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Does a med spa in Washington need a medical director?

Oversight · part of The Practice Perimeter

Short answer
Not directly — Washington's rules name no "medical director," but using a laser, IPL, radiofrequency or plasma device on skin is the practice of medicine, so a physician must authorize it and may delegate only under a written office protocol.

Washington answers the supervision question twice, because it has two rules and they disagree on purpose. For a delegated llrp device — a laser, noncoherent light, IPL, radiofrequency or plasma device that topically penetrates and alters tissue — the physician must be on the premises for the patient’s first treatment. For a cosmetic INJECTION it turns on the label: on-site for the whole procedure if the substance is used off-label, and merely reachable within thirty minutes if it is FDA-approved for that use.

Drawn from 10 verified rules in this section · regulatory monitoring, not legal advice

Related Washington rules

  • Using a laser, noncoherent light, intense pulsed light, radiofrequency or plasma device that topically penetrates skin and alters human tissue — an “LLRP device”, and one the FDA classifies as a prescription device — is the practice of medicine under RCW 18.71.011. Washington settles the threshold question in the rule itself rather than leaving it to be argued.

    Wash. Admin. Code 246-919-605(1) and (2) · verified Sep 2, 2026

  • ⚠️ and any other energy device that penetrates tissue is surgery. Use of a medical device using any form of energy to penetrate or alter human tissue for a purpose other than the topical one defined above constitutes SURGERY and is outside this rule entirely — which means outside everything the rule permits a physician to delegate.

    Wash. Admin. Code 246-919-605(3) · verified Sep 2, 2026

All 10 cited Washington rules on physician supervision & delegation →

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← All Washington rules and changes · 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. Legislative data via LegiScan (CC BY 4.0).