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Medical Director Requirements for a Med Spa

By Marissa Delgado, Head of Partner Education · Last updated 2026-09-18

Requirements are set by state, and two states show how much they differ. Florida requires a Florida-licensed physician as medical director under its medical practice statutes. Texas requires a licensed physician for delegated medical procedures under 22 TAC 169.26, and requires public posting of that physician's name and licence number.

Two states make the pattern clear. Both require a physician, and they require it in different ways, under different rules, with different obligations attached.

That is why a national summary of med spa requirements is not much use to you.

What does Florida require?

Florida requires a physician licensed in the state to serve as medical director for a med spa offering medical treatments. The licence must be active and unencumbered, held under Chapter 458 for allopathic physicians or Chapter 459 for osteopathic physicians.

Three details matter more than the headline requirement.

• It must be written. The arrangement is expected to be documented, with the supervision responsibilities set out.
• Oversight is expected to be active and recorded. The director does not have to be on site daily, but the oversight has to exist and be evidenced.
• Coverage is limited. There are restrictions on how many locations and which ones a single director may supervise.

Florida also restricts which physicians may perform or supervise certain procedures. Chapter 458 Section 348 speaks to board certification or eligibility in dermatology or plastic surgery for particular treatments. If your menu includes those, check the statute rather than a general guide.

Med spas providing medical services also register with the Florida Department of Health. The registration and the director requirement are separate obligations.

What does Texas require?

Texas approaches it through delegation. A med spa performing delegated medical procedures must have a licensed physician as medical director under 22 TAC 169.26. The physician needs an active, unrestricted Texas licence and must be in good standing.

Texas adds a transparency requirement that is easy to miss. Any individual, business or facility providing delegated acts must post the name and Texas Medical Board licence number of the delegating physician. That is a public-facing obligation, not an internal one.

There is also a licensing overlap worth knowing. The Texas Department of Licensing and Regulation governs barbering and cosmetology requirements, including premises standards. The Texas Medical Board governs the medical side. A med spa can be inside both sets of rules at once.

Why do the two states differ?

Florida names the role and attaches obligations to it directly. Texas regulates who may delegate a medical act and then requires the delegating physician to be identifiable.

Neither approach is unusual. States generally regulate the practice of medicine, who supervises a delegated act, and who may own a medical practice. They differ in which of those levers they pull hardest.

How do you establish your own state's requirement?

1. Read your state medical board's rules on delegation and supervision.
2. Check whether your state has a corporate practice of medicine restriction.
3. Check the nursing board if nurses perform medical acts at your practice.
4. Look for a licence and posting requirement, which some states impose separately.
5. Write out your treatment list and who performs each item.
6. Take that to a healthcare attorney in your state before you sign anything.

What stays the same across states?

Whatever the rule, the physician has to be licensed where the patient is. That applies to your own medical director and to any platform prescribing for your patients.

When you evaluate a platform, ask which states its clinicians hold licences in and whether that list covers everywhere you sell. Coverage gaps show up as orders you cannot fill rather than as an error message.

What qualifications does a medical director need?

Requirements vary by state, and four things come up regardless.

A licence in the state

The physician has to be licensed where the patients are. A director licensed in one state does not satisfy a requirement in another, so multi-state groups usually need more than one person.

Standing with the board

An active licence without restrictions. A licence under probation or with conditions is its own problem, and most state board lookups disclose it.

Relevant experience

Some states name a specialty and others leave it to the practice. Where your treatments are aesthetic, experience with injectables matters more than the specialty on a certificate.

A DEA registration, where medication is involved

Not every state requires one for a supervisory role. Where the arrangement carries prescribing authority over controlled substances, it usually does.

How do you verify a physician's standing?

Four checks, and each takes minutes.

The state board lookup

Every state publishes one. Search the licence, confirm it is active, and read the disciplinary history rather than the status field alone.

Malpractice cover

Ask directly, and ask what they carry for the supervisory role. A physician who carries nothing for supervision passes that cost to you.

References from practices like yours

Two references from med spas rather than hospitals. A hospital reference will not tell you how they handle a nurse injecting off-protocol.

A written scope before a rate

Ask them to price a written scope instead of quoting a monthly figure for an unnamed amount of work.

What documents show you are compliant?

Document	What it proves
Collaborative or supervisory agreement	The arrangement exists and is signed.
Licence verification for the director	The physician may practise in the state.
Signed protocols	The treatments have a written basis.
Chart review records	The supervision is happening, not only documented.
Delegation records per clinician	Each staff member may perform their role.

The fourth row is the one boards ask for and practices rarely keep. A signed agreement with no review records describes an arrangement you cannot show working.

What changes when you add a state?

Three things, and owners usually plan for only the first.

• You need a director licensed there, or an amendment to the existing arrangement.
• The delegation rules there may differ from the ones you already work to.
• Your posted delegation notice may need the new physician named, where a state requires it.

Ask about the second point specifically. A protocol set written for one state does not automatically travel, and assuming it does is the most common compliance error in a multi-state launch.

More on medical directors

• Medical director for a med spaWhat a medical director does in a med spa, when one is required, what it costs, and how it differs from the clinicians who write prescriptions.
• Does a med spa need a medical director?How to work out whether your med spa needs a medical director, which state rules decide it, and why the answer changes when you add prescriptions.
• How to find a medical director for a med spaWhere to look for a medical director, what to check before signing, and the terms that need to be in the agreement for a med spa.
• What a medical director costsPublished rates for a med spa medical director, why the figures disagree by an order of magnitude, and what actually determines what you pay.
• Medical director responsibilitiesWhat a med spa medical director is responsible for, what belongs in the job description, and which duties owners most often leave undefined.
• The medical director agreementThe clauses a med spa medical director agreement needs, the terms that cause disputes later, and what to check before you sign one.