Does a med spa in Minnesota need a medical director?

The rest of what Minnesota says on this

Every other rule we have verified under med-spa registration & licensing, each linked to its primary source.

• ⚠️ SELLING A COMPOUNDED OR ANY OTHER LEGEND DRUG AT A MARK-UP CAN REQUIRE A FILING ALMOST NOBODY MAKES — BUT ONLY FOR ORAL DRUGS. A practitioner who “DISPENSES FOR PROFIT A LEGEND DRUG THAT IS TO BE ADMINISTERED ORALLY, is ordinarily dispensed by a pharmacist, and is not a vaccine” MUST FILE a statement with their licensing board, and “IT IS UNLAWFUL TO DISPENSE LEGEND DRUGS FOR PROFIT … UNLESS THE STATEMENT HAS BEEN FILED.” “Profit” is any amount above acquisition cost, plus the cost of making it available where the drug was compounded. ⚠️ INJECTABLE semaglutide falls OUTSIDE this filing duty; an ORAL compounded GLP-1 does not.

  Minn. Stat. § 151.37, subd. 2(c) · verified Sep 2, 2026

• And the bar on non-practitioners is flat: “ANY PERSON OTHER THAN A LICENSED PRACTITIONER WITH THE AUTHORITY TO PRESCRIBE, DISPENSE, AND ADMINISTER A LEGEND DRUG UNDER PARAGRAPH (a) SHALL NOT DISPENSE FOR PROFIT.” A med spa’s non-clinical owner or manager cannot be the one selling the drug, whatever the corporate arrangement above them.

  Minn. Stat. § 151.37, subd. 2(c) (final sentence) · verified Sep 2, 2026

• What Minnesota regulates instead is the ACT: a person is practicing medicine if they OFFER OR UNDERTAKE TO PRESCRIBE, GIVE, OR ADMINISTER ANY DRUG OR MEDICINE FOR THE USE OF ANOTHER, or offer or undertake to PREVENT OR TO DIAGNOSE, CORRECT, OR TREAT IN ANY MANNER OR BY ANY MEANS, METHODS, DEVICES, OR INSTRUMENTALITIES, any disease, illness, pain, wound, fracture, infirmity, deformity or defect. The breadth of “any means, methods, devices, or instrumentalities” is why no separate med spa category was needed.

  Minn. Stat. § 147.081, subd. 3(2)–(3) · verified Sep 2, 2026

• 💰 MINNESOTA PUBLISHES THE ACTUAL NUMBERS, AND THEY RUN ON A THREE-YEAR CYCLE. The statutory schedule sets “$350 INITIAL SALON LICENSE, DIVIDED AS FOLLOWS: (I) $250 FOR EACH INITIAL LICENSE; AND (II) $100 FOR EACH INITIAL LICENSE APPLICATION FEE” and “$195 INITIAL PRACTITIONER, MANAGER, OR INSTRUCTOR LICENSE”, with renewals at “$225 RENEWAL OF SALON LICENSE” and “$115 RENEWAL OF PRACTITIONER LICENSE”. These are cosmetology licenses — the medical side of a med spa is licensed separately and is not in this schedule.

  Minn. Stat. § 155A.25, subd. 1a(b) · verified Sep 2, 2026

• ⚠️ AND MINNESOTA PRICES THE MISTAKES IN THE SAME SECTION, WHICH IS WORTH READING BEFORE YOU OPEN. Penalties may be assessed up to “REINSPECTION FEE, $150”, “EXPIRED SALON FOUND ON INSPECTION, $500”, “PERFORMING NAIL OR COSMETOLOGY SERVICES IN ESTHETICIAN SALON, OR PERFORMING ESTHETICIAN OR COSMETOLOGY SERVICES IN A NAIL SALON, $500”, and “OWNER AND MANAGER ALLOWING AN OPERATOR TO WORK AS AN INDEPENDENT CONTRACTOR, $200”. The last one matters for the booth-rental model a lot of spas assume they can use.

  Minn. Stat. § 155A.25, subd. 1a(c) · verified Sep 2, 2026

• MINNESOTA ALSO WRITES IT AS A GROUND RATHER THAN AS A DUTY, AND IT REACHES CHARGES, NOT ONLY OUTCOMES: a “failure to report to the board that charges regarding the person’s license have been brought in another state or jurisdiction” is itself grounds for disciplinary action, alongside discipline actually imposed elsewhere and a refusal of licensure by another state.

  Minn. Stat. § 147.091 subd. 1(d) · verified Sep 8, 2026

How other states answer this

• Alabama
• Alaska
• Arizona
• Arkansas
• California
• Colorado
• Connecticut
• Delaware
• District of Columbia
• Florida
• Georgia
• Hawaii
• Idaho
• Illinois
• Indiana
• Iowa
• Kansas
• Kentucky
• Louisiana
• Maine
• Maryland
• Massachusetts
• Michigan
• Mississippi
• Missouri
• Montana
• Nebraska
• Nevada
• New Hampshire
• New Jersey
• New Mexico
• New York
• North Carolina
• North Dakota
• Ohio
• Oklahoma
• Oregon
• Pennsylvania
• Rhode Island
• South Carolina
• South Dakota
• Tennessee
• Texas
• Utah
• Vermont
• Virginia
• Washington
• West Virginia
• Wisconsin
• Wyoming

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