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

Oversight · part of The Practice Perimeter

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.

Drawn from 8 verified rules in this section · regulatory monitoring, not legal advice

The rest of what District of Columbia says on this

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

  • The practice of medicine includes offering or performing any type of invasive procedure of the body, whether through a body opening or a cutting of the skin, or otherwise affecting the layer of skin below the stratum corneum, for surgical, therapeutic, or cosmetic purposes, excluding procedures known as body tattooing or body piercing.

    D.C. Code §3-1201.02(7)(A)(iv) · verified Sep 3, 2026

  • Nothing in this paragraph shall be construed as preventing or restricting other health professionals from offering or undertaking any type of invasive procedure of the body, whether through a body opening or a cutting of the skin, or otherwise affecting the layer of skin below the stratum corneum, for surgical, therapeutic, or cosmetic purposes, if the procedure has been authorized by a licensed physician; or is performed by an advanced practice registered nurse, an anesthesiologist assistant, a dentist, a physician assistant, a podiatrist, a practical nurse, a registered nurse, or a surgical assistant who has received the necessary training and experience to perform the procedure in a safe and effective manner.

    D.C. Code §3-1201.02(7)(B) · verified Sep 3, 2026

  • Esthetics – the application of creams, lotions, scrubs, polishes, waxes, cosmetics, eyelashes, and other beauty treatments directly onto the skin to bring about a temporary improvement in appearance, excluding peels and microdermabrasion; and the removal of superfluous hair from the face and neck area of any person by the use of depilatories, waxing or tweezers. Master esthetics - esthetics and more specialized skincare treatments, including microdermabrasion, resurfacing, and chemical peel.

    17 DCMR § 3799.1 (Definitions — “Esthetics”; “Master esthetics”) · verified Sep 7, 2026

  • Licensees are prohibited from performing procedures using cosmetic exfoliating substances or devices that affect more than the top layer of the epidermis or outer-most layer of dead cells. A cosmetic exfoliation substance or device is not intended to remove viable (living) skin below the stratum corneum. Use of such substances and devices are deemed beyond the scope of practice of persons and establishments licensed by the Board. Licensees shall be permitted to use devices registered or approved by the U.S. Food and Drug Administration that are intended to be used for cosmetic skin care purposes, including, but not limited to, beautifying and improving the appearance of the skin.

    17 DCMR § 3729.2-.3 (Facial Procedures, Devices, and Equipment) · verified Sep 7, 2026

  • The practice of basic esthetics is limited to listed skin care procedures done for cosmetic purposes and not for the treatment of medical, physical, or mental ailments, and its hair-removal component is limited to removing superfluous hair by means other than electrolysis, laser procedures, or intense pulsed light.

    17 DCMR § 3799.1 (Definitions — “Practice of basic esthetics”) · verified Sep 8, 2026

  • The practice of medical assistants means performing assistance with minor medical practices that, other than the administration of vaccines or other injections, do not involve any subcutaneous procedure.

    D.C. Code §3-1201.02(6D) · verified Sep 8, 2026

  • The practice of medical assistants occurs only under the direct supervision of a physician, physician assistant, or advance practice registered nurse.

    D.C. Code §3-1201.02(6D) · verified Sep 8, 2026

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← All District of Columbia 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).