified in all procedures offered; an RN or LPN may not serve.	16.12.14.8(B) NMAC (Nursing Practice in Aesthetic Healthcare Facilities, eff. 2024-05-21) Sep 4, 2026
New York	Not directly — the cited rules impose no medical director requirement and New York has no med spa license; they require only that injecting or prescribing a neuromodulator or filler, which is the practice of medicine, be done by a licensed practitioner.	N.Y. Educ. Law §6521 Aug 17, 2026
North Carolina	Not directly — no cited rule creates a "medical director" title; but laser work that destroys, incises or structurally alters tissue is surgery, performed by a physician or a licensed professional with appropriate medical training under physician supervision.	NCMB Position Statement 5.1.2 (adopted July 1999, amended May 2021) Aug 17, 2026
North Dakota	The cited rules do not settle this — none requires a med spa to have a medical director; they only allow board rule to require certain advanced esthetic services be performed under the supervision or direction of a physician, PA, or advanced practice nurse.	N.D.C.C. § 43-17-02.1(1) (Physician assistant — scope of practice) Sep 5, 2026
Ohio	Not directly — Ohio imposes no med spa license and names no "medical director," but applying a light-based device is itself the practice of medicine, so a non-physician may only do it as the delegate of a supervising physician.	Ohio Admin. Code 4731-18-02(A) Sep 1, 2026
Oklahoma	The cited rules do not settle this — none mentions a medical director. What they do require is a supervising physician for any physician assistant, responsible for all orders and protocols, regular review of services and charts, and available for consultation.	Okla. Stat. tit. 59, § 519.6 (Supervision in all patient care settings) Sep 5, 2026
Oregon	The cited rules do not settle this — none of them requires a med spa to appoint a medical director; they only require a physician associate to hold a collaboration agreement signed by a physician, podiatric physician or employer before practicing.	Or. Rev. Stat. §677.510(2)(a) Sep 3, 2026
Pennsylvania	Not directly — no cited rule requires a titled medical director; a physician delegating a medical service must verify competency, judge risk patient-by-patient, explain it and take responsibility, but separately licensed staff may work within their own scope.	49 Pa. Code §18.402(a) Aug 17, 2026
Rhode Island	The cited rules do not settle this — none of them require a "medical director" title. They establish only that diagnosing, treating, or prescribing is the practice of medicine, and that practicing it without a license is a crime carrying fine or prison.	R.I. Gen. Laws §5-37-1(a)(22) Sep 3, 2026
South Carolina	The cited rules do not settle this — none names a medical director requirement; they establish only that medical acts must be delegated and supervised by a physician, and that a licensee who assists an unlicensed person to practice faces board discipline.	S.C. Code §40-47-110(B)(7) Sep 3, 2026
South Dakota	The cited rules do not settle this — none require a medical director; they only limit esthetics to noninvasive stratum corneum care, so anything past that is outside an esthetician's license, and a medical corporation's owners and officers must be physicians.	S.D. Codified Laws §36-15-2.2(1) Sep 3, 2026
Tennessee	Yes — a Tennessee med spa's registration application must name a medical director or supervising physician, give their Tennessee license number and primary practice address, and include their attestation accepting responsibility for the cosmetic services.	Tenn. Comp. R. & Regs. 0880-02-.24(1)(a)–(f) Sep 2, 2026
Texas	Cosmetic injections, dermal fillers and cosmetic laser use are medical acts a Texas physician may delegate to a qualified, properly trained person under supervision — with a written order that identifies the physician and sets patient-screening criteria.	Tex. Occ. Code §157.001 Jul 26, 2026
Utah	The cited rules do not settle this — they never use the term "medical director," but each nonablative cosmetic procedure needs a supervisor holding an unrestricted medicine or APRN license, whose name and license must be posted at the facility.	Utah Code § 58-1-506(1)(a)-(b) (Supervision of cosmetic medical procedures) Sep 4, 2026
Vermont	The cited rules do not settle this — they impose no med spa medical director requirement; they only make it unprofessional conduct for a licensed physician to delegate care to anyone not qualified by training, experience, education, or credentials.	Vt. Stat. tit. 26, §1354(a)(29) Sep 3, 2026
Virginia	The cited rules do not settle this — none of them require a medical director; they impose duties on the licensed practitioners inside, such as the physician who performs or supervises laser hair removal, and price an esthetics "Spas" premises license.	18 Va. Admin. Code § 85-20-91(A) Sep 2, 2026
Washington	Not directly — Washington's rules name no "medical director," but using a laser, IPL, radiofrequency or plasma device on skin is the practice of medicine, so a physician must authorize it and may delegate only under a written office protocol.	Wash. Admin. Code 246-919-605(1) and (2) Sep 2, 2026
West Virginia	The cited rules do not settle this — none require a med spa to name a medical director; they do require a corporation practicing medicine or performing medical acts through PAs to hold a board certificate of authorization with physician shareholders.	W. Va. Code § 30-27-3(a) (aesthetics is a CLOSED list of surface acts, and none of them break skin) Sep 7, 2026
Wisconsin	Not directly — Wisconsin has no med spa license and names no "medical director," but every delegated medical act needs a supervising physician who is competent to perform it and has reasonable evidence the person doing it is competent.	Wis. Admin. Code Med § 10.02(1) Sep 2, 2026
Wyoming	The cited rules do not settle this — no cited rule requires a medical director; they establish only that treating any condition is practicing medicine, so a licensed practitioner must do it and licensees risk discipline for aiding unlicensed practice.	Wyo. Stat. Ann. §33-26-102(a)(xi)(A)-(B) Sep 3, 2026

Does a med spa in each state need a medical director

Every state, in its own words

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

Which states this covers

Solo-State — your state, watched.

Get regulatory changes as they publish