Maryland medical director requirements for med spas

Physician supervision & delegation in Maryland

Maryland attaches its delegation duties to the licensed physician who actually delegates. That physician must evaluate the risk to the patient, delegate only technical acts customary to their own practice and for which the assistant has been trained, remain responsible for the act, and supervise it — and responsibility cannot be handed to another physician without that physician’s express consent. Maryland sets the required presence by tier rather than by one nonsurgical rule: patient preparation, history interviews, specimen collection, tuberculin skin tests, electrocardiography, prescription transmittal, oral drugs and microdermabrasion may be delegated without on-site supervision; injections and peripheral intravenous lines require on-site supervision; and a surgical technical act requires the delegating physician present, scrubbed and personally performing the surgery in the same surgical field. An act that is exclusively limited to a licensed, certified or registered occupation may not be delegated TO AN ASSISTANT — a limit on who may receive the act, not a bar on delegating it to someone whose own license covers it. The cosmetology statute answers the microneedling question in its own definition: “provide esthetic services” means cleansing, exercising, exfoliating, massaging, COSMETIC MICRONEEDLING, stimulating, toning or any similar procedure on the skin or scalp by electrical, mechanical or any other means, and includes superficial exfoliation of the epidermis and nonablative skin rejuvenation — but it does not include the diagnosis of illness, disease or injury, or performing ABLATION OF THE DERMIS OR HYPODERMIS; hair removal under that definition is by any means other than a laser light-based device.

• A licensed physician who delegates shall: (1) Evaluate the risk to the patient and the outcome of the delegated acts; (2) Delegate only those technical acts that are customary to the practice of the licensed physician; (3) Delegate only those technical acts for which the assistant has been trained; (4) Be responsible for the acts of the assistant; and (5) Supervise the assistant.

  Md. Code Regs. 10.32.12.03(A) (Standards for the Licensed Physician Delegating to an Assistant) · verified Sep 3, 2026

• With on-site supervision a licensed physician may delegate to an assistant the preparing and administering of injections limited to intradermal, subcutaneous, and intramuscular (deltoid, gluteal, vastus lateralis), to include small amounts of local anesthetics, and the establishing of a peripheral intravenous line. Microdermabrasion may be delegated without on-site supervision.

  Md. Code Regs. 10.32.12.04(D)(1)(j), (D)(2)(a)–(b) · verified Sep 8, 2026

• A licensed physician may not delegate to an assistant technical acts which are exclusively limited to any individual required to be licensed, certified, registered, or otherwise recognized pursuant to any provision of the Health Occupations Article and the Education Article.

  Md. Code Regs. 10.32.12.04(A) · verified Sep 3, 2026

• A licensed physician may delegate nonsurgical technical acts while the assistant is under the licensed physician’s direct supervision or on-site supervision if the assistant performs the act in accordance with procedures of the site.

  Md. Code Regs. 10.32.12.04(B)(2) · verified Sep 3, 2026

• The responsibility for the delegated act cannot be transferred from the delegating physician to another licensed physician without the expressed consent of the other physician and informing the assistant.

  Md. Code Regs. 10.32.12.03(B) · verified Sep 3, 2026

• To the extent permitted by the rules, regulations, and orders of the Board, an individual to whom duties are delegated by a licensed physician or physician assistant may perform those duties without a license. The individuals to whom duties may be delegated include any individual authorized to practice any other health occupation regulated under this article.

  Md. Code, Health Occ. §14-306(a)-(b) · verified Sep 3, 2026

• “Provide esthetic services” means to provide to an individual, for compensation, the service of: (i) cleansing, exercising, exfoliating, massaging, cosmetic microneedling, stimulating, toning, or performing any other similar procedure on the skin or scalp by electrical, mechanical, or any other means; “Provide esthetic services” does not include: (i) the diagnosis of illness, disease, or injury; or (ii) performing ablation of the dermis or hypodermis.

  Md. Code, Bus. Occ. & Prof. §5-101(o)(1)(i), (3) (“Provide esthetic services” — cosmetic microneedling included; ablation of the dermis excluded) · verified Sep 7, 2026

• “Provide esthetic services” includes: (i) applying eyelash extensions; (ii) performing superficial exfoliation treatments of the epidermis using professional and other commercially available products or devices; (iii) performing treatments for the relaxation, hydration, contouring, and beautification of the face, skin, body, eyelashes, or eyebrows; and (iv) performing nonablative skin rejuvenation.

  Md. Code, Bus. Occ. & Prof. §5-101(o)(2) · verified Sep 7, 2026

• Providing esthetic services includes removing superfluous hair by the use of electrical, mechanical, or any means other than by the use of a laser light–based device.

  Md. Code, Bus. Occ. & Prof. §5-101(o)(1)(iii) · verified Sep 7, 2026

• Assistant means an individual to whom only routine technical acts are delegated by a licensed physician and who is either trained as the chapter defines and not certified, registered, or licensed by the Board or any other State health occupation board, or is so credentialed but is not acting under the authority of that credential.

  Md. Code Regs. 10.32.12.02(B)(1) (Definitions — “Assistant”) · verified Sep 8, 2026

• Maryland sets the required physical presence by tier rather than by procedure. Patient preparation, history interviews, specimen collection, tuberculin skin tests, electrocardiography, transmitting prescriptions to a pharmacy, preparing and administering oral drugs and microdermabrasion may be delegated without on-site supervision. Injections and peripheral intravenous lines require on-site supervision. Surgical technical acts require the delegating physician to be present, scrubbed and personally performing the surgery in the same surgical field.

  Md. Code Regs. 10.32.12.04(B)(1), (D)(1), (D)(2) · verified Sep 8, 2026