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. Monitoring and reference, not legal advice.

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 SITS OUTSIDE THAT ROUTE ENTIRELY: it is separately licensed under the Health & Safety Code, on a tiered certificate.

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 is separately licensed in Texas and sits OUTSIDE the medical-delegation route above. 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.
Tex. Health & Safety Code §401.504 · verified Aug 17, 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
⚠️ 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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