Georgia reads like an easy state on paper. There is no med spa license, no state registry, and no requirement that your medical director be a dermatologist. Operators arrive from California expecting friction and find almost none.
Then they open a second location, and a third, and discover the constraint Georgia actually imposes: a delegating physician may hold nurse protocol agreements with no more than four advanced practice registered nurses at a time. Not four per site. Four, total.
Who may own the entity that practices medicine
Georgia does not have a single statute announcing that the corporate practice of medicine is prohibited. The restriction arrives sideways, through the licensing statutes in Title 43 and the Georgia Professional Corporation Act, which limits ownership of a professional corporation rendering a licensed service to people holding that license.
The practical result is the same as in a declared CPOM state. The entity delivering medical services is physician-owned; a separate, freely owned company handles marketing, premises, staffing, technology and everything else that is not medicine. That is the friendly PC-MSO structure, and Georgia expects to see it if anyone looks.
What Georgia does not do is license the facility. Unlike Florida, where AHCA licenses the clinic itself, there is no Georgia med spa permit to hang on the wall. The scrutiny is on the people and the paperwork.
The nurse protocol agreement is the instrument
In Georgia, a physician delegates medical acts to an APRN through a nurse protocol agreement under O.C.G.A. § 43-34-25. It is a written document, mutually agreed and signed by both, and it is what authorizes the APRN to order drugs, devices, treatments and diagnostic studies.
The statute sets out what the agreement has to do. It must:
- Be in writing and signed by both the delegating physician and the APRN
- Be between an APRN who is in a comparable specialty area or field as the delegating physician
- Be reviewed, revised or updated annually
- Be available for review on written request from the Georgia Composite Medical Board or the Georgia Board of Nursing
An unsigned protocol, an expired protocol, or a protocol that describes a service menu you stopped offering two years ago is not a technicality. It is the only document standing between a delegated injection and the unlicensed practice of medicine.
The four-APRN cap, and why it decides your growth plan
O.C.G.A. § 43-34-25 states that a delegating physician may not enter into a nurse protocol agreement with more than four advanced practice registered nurses at any one time.
The statute lists exceptions, and it is worth reading them precisely, because none of them describes a med spa. The carve-outs cover settings such as licensed hospitals, universities, public health departments, county boards of health, community service boards, free health clinics, birthing centers, certain tax-exempt entities, school nurse programs and specified HMO arrangements. A private aesthetic or wellness clinic is not on the list.
So the arithmetic is unavoidable. If your Georgia model is one physician signing for a growing roster of nurse practitioners, you hit the ceiling at four and the fifth hire has nothing to practice under.
| Georgia footprint | APRNs needing protocols | Delegating physicians required |
|---|---|---|
| Single clinic, 2 injectors | 2 | 1 |
| Two clinics, 2 APRNs each | 4 | 1 (at the cap) |
| Three clinics, 2 APRNs each | 6 | 2 |
| Five clinics, 3 APRNs each | 15 | 4 |
This is the single most common reason a Georgia expansion stalls, and it stalls late — usually after the lease is signed and the hire is made.
“Comparable specialty area or field” is a real filter
The comparable-specialty requirement gets skimmed past, and it should not be. The statute does not say any licensed physician may delegate to any APRN. It says the APRN must be in a comparable specialty area or field as the delegating physician.
If your delegating physician practices emergency medicine and your APRN is a family nurse practitioner running an aesthetics and weight management panel, a reviewer can reasonably ask how those two align. There is no bright-line list, which is exactly why the pairing decision belongs in front of counsel rather than being made on the basis of who was willing to sign.
What an APRN cannot do under a Georgia protocol
Two limits matter for the services med spas and wellness clinics actually sell:
- Schedule I and II controlled substances. An APRN may not issue a prescription drug order for these under a nurse protocol agreement. Testosterone is Schedule III, so TRT sits outside that particular bar — but it sits squarely inside the federal telemedicine rules, which have their own expiry date.
- Radiographic imaging. Georgia treats the ordering of radiographic imaging tests narrowly under the protocol framework. If imaging is anywhere in your care pathway, read the current text before you assume your APRN can order it.
Physician assistants follow a different track
Georgia regulates physician assistants under a separate part of Title 43, with its own application and job description filed with the Board. It is not the nurse protocol framework and the numbers do not work the same way. If your staffing model mixes PAs and APRNs, they need to be documented separately — and a single “supervision agreement” template covering both is a sign the paperwork was bought rather than written.
How MDside handles Georgia
We place Georgia-licensed physicians, match the delegating physician to the APRN’s specialty rather than to whoever is available, write nurse protocol agreements against your actual service menu, calendar the annual review so it does not lapse, and — most importantly for anyone with more than one location — model the four-APRN cap against your hiring plan before you sign the lease.
See what is included, or compare with how delegation works in Texas, where the constraint is written delegation and a prescriptive authority cap rather than a headcount limit.
Related reading
Frequently asked questions
Can a nurse practitioner be the medical director of a Georgia med spa?
No. The delegating role in Georgia’s nurse protocol framework belongs to a physician. An APRN practices under a protocol; they do not sign one for someone else.
How many nurse practitioners can one Georgia physician cover?
Four at any one time under a nurse protocol agreement, subject to the statutory exceptions — which cover hospitals, health departments and similar settings, not private aesthetic clinics.
Does Georgia license med spas?
No. There is no facility license or state med spa registry in Georgia. That is a meaningful difference from Tennessee, which publishes a registry naming the supervising physician.
Does the medical director have to be a dermatologist or plastic surgeon?
No. Georgia does not require a specific board certification. It does require the APRN to be in a comparable specialty area or field as the delegating physician, which is a different question and a more practical one.
How often does a nurse protocol agreement have to be updated?
Annually, by statute — and in practice whenever the service menu, products or staff change. A protocol that predates your current offering does not cover it.
General information about Georgia delegation and med spa regulation, not legal advice. Statutes, board rules and scope-of-practice requirements change. Confirm your obligations with healthcare counsel licensed in Georgia.