Does a med spa in Maryland need a medical director?

Oversight · part of The Practice Perimeter

Short answer
The cited rules do not settle this — no medical director title appears in them; they require only that a physician delegating a technical act to an assistant supervise that assistant, delegate only acts the assistant is trained for, and stay responsible.

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.

Related Maryland rules

  • 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

All 11 cited Maryland rules on physician supervision & delegation →

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← All Maryland rules and changes · MedSpaRadar is regulatory monitoring and reference: it summarizes public laws, regulations and agency actions and links each to its source. It is not legal, medical, or compliance advice, and using it creates no attorney-client relationship. A summary can lag its source or leave out detail, and monitoring itself can be interrupted — so an absence of alerts means nothing reached you, not that nothing happened. Read the cited source, check its effective date, and confirm any change to your operations or clinical practice with qualified health-law counsel and your medical director. Legislative data via LegiScan (CC BY 4.0).