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Does a med spa in Alaska need a medical director?

Oversight · part of The Practice Perimeter

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.

Drawn from 16 verified rules in this section · regulatory monitoring, not legal advice

The rest of what Alaska says on this

Every other rule we have verified under physician supervision & delegation, each linked to its primary source.

  • the duty to be delegated must be within the scope of practice of the delegating physician, podiatrist, osteopath, or physician assistant; (2) a licensed physician, podiatrist, osteopath, or physician assistant must assess the patient's medical condition and needs to determine if a duty for that patient may be safely delegated; (3) the patient's medical condition must be stable and predictable;

    12 AAC 40.920(a)(1)-(3) (Standards for delegation of routine duties) · verified Sep 5, 2026

  • the person to whom the duty is to be delegated has received the training needed to safely perform the delegated duty, and this training has been documented;

    12 AAC 40.920(a)(4)-(6) (Standards for delegation of routine duties) · verified Sep 5, 2026

  • performance of the delegated duty would not require the person to whom it is delegated to exercise professional medical judgment or have knowledge of complex medical skills;

    12 AAC 40.920(a)(6) (Standards for delegation of routine duties) · verified Sep 5, 2026

  • written instructions that include (A) a clear description of the procedure to follow to perform each task in the delegated duty; (B) the predicted outcomes of the delegated task; (C) procedures for observing, reporting, and responding to side effects, complications, or unexpected outcomes in the patient; and (D) the procedure to document the performance of the duty in the patient's record.

    12 AAC 40.920(a)(7) (Written instructions for a delegated duty) · verified Sep 5, 2026

  • shall provide appropriate direction and supervision of the person, including the evaluation of patient outcomes.

    12 AAC 40.920(b) (Direction, supervision and availability) · verified Sep 5, 2026

  • shall remain readily available for consultation by the person to whom the duty is delegated, either in person or by telecommunication.

    12 AAC 40.920(b) (Availability for consultation) · verified Sep 5, 2026

  • The delegation of a routine duty to another person under this section is specific to that person and for that patient, and does not authorize any other person to perform the delegated duty.

    12 AAC 40.920(c) (Delegation is specific to person and patient) · verified Sep 5, 2026

  • remains responsible for the quality of the medical care provided to the patient.

    12 AAC 40.920(d) (Delegating clinician remains responsible) · verified Sep 5, 2026

  • require that a physician, podiatrist, osteopath, or physician assistant may not delegate duties related to pain management and opioid use and addiction;

    AS 08.64.106(2) (Delegation of routine medical duties) · verified Sep 5, 2026

  • intentionally or negligently permitted the performance of patient care by persons under the licensee's supervision that does not conform to minimum professional standards even if the patient was not injured;

    AS 08.64.326(a)(6) (Liability for care by supervised persons) · verified Sep 5, 2026

  • The collaborative relationship must be documented by a collaborative plan on a form provided by the board and must include (1) the name, license number, and specialty, if any, for the primary supervising physician and at least one alternate collaborating physician;

    12 AAC 40.410(a) (What the collaborative plan must record) · verified Sep 5, 2026

  • For the purposes of AS 08.13.220 (5), (1) "appliances" in the field of esthetics means only those devices used to stimulate natural physiological processes intended to improve the health and appearance of a person's skin; a device (A) operates within the manufacturer's guidelines; (B) does not directly ablate or destroy live tissue; (C) does not involve an incision into skin beyond the epidermis;

    12 AAC 09.990(b)(1)(A)-(C) (Definitions — “appliances” in the field of esthetics) · verified Sep 7, 2026

  • An appliance in the field of esthetics also (D) is not defined as a Class III or Class IV laser device under 21 C.F.R. 1040.10, revised as of April 2, 2018, and adopted by reference;

    12 AAC 09.990(b)(1)(D) (Definitions — no Class III or IV laser) · verified Sep 7, 2026

  • A registered, advanced practice registered, or practical nurse licensed under the chapter may delegate nursing duties to other persons, including unlicensed assistive personnel, under regulations adopted by the board; and a person to whom the nursing duties are delegated may perform the delegated duties without a license or certificate under the chapter if the person meets the applicable requirements established by the board.

    AS 08.68.805 (Delegation of nursing functions) · verified Sep 8, 2026

  • ⛔ THE ONE INJECTION ALASKA LETS A CLINICIAN DELEGATE IS NARROW AND CARRIES THREE CONDITIONS AT ONCE. Administering injectable medications sits on the non-delegable list “unless (A) it is a single intramuscular, intradermal, or subcutaneous injection, not otherwise prohibited under 12 AAC 40.967 (33); and (B) all other provisions of this section are met; and (C) the delegating physician, podiatrist, osteopath, or physician assistant is immediately available on site.”

    12 AAC 40.920(f)(14) (injectable medications — the delegation carve-out) · verified Sep 8, 2026

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← All Alaska rules and changes · MedSpaRadar is regulatory monitoring and reference, not legal, medical, or compliance advice. Verify against the linked primary source and consult qualified counsel before acting — rules change and turn on your specific facts. Legislative data via LegiScan (CC BY 4.0).