Does a med spa in Vermont need a medical director?

Short answer
The cited rules do not settle this — they impose no med spa medical director requirement; they only make it unprofessional conduct for a licensed physician to delegate care to anyone not qualified by training, experience, education, or credentials.

Vermont names the delegation failure directly: handing health care services to someone the licensee knows, or has reason to know, is not qualified by training, experience, education or licensing credentials is unprofessional conduct. Practicing medicine with a physician who is not legally practicing in the State, or aiding such a physician, is a separate ground. The cosmetology chapter draws the esthetics line from both directions: esthetics MEANS skin-care services to enhance or improve the appearance of the skin — cleansing, toning, stimulating, manipulating, beautifying, exfoliating or similar procedures using only cosmetic preparations, hands, mechanical or electrical apparatus, tonics, lotions, creams or makeup, plus lash and brow work and manual or mechanical hair removal — and esthetics does not include any practice that constitutes the practice of medicine, including injections of any substance and the use of lasers.