California medical director requirements for med spas
Medical-director, supervision, and delegation requirements for aesthetic practices. Below are the California rules that govern it, each linked to its primary source. Monitoring and reference, not legal advice.
Physician supervision & delegation in California
In California, using prescriptive drugs (Botox, fillers) and prescriptive/energy devices (lasers, IPL) for cosmetic reasons IS the practice of medicine.
A physician may delegate injectable and laser procedures only to appropriately licensed personnel — registered nurses, nurse practitioners, or physician assistants — under genuine supervision. Unlicensed staff (including medical assistants) and improperly licensed staff (estheticians, cosmetologists, LVNs) may not perform them, regardless of training. A “paper” medical-director arrangement is aiding and abetting the unlicensed practice of medicine.
Cal. Bus. & Prof. Code §2052; Medical Board of California — Medical Spas guidance · verified Jul 26, 2026
For an elective cosmetic laser or IPL procedure performed by a licensed provider, a trained physician must be “immediately available” — reachable without delay and able to direct throughout the procedure.
Cal. Code Regs. tit. 16, §1364.50 · verified Jul 26, 2026
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