Florida med spa & injectable regulations

Physician supervision & delegation

Florida regulates cosmetic procedures through the physician’s duty to supervise and to delegate only to qualified people — not a single “cosmetic procedures” statute.

• Delegating professional responsibilities to a person the physician knows (or should know) is not qualified by training, experience, or licensure is a disciplinable offense.

  Fla. Stat. §458.331(1)(w)

• Aiding, assisting, procuring, or advising an unlicensed person to practice medicine is a ground for discipline against the physician.

  Fla. Stat. §458.331(1)(f)

• Formal supervisory relationships, standing orders, and established protocols between a physician and nonphysician practitioners are governed by statute, which also limits how many offices a physician may supervise.

  Fla. Stat. §458.348

• A medical assistant may perform defined clinical tasks — including administering medications and giving injections — only under the direct supervision and responsibility of a physician.

  Fla. Stat. §458.3485

• When an office procedure rises to the level of surgery, it is classified by anesthesia level (Level I–III), and the physician is responsible for being appropriately qualified and for the personnel assisting.

  Fla. Admin. Code r. 64B8-9.009

Good-faith examination

Florida has no statute literally titled “good-faith exam.” The requirement is built from prescribing-practice and standard-of-care law.

• Because Botox and dermal fillers are prescription (legend) drugs, a valid physician evaluation supporting the treatment is required; prescribing or administering a legend drug other than in the course of the physician’s professional practice is a disciplinable offense.

  Fla. Stat. §458.331(1)(q)

• A remote (telehealth) evaluation must meet the same standard of care as an in-person visit; a telehealth provider who conducts a patient evaluation sufficient to diagnose and treat is not separately required to perform a prior in-person exam.

  Fla. Stat. §456.47(2)

Ownership & corporate practice of medicine

Florida has no strict corporate-practice-of-medicine ban. Non-physician ownership is instead gated by the Health Care Clinic Act.

• Unlike some states, Florida does not broadly prohibit non-physician ownership of a medical practice or med spa; ownership is governed by the Health Care Clinic Act rather than a corporate-practice-of-medicine prohibition.

  Fla. Stat. §400.990

• An entity that provides health-care services and bills for reimbursement is a “clinic” that must be licensed by AHCA to operate — each location licensed separately — unless it qualifies for an exemption.

  Fla. Stat. §400.991(1)(a)

• The exemptions that matter most for med spas are for an entity wholly owned by one or more physicians, or wholly owned by one or more licensed health care practitioners (with specified family members) — such an entity is exempt from clinic licensure.

  Fla. Stat. §400.9905(4)(f)–(g)

• Even an otherwise-exempt entity is still deemed a clinic and must be licensed in order to receive personal-injury-protection (PIP / no-fault motor-vehicle) reimbursement.

  Fla. Stat. §400.9905(4)

RN / NP scope for injectables

• A registered nurse may administer medications and treatments — including injectables — as prescribed or authorized by a duly licensed practitioner. RNs are not independent prescribers.

  Fla. Stat. §464.003

• An APRN performs authorized functions within the framework of an established protocol maintained on-site, unless the APRN is registered for autonomous practice.

  Fla. Stat. §464.012(3)

• APRN autonomous practice (without a supervising physician) is available only in primary care — family medicine, general pediatrics, and general internal medicine — which does not encompass cosmetic/aesthetic injectable practice.

  Fla. Stat. §464.0123

Med-spa registration & licensing

Med spas are regulated indirectly — through physician supervision/delegation law, the Nurse Practice Act, the Health Care Clinic Act, office-surgery rules, and prescribing law — not a bespoke registry.

• As of July 2026, Florida has no med-spa-specific registration or licensure law in effect. A 2025 bill (HB 625) that would have defined “medspa” and required posting the supervising physician’s information died in committee.

  Fla. HB 625 (2025) — died in committee

Advertising rules

• False, deceptive, or misleading advertising by a physician is a ground for discipline.

  Fla. Stat. §458.331(1)(d)

• Deceptive or unfair med-spa, injectable, or weight-loss marketing is also unlawful under Florida’s Deceptive and Unfair Trade Practices Act.

  Fla. Stat. §501.204(1)

Disciplinary landscape

• Practicing or attempting to practice medicine without a license in Florida is a third-degree felony.

  Fla. Stat. §458.327(1)(a)

• Physicians face Board of Medicine discipline across a broad set of statutory grounds, enforced by the Department of Health.

  Fla. Stat. §458.331

• Operating an unlicensed health care clinic carries AHCA administrative penalties — including fines up to $5,000 per violation and license denial, suspension, or revocation.

  Fla. Stat. §400.995