Med Spa Medical Director Requirements by State

Alabama has a chapter for this and it tiers the delegate. 540-x-11 governs lasers and light/energy-based devices — any energy source, chemical or modality affecting living tissue below the stratum corneum, for surgical, therapeutic or cosmetic purposes — and says outright that using them is the practice of medicine.

Ala. Admin. Code r. 540-X-11-.06(1) (Initial training requirements for physicians and delegates) · verified Sep 4, 2026

Alaska’s Medical Board sets the delegation standard in regulation, and it is unusually specific about the paperwork.

12 AAC 40.920(a)(1)-(3) (Standards for delegation of routine duties) · verified Sep 5, 2026

Arizona’s delegation rules here are about the unlicensed medical assistant: what one may do, that injections require DIRECT supervision, and what direct supervision physically means.

A.R.S. §32-1401 · verified Jul 26, 2026

Arkansas says the cosmetic laser is the practice of medicine, and writes the delegation protocol around it. 17 CAR § 140-1601 finds that using medical lasers on human beings, for therapeutic or cosmetic purposes, constitutes the practice of medicine, and lets a physician delegate a minor procedure only on a protocol.

17 CAR § 140-1601(b)(2) (Laser surgery guidelines — protocol) · verified Sep 4, 2026

In California, using prescriptive drugs (Botox, fillers) and prescriptive/energy devices (lasers, IPL) for cosmetic reasons IS the practice of medicine.

Cal. Bus. & Prof. Code §2052; Medical Board of California — Medical Spas guidance · verified Jul 26, 2026

Colorado permits delegation to UNLICENSED people who are “qualified by experience, education, or training” under a physician’s personal and responsible direction — but carves prescribing out of it entirely, and shuts the door on an unlicensed physician using the exemption as a side entrance.

Colo. Rev. Stat. § 12-240-107(1)(a) · verified Sep 2, 2026

Connecticut names, by statute, exactly who may perform a cosmetic medical procedure in a medical spa: the physician, physician assistant or advanced practice registered nurse the spa employs or contracts with, or a registered nurse.

Conn. Gen. Stat. §19a-903c(b) (Medical spas) · verified Sep 3, 2026

Delaware writes two supervision regimes and a med spa can sit under either.

24 Del. C. §5124(1) · verified Sep 3, 2026

The District draws its line at the stratum corneum and does it inside the definition of practicing medicine: offering or performing any invasive procedure of the body, or otherwise affecting the layer of skin below the stratum corneum for surgical, therapeutic or COSMETIC purposes, is the practice of medicine —…

D.C. Code §3-1201.02(7)(A)(iv) · verified Sep 3, 2026

Florida regulates cosmetic procedures through the physician’s duty to supervise and to delegate only to qualified people.

Fla. Stat. §458.331(1)(w) · verified Jul 26, 2026

Georgia licenses the people who operate cosmetic lasers, in two tiers, and requires the facility to have a consulting physician behind them.

Ga. Comp. R. & Regs. 360-35-.05 · verified Aug 17, 2026

The practice of medicine includes the use of drugs, surgery, electricity, telehealth, and any means to diagnose, treat, prescribe for, or correct any human condition, and no person may practice or offer to practice medicine without a license from the Hawaii medical board.

Haw. Rev. Stat. § 453-1 · verified Sep 8, 2026

A “supervising physician” is a physician responsible for the direction and supervision of the activities of, and patient services provided by, licensed or unlicensed medical personnel — so the statute contemplates unlicensed staff working under a physician and puts the physician on the hook for what they do.

Idaho Code §54-1803(4) · verified Sep 3, 2026

Illinois treats energy devices that disrupt the skin as the practice of medicine, then grades the supervision by whether the procedure is ablative.

68 Ill. Adm. Code 1285.336 (as stated in the IDFPR/IDPH med spa memo) · verified Aug 17, 2026

Indiana defines the practice of medicine broadly enough to reach injectables and energy procedures: prescribing or administering treatment, and procedures that cut, burn or vaporize tissue, are the practice of medicine.

Ind. Code §25-22.5-1-1.1 · verified Jul 26, 2026

Iowa wrote a rule for the medical director at a medical spa, and it counts in hours, miles and percentages. 481—655.6 requires the medical director to hold an active unrestricted Iowa license to supervise EACH delegated service, to ENSURE that the people performing delegated services receive direct, in-person,…

Iowa Admin. Code r. 481—655.6(2) (Delegation by a medical director) · verified Sep 4, 2026

An esthetician practices the profession of cosmetology ONLY to the listed extent, and the skin work on that list must be both NONINVASIVE and “provided for esthetic rather than medical purposes” — two independent conditions, either of which a cosmetic medical procedure can fail.

Kan. Stat. Ann. §65-1901(f) · verified Sep 3, 2026

No person shall engage in the practice of cosmetology, esthetic practices or nail technology for other than cosmetic purposes, nor engage in them for the treatment of physical or mental ailments — and the chapter does not apply to persons authorized by Kentucky law to practice medicine, nursing and the other named…

Ky. Rev. Stat. §317A.020(1) · verified Sep 3, 2026

R.S. 37:1285(A)(13) makes unprofessional conduct a cause for refusing, suspending or revoking a license, and its enumerated examples read like a list of how a cosmetic practice goes wrong: Failing to maintain independent medical judgment, improperly delegating or supervising, exercising undue influence, ENABLING…

La. Rev. Stat. §37:1285(A)(13) · verified Sep 3, 2026

Maine writes the delegation rule a med spa actually operates under, and it is CONDITIONAL rather than open: a physician may delegate activities relating to medical care to employees or support staff only where the activities are carried out by custom and usage under the physician’s control, do not themselves…

32 M.R.S. §14202(7) · verified Sep 3, 2026

Maryland attaches its delegation duties to the licensed physician who actually delegates.

Md. Code Regs. 10.32.12.03(A) (Standards for the Licensed Physician Delegating to an Assistant) · verified Sep 3, 2026

What chapter 112 creates behind a physician assistant is a supervising physician, in one unusually direct sentence: supervision must be CONTINUOUS, and it expressly does not require the physician to be present.

Mass. Gen. Laws ch. 112, § 9E · verified Sep 1, 2026

Michigan is a delegation-permissive state with real limits inside it.

Mich. Comp. Laws § 333.16215(1) · verified Sep 2, 2026 · read at Internet Archive snapshot — evidence of a page, not the current rule

Minnesota puts laser use inside the statutory definition of practicing medicine — invasive and NONINVASIVE alike — and makes unlicensed practice a gross misdemeanor.

Minn. Stat. § 147.081, subd. 3(4) · verified Sep 2, 2026

The statute defines the practice of medicine as suggesting, recommending, prescribing, or directing any drug, medicine, appliance, or other agency for the cure, relief, or palliation of any ailment for compensation, and requires a license from the State Board of Medical Licensure before practicing.

Miss. Code Ann. § 73-25-33(1) · verified Sep 8, 2026

A physician may enter collaborative practice arrangements with registered professional nurses, in the form of written agreements, jointly agreed-upon protocols or standing orders, and those arrangements may delegate authority to administer or dispense drugs and provide treatment — but only within the nurse’s scope…

Mo. Rev. Stat. §329.010(5)(d) · verified Sep 3, 2026

The statute makes the diagnosis, treatment, or correction of human conditions by any means the practice of medicine, telemedicine included, and a medical assistant is exempt only when rendering services under the appropriate amount and type of supervision of a licensee.

Mont. Code Ann. § 37-3-102(11) · verified Sep 8, 2026

Nebraska defines delegation in nursing terms — transferring the authority, responsibility AND accountability to perform nursing interventions — and places delegating, directing and assigning within the registered nurse’s own practice, bounded by the Nurse Practice Act. It also puts an affirmative duty on every…

Neb. Rev. Stat. §38-2205 (“Delegating” defined) · verified Sep 3, 2026

Nevada’s Medical Practice Act contains no med-spa “medical director” designation — the phrase does not appear anywhere in NRS chapter 630, which was surveyed in full.

Nev. Rev. Stat. ch. 630 (Physicians and Physician Assistants — full chapter surveyed) · verified Sep 3, 2026

New Hampshire makes the licensee answerable for who works in their office: employing or ALLOWING an unlicensed person to practice there is itself a disciplinary ground.

N.H. Rev. Stat. §329:17, VI(e) · verified Sep 3, 2026

Two rules meet here and they must not be confused.

N.J.A.C. 13:35-4A.3 · verified Aug 17, 2026 · read at Cornell Legal Information Institute

New Mexico wrote a rule for this exact business, and it is recent. 16.12.14 NMAC — "Nursing Practice in Aesthetic Healthcare Facilities", effective 2024-05-21 — defines an aesthetic healthcare facility and requires it to employ a clinical supervisor who is an APRN or other licensed independent practitioner with…

16.12.14.8(B) NMAC (Nursing Practice in Aesthetic Healthcare Facilities, eff. 2024-05-21) · verified Sep 4, 2026

New York reaches cosmetic procedures through the definition of the practice of medicine, plus the physician’s own duties not to delegate to the unqualified and not to permit unlicensed practice.

N.Y. Educ. Law §6521 · verified Aug 17, 2026

The Medical Board treats an aesthetic laser as a surgical instrument: altering human tissue with one is surgery, and therefore the practice of medicine.

NCMB Position Statement 5.1.2 (adopted July 1999, amended May 2021) · verified Aug 17, 2026

The Medical Practice Act itself sets the terms on which a physician assistant may practice.

N.D.C.C. § 43-17-02.1(1) (Physician assistant — scope of practice) · verified Sep 5, 2026

Across the acts these chapters cover — light-based devices and the administration of drugs — Ohio puts a delegating physician behind the act, answerable to the Board for it, and the esthetics license itself authorizes nothing that breaks the skin.

Ohio Admin. Code 4731-18-02(A) · verified Sep 1, 2026

Oklahoma writes the supervision duty as a list the supervising physician must satisfy, and it is unusually concrete about orders.

Okla. Stat. tit. 59, § 519.6 (Supervision in all patient care settings) · verified Sep 5, 2026

Oregon does not let a physician associate practice on an informal understanding: a written collaboration agreement signed by a physician, podiatric physician or employer is a precondition of practicing at all, and the degree of collaboration is set at the associate’s primary location of practice by reference to the…

Or. Rev. Stat. §677.510(2)(a) · verified Sep 3, 2026

On the medical side Pennsylvania delegates by TEST rather than by list: seven conditions, all of which must hold before a physician delegates a medical service to a health care practitioner or a technician — with a separate standing-protocol route for emergencies.

49 Pa. Code §18.402(a) · verified Aug 17, 2026 · read at Cornell Legal Information Institute

Rhode Island’s practice-of-medicine definition reaches holding out as well as doing: a person is regarded as practicing medicine who holds themself out as able to diagnose, treat, operate or prescribe for anyone ill or alleged to be ill, or who professes to heal or undertakes by any means or method to do those…

R.I. Gen. Laws §5-37-1(a)(22) · verified Sep 3, 2026

South Carolina reaches supervision and delegation failures through the Board of Medical Examiners’ misconduct grounds: knowingly performing an act that in any way assists an UNLICENSED person to practice is itself misconduct, as is being convicted of or sanctioned for illegal or unauthorized practice, and so is…

S.C. Code §40-47-110(B)(7) · verified Sep 3, 2026

The practice of esthetics is confined to the NONINVASIVE care of the skin, and the statute says what noninvasive means: Confined to the nonliving cells of the stratum corneum of the epidermis.

S.D. Codified Laws §36-15-2.2(1) · verified Sep 3, 2026

Tennessee treats a laser procedure as the practice of medicine and requires the person performing it to be under a physician’s supervision, while its definition of aesthetics covers surface work only.

Tenn. Comp. R. & Regs. 0880-02-.14(10) · verified Sep 2, 2026

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.

Tex. Occ. Code §157.001 · verified Jul 26, 2026

Section 58-1-506 sorts who may be delegated a cosmetic medical procedure into delegation group a (physician assistant, registered nurse, master esthetician, and an electrologist for laser hair removal) and GROUP B (practical nurse, esthetician, medical assistant), then grades supervision — GENERAL supervision…

Utah Code § 58-1-506(1)(a)-(b) (Supervision of cosmetic medical procedures) · verified Sep 4, 2026

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.

Vt. Stat. tit. 26, §1354(a)(29) · verified Sep 3, 2026

Virginia’s procedure-specific rule here is about laser hair removal.

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

Washington answers the supervision question twice, because it has two rules and they disagree on purpose.

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

The Medical Practice Act defines the practice of medicine and surgery as the diagnosis or treatment of, or operation or prescription for, any human disease, pain, injury, deformity or other physical or mental condition — and says in terms that “surgery” includes the use on humans of lasers, ionizing radiation,…

W. Va. Code § 30-27-3(a) (aesthetics is a CLOSED list of surface acts, and none of them break skin) · verified Sep 7, 2026

Wisconsin works from both ends.

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

A person is practicing medicine who advertises, holds out or represents to the public that they are authorized to practice medicine; who offers or undertakes to prevent, diagnose, correct or treat, in any manner, by any means, method or device, any human disease, illness, pain, wound, infirmity, defect or abnormal…

Wyo. Stat. Ann. §33-26-102(a)(xi)(A)-(B) · verified Sep 3, 2026