Virginia medical director requirements for med spas

Physician supervision & delegation in Virginia

Virginia’s procedure-specific rule here is about LASER HAIR REMOVAL. It requires a named training curriculum including TEN PROCTORED CASES, lets the physician delegate to a properly trained person, and defines supervision as “readily available” rather than physically present — with one duty the physician cannot delegate at all.

• A doctor of medicine or osteopathic medicine may perform or supervise laser hair removal only on completing training in six named subjects: skin physiology and histology; skin type and appropriate patient selection; laser safety; operation of the laser device to be used; recognition of and response to potential complications; and A MINIMUM OF TEN PROCTORED PATIENT CASES with demonstrated competency in treating various skin types.

  18 Va. Admin. Code § 85-20-91(A) · verified Sep 2, 2026

• Doctors who were performing laser hair removal before 7 August 2019 are not required to complete that training. The rule grandfathers experience rather than requiring everyone to re-qualify — so the training file a practice holds may legitimately be empty for a long-serving physician and complete for a recent one.

  18 Va. Admin. Code § 85-20-91(B) · verified Sep 2, 2026

• ⚠️ DELEGATION TURNS ON WHO THE DELEGATE IS. A doctor who delegates laser hair removal and supervises a person OTHER THAN a licensed physician assistant or licensed nurse practitioner must ensure THAT PERSON has completed the same six-subject training, ten proctored cases included. Delegating to a PA or NP does not carry that requirement; delegating to anyone else does.

  18 Va. Admin. Code § 85-20-91(C) · verified Sep 2, 2026

• ⚠️ SUPERVISION MEANS READILY AVAILABLE, NOT PRESENT — WITH ONE THING THE DOCTOR MUST DO PERSONALLY. A doctor may delegate laser hair removal to a properly trained person under the doctor’s direction and supervision, which the rule defines as the doctor being READILY AVAILABLE at the time it is performed. The doctor is NOT required to be physically present, but IS required to SEE AND EVALUATE any patient whose treatment has resulted in complications BEFORE that patient’s treatment continues.

  18 Va. Admin. Code § 85-20-91(E) · verified Sep 2, 2026

• Competency is a continuing obligation on both sides. A doctor who performs laser hair removal or supervises others in it shall receive ongoing training as necessary to maintain competency in new techniques and laser devices, AND shall ensure that the persons the doctor supervises also receive ongoing training to maintain competency.

  18 Va. Admin. Code § 85-20-91(D) · verified Sep 2, 2026

• ⚠️ AND THE RULE STOPS AT HAIR REMOVAL. 18VAC85-20-91 governs the practice and supervision of LASER HAIR REMOVAL and nothing else. Virginia publishes no counterpart rule for cosmetic injectables, for intense pulsed light, or for other energy devices, so a practice cannot read the ten-case training standard or the “readily available” supervision definition across to those services.

  18 Va. Admin. Code § 85-20-91 (scope of the rule) · verified Sep 2, 2026

• ⚠️ VIRGINIA SETTLES THIS BY DEFINITION RATHER THAN BY NAMING THE PROCEDURE. “ESTHETICS IS NOT A HEALING ART AND SHALL NOT INCLUDE ANY PRACTICE, ACTIVITY, OR TREATMENT THAT CONSTITUTES THE PRACTICE OF MEDICINE, OSTEOPATHIC MEDICINE, OR CHIROPRACTIC.” The licensed acts are surface acts — “CLEANSING, TONING, PERFORMING EFFLEURAGE OR OTHER RELATED MOVEMENTS, STIMULATING, EXFOLIATING, OR PERFORMING ANY OTHER SIMILAR PROCEDURE ON THE SKIN” — and every device permitted is qualified as “ANY NONLASER DEVICE.” Microneedling is nowhere in the definition, so the question in Virginia is whether puncturing skin is the practice of medicine, not whether an esthetics license lists it.

  Va. Code § 54.1-700 (definition of “esthetics”) · verified Sep 2, 2026