Texas medical director requirements for med spas

Medical-director, supervision, and delegation requirements for aesthetic practices. Below are the Texas rules that govern it, each linked to its primary source.

Physician supervision & delegation in Texas

Cosmetic injections, dermal fillers and cosmetic laser use are medical acts a Texas physician may delegate to a qualified, properly trained person under supervision — with a written order that identifies the physician and sets patient-screening criteria. ⚠️ laser hair removal also has its own licensing route: the Health & Safety Code requires a tiered TDLR certificate to perform it — EXCEPT for a physician or a physician’s employee or delegate acting under the physician-delegation chapter, and for a health professional licensed under another law whose own licensing board places laser hair removal within that professional’s scope.

A Texas physician may delegate a medical act — including cosmetic injections, dermal fillers, and cosmetic laser use — to a qualified, properly trained person acting under the physician’s supervision, where a reasonable and prudent physician would find it consistent with sound medical judgment. The delegating physician remains responsible for the delegated act.
Tex. Occ. Code §157.001 · verified Jul 26, 2026
The Texas Medical Board classifies nonsurgical medical cosmetic procedures — including the injection of medications or substances for cosmetic purposes and the use of a prescription medical device for cosmetic purposes — as the practice of medicine that may be properly delegated and supervised.
22 TAC §169.25 · verified Jul 26, 2026 · read at Cornell Legal Information Institute
The delegating physician must review, approve, or develop a written order for the delegated procedure that identifies the physician, sets patient-screening criteria, describes appropriate care, and provides procedures for handling common complications.
22 TAC §169.27 · verified Jul 26, 2026 · read at Cornell Legal Information Institute
Laser hair removal has its own licensing route in Texas. No person may perform or attempt to perform laser hair removal — the use of a laser or pulsed light device for nonablative hair removal — unless they hold the appropriate certificate from the Texas Department of Licensing and Regulation. That certificate authorizes nonablative cosmetic laser hair removal ONLY: it does not authorize the holder to diagnose, treat, or offer to treat any illness, disease, injury, defect or deformity, and the holder must disclose that limitation in writing to every client and prospective client. The certificate requirement has two exceptions: it does not require a health professional licensed under another law to hold a certificate to perform laser hair removal if the performance of laser hair removal is within the scope of that professional's practice as determined by the professional's licensing board, and it does not apply to a physician or to a physician's employee or delegate acting under Chapter 157, Occupations Code.
Tex. Health & Safety Code §401.504 · verified Sep 30, 2026
The certificate is tiered. A laser hair removal technician certificate is the base rung; a senior laser hair removal technician must meet the technician requirements and have supervised at least 100 laser hair removal procedures, audited by a certified laser hair removal professional; and a certified laser hair removal professional must meet the senior technician requirements, hold certification from a department-recognized certifying agency, and pass a department examination. A certified professional performs laser hair removal under a protocol established with a consulting physician.
Tex. Health & Safety Code §401.505, §401.506 · verified Aug 17, 2026
TDLR's medspa services chart lists each service offered at a med spa alongside the agency that regulates it. The entry reads “Microneedling (Platelet-rich plasma (PRP) injections/Vampire facials) Texas Medical Board”, placing that service under the Texas Medical Board rather than under a TDLR license.
TDLR, MedSpas at a Glance, Service/Who Regulates chart (Microneedling) · verified Sep 20, 2026
⚠️ Texas draws the esthetician line at living tissue, and microneedling is a device that punctures it. tdlr states the test twice. On exfoliation: a treatment that “does not pierce the dermal layer of skin” is within scope, while treatments that “contact or penetrate the dermis (living tissue) DO not fall within the scope of an esthetician or cosmetology operator license and must be administered or delegated by a physician.” On peels, the same line: those that “penetrate the dermis (living tissue) and are considered medical procedures regulated by the Texas medical board.” tdlr’s guidance does not name microneedling — it states a depth test, and a needle depth is the operator’s setting.
TDLR Barbering and Cosmetology — Medical Spas guidance · verified Sep 2, 2026
And the scope description carries a parenthetical worth reading: an esthetician may “administer facial treatments, (please note that these treatments DO not include injectables, fillers and other types of medical-type procedures that require the use of needles).” TDLR’s express out-of-scope list names hypodermic needles used to inject; it does not address a needling device that injects nothing.
TDLR Barbering and Cosmetology — Medical Spas guidance · verified Sep 2, 2026
Beginning September 1, 2025, HB 3749 limits both the ordering and administration of elective IV hydration or vitamin infusions to physicians, advanced practice registered nurses, and registered nurses acting under a physician's delegation; licensed vocational nurses, emergency medical technicians, paramedics and unlicensed persons may not be delegated these services.
Texas BON Position Statement 15.3 (LVNs engaging in intravenous therapy — elective IV hydration after HB 3749) · verified Sep 8, 2026

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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.