Rhode Island medical director requirements for med spas

Physician supervision & delegation in Rhode Island

Rhode Island’s practice-of-medicine definition reaches HOLDING OUT as well as doing: a person is regarded as practicing medicine who holds themself out as able to diagnose, treat, operate or prescribe for anyone ill or alleged to be ill, or who professes to heal or undertakes by ANY MEANS OR METHOD to do those things — and attaching M.D., D.O. or a similar abbreviation indicating engagement in treatment or diagnosis is itself practicing medicine. The delegation ground is stated as unprofessional conduct: practicing medicine with an unlicensed physician, except in an accredited preceptorship or residency training program, OR AIDING OR ABETTING UNLICENSED PERSONS IN THE PRACTICE OF MEDICINE. On the cosmetology side, esthetics is defined as cleansing, stimulating, manipulating and beautifying skin, including the treatment of skin problems such as dehydration, temporary capillary dilation, excessive oiliness and clogged pores.

• “Practice of medicine” includes the practice of allopathic and osteopathic medicine. Any person is regarded as practicing medicine within the meaning of this chapter who holds themself out as being able to diagnose, treat, operate, or prescribe for any person ill or alleged to be ill with disease, pain, injury, deformity, or abnormal physical or mental condition, or who either professes to heal, offer, or undertake, by any means or method, to diagnose, treat, operate, or prescribe for any person for disease, pain, injury, deformity, or physical or mental condition.

  R.I. Gen. Laws §5-37-1(a)(22) · verified Sep 3, 2026

• Unprofessional conduct includes practicing medicine with an unlicensed physician except in an accredited preceptorship or residency training program, or aiding or abetting unlicensed persons in the practice of medicine.

  R.I. Gen. Laws §5-37-5.1(15) · verified Sep 3, 2026

• One who attaches the title, M.D., physician, surgeon, D.O., osteopathic physician, and surgeon, or any other similar word or words or abbreviation to their name indicating that they are engaged in the treatment or diagnosis of the diseases, injuries, or conditions of persons, shall be held to be engaged in the practice of medicine.

  R.I. Gen. Laws §5-37-1(a)(22) · verified Sep 3, 2026

• “Esthetics” means the practice of cleansing, stimulating, manipulating, and beautifying skin, including, but not limited to, the treatment of such skin problems as dehydration, temporary capillary dilation, excessive oiliness, and clogged pores.

  R.I. Gen. Laws §5-10-1(8) · verified Sep 3, 2026

• “Esthetician” means a person who engages in the practice of esthetics, and is licensed as an esthetician.

  R.I. Gen. Laws §5-10-1(6) · verified Sep 3, 2026

• ⛔ RHODE ISLAND PUTS THE LASER INSIDE THE DEFINITION OF PRACTICING MEDICINE, SO OPERATING ONE IS NOT A COSMETOLOGY QUESTION. “Any person shall be regarded as practicing medicine within the meaning of the Act who holds himself or herself out as being able to diagnose, treat, perform surgery, use a laser/intense pulsed light, or prescribe for any person for disease, pain, injury, deformity or physical or mental condition”. And the same Part closes the obvious escape hatch in one sentence: “Non-ablative treatment is part of the practice of medicine.” “Non-ablative treatment” is defined to mean “any laser/intense pulsed light treatment or other energy source, chemical, or modality that is not expected or intended to remove, burn, or vaporize tissue”, and — the sentence a med spa needs — “This shall include treatments related to laser hair removal.” So both halves of the device menu, ablative and non-ablative, sit inside the practice of medicine.

  216-RICR-40-05-1 § 1.2(A)(18), (22) (Licensure and Discipline of Physicians — “Non-ablative treatment” and “Practice of medicine” defined) · verified Sep 8, 2026

• AND THE SAME DEFINITIONS SEPARATE THE DEVICE FROM THE SYRINGE, EXPLICITLY. “Surgery” is “the diagnostic or therapeutic treatment of conditions or disease processes by any instruments causing localized alteration or transposition of human tissue which include lasers, ultra-sound, ionizing radiation, scalpels, probes, and needles”, and the rule says in terms that “All of these surgical procedures are invasive, including those that are performed with lasers, and the risks of any surgical procedure are not eliminated by using a light knife or laser in place of a metal knife, or scalpel.” ⛔ FOUR COSMETIC INJECTIONS ARE THEN CARVED OUT BY NAME: “Notwithstanding the above, the following injection procedures are not considered surgery: FDA-approved Botulinum toxin type A (BoNT-A) products for cosmetic purposes, FDA-approved dermal filler for cosmetic purposes, Platelet-Rich Fibrin for cosmetic purposes, and Platelet-Rich Plasma for cosmetic purposes.” The carve-out is from SURGERY, not from the practice of medicine — it removes the surgical characterization from those four injections and says nothing about who may perform them.

  216-RICR-40-05-1 § 1.2(A)(24) (Licensure and Discipline of Physicians — “Surgery” defined) · verified Sep 8, 2026

Recent Rhode Island changes

• RI H7721: Establishes the Rhode Island Ban on the Corporate Practice of Medicine Act.Feb 12, 2026
• RI H5351: Mandates cosmetic medical procedures be performed by a physician, PA, APRN, or delegated to a qualified non-physician, non-PA or non-APRN under the supervision of a physician, physician assistant, or advanced practice registered nurse.Jun 30, 2025
• RI S2870: Provides that the performance of cosmetic medical services is the practice of medicine and surgery.Mar 22, 2024