Does a med spa in New York need a medical director?

Short answer
Not directly — the cited rules impose no medical director requirement and New York has no med spa license; they require only that injecting or prescribing a neuromodulator or filler, which is the practice of medicine, be done by a licensed practitioner.

New York reaches cosmetic procedures through the definition of the practice of medicine, plus the physician’s own duties not to delegate to the unqualified and not to permit unlicensed practice. On 7 March 2025 the State Board for Medicine determined that using an energy device which affects the basement membrane or deeper tissue is the practice of medicine — grading devices by depth. The Education Department adopted that determination for every physical condition except laser hair removal, on which it has not acted. Inside it, only a licensed practitioner or a registered professional nurse under a physician’s general supervision may carry out the treatment.