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

Short answer
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.

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.