Does a med spa in Oregon need a medical director?

Short answer
The cited rules do not settle this — none of them requires a med spa to appoint a medical director; they only require a physician associate to hold a collaboration agreement signed by a physician, podiatric physician or employer before practicing.

Oregon does not let a physician associate practice on an informal understanding: a written collaboration agreement signed by a physician, podiatric physician or employer is a precondition of practicing at all, and the degree of collaboration is set at the associate’s primary location of practice by reference to the patient’s condition, the standard of care and the associate’s own education, experience and competence. The cosmetology chapter draws its own line inside the definition of esthetics: the listed skin and facial care practices — cleansing, stimulating, manipulating, exfoliating and applying lotions or creams with the hands or apparatuses, temporary hair removal including dermaplaning, makeup artistry, eyebrow and eyelash services, and facial and body treatments — count as esthetics only when performed to keep the skin healthy and attractive and NOT for medical diagnosis or treatment of disease or physical or mental ailments. The Board’s device rules then answer the microneedling question by DEPTH rather than by name: an esthetician is limited to mechanical or electric apparatuses, appliances or devices that do not penetrate beyond the epidermis except through natural physiological effects, and the devices an esthetician may use expressly include those used for nanoneedling, microneedling and similar procedures — within that limit. The epidermis is the outermost layer only; an esthetician is presumed to be working below it on exfoliating or removing skin below the epidermal layer or destroying or damaging the dermis or muscle; an esthetic device is not a laser, intense pulsed light or a needle-free filler injector; and an esthetician may not use any device for medical diagnosis or treatment of disease or physical or mental ailments.