Colorado medical director requirements for med spas

Physician supervision & delegation in Colorado

Colorado permits delegation to UNLICENSED people who are “qualified by experience, education, or training” under a physician’s personal and responsible direction — but carves prescribing out of it entirely, and shuts the door on an unlicensed physician using the exemption as a side entrance.

• The “practice of medicine” reaches energy devices without naming them: it means holding out as able to diagnose, treat, prescribe for, palliate, or prevent any human disease, ailment, pain, injury, deformity or physical condition — “whether by the use of drugs, surgery, manipulation, electricity, telemedicine, the interpretation of tests … or any physical, mechanical, or other means whatsoever.” Colorado wrote a catch-all rather than a device list, so a modality invented after 2019 is inside it by construction.

  Colo. Rev. Stat. § 12-240-107(1)(a) · verified Sep 2, 2026

• ⚠️ the delegation exemption, and its three limits. No license is required for “the rendering of services, other than the prescribing of drugs, by persons qualified by experience, education, or training, under the personal and responsible direction and supervision of a person licensed … to practice medicine.” Colorado will let an unlicensed person perform a medical service — but never prescribe, never without demonstrable qualification, and never at arm’s length.

  Colo. Rev. Stat. § 12-240-107(3)(l) · verified Sep 2, 2026

• Licensees are prohibited from performing a service and/or using an implement, device, product, machine, tool, or technique, or combination of the same that: a. Penetrates, destroys or alters the clients skin beyond the epidermis; b. Is banned or deemed unsafe by local, state or federal governmental agencies responsible for making such determinations: or, c. Has a reasonable likelihood of causing harm or injury to the client.

  4 Colo. Code Regs. § 731-1, Rule 1.8(A)(1) · verified Aug 31, 2026

• ⚠️ and the same sentence closes two loopholes. “nothing in this exemption shall be deemed to extend or limit the scope of any license” — delegation cannot enlarge what a nurse or esthetician may already do. And the exemption “shall not apply to persons otherwise qualified to practice medicine but not licensed to practice in this state” — a physician unlicensed in Colorado cannot work as somebody’s delegate.

  Colo. Rev. Stat. § 12-240-107(3)(l) · verified Sep 2, 2026

• Nurses have their own exemption on a different footing: no medical license is required for “the rendering of NURSING or midwifery services and delegated medical functions by registered or other nurses … in the lawful discharge of their duties.” A nurse is not relying on the qualified-person exemption above; the statute names delegated medical functions as part of lawful nursing.

  Colo. Rev. Stat. § 12-240-107(3)(j) · verified Sep 2, 2026

• The Nurse Practice Act matches it from the other side. Professional nursing includes “providing therapy and treatment that is supportive and restorative to life and well-being either directly to the patient or indirectly through consultation with, delegation to, supervision of, or teaching of others”, and separately “executing delegated medical functions and delegated patient care functions.” a Colorado RN may both receive a delegated medical function and delegate onward.

  Colo. Rev. Stat. § 12-255-104(10)(b)(III)–(IV) · verified Sep 2, 2026

• Aiding or abetting the practice of medicine by any unlicensed person — or by a person whose license is suspended — is unprofessional conduct in its own right. It is the provision that reaches the supervising physician when the delegation limits above are not met.

  Colo. Rev. Stat. § 12-240-121(1)(f) · verified Sep 2, 2026

Recent Colorado changes

• CO HB1024: Medical-Aesthetic Services Delegation DisclosuresApr 7, 2025