Wisconsin medical director requirements for med spas

Physician supervision & delegation in Wisconsin

Wisconsin works from both ends. The medical board defines ADEQUATE SUPERVISION as a two-sided competence test — the physician must be competent to do the delegated act, and must have reasonable evidence the delegate is minimally competent to do it — and failing to supervise adequately is unprofessional conduct, expressly including delegation to UNLICENSED personnel. The cosmetology board comes at it from the other side and names procedures: microneedling is listed as a DELEGATED MEDICAL PROCEDURE, alongside a catch-all for any treatment reaching below the stratum corneum, so an esthetician may perform it only under a physician’s direction.

• “Adequate supervision” is defined as a TWO-SIDED COMPETENCE TEST: a physician SHOULD BE COMPETENT TO PERFORM THE DELEGATED MEDICAL ACT, and MUST HAVE REASONABLE EVIDENCE THAT THE SUPERVISED INDIVIDUAL IS MINIMALLY COMPETENT to perform the act under the circumstances. Both halves have to hold — a competent delegate supervised by a physician who could not do the procedure themselves does not satisfy it.

  Wis. Admin. Code Med § 10.02(1) · verified Sep 2, 2026

• ⚠️ AND FAILING IT IS UNPROFESSIONAL CONDUCT BY NAME. “Failure to adequately supervise delegated medical acts performed by LICENSED OR UNLICENSED PERSONNEL” is listed as unprofessional conduct. Wisconsin does not restrict delegation to licensed people; it makes the supervising physician answerable for whoever performs the act.

  Wis. Admin. Code Med § 10.03(1)(L) · verified Sep 2, 2026

• The board frames the whole chapter around that responsibility: physicians act with a high level of independence, every physician represents the profession, and the minimally competent practice of medicine requires that CARE OF THE PATIENT IS PARAMOUNT — physicians must act with honesty, respect for the law, reasonable judgment, competence, and respect for patient boundaries.

  Wis. Admin. Code Med § 10.01(2) · verified Sep 2, 2026

• ⚠️ Wisconsin publishes NO cosmetic-procedure rule and no energy-device rule — there is no counterpart to Ohio’s four light-based lanes, Washington’s LLRP rule or Virginia’s laser hair removal training. A Wisconsin med spa cannot look up a procedure checklist, because the state did not write one; what governs is the competence test above and the general standard of care.

  Wis. Admin. Code ch. Med 10 (surveyed via the chapter index) · verified Sep 2, 2026

• ✅ WISCONSIN ANSWERS THIS DIRECTLY — AND IT IS ONE OF THE FEW THAT DOES. Microneedling is listed by name as a DELEGATED MEDICAL PROCEDURE, and the rule that governs those says licensees “MAY PROVIDE CLIENT SERVICES CONSTITUTING MEDICAL PROCEDURES ONLY AS DIRECTED, SUPERVISED AND INSPECTED BY A PHYSICIAN WHO HAS THE POWER TO DIRECT, DECIDE AND OVERSEE THE IMPLEMENTATION OF THE CLIENT SERVICES PROVIDED IN LICENSED ESTABLISHMENTS.” So an esthetician may perform it, but only under that physician relationship — not on an esthetics license alone.

  Wis. Admin. Code § Cos 2.025(1), (2)(d) · verified Sep 2, 2026

• ⚠️ AND THE CATCH-ALL BESIDE IT IS BROADER THAN THE NAMED LIST. The same subsection makes a delegated medical procedure of “ANY TREATMENT IMPACTING A SKIN LAYER BELOW THE STRATUM CORNEUM.” Wisconsin then sets out a separate list of procedures that are delegated “UNLESS THE LICENSEE HAS RECEIVED FORMAL TRAINING IN THE PROCEDURE AS PART OF A BOARD-APPROVED CURRICULUM AND THE TREATMENT, AS PERFORMED, DOES NOT IMPACT A SKIN LAYER BELOW THE STRATUM CORNEUM” — dermaplaning, eyelash tinting, microblading, electromagnetic radiation, thermal energy. Microneedling is not on that second list, so the training-plus-depth escape does not reach it.

  Wis. Admin. Code § Cos 2.025(2)(e), (2m) · verified Sep 2, 2026

• Wisconsin also defines the procedure, which is why its rule can be this precise: “MICRONEEDLING, ALSO REFERRED TO AS COLLAGEN INDUCTION THERAPY, MEANS A COSMETIC PROCEDURE THAT INVOLVES REPEATEDLY PUNCTURING THE SKIN WITH TINY STERILE NEEDLES IN A SINGLE USE CARTRIDGE. THE NEEDLE DEPTH OF THE SINGLE USE CARTRIDGE MAY BE ADJUSTED BY THE OPERATOR.”

  Wis. Admin. Code § Cos 2.01(5) · verified Sep 2, 2026

• Delegated medical procedures shall be undertaken only pursuant to formal written protocols setting forth the nature and scope of the procedures delegated, describing the supervisory plan, and indicating any contraindications to undertaking the procedure; a laser hair removal product or device, or intense pulsed light device, shall not be used on a minor unless the minor is accompanied by a parent or guardian and only under the general supervision of a physician; and a licensee providing delegated medical procedures shall upon request make a copy of the formal written protocols available to the client and to the board.

  Wis. Admin. Code § Cos 2.025(3)–(4) · verified Sep 8, 2026

Recent Wisconsin changes

• WI State Administrative Register: Emergency Rules Filed with Legislative Reference Bureau - 2026-08-10
• WI State Administrative Register: 848A1 Register (8/3/2026) - 2026-08-03
• WI State Administrative Register: 848A3 Register (8/17/2026) - 2026-08-17