Maine medical director requirements for med spas

Physician supervision & delegation in Maine

Maine’s physician delegation statute permits trained employees or support staff to carry out activities that do not themselves require licensure under the physician’s control, with the physician responsible for safe, competent performance. RN and PA practice is governed separately. Under §3270-G(5), PAs below 4,000 documented clinical hours need a collaborative agreement or the specified physician-group or facility credentialing, privileges and scope agreement system; submission of 4,000 documented hours ends subsection 5’s requirements. LD2088 repealed subsection 6’s experienced-PA practice agreement requirement effective April 3, 2026. Chapter 15, effective July 14, 2026, does not expand scope. It prohibits delegating examination, nursing assessment, diagnosis, prescribing or medication administration to unlicensed personnel. Only physicians, PAs and APRNs with prescriptive authority may evaluate, diagnose and prescribe; a medical-director title alone does not establish the required patient relationship. Aesthetics licensure excludes diagnosis, treatment or therapy of dermatological conditions.

• The practice of aesthetics under this subsection does not include the diagnosis, treatment or therapy of any dermatological condition.

  32 M.R.S. §14202(7) · verified Sep 3, 2026

• This chapter may not be construed as prohibiting a physician or surgeon from delegating to the physician’s or surgeon’s employees or support staff certain activities relating to medical care and treatment carried out by custom and usage when the activities are under the control of the physician or surgeon; the activities being delegated do not, unless otherwise provided by law, require a license, registration or certification to perform; the physician or surgeon ensures that the employees or support staff have the appropriate training, education and experience to perform these delegated activities; and the physician or surgeon ensures that the employees or support staff perform these delegated activities competently and safely.

  32 M.R.S. §3270-A · verified Sep 3, 2026

• The physician delegating these activities to employees or support staff, to program graduates or to participants in an approved training program is legally liable for the activities of those individuals, and any individual in this relationship is considered the physician’s agent.

  32 M.R.S. §3270-A · verified Sep 3, 2026

• This section may not be construed to apply to registered nurses acting pursuant to chapter 31 and licensed physician associates acting pursuant to this chapter and chapter 36.

  32 M.R.S. §3270-A · verified Sep 3, 2026

• A physician associate with less than 4,000 hours of clinical practice documented to the board shall work in accordance with a collaborative agreement with an active physician that describes the physician associate’s scope of practice, except that a physician associate working in a physician group practice setting or a health care facility setting under a system of credentialing and granting of privileges and scope of practice agreement may use that system in lieu of a collaborative agreement.

  32 M.R.S. §3270-G(5) · verified Oct 23, 2026

• The collaborative agreement, or, if appropriate, the scope of practice agreement, must be submitted to the board for approval and the agreement must be kept on file at the main location of the place of practice and be made available to the board or the board’s representative upon request. Upon submission to the board of documentation of 4,000 hours of clinical practice, a physician associate is no longer subject to the requirements of this subsection.

  32 M.R.S. §3270-G(5) · verified Oct 23, 2026

• Effective April 3, 2026, PL 2025, c. 604, §8 repealed 32 M.R.S. §3270-G(6), the practice agreement requirement.

  32 M.R.S. §3270-G(5)–(6); PL 2025, c. 604, §8 (practice agreement repeal) · verified Oct 23, 2026

• The practice of nursing includes the delegation of specific nursing activities and tasks to be provided by unlicensed assistive personnel, and unlicensed assistive personnel means individuals trained to function in a supportive role, regardless of job title, to whom a specific nursing activity or task may be delegated; the paragraph may not be construed to require a nurse to delegate, or to permit a person to coerce a nurse into delegating, against the nurse's professional judgment.

  32 M.R.S. §2102(2)(H), (11) · verified Sep 8, 2026

• Under Chapter 15, effective July 14, 2026, designation as a medical director, or participation as an owner, co-owner, investor or associate, is insufficient to establish the valid licensee-patient relationship required before prescription and administration of drugs, including IV therapies, aesthetic treatments and medications requiring prescriptions. Only physicians, physician associates and advanced practice registered nurses with prescriptive authority can evaluate, diagnose and prescribe treatment; that authority cannot be delegated to someone without prescriptive authority, including an RN.

  02-373 C.M.R. ch. 15 §1 (medical director and prescribing) · verified Oct 23, 2026

• A licensee delegating health care services to unlicensed personnel in a medical spa, IV therapy or medical aesthetic business must verify systems ensuring personnel are qualified, trained and authorized, and remain available in person or electronically for consultation. Under no circumstances may the licensee delegate examination, nursing assessment, diagnosis, prescription or administration of medications to unlicensed personnel. A course certificate of completion does not constitute a license. Chapter 15 does not expand any licensee’s scope or change the scope and process of delegation; applicable Board laws and rules still apply.

  02-373 C.M.R. ch. 15 §3 (unlicensed personnel and scope) · verified Oct 23, 2026

Recent Maine changes

• ME LD2201: An Act to Implement Certain Recommendations Related to the Regulatory Review and Approval of Certain Health Care Transactions Involving Private Equity Companies, Hedge Funds or Management Services Organizations from the Commission to Evaluate the Scope of Regulatory Review and Oversight over Health Care Transactions That Impact the Delivery of Health Care Services in the StateApr 8, 2026