Medical Director Requirements by State (All 52)

The short answer. There is no national standard. Whether you need a medical director, who may hold the role, who may perform the good faith exam, and how you are allowed to pay for any of it are four separate questions and every state answers them differently — and in at least one state the answer to the fourth is that the industry-standard fee arrangement is unlawful. This page carries the verified answer for all fifty-two jurisdictions, the primary source behind each one, and the eight claims circulating in this market that are simply wrong.

MDside is a physician-led PC-MSO. We supply the medical director, the professional entity underneath them, the licensed providers who do the clinical work, and the platform the good faith exams actually run on. This page is the reference we work from, published in full.

Reviewed by Victor D. Cruz, MD — founder of MDside, licensed in Florida (ME117105) and New York. Last reviewed 2026-09-03. Every state row below cites the statute, administrative code section, board position statement or decided case it comes from. Where we have not verified a jurisdiction against a primary source, we say so on that jurisdiction’s page and leave it out of the table rather than paraphrasing another vendor’s blog.

On this page: Find your state · The 52-jurisdiction comparison · State-by-state detail · The five tests · What changed recently · Eight things you will read that are wrong · How the fee has to be structured · What the role actually involves · What MDside provides · Broker, direct hire, or network · Every jurisdiction, with sources · Explore by business type · Frequently asked questions · How this page is maintained

Find your state

Fifty-two jurisdictions, including the District of Columbia and Puerto Rico. Every one of them now carries verified, statute-level guidance — the last coverage stub was retired on 2026-09-03. Type to filter.

Filter 52 jurisdictions

Jurisdiction	Corporate practice restricted?	Who may hold the role	Depth
Alabama	Not strictly prohibited. Non-physicians may own; confirm the entity with Alabama counsel.	A designated medical director who is a licensed physician, responsible for written protocols and active supervision of delegated tasks.	Exams in Alabama
Alaska	No express statute. AS 10.45, the Professional Corporation Act, does the same work through licensure and a board filing.	An Alaska-licensed MD or DO.	Exams in Alaska
Arizona	Not strictly enforced.	Often not required by statute — NPs hold full practice authority and may own the clinic and be their own clinical lead.	Exams in Arizona
Arkansas	Yes. Ownership of the medical entity is physician-held.	An Arkansas-licensed MD or DO.	Exams in Arkansas
California	Yes — the strictest in the country.	MD or DO.	Exams in California
Colorado	Restricted, with a disclosure regime layered on top.	Physician under CRS art. 240, or an APRN under art. 255.	Exams in Colorado
Connecticut	The med spa itself need not be physician-owned. A professional corporation rendering the service must have shareholders licensed in that same service.	A named provider — physician, PA or APRN — licensed and ACTIVELY PRACTISING in Connecticut, with demonstrable training or experience in cosmetic procedures.	Exams in Connecticut
Delaware	Yes. A professional service corporation may be formed only by licensees of the SAME profession.	A Delaware-licensed MD or DO. Delaware grants nurse practitioners full practice authority, but the med spa director role is physician-held where the menu exceeds NP scope.	Exams in Delaware
District of Columbia	Yes, through DC Code § 29-508: shareholders, directors and officers must each be licensed for the service the corporation is organized for.	A DC-licensed MD or DO.	Exams in District of Columbia
Florida	No broad prohibition. Non-physicians may own.	Active, unencumbered Florida MD (ch. 458) or DO (ch. 459). No specialty required.	Exams in Florida
Georgia	Yes.	MD or DO.	Exams in Georgia
Hawaii	No express prohibition in HRS ch. 453. The practical position is a physician-led ownership model.	A licensed MD or DO.	Exams in Hawaii
Idaho	RESCINDED by the Idaho Board of Medicine in 2016. Non-physicians may own.	A licensed physician — and Idaho maintains DETAILED rules on that person’s qualifications and experience, which is unusual for an open-ownership state.	Exams in Idaho
Illinois	Yes, by the Medical Corporation Act — but an APRN with full practice authority may own and practise.	MD or DO, or an APRN holding full practice authority (attested 250 CE hours plus 4,000 post-certification clinical hours).	Exams in Illinois
Indiana	Yes — and the MSO/MSA route is a contested legal question here rather than a settled workaround.	A licensed physician actively involved in operations, with a written practice plan. Indiana imposes no geographic limit on who may serve.	Exams in Indiana
Iowa	Yes, with exceptions.	An Iowa-licensed MD or DO.	Exams in Iowa
Kansas	Yes. A general business entity may not engage in a learned profession by employing or contracting with physicians unless it is a professional corporation or LLC wholly owned by licensed professionals.	An MD or DO whose licence is used BY THE PHYSICIAN and not by the business — real involvement in protocols, delegation and oversight.	Exams in Kansas
Kentucky	Restricted for the clinical entity. A non-physician participates through an MSO or management arrangement rather than owning it; a qualifying APRN may own a med spa.	An MD or DO, or an APRN meeting Kentucky’s educational and experiential requirements.	Exams in Kentucky
Louisiana	Yes. A corporation may not practise medicine except a Professional Medical Corporation owned and governed exclusively by physicians.	MD or DO. Physicians alone delegate the medical acts — neurotoxin, fillers, lasers, microneedling.	Exams in Louisiana
Maine	Recognised but loosely enforced. Non-physicians, INCLUDING ESTHETICIANS, may own a medical spa.	An MD, DO, or a full-practice-authority nurse practitioner within NP scope. Not universally required.	Exams in Maine
Maryland	Yes. No business entity may practise medicine, and none may employ physicians to deliver professional medical services.	MD or DO, with the administrative side held by a separately owned management company.	Exams in Maryland
Massachusetts	Yes, and long-settled — it traces to McMurdo v. Getter (1937), not to a recent statute.	An MD or DO holding MAJORITY ownership of the entity delivering medical services.	Exams in Massachusetts
Michigan	Yes, through the Professional Service Corporation Act.	A Michigan-licensed physician who retains medical judgment and direction of clinical care.	Exams in Michigan
Minnesota	Yes, through the professional firm statute. Interests may be held only by licensed, non-disqualified professionals, qualifying general partnerships, or other professional firms authorised to furnish at least one category of the service.	A Minnesota-licensed physician holding clinical responsibility for the medical services the firm provides.	Exams in Minnesota
Mississippi	Restricted in practice through the collaboration rules rather than an ownership bar alone.	A collaborating physician within 75 MILES of the primary practice location, practising in Mississippi at least 20 hours a week or 80 hours a month.	Exams in Mississippi
Missouri	Yes. Shares may be issued only to natural persons authorised to render a professional service permitted by the articles, and the corporation renders services only through them.	A physician licensed by the Missouri Board of Registration for the Healing Arts. Anyone practising medicine in Missouri — including solely as a medical director overseeing other personnel — must hold a Missouri licence.	Exams in Missouri
Montana	Yes. Ownership of a medical or professional nursing practice is limited to physicians and to QUALIFYING nurse practitioners.	An MD, DO, or a qualifying nurse practitioner with the correct education and training, within NP scope.	Exams in Montana
Nebraska	No corporate practice doctrine — and oversight obligations are unaffected by that.	An MD, DO, or an independent nurse practitioner within NP scope.	Exams in Nebraska
Nevada	Yes, through the professional-entity statute.	A licensee eligible to render the service. A professional entity may act only through licensed officers, managers and employees.	Exams in Nevada
New Hampshire	No. The fee-splitting prohibition was REPEALED in 1996.	An MD, DO, or a full-practice-authority nurse practitioner within NP scope.	Exams in New Hampshire
New Jersey	Yes.	MD or DO. The PC must be physician-owned, with the MSO a separate entity.	Exams in New Jersey
New Mexico	Not actively enforced. Non-physicians may hold the business.	An MD or DO where the menu exceeds NP scope; New Mexico grants nurse practitioners full practice authority.	Exams in New Mexico
New York	Yes.	MD or DO. Only a physician licensed under Educ. Law art. 131 may own the entity that practises medicine — not an RN, NP, esthetician or investor.	Exams in New York
North Carolina	Yes, and strictly.	An active North Carolina licensee. The business must be owned in its entirety by licensees — physicians, or physicians together with NPs or PAs.	Exams in North Carolina
North Dakota	No express prohibition in N.D.C.C. ch. 43-17. ⚠️ Sources citing § 43-17-31 as a ban are misreading a section titled “Grounds for disciplinary action”.	A North Dakota-licensed MD or DO.	Exams in North Dakota
Ohio	No — Ohio has ABOLISHED the doctrine. Entities may employ physicians and non-physicians may own.	A physician for the clinical oversight the device rules require. Ownership is not the constraint here.	Exams in Ohio
Oklahoma	No ownership bar. A lay person or entity may own the med spa provided they do not interfere with the physician’s professional judgment.	A physician medical director genuinely involved in protocols, delegation and oversight — open ownership puts MORE weight on the role, not less.	Exams in Oklahoma
Oregon	Restricted, and SB 951 is the most restrictive MSO statute in the country.	A licensed physician — or an independent nurse practitioner — actively involved in patient care and supervision. Not a name on a protocol.	Exams in Oregon
Pennsylvania	Yes. Medical services must be rendered by licensees, or by entities wholly owned by them.	MD or DO. A director in name only is expressly insufficient.	Exams in Pennsylvania
Puerto Rico	Governed by the Junta de Licenciamiento y Disciplina Médica under Ley 139-2008. A mainland licence confers nothing on the island.	An MD or DO licensed IN PUERTO RICO.	Exams in Puerto Rico
Rhode Island	Yes — and Rhode Island goes further, licensing the med spa itself as a healthcare facility.	A physician OR certified nurse practitioner, employed or contracted, who is TRAINED IN THE INDICATIONS AND PERFORMANCE of the cosmetic medical procedures the med spa offers. General licensure does not satisfy it.	Exams in Rhode Island
South Carolina	No ownership bar — the Board does not license or regulate corporations. A non-licensee may not control the practice of medicine or independent clinical judgment.	A South Carolina-licensed physician with genuine clinical control over medical decisions, on site for certain procedures.	Exams in South Carolina
South Dakota	Yes — SDCL 36-4-8.1 declares it the public policy of the state, with an employment exception on three conditions.	A South Dakota-licensed MD or DO. Under SDCL 47-11-3 all officers, directors and shareholders of a medical corporation must be licensed AT ALL TIMES, and no proxy to vote shares may be given to an unlicensed person.	Exams in South Dakota
Tennessee	Yes.	MD or DO. No specialty required.	Exams in Tennessee
Texas	Yes.	MD or DO only. Not an NP, not a PA.	Exams in Texas
Utah	Utah does not restrict ownership. It writes down, in detail, who may do what and where.	A cosmetic medical procedure supervisor: a physician with an unrestricted licence under the Medical Practice Act, or an APRN with an unrestricted licence under the Nurse Practice Act, acting within scope.	Exams in Utah
Vermont	NEW. H.583 was signed 15 June 2026 and took effect 1 July 2026 — drafted as a CONTROL and DISCLOSURE statute rather than an ownership ban.	A Vermont-licensed MD or DO with genuine authority over clinical decisions. Vermont grants nurse practitioners full practice authority within NP scope.	Exams in Vermont
Virginia	Restricted through the professional-entity statute — but not physician-only. An authorised licensee may co-own.	MD or DO. A PA may perform under § 54.1-2952 and an APRN under § 54.1-2957; a properly trained person may perform laser hair removal under a physician’s or PA’s direction.	Exams in Virginia
Washington	Restricted, with a training-before-delegation rule that governs in practice.	A physician who is fully and appropriately trained in the procedure — before performing it OR delegating it.	Exams in Washington
West Virginia	Yes. A corporation may not practise medicine without a CERTIFICATE OF AUTHORIZATION from the Board of Medicine.	A West Virginia-licensed MD or DO exercising genuine oversight of the medical services delivered.	Exams in West Virginia
Wisconsin	Yes. Every shareholder, director and officer must be licensed in the same field, or be a health care professional — at all times, not just at formation.	A Wisconsin-licensed physician. No person may practise medicine and surgery in Wisconsin without a licence from the Medical Examining Board.	Exams in Wisconsin
Wyoming	Yes, through W.S. 17-3-101: capital stock owned EXCLUSIVELY by persons licensed to practise the profession BY THE STATE OF WYOMING.	An MD or DO licensed IN WYOMING. An out-of-state licence does not satisfy the statute.	Exams in Wyoming

What the fifty-two jurisdictions actually require

Read across a single row and the point lands. A structure that is lawful in Florida can leave you with no valid clinical entity in North Carolina. A fee formula that is ordinary in Florida is prohibited in New York. A laser delegation that is fine in Texas is unlawful in Ohio unless the physician is standing in the room. This is why a national compliance template is not a product.

State	Corporate practice	Who may hold the role	Good faith exam	Delegation & supervision	The gate that catches operators	Primary source
Florida	No broad prohibition. Non-physicians may own.	Active, unencumbered Florida MD (ch. 458) or DO (ch. 459). No specialty required.	Physician exam and written order before an RN may inject. ARNP works under a written protocol.	MD/DO independent; ARNP under written protocol; PA under delegation; RN on delegation only, after a physician exam and written order.	AHCA licensure under the Health Care Clinic Act, or a certificate of exemption you have to apply for — not assume.	Fla. Stat. ch. 400 pt. X; § 400.9905(4); § 464.012; ch. 458/459
Texas	Yes.	MD or DO only. Not an NP, not a PA.	Physician delegation required before a delegate may treat; prescriptive authority agreements count toward the statutory cap.	Written delegation only — verbal delegation is not recognised. Physician must be immediately available.	The physician’s name and TMB licence number must be posted in treatment areas (22 TAC 169.26).	22 TAC 169.26; Tex. Occ. Code ch. 157; elective IV therapy law eff. 2025-09-01
California	Yes — the strictest in the country.	MD or DO.	Required before treatment; the exam is a physician act that cannot be handed to a non-licensee.	Standing orders are the usual instrument, but some counsel read SB 351 to require patient-specific orders. That reading is aggressive and not settled.	SB 351 (signed 6 Oct 2025, effective 1 Jan 2026) bars private-equity and management entities from controlling treatment options, patient quotas or competency-based staffing. AG enforcement: injunctions, attorneys’ fees, penalties.	Cal. SB 351 (2025); AB 1415 (OHCA pre-transaction notice)
New York	Yes.	MD or DO. Only a physician licensed under Educ. Law art. 131 may own the entity that practises medicine — not an RN, NP, esthetician or investor.	Physician or authorised licensee. The exam cannot be delegated to a non-licensee.	Standard delegation rules apply, and physician conduct oversight runs through OPMC and attaches to the individual.	Fee splitting with a non-licensee is prohibited. A percentage-based MSO management fee is unlawful here, not merely risky.	N.Y. Educ. Law § 6530(18),(19); 8 NYCRR § 29.1(b)(4); Educ. Law art. 131
Georgia	Yes.	MD or DO.	Physician exam or an APRN acting under a nurse protocol agreement.	Protocol must be reviewed annually, and the APRN must work in a comparable specialty area or field to the delegating physician. An APRN may not prescribe Schedule I or II under a protocol.	A delegating physician may not hold nurse protocol agreements with more than FOUR APRNs at one time. The statutory exceptions do not include private aesthetic clinics.	O.C.G.A. § 43-34-25
Arizona	Not strictly enforced.	Often not required by statute — NPs hold full practice authority and may own the clinic and be their own clinical lead.	An NP with full practice authority may perform it independently.	No collaborative agreement required for an NP. The statutory duty to refer and consult outside one’s competence remains.	The regulator is the Arizona Board of NURSING, not the Medical Board — operators route questions to the wrong agency.	A.R.S. tit. 32 ch. 15; Arizona State Board of Nursing
New Jersey	Yes.	MD or DO. The PC must be physician-owned, with the MSO a separate entity.	Physician exam before RN injection; the exam is the trigger for a physician-signed protocol.	Direct supervision means immediately available on the premises, or real-time audio-video plus periodic chart review. RNs only under a detailed physician-signed protocol. Unlicensed staff never.	Allstate Ins. Co. v. Northfield Medical Center (N.J. Sup. Ct., 4 May 2017): roughly $4M under the Insurance Fraud Prevention Act, and liability reached the parties who PROMOTED the structure.	Allstate Ins. Co. v. Northfield Med. Ctr., N.J. Sup. Ct., 4 May 2017; N.J. Insurance Fraud Prevention Act
Illinois	Yes, by the Medical Corporation Act — but an APRN with full practice authority may own and practise.	MD or DO, or an APRN holding full practice authority (attested 250 CE hours plus 4,000 post-certification clinical hours).	Physician, or an FPA APRN acting independently.	Standard delegation, with the FPA carve-out removing the collaborative-agreement requirement for qualifying APRNs.	BIPA. A photograph alone is not a biometric identifier; a scan of face geometry is. $1,000 negligent / $5,000 intentional, private right of action, no proof of harm required.	805 ILCS 15 (Medical Corporation Act); 740 ILCS 14 (BIPA); SB 2979 (signed 2 Aug 2024)
Tennessee	Yes.	MD or DO. No specialty required.	Physician exam or an appropriately authorised licensee.	Standard delegation rules.	A public online med spa REGISTRY listing clinic name and address, your medical director’s name and licence number. The definition reaches any practice that advertises or holds itself out as a medical spa.	Tenn. Code Ann. § 63-6-105; § 63-1-153
Nevada	Yes, through the professional-entity statute.	A licensee eligible to render the service. A professional entity may act only through licensed officers, managers and employees.	An RN may NOT perform the good faith exam in Nevada.	An RN may inject, run IV and assist with devices only under an order. Medical assistants sit under NAC 630.830.	NRS 89.070: shares may not be transferred except to a natural person eligible to hold them, or to the estate of a deceased or incompetent holder. The friendly PC does not exit like a normal company.	NRS 89.050; NRS 89.070; NRS 630.3062; NRS 630.301, 630.306; NAC 630.830
Colorado	Restricted, with a disclosure regime layered on top.	Physician under CRS art. 240, or an APRN under art. 255.	Delegating practitioner. Written informed consent must be retained for seven years.	Delegation to an RN runs through the Nurse Practice Act, not the medical board’s cosmetic delegation rule — a distinction that changes who may do what.	HB25-1024 (signed 7 April 2025): on-site signage naming the delegating practitioner, their licence number and contact details plus the board’s complaint URL, the same disclosure on your website and in advertising, and seven-year consent retention.	Colo. HB25-1024 (2025); CRS tit. 12 arts. 240, 255
North Carolina	Yes, and strictly.	An active North Carolina licensee. The business must be owned in its entirety by licensees — physicians, or physicians together with NPs or PAs.	Physician or authorised licensee.	Standard delegation, read against NCMB position statements.	The straw-director pattern is named in the board’s own disciplinary commentary: a physician paid $2,000 a month, told he need not attend, over a med spa owned by a non-licensee — characterised as aiding the unlicensed practice of medicine.	NCMB Position Statement 10.1.2; NCMB disciplinary commentary
Pennsylvania	Yes. Medical services must be rendered by licensees, or by entities wholly owned by them.	MD or DO. A director in name only is expressly insufficient.	An RN may inject only after a good faith exam by a physician, CRNP or PA.	A CRNP practises under a collaborative agreement FILED with the State Board of Medicine — filed, not merely signed and kept in a drawer.	Non-compliance is framed as civil and criminal exposure, not only board enforcement.	Pa. professional corporation law; 49 Pa. Code (State Board of Medicine); collaborative agreement filing requirement
Ohio	No — Ohio has ABOLISHED the doctrine. Entities may employ physicians and non-physicians may own.	A physician for the clinical oversight the device rules require. Ownership is not the constraint here.	Physician or authorised licensee.	Laser is the strictest in the country: the delegate must have OBSERVED 15 and PERFORMED 20 procedures per device type under direct physical oversight, and direct physical oversight means the physician in the SAME ROOM directly observing.	Ablative light-based procedures may not be delegated at all. And while entities may employ physicians, they may not control clinical judgment (ORC 4731.22).	ORC 4731.22; ORC 4731.33; OAC ch. 4731-18
Washington	Restricted, with a training-before-delegation rule that governs in practice.	A physician who is fully and appropriately trained in the procedure — before performing it OR delegating it.	Physician or authorised licensee.	Delegable to a properly trained PA, RN or LPN. The written office protocol must name the delegating physician and set out patient selection criteria and care and follow-up for common complications, serious injury and emergencies.	A medical assistant-certified may establish an IV line WITHOUT administering medication, and may give IV injections only under direct visual supervision (RCW 18.360).	WAC 246-919-606; RCW 18.71; RCW 18.360
Massachusetts	Yes, and long-settled — it traces to McMurdo v. Getter (1937), not to a recent statute.	An MD or DO holding MAJORITY ownership of the entity delivering medical services.	Physician, or an independent nurse practitioner — Massachusetts grants NPs full practice authority.	The second failure mode here is assigning procedures to staff who are not qualified for them, or a director who does not provide the oversight the role requires.	243 CMR 2.11 lists the permitted entity forms: individual licensed practitioner, professional partnership, PC, PLLP or PLLC. A conventional business corporation is not on the list.	243 CMR 2.11; McMurdo v. Getter, Mass. 1937
Michigan	Yes, through the Professional Service Corporation Act.	A Michigan-licensed physician who retains medical judgment and direction of clinical care.	Physician or an authorised licensee.	MCL 333.16215 requires delegation to be genuine authorisation, matched to the individual delegatee’s education, training and experience, and paired with actual supervision. An unlicensed individual may receive delegated acts if so qualified, under supervision.	For a Public Health Code service, every PC shareholder must be licensed or legally authorised in Michigan to render the same service. A plan to give an NP, a PA and an investor equity in the same medical PC does not survive it.	MCL 333.16215; Professional Service Corporation Act, Act 192 of 1962, § 4(3); Michigan Public Health Code
Virginia	Restricted through the professional-entity statute — but not physician-only. An authorised licensee may co-own.	MD or DO. A PA may perform under § 54.1-2952 and an APRN under § 54.1-2957; a properly trained person may perform laser hair removal under a physician’s or PA’s direction.	Physician, PA or APRN.	Supervision must be readily available at the time treatment is given — reachable, not necessarily on site.	The complication rule. When a treatment causes a complication, the supervising doctor must see and evaluate that patient before treatment continues. That is a clinical appointment, not a phone note.	Va. Code § 13.1-543; § 54.1-2952; § 54.1-2957; 18VAC85-20-91; 18VAC85-50-191
Maryland	Yes. No business entity may practise medicine, and none may employ physicians to deliver professional medical services.	MD or DO, with the administrative side held by a separately owned management company.	Physician or an authorised licensee.	Delegation to unlicensed personnel runs through COMAR 10.32.09, with physician responsibility and training documented — and never for a surgical act.	The Board of Physicians treats laser hair removal as a SURGICAL act (Declaratory Ruling 00-1, October 2002), which sets the ceiling on who may perform it: physicians, certified nurse practitioners, RNs under the Board of Nursing’s own ruling, and PAs.	Md. Health Occ. § 14-303(a); Board of Physicians Declaratory Ruling 00-1 (Oct 2002); COMAR 10.32.09
Missouri	Yes. Shares may be issued only to natural persons authorised to render a professional service permitted by the articles, and the corporation renders services only through them.	A physician licensed by the Missouri Board of Registration for the Healing Arts. Anyone practising medicine in Missouri — including solely as a medical director overseeing other personnel — must hold a Missouri licence.	An RN may administer injectables and infusions only after a good faith exam by a qualified provider.	APRNs work under a written collaborative practice arrangement that reflects the services actually being delivered. LPNs are generally restricted from injectables.	The geographic proximity requirement between the collaborating physician and each APRN. A physician three states away is not a Missouri solution.	RSMo ch. 356; RSMo ch. 334; Missouri collaborative practice arrangement rules
Minnesota	Yes, through the professional firm statute. Interests may be held only by licensed, non-disqualified professionals, qualifying general partnerships, or other professional firms authorised to furnish at least one category of the service.	A Minnesota-licensed physician holding clinical responsibility for the medical services the firm provides.	Physician or an authorised licensee.	A multi-category professional firm is permitted under § 319B.40 only where the licensing statutes authorise the combination — which is what lets an RN or APRN co-own.	Any other transfer of ownership is VOID, including a transfer by will. Succession has to be designed into the documents, not assumed.	Minn. Stat. ch. 319B; § 319B.40
Alabama	Not strictly prohibited. Non-physicians may own; confirm the entity with Alabama counsel.	A designated medical director who is a licensed physician, responsible for written protocols and active supervision of delegated tasks.	Physician. An RN performing laser hair removal is expected to have physician presence during the procedure.	A collaborating physician must deliver 10% of a CRNP’s scheduled hours ON SITE while the CRNP is inside the two-year / 4,000-hour window; after it, meet no less than quarterly, and visit remote practice sites no less than twice a year.	The 10% arithmetic. A CRNP working 32 hours a week needs roughly three and a quarter hours of on-site physician presence every week. Aesthetic clinics are not among the settings excluded from the minimum presence hours.	Alabama collaborative practice rules (10% on-site presence; quarterly meetings; twice-yearly remote site visits)
Connecticut	The med spa itself need not be physician-owned. A professional corporation rendering the service must have shareholders licensed in that same service.	A named provider — physician, PA or APRN — licensed and ACTIVELY PRACTISING in Connecticut, with demonstrable training or experience in cosmetic procedures.	An initial IN-PERSON assessment by that named provider. This is the clause that rules out a purely remote model for new patients.	Only licensed persons may diagnose, treat or prescribe. An RN works within scope under a valid order.	An inactive or out-of-state licence does not satisfy the named-provider requirement, and general licensure is not the training test.	CGS § 19a-903c; CGS § 20-9; CGS § 33-182a
Indiana	Yes — and the MSO/MSA route is a contested legal question here rather than a settled workaround.	A licensed physician actively involved in operations, with a written practice plan. Indiana imposes no geographic limit on who may serve.	Physician or an authorised licensee.	NP and PA within scope under the applicable arrangement; RN within scope on a valid order.	Registration with the Indiana Medical Licensing Board by 1 January 2027, a designated responsible practitioner, adverse-event reporting within 15 DAYS, and location restrictions. Most provisions from 1 July 2026.	Ind. SB 282 med spa framework (most provisions 1 Jul 2026; registration 1 Jan 2027); Indiana corporate practice prohibition
Kansas	Yes. A general business entity may not engage in a learned profession by employing or contracting with physicians unless it is a professional corporation or LLC wholly owned by licensed professionals.	An MD or DO whose licence is used BY THE PHYSICIAN and not by the business — real involvement in protocols, delegation and oversight.	Physician or an authorised licensee.	KSA 65-28,127 governs licensees who direct, supervise, order, refer, accept responsibility for, enter practice protocols with, or delegate acts constituting the practice of the healing arts.	The entity form. Kansas professional corporations are designated “PA” (Professional Association), not “PC” — a small thing that shows whether your adviser has done this here before.	KSA 65-28,127; the licence-use subsection (b)(15); Kansas Board of Healing Arts guidance on corporations
Kentucky	Restricted for the clinical entity. A non-physician participates through an MSO or management arrangement rather than owning it; a qualifying APRN may own a med spa.	An MD or DO, or an APRN meeting Kentucky’s educational and experiential requirements.	An RN or LPN may administer an injection only when lawfully ordered by a qualified prescriber as part of a documented medical plan of care.	APRN prescriptive authority runs through a collaborative agreement until the four-year threshold for non-scheduled drugs, after which it is independent for those. APRNs may order and stock non-scheduled legend drugs for the practice.	Three chapters at once — KRS 311 (medicine), KRS 314 (nursing) and KRS 317A (cosmetology). Injectables, laser and IV therapy are the practice of medicine.	KRS 311; KRS 314; KRS 317A; Kentucky board advisory opinions
Louisiana	Yes. A corporation may not practise medicine except a Professional Medical Corporation owned and governed exclusively by physicians.	MD or DO. Physicians alone delegate the medical acts — neurotoxin, fillers, lasers, microneedling.	A PRE-TREATMENT PHYSICAL EXAMINATION BY THE PHYSICIAN, with the prescriber physically present on the premises.	An RN may perform light treatments, non-ablative laser, FDA-approved neurotoxin injectables and chemical peels on a prescriber’s order with a physician or NP physically present — and is EXPRESSLY PROHIBITED from dermal fillers.	Neurotoxin and filler are not the same delegation. Book them into the same RN column and a scheduling problem reads as a scope problem.	LSBME Rule § 7911; LSBME Statement of Position on the corporate practice of medicine
Mississippi	Restricted in practice through the collaboration rules rather than an ownership bar alone.	A collaborating physician within 75 MILES of the primary practice location, practising in Mississippi at least 20 hours a week or 80 hours a month.	Physician, or an NP under an approved, filed collaborative agreement.	Quality-assurance chart review of 10% or 20 charts, whichever is fewer, per quarter, documented. The agreement must be written, signed, filed with the Board of Nursing, retained on site and available for inspection at any time.	TELEMEDICINE HOURS ARE EXPRESSLY EXCLUDED from the 20-hour count. A national network leaning on remote coverage does not meet it.	Mississippi Board of Nursing collaborative practice rules (75-mile radius; 20 hrs/week or 80/month; quarterly QA review)
Oklahoma	No ownership bar. A lay person or entity may own the med spa provided they do not interfere with the physician’s professional judgment.	A physician medical director genuinely involved in protocols, delegation and oversight — open ownership puts MORE weight on the role, not less.	A good faith exam before treatment. An RN may administer injectables and infusions on a valid order AFTER the exam, but may not perform the exam and may not prescribe.	Written protocols covering each delegated service. NPs participate through a collaboration or protocol arrangement and do not independently own the clinical entity. Unlicensed staff never for medical procedures.	Nobody is forced to have the structure conversation at formation, so the arrangement becomes whatever it drifted into.	Okla. tit. 59 §§ 492, 519.6, 567.4c; Oklahoma State Board of Medical Licensure and Supervision guidance
Oregon	Restricted, and SB 951 is the most restrictive MSO statute in the country.	A licensed physician — or an independent nurse practitioner — actively involved in patient care and supervision. Not a name on a protocol.	Every med spa patient is treated as the director’s own: an evaluation establishing the diagnosis and treatment, informed consent before treatment, and proper documentation.	Diagnosis of a medical condition and development of a treatment plan are NON-DELEGABLE to anyone not licensed to provide independent medical judgment. Delegation otherwise only where the director has confirmed the staff member’s education and training.	SB 951 bars dual roles between the professional entity and the MSO and bars MSO control over clinical and defined business decisions. Ownership and control rules bite 1 Jan 2026 for entities formed on or after 9 June 2025, and 1 Jan 2029 for pre-existing ones.	Or. SB 951 (2025); ORS ch. 677; Oregon Medical Board guidance
South Carolina	No ownership bar — the Board does not license or regulate corporations. A non-licensee may not control the practice of medicine or independent clinical judgment.	A South Carolina-licensed physician with genuine clinical control over medical decisions, on site for certain procedures.	The physician. Initial patient examinations are expected of the director.	NP and PA within scope under the applicable arrangement; RN within scope on a valid order.	The Board reaches the LICENSEE, not the company. An aggressive structure transfers the exposure onto your medical director personally.	South Carolina Board of Medical Examiners guidance and disciplinary jurisdiction
Utah	Utah does not restrict ownership. It writes down, in detail, who may do what and where.	A cosmetic medical procedure supervisor: a physician with an unrestricted licence under the Medical Practice Act, or an APRN with an unrestricted licence under the Nurse Practice Act, acting within scope.	The supervisor, within scope.	Statutory delegation groups. Group A includes PAs under the Utah Physician Assistant Act, RNs, MASTER ESTHETICIANS and electrologists evaluating for or performing laser hair removal. Supervision must be of the person performing the procedure WHILE they perform it.	The procedure may only be performed in a COSMETIC MEDICAL FACILITY — Utah regulates the venue, not just the act. Ablative procedures may not be delegated to anyone not licensed under the Medical or Osteopathic Practice Acts, subject to limited APRN exceptions.	Utah Code § 58-1-505; Utah Physician Assistant Act; Medical Practice Act; Osteopathic Medical Practice Act
Wisconsin	Yes. Every shareholder, director and officer must be licensed in the same field, or be a health care professional — at all times, not just at formation.	A Wisconsin-licensed physician. No person may practise medicine and surgery in Wisconsin without a licence from the Medical Examining Board.	Physician or an authorised licensee. A physician using telemedicine to diagnose or treat a patient located in Wisconsin must be licensed by the Medical Examining Board.	NP and PA within scope under the applicable arrangement; RN within scope on a valid order.	The automatic conversion provision: if all shareholders cease at any one time and for any reason to be licensed in the field the corporation was organised for, the service corporation is converted into a business corporation by operation of law.	Wis. Stat. § 180.1901(2); Wis. Stat. § 448.03; Wis. Admin. Code ch. Med 24; Wis. Stat. ch. 766
Delaware	Yes. A professional service corporation may be formed only by licensees of the SAME profession.	A Delaware-licensed MD or DO. Delaware grants nurse practitioners full practice authority, but the med spa director role is physician-held where the menu exceeds NP scope.	A qualified practitioner must evaluate the patient and document the decision before treatment. Delegation is only as good as the documentation behind it.	NP under full practice authority within NP scope; PA under the applicable arrangement; RN within scope on a valid order, documented.	The same-profession rule kills mixed-licence equity. A physician and a nurse practitioner cannot co-own one Delaware professional service corporation.	Del. Code tit. 8 ch. 6 (Professional Service Corporations); Del. Code tit. 24 ch. 17 (Medical Practice Act); Del. Code tit. 24 ch. 19
Arkansas	Yes. Ownership of the medical entity is physician-held.	An Arkansas-licensed MD or DO.	⚠️ Confirm the in-person examination requirement with the Arkansas State Medical Board BEFORE building a remote intake funnel. This is the single question that decides whether an asynchronous model works here.	APRN under the applicable collaborative arrangement; RN within scope on a valid order from a practitioner who has evaluated the patient.	A remote-first funnel designed in another state can fail on the examination question alone, after the marketing spend.	Ark. Code Ann. § 17-95-201 et seq.; Arkansas State Medical Board regulations
Iowa	Yes, with exceptions.	An Iowa-licensed MD or DO.	A physician evaluation and order before treatment. Iowa also regulates how the exam and the practice are ADVERTISED — the med spa rule reaches your marketing, not only your clinic.	ARNP within scope; PA under the applicable arrangement; laser work runs through the qualified laser technician framework.	IAC 653—13.8 is a rule written specifically about medical spas, including how they may hold themselves out. Most operators never read it because they are looking for a statute.	Iowa Admin. Code 653—13.8; Iowa Code ch. 148; Iowa Code ch. 152
Nebraska	No corporate practice doctrine — and oversight obligations are unaffected by that.	An MD, DO, or an independent nurse practitioner within NP scope.	An evaluation and order by a practitioner permitted to make that decision. The absence of a corporate practice doctrine does nothing to relax it.	NP independent within scope after the transition requirements; PA under the applicable arrangement; RN within scope on a valid order.	THREE separate regulators: the Board of Medicine and Surgery, the Board of Nursing, and facility licensing at DHHS. Clearing one is not clearing the others.	Neb. Rev. Stat. ch. 38 art. 20 (Medicine and Surgery); ch. 38 art. 23 (Nursing); Neb. DHHS facility licensure
New Mexico	Not actively enforced. Non-physicians may hold the business.	An MD or DO where the menu exceeds NP scope; New Mexico grants nurse practitioners full practice authority.	A practitioner permitted to prescribe the treatment must evaluate the patient and issue the order. An RN may inject only on that order.	NP independent within NP scope; PA under the applicable arrangement; RN within scope, on an order from a practitioner who evaluated the patient.	Open ownership plus full practice authority moves the constraint entirely onto the MENU. What you offer, not who owns you, decides which licences you need.	NMSA 1978 ch. 61 art. 6 (Medical Practice Act); ch. 61 art. 3 (Nursing Practice Act)
New Hampshire	No. The fee-splitting prohibition was REPEALED in 1996.	An MD, DO, or a full-practice-authority nurse practitioner within NP scope.	An evaluation and order by a practitioner permitted to make the decision, before treatment.	⚠️ LASER use is limited to physicians and physician assistants. NP within scope otherwise; RN within scope on a valid order.	The laser restriction. New Hampshire is permissive on structure and narrow on who may fire a device — the opposite of the usual trade.	N.H. RSA ch. 329 (Medicine); RSA ch. 326-B (Nursing); 1996 repeal of the fee-splitting prohibition
Idaho	RESCINDED by the Idaho Board of Medicine in 2016. Non-physicians may own.	A licensed physician — and Idaho maintains DETAILED rules on that person’s qualifications and experience, which is unusual for an open-ownership state.	An evaluation and order by a practitioner permitted to make it. Idaho grants nurse practitioners full practice authority, so an NP-led model exists for services within NP scope.	NP independent within scope; PA under the applicable arrangement; RN within scope on a valid order; written protocols throughout.	The person, not the entity. Idaho removed the ownership constraint and specified director qualifications — verify your intended director actually meets them for YOUR service menu.	Idaho Board of Medicine 2016 rescission; Idaho Code ch. 54-18 (Medical Practice Act); Idaho Code ch. 54-14 (Nursing)
Hawaii	No express prohibition in HRS ch. 453. The practical position is a physician-led ownership model.	A licensed MD or DO.	Neurotoxin injections and laser treatments are MEDICAL services and must be performed by appropriately licensed professionals under the physician medical director’s supervision, following an evaluation.	NP has full practice authority for clinical purposes — but may NOT own the med spa business; PA within scope; RN within scope on a valid order.	Full practice authority does not carry ownership. Plans built on “the NP is independent, so the NP can own it” fail in Hawaii.	HRS ch. 453 (Medicine and Surgery); HRS ch. 457 (Nursing)
Rhode Island	Yes — and Rhode Island goes further, licensing the med spa itself as a healthcare facility.	A physician OR certified nurse practitioner, employed or contracted, who is TRAINED IN THE INDICATIONS AND PERFORMANCE of the cosmetic medical procedures the med spa offers. General licensure does not satisfy it.	An evaluation and order by the medical director or another practitioner permitted to make it, before treatment.	⚠️ Licensed practical nurses, nursing assistants and MEDICAL ASSISTANTS may not provide services — it falls outside their scopes. RN within scope on a valid order.	Facility licensure gates the OPENING DATE, and the exclusion of LPNs, NAs and MAs changes your cost per treatment against any model built in another state.	R.I. Medical Spas Safety Act; R.I. Dept. of Health guidance for medical spa and IV therapy businesses; R.I. Gen. Laws ch. 5-37
West Virginia	Yes. A corporation may not practise medicine without a CERTIFICATE OF AUTHORIZATION from the Board of Medicine.	A West Virginia-licensed MD or DO exercising genuine oversight of the medical services delivered.	A good faith examination and treatment plan before treatment, by a qualified practitioner, under signed protocols.	NP and PA within scope under the applicable arrangement; RN within scope on a valid order; delegation only to practitioners whose licence and training support the task.	§ 30-3-15. Forming the entity is not the last step — the entity needs the Board’s certificate BEFORE it holds itself out as providing medical services.	W. Va. Code § 30-3-15; W. Va. Code ch. 30 art. 3; W. Va. Code ch. 30 art. 7
Maine	Recognised but loosely enforced. Non-physicians, INCLUDING ESTHETICIANS, may own a medical spa.	An MD, DO, or a full-practice-authority nurse practitioner within NP scope. Not universally required.	A qualified practitioner must evaluate and authorise treatment. Ownership confers NO authority to perform or to order.	⚠️ Maine grants NPs full practice authority only AFTER a supervised transition period — before that, a physician relationship is required, and the answer is INDIVIDUAL-SPECIFIC.	Reading the ownership permission as a clinical one. An esthetician-owner who employs clinical staff is lawful; an esthetician-owner who injects is not.	Me. Rev. Stat. tit. 32 ch. 48 (Medicine); tit. 32 ch. 31 (Nursing); Maine State Board of Nursing transition-to-practice requirements
Montana	Yes. Ownership of a medical or professional nursing practice is limited to physicians and to QUALIFYING nurse practitioners.	An MD, DO, or a qualifying nurse practitioner with the correct education and training, within NP scope.	An evaluation and order by a practitioner permitted to make it, before treatment.	NP has full practice authority within NP scope; PA under the applicable arrangement; RN within scope on a valid order.	There is no third ownership category. An investor, esthetician or spa operator does not own the clinical entity — they use a management services organisation.	Mont. Code Ann. tit. 37 ch. 3 (Medicine); tit. 37 ch. 8 (Nursing)
Alaska	No express statute. AS 10.45, the Professional Corporation Act, does the same work through licensure and a board filing.	An Alaska-licensed MD or DO.	An evaluation and order by a practitioner permitted to make it. ⚠️ Alaska’s Division convened a Medical Spa Services Work Group and published a DRAFT interdisciplinary scope matrix — who may perform what is still being mapped.	Conservative delegation only, to practitioners whose own licence clearly supports the task, under written protocols. Silence in an unsettled state is not permission.	AS 10.45 requires a CERTIFICATE FROM THE PROFESSION’S REGULATORY BOARD, certifying every incorporator, director and shareholder is licensed, filed WITH the articles of incorporation. AS 10.45.030 limits a PC to one type of professional service.	AS 10.45.020; AS 10.45.030; AS 08.64 (State Medical Board); Alaska Div. of Corporations, Business and Professional Licensing, Medical Spa Services Work Group
District of Columbia	Yes, through DC Code § 29-508: shareholders, directors and officers must each be licensed for the service the corporation is organized for.	A DC-licensed MD or DO.	An evaluation and order by a practitioner permitted to make it, before treatment. The entity rule says nothing about how the care is supervised — that is a separate obligation.	NP and PA within scope under the applicable arrangement; RN within scope on a valid order.	The only unlicensed seat is the SECRETARY of a single-shareholder professional corporation, and that person may not perform professional services.	DC Code § 29-508(a), (b), (c); DC Code tit. 3 ch. 12 (Health Occupations)
North Dakota	No express prohibition in N.D.C.C. ch. 43-17. ⚠️ Sources citing § 43-17-31 as a ban are misreading a section titled “Grounds for disciplinary action”.	A North Dakota-licensed MD or DO.	⚠️ § 43-17-02.3: the practice of medicine is DEEMED TO OCCUR IN THE STATE THE PATIENT IS LOCATED. Whoever performs the exam needs an ACTIVE North Dakota licence, wherever they sit.	NP and PA within scope under the applicable nursing and medical rules; RN within scope on a valid order.	Licensure by patient location. Statutory exceptions are narrow — organ harvest team, air ambulance, one-time diagnostic consult to a licensed ND physician or ≤7 days teaching, board-approved charitable, board rules. None is a business model.	N.D.C.C. § 43-17-02.3; N.D.C.C. § 43-17-31; N.D.C.C. ch. 43-12.1 (Nursing)
Puerto Rico	Governed by the Junta de Licenciamiento y Disciplina Médica under Ley 139-2008. A mainland licence confers nothing on the island.	An MD or DO licensed IN PUERTO RICO.	An evaluation by a practitioner licensed by the Junta. ⚠️ Ley 8-2025 (approved 11 April 2025) removed the separate telemedicine CERTIFICATION for professionals already authorized to practise in Puerto Rico — practitioners licensed only in a mainland or federal jurisdiction still need it.	Within scope under the applicable Puerto Rico rules; RN within scope on a valid order.	Fifty-state coverage is not national coverage. A brand advertising nationwide availability with fifty licences has not covered Puerto Rico.	Ley 139-2008 (Junta de Licenciamiento y Disciplina Médica); Ley 168-2018 (Telemedicina), as amended by Ley 8-2025
South Dakota	Yes — SDCL 36-4-8.1 declares it the public policy of the state, with an employment exception on three conditions.	A South Dakota-licensed MD or DO. Under SDCL 47-11-3 all officers, directors and shareholders of a medical corporation must be licensed AT ALL TIMES, and no proxy to vote shares may be given to an unlicensed person.	An evaluation and order by a practitioner permitted to make it. ⚠️ SDCL 36-4-8.2: use of a LASER or ionizing radiation to cut “or otherwise alter” human tissue IS SURGERY constituting the practice of medicine.	Delegation only to a practitioner whose licence and training support performing a surgical act, under written protocols naming device, settings, indications and contraindications.	A physician employment agreement may not run more than THREE YEARS, renewable annually — and the corporation may take no profit from the practice of medicine itself, though facility, equipment and administrative charges are expressly allowed.	SDCL 36-4-8.1; SDCL 36-4-8.2; SDCL 47-11-1; SDCL 47-11-2; SDCL 47-11-3
Vermont	NEW. H.583 was signed 15 June 2026 and took effect 1 July 2026 — drafted as a CONTROL and DISCLOSURE statute rather than an ownership ban.	A Vermont-licensed MD or DO with genuine authority over clinical decisions. Vermont grants nurse practitioners full practice authority within NP scope.	An evaluation and order by a practitioner permitted to make it. § 9772’s stated purpose is to keep clinical and treatment decisions EXCLUSIVELY in the hands of health care providers.	NP independent within scope; PA under the applicable arrangement; RN within scope on a valid order.	⚠️ § 9773: EVERY health care facility AND EVERY management services organization must file with the Green Mountain Care Board ON OR BEFORE 1 MARCH 2027 — the full ownership report if a private equity group or hedge fund held an interest as of 1 June 2026, otherwise an ATTESTATION that none did. There is no “not applicable” option.	Vt. H.583 (2026), § 9772, § 9773; 26 V.S.A. ch. 23 (Medicine)
Wyoming	Yes, through W.S. 17-3-101: capital stock owned EXCLUSIVELY by persons licensed to practise the profession BY THE STATE OF WYOMING.	An MD or DO licensed IN WYOMING. An out-of-state licence does not satisfy the statute.	An evaluation and order by a practitioner permitted to make it. Services may be rendered only by and through licensed stockholders OR LICENSED EMPLOYEES — the treating clinicians need not be owners.	NP and PA within scope under the applicable arrangement; RN within scope on a valid order; written protocols throughout.	Wyoming’s permissive LLC and holding-company reputation says NOTHING about the clinical entity. A single Wyoming LLC doing both is the most common local mistake.	W.S. 17-3-101; W.S. tit. 33 ch. 26 (Medical Practice Act); W.S. tit. 33 ch. 21 (Nursing)

Every row above was verified against the cited primary source on 2026-09-03. Secondary sources in this market contradict each other constantly — searching Nevada returns “does not strictly enforce corporate practice” and “prohibits corporate practice” on the same page of results, and the AANP’s own May 2026 practice-authority map disagrees with a widely cited chart on New Jersey. That is the reason for the citation column.

State-by-state detail

The same fifty-two jurisdictions, expanded. Each card is the at-a-glance answer, the thing that actually catches operators, the primary sources, and the longer write-ups behind it.

Florida

Corporate practice of medicine: No broad prohibition. Non-physicians may own.
Who may hold the medical-director role: Active, unencumbered Florida MD (ch. 458) or DO (ch. 459). No specialty required.
Good faith exam: Physician exam and written order before an RN may inject. ARNP works under a written protocol.
Delegation and supervision: MD/DO independent; ARNP under written protocol; PA under delegation; RN on delegation only, after a physician exam and written order.
The gate that catches operators: AHCA licensure under the Health Care Clinic Act, or a certificate of exemption you have to apply for — not assume.
Primary sources: Fla. Stat. ch. 400 pt. X; § 400.9905(4); § 464.012; ch. 458/459
Last verified: 2026-09-03

Florida is where copied California framing does the most damage. CPOM content written for a strict state is simply wrong here.

Go deeper: Medical direction in Florida · Florida med spa medical director requirements · Florida medical director cost and agreement · Florida IV hydration clinic requirements

Texas

Corporate practice of medicine: Yes.
Who may hold the medical-director role: MD or DO only. Not an NP, not a PA.
Good faith exam: Physician delegation required before a delegate may treat; prescriptive authority agreements count toward the statutory cap.
Delegation and supervision: Written delegation only — verbal delegation is not recognised. Physician must be immediately available.
The gate that catches operators: The physician’s name and TMB licence number must be posted in treatment areas (22 TAC 169.26).
Primary sources: 22 TAC 169.26; Tex. Occ. Code ch. 157; elective IV therapy law eff. 2025-09-01
Last verified: 2026-09-03

SB 378 was VETOED on 2 June 2025 and never became law. Competitor pages still publish it as live Texas requirement.

Go deeper: Medical direction in Texas · The Texas SB 378 veto · Texas delegation rules · Adding weight management in Texas

California

Corporate practice of medicine: Yes — the strictest in the country.
Who may hold the medical-director role: MD or DO.
Good faith exam: Required before treatment; the exam is a physician act that cannot be handed to a non-licensee.
Delegation and supervision: Standing orders are the usual instrument, but some counsel read SB 351 to require patient-specific orders. That reading is aggressive and not settled.
The gate that catches operators: SB 351 (signed 6 Oct 2025, effective 1 Jan 2026) bars private-equity and management entities from controlling treatment options, patient quotas or competency-based staffing. AG enforcement: injunctions, attorneys’ fees, penalties.
Primary sources: Cal. SB 351 (2025); AB 1415 (OHCA pre-transaction notice)
Last verified: 2026-09-03

SB 351 changed what a management agreement may say. Agreements drafted before 2026 should be re-read, not renewed.

Go deeper: Medical direction in California · California SB 351 and MSO agreements · California corporate practice of medicine · Adding weight management in California

New York

Corporate practice of medicine: Yes.
Who may hold the medical-director role: MD or DO. Only a physician licensed under Educ. Law art. 131 may own the entity that practises medicine — not an RN, NP, esthetician or investor.
Good faith exam: Physician or authorised licensee. The exam cannot be delegated to a non-licensee.
Delegation and supervision: Standard delegation rules apply, and physician conduct oversight runs through OPMC and attaches to the individual.
The gate that catches operators: Fee splitting with a non-licensee is prohibited. A percentage-based MSO management fee is unlawful here, not merely risky.
Primary sources: N.Y. Educ. Law § 6530(18),(19); 8 NYCRR § 29.1(b)(4); Educ. Law art. 131
Last verified: 2026-09-03

Fees must be fixed, at fair market value, and agreed in writing BEFORE services are rendered.

Go deeper: Medical direction in New York · New York corporate practice of medicine · Who may own a New York med spa · New York medical director agreements

Georgia

Corporate practice of medicine: Yes.
Who may hold the medical-director role: MD or DO.
Good faith exam: Physician exam or an APRN acting under a nurse protocol agreement.
Delegation and supervision: Protocol must be reviewed annually, and the APRN must work in a comparable specialty area or field to the delegating physician. An APRN may not prescribe Schedule I or II under a protocol.
The gate that catches operators: A delegating physician may not hold nurse protocol agreements with more than FOUR APRNs at one time. The statutory exceptions do not include private aesthetic clinics.
Primary sources: O.C.G.A. § 43-34-25
Last verified: 2026-09-03

No med spa licence and no registry in Georgia. The cap is the constraint, and it caps your hiring plan.

Go deeper: Medical direction in Georgia · The Georgia four-APRN protocol cap

Arizona

Corporate practice of medicine: Not strictly enforced.
Who may hold the medical-director role: Often not required by statute — NPs hold full practice authority and may own the clinic and be their own clinical lead.
Good faith exam: An NP with full practice authority may perform it independently.
Delegation and supervision: No collaborative agreement required for an NP. The statutory duty to refer and consult outside one’s competence remains.
The gate that catches operators: The regulator is the Arizona Board of NURSING, not the Medical Board — operators route questions to the wrong agency.
Primary sources: A.R.S. tit. 32 ch. 15; Arizona State Board of Nursing
Last verified: 2026-09-03

Competitor pages claiming Arizona requires physicians to own 51% of clinical assets contradict full practice authority. We do not repeat that claim.

Go deeper: Medical direction in Arizona · Arizona NP full practice authority

New Jersey

Corporate practice of medicine: Yes.
Who may hold the medical-director role: MD or DO. The PC must be physician-owned, with the MSO a separate entity.
Good faith exam: Physician exam before RN injection; the exam is the trigger for a physician-signed protocol.
Delegation and supervision: Direct supervision means immediately available on the premises, or real-time audio-video plus periodic chart review. RNs only under a detailed physician-signed protocol. Unlicensed staff never.
The gate that catches operators: Allstate Ins. Co. v. Northfield Medical Center (N.J. Sup. Ct., 4 May 2017): roughly $4M under the Insurance Fraud Prevention Act, and liability reached the parties who PROMOTED the structure.
Primary sources: Allstate Ins. Co. v. Northfield Med. Ctr., N.J. Sup. Ct., 4 May 2017; N.J. Insurance Fraud Prevention Act
Last verified: 2026-09-03

This is the case that shows exposure is not limited to board discipline, and not limited to the physician.

Go deeper: Medical direction in New Jersey · Allstate v. Northfield and sham PCs

Illinois

Corporate practice of medicine: Yes, by the Medical Corporation Act — but an APRN with full practice authority may own and practise.
Who may hold the medical-director role: MD or DO, or an APRN holding full practice authority (attested 250 CE hours plus 4,000 post-certification clinical hours).
Good faith exam: Physician, or an FPA APRN acting independently.
Delegation and supervision: Standard delegation, with the FPA carve-out removing the collaborative-agreement requirement for qualifying APRNs.
The gate that catches operators: BIPA. A photograph alone is not a biometric identifier; a scan of face geometry is. $1,000 negligent / $5,000 intentional, private right of action, no proof of harm required.
Primary sources: 805 ILCS 15 (Medical Corporation Act); 740 ILCS 14 (BIPA); SB 2979 (signed 2 Aug 2024)
Last verified: 2026-09-03

SB 2979 ended per-scan damages accrual and the Seventh Circuit held that retroactive in 2026 — but the exposure itself is untouched.

Go deeper: Medical direction in Illinois · Illinois CPOM and BIPA

Tennessee

Corporate practice of medicine: Yes.
Who may hold the medical-director role: MD or DO. No specialty required.
Good faith exam: Physician exam or an appropriately authorised licensee.
Delegation and supervision: Standard delegation rules.
The gate that catches operators: A public online med spa REGISTRY listing clinic name and address, your medical director’s name and licence number. The definition reaches any practice that advertises or holds itself out as a medical spa.
Primary sources: Tenn. Code Ann. § 63-6-105; § 63-1-153
Last verified: 2026-09-03

Registered since 1 January 2016, annual fee authorised. Your directorship is public information in Tennessee.

Go deeper: Medical direction in Tennessee · The Tennessee med spa registry

Nevada

Corporate practice of medicine: Yes, through the professional-entity statute.
Who may hold the medical-director role: A licensee eligible to render the service. A professional entity may act only through licensed officers, managers and employees.
Good faith exam: An RN may NOT perform the good faith exam in Nevada.
Delegation and supervision: An RN may inject, run IV and assist with devices only under an order. Medical assistants sit under NAC 630.830.
The gate that catches operators: NRS 89.070: shares may not be transferred except to a natural person eligible to hold them, or to the estate of a deceased or incompetent holder. The friendly PC does not exit like a normal company.
Primary sources: NRS 89.050; NRS 89.070; NRS 630.3062; NRS 630.301, 630.306; NAC 630.830
Last verified: 2026-09-03

Failure to supervise is its own ground for discipline under NRS 630.3062 — separate from whatever the delegate did.

Go deeper: Medical direction in Nevada · Nevada professional entity ownership · Who performs the exam in Nevada

Colorado

Corporate practice of medicine: Restricted, with a disclosure regime layered on top.
Who may hold the medical-director role: Physician under CRS art. 240, or an APRN under art. 255.
Good faith exam: Delegating practitioner. Written informed consent must be retained for seven years.
Delegation and supervision: Delegation to an RN runs through the Nurse Practice Act, not the medical board’s cosmetic delegation rule — a distinction that changes who may do what.
The gate that catches operators: HB25-1024 (signed 7 April 2025): on-site signage naming the delegating practitioner, their licence number and contact details plus the board’s complaint URL, the same disclosure on your website and in advertising, and seven-year consent retention.
Primary sources: Colo. HB25-1024 (2025); CRS tit. 12 arts. 240, 255
Last verified: 2026-09-03

This is a marketing-department obligation as much as a clinical one. Your website copy is now regulated.

Go deeper: Medical direction in Colorado · Colorado HB25-1024 disclosure rules · Colorado delegation to unlicensed staff

North Carolina

Corporate practice of medicine: Yes, and strictly.
Who may hold the medical-director role: An active North Carolina licensee. The business must be owned in its entirety by licensees — physicians, or physicians together with NPs or PAs.
Good faith exam: Physician or authorised licensee.
Delegation and supervision: Standard delegation, read against NCMB position statements.
The gate that catches operators: The straw-director pattern is named in the board’s own disciplinary commentary: a physician paid $2,000 a month, told he need not attend, over a med spa owned by a non-licensee — characterised as aiding the unlicensed practice of medicine.
Primary sources: NCMB Position Statement 10.1.2; NCMB disciplinary commentary
Last verified: 2026-09-03

North Carolina is the clearest published description of what a signature-only directorship looks like from the regulator’s side.

Go deeper: Medical direction in North Carolina · The North Carolina straw medical director · Who may own a North Carolina practice

Pennsylvania

Corporate practice of medicine: Yes. Medical services must be rendered by licensees, or by entities wholly owned by them.
Who may hold the medical-director role: MD or DO. A director in name only is expressly insufficient.
Good faith exam: An RN may inject only after a good faith exam by a physician, CRNP or PA.
Delegation and supervision: A CRNP practises under a collaborative agreement FILED with the State Board of Medicine — filed, not merely signed and kept in a drawer.
The gate that catches operators: Non-compliance is framed as civil and criminal exposure, not only board enforcement.
Primary sources: Pa. professional corporation law; 49 Pa. Code (State Board of Medicine); collaborative agreement filing requirement
Last verified: 2026-09-03

The filing requirement is the one operators miss. An unfiled agreement is not an agreement for this purpose.

Go deeper: Medical direction in Pennsylvania · Pennsylvania CRNP collaborative agreements · Pennsylvania: the exam before RN injection

Ohio

Corporate practice of medicine: No — Ohio has ABOLISHED the doctrine. Entities may employ physicians and non-physicians may own.
Who may hold the medical-director role: A physician for the clinical oversight the device rules require. Ownership is not the constraint here.
Good faith exam: Physician or authorised licensee.
Delegation and supervision: Laser is the strictest in the country: the delegate must have OBSERVED 15 and PERFORMED 20 procedures per device type under direct physical oversight, and direct physical oversight means the physician in the SAME ROOM directly observing.
The gate that catches operators: Ablative light-based procedures may not be delegated at all. And while entities may employ physicians, they may not control clinical judgment (ORC 4731.22).
Primary sources: ORC 4731.22; ORC 4731.33; OAC ch. 4731-18
Last verified: 2026-09-03

Ohio breaks the pattern in both directions: the ownership answer is the most permissive in this table and the device answer is the most restrictive.

Go deeper: Medical direction in Ohio · Ohio abolished corporate practice of medicine · The Ohio laser delegation numbers

Washington

Corporate practice of medicine: Restricted, with a training-before-delegation rule that governs in practice.
Who may hold the medical-director role: A physician who is fully and appropriately trained in the procedure — before performing it OR delegating it.
Good faith exam: Physician or authorised licensee.
Delegation and supervision: Delegable to a properly trained PA, RN or LPN. The written office protocol must name the delegating physician and set out patient selection criteria and care and follow-up for common complications, serious injury and emergencies.
The gate that catches operators: A medical assistant-certified may establish an IV line WITHOUT administering medication, and may give IV injections only under direct visual supervision (RCW 18.360).
Primary sources: WAC 246-919-606; RCW 18.71; RCW 18.360
Last verified: 2026-09-03

“Trained before delegating” is the unusual part: a physician cannot delegate a procedure they are not themselves trained to perform.

Go deeper: Medical direction in Washington · Washington: trained before delegating · Washington IV rules for medical assistants

Massachusetts

Corporate practice of medicine: Yes, and long-settled — it traces to McMurdo v. Getter (1937), not to a recent statute.
Who may hold the medical-director role: An MD or DO holding MAJORITY ownership of the entity delivering medical services.
Good faith exam: Physician, or an independent nurse practitioner — Massachusetts grants NPs full practice authority.
Delegation and supervision: The second failure mode here is assigning procedures to staff who are not qualified for them, or a director who does not provide the oversight the role requires.
The gate that catches operators: 243 CMR 2.11 lists the permitted entity forms: individual licensed practitioner, professional partnership, PC, PLLP or PLLC. A conventional business corporation is not on the list.
Primary sources: 243 CMR 2.11; McMurdo v. Getter, Mass. 1937
Last verified: 2026-09-03

Your director will be asked to describe the arrangement accurately on their biennial renewal. Two regulators, not one: DPH licenses the clinic, the Board of Registration in Medicine handles physicians.

Go deeper: Medical direction in Massachusetts · Who may own a Massachusetts practice · The biennial ownership question

Michigan

Corporate practice of medicine: Yes, through the Professional Service Corporation Act.
Who may hold the medical-director role: A Michigan-licensed physician who retains medical judgment and direction of clinical care.
Good faith exam: Physician or an authorised licensee.
Delegation and supervision: MCL 333.16215 requires delegation to be genuine authorisation, matched to the individual delegatee’s education, training and experience, and paired with actual supervision. An unlicensed individual may receive delegated acts if so qualified, under supervision.
The gate that catches operators: For a Public Health Code service, every PC shareholder must be licensed or legally authorised in Michigan to render the same service. A plan to give an NP, a PA and an investor equity in the same medical PC does not survive it.
Primary sources: MCL 333.16215; Professional Service Corporation Act, Act 192 of 1962, § 4(3); Michigan Public Health Code
Last verified: 2026-09-03

A medical director who is a silent partner does not satisfy the supervision the delegation statute assumes. Enforcement runs through LARA and the Michigan Board of Medicine.

Go deeper: Medical direction in Michigan · The Michigan PC shareholder rule · Delegating to unlicensed staff in Michigan

Virginia

Corporate practice of medicine: Restricted through the professional-entity statute — but not physician-only. An authorised licensee may co-own.
Who may hold the medical-director role: MD or DO. A PA may perform under § 54.1-2952 and an APRN under § 54.1-2957; a properly trained person may perform laser hair removal under a physician’s or PA’s direction.
Good faith exam: Physician, PA or APRN.
Delegation and supervision: Supervision must be readily available at the time treatment is given — reachable, not necessarily on site.
The gate that catches operators: The complication rule. When a treatment causes a complication, the supervising doctor must see and evaluate that patient before treatment continues. That is a clinical appointment, not a phone note.
Primary sources: Va. Code § 13.1-543; § 54.1-2952; § 54.1-2957; 18VAC85-20-91; 18VAC85-50-191
Last verified: 2026-09-03

Virginia says readily available; Ohio says in the same room. A single national supervision policy cannot satisfy both, which is the whole argument for writing them per state.

Go deeper: Medical direction in Virginia · The Virginia complication rule · Virginia sole-purpose entities

Maryland

Corporate practice of medicine: Yes. No business entity may practise medicine, and none may employ physicians to deliver professional medical services.
Who may hold the medical-director role: MD or DO, with the administrative side held by a separately owned management company.
Good faith exam: Physician or an authorised licensee.
Delegation and supervision: Delegation to unlicensed personnel runs through COMAR 10.32.09, with physician responsibility and training documented — and never for a surgical act.
The gate that catches operators: The Board of Physicians treats laser hair removal as a SURGICAL act (Declaratory Ruling 00-1, October 2002), which sets the ceiling on who may perform it: physicians, certified nurse practitioners, RNs under the Board of Nursing’s own ruling, and PAs.
Primary sources: Md. Health Occ. § 14-303(a); Board of Physicians Declaratory Ruling 00-1 (Oct 2002); COMAR 10.32.09
Last verified: 2026-09-03

Three regulators to keep straight: the Board of Physicians defines which procedures are medical, the Board of Nursing governs nursing scope, and facility licensing sits elsewhere again.

Go deeper: Medical direction in Maryland · Laser is a surgical act in Maryland · Maryland §14-303 and employing physicians

Missouri

Corporate practice of medicine: Yes. Shares may be issued only to natural persons authorised to render a professional service permitted by the articles, and the corporation renders services only through them.
Who may hold the medical-director role: A physician licensed by the Missouri Board of Registration for the Healing Arts. Anyone practising medicine in Missouri — including solely as a medical director overseeing other personnel — must hold a Missouri licence.
Good faith exam: An RN may administer injectables and infusions only after a good faith exam by a qualified provider.
Delegation and supervision: APRNs work under a written collaborative practice arrangement that reflects the services actually being delivered. LPNs are generally restricted from injectables.
The gate that catches operators: The geographic proximity requirement between the collaborating physician and each APRN. A physician three states away is not a Missouri solution.
Primary sources: RSMo ch. 356; RSMo ch. 334; Missouri collaborative practice arrangement rules
Last verified: 2026-09-03

Model the proximity rule against your actual locations before you sign a lease or a directorship. It is the most common reason a Missouri arrangement that reads well on paper cannot be delivered.

Go deeper: Medical direction in Missouri · Missouri geographic proximity · Who may inject in Missouri

Minnesota

Corporate practice of medicine: Yes, through the professional firm statute. Interests may be held only by licensed, non-disqualified professionals, qualifying general partnerships, or other professional firms authorised to furnish at least one category of the service.
Who may hold the medical-director role: A Minnesota-licensed physician holding clinical responsibility for the medical services the firm provides.
Good faith exam: Physician or an authorised licensee.
Delegation and supervision: A multi-category professional firm is permitted under § 319B.40 only where the licensing statutes authorise the combination — which is what lets an RN or APRN co-own.
The gate that catches operators: Any other transfer of ownership is VOID, including a transfer by will. Succession has to be designed into the documents, not assumed.
Primary sources: Minn. Stat. ch. 319B; § 319B.40
Last verified: 2026-09-03

The multi-category firm is genuinely useful for retaining a lead clinician with equity rather than salary. The void-transfer rule is the price of it.

Go deeper: Medical direction in Minnesota · The Minnesota multi-category firm · Minnesota void transfers

Alabama

Corporate practice of medicine: Not strictly prohibited. Non-physicians may own; confirm the entity with Alabama counsel.
Who may hold the medical-director role: A designated medical director who is a licensed physician, responsible for written protocols and active supervision of delegated tasks.
Good faith exam: Physician. An RN performing laser hair removal is expected to have physician presence during the procedure.
Delegation and supervision: A collaborating physician must deliver 10% of a CRNP’s scheduled hours ON SITE while the CRNP is inside the two-year / 4,000-hour window; after it, meet no less than quarterly, and visit remote practice sites no less than twice a year.
The gate that catches operators: The 10% arithmetic. A CRNP working 32 hours a week needs roughly three and a quarter hours of on-site physician presence every week. Aesthetic clinics are not among the settings excluded from the minimum presence hours.
Primary sources: Alabama collaborative practice rules (10% on-site presence; quarterly meetings; twice-yearly remote site visits)
Last verified: 2026-09-03

That is a staffing commitment, not a retainer. Do the arithmetic before you sign.

Go deeper: Medical direction in Alabama · The Alabama 10% presence rule · Open ownership, closed presence

Connecticut

Corporate practice of medicine: The med spa itself need not be physician-owned. A professional corporation rendering the service must have shareholders licensed in that same service.
Who may hold the medical-director role: A named provider — physician, PA or APRN — licensed and ACTIVELY PRACTISING in Connecticut, with demonstrable training or experience in cosmetic procedures.
Good faith exam: An initial IN-PERSON assessment by that named provider. This is the clause that rules out a purely remote model for new patients.
Delegation and supervision: Only licensed persons may diagnose, treat or prescribe. An RN works within scope under a valid order.
The gate that catches operators: An inactive or out-of-state licence does not satisfy the named-provider requirement, and general licensure is not the training test.
Primary sources: CGS § 19a-903c; CGS § 20-9; CGS § 33-182a
Last verified: 2026-09-03

Two provisions pull in different directions and both are true. Which governs depends on the entity you actually use, which is the question to settle first.

Go deeper: Medical direction in Connecticut · The Connecticut in-person assessment · Connecticut ownership

Indiana

Corporate practice of medicine: Yes — and the MSO/MSA route is a contested legal question here rather than a settled workaround.
Who may hold the medical-director role: A licensed physician actively involved in operations, with a written practice plan. Indiana imposes no geographic limit on who may serve.
Good faith exam: Physician or an authorised licensee.
Delegation and supervision: NP and PA within scope under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: Registration with the Indiana Medical Licensing Board by 1 January 2027, a designated responsible practitioner, adverse-event reporting within 15 DAYS, and location restrictions. Most provisions from 1 July 2026.
Primary sources: Ind. SB 282 med spa framework (most provisions 1 Jul 2026; registration 1 Jan 2027); Indiana corporate practice prohibition
Last verified: 2026-09-03

Unusually candid: an aggressive structure carries more uncertainty in Indiana than the same structure elsewhere, because the MSO question is not settled.

Go deeper: Medical direction in Indiana · Indiana SB 282 registration · The Indiana 15-day report

Kansas

Corporate practice of medicine: Yes. A general business entity may not engage in a learned profession by employing or contracting with physicians unless it is a professional corporation or LLC wholly owned by licensed professionals.
Who may hold the medical-director role: An MD or DO whose licence is used BY THE PHYSICIAN and not by the business — real involvement in protocols, delegation and oversight.
Good faith exam: Physician or an authorised licensee.
Delegation and supervision: KSA 65-28,127 governs licensees who direct, supervise, order, refer, accept responsibility for, enter practice protocols with, or delegate acts constituting the practice of the healing arts.
The gate that catches operators: The entity form. Kansas professional corporations are designated “PA” (Professional Association), not “PC” — a small thing that shows whether your adviser has done this here before.
Primary sources: KSA 65-28,127; the licence-use subsection (b)(15); Kansas Board of Healing Arts guidance on corporations
Last verified: 2026-09-03

Kansas hands the physician a subsection number. Every other state leaves them to infer the exposure from a doctrine.

Go deeper: Medical direction in Kansas · The Kansas licence-use statute · In Kansas it is a PA, not a PC

Kentucky

Corporate practice of medicine: Restricted for the clinical entity. A non-physician participates through an MSO or management arrangement rather than owning it; a qualifying APRN may own a med spa.
Who may hold the medical-director role: An MD or DO, or an APRN meeting Kentucky’s educational and experiential requirements.
Good faith exam: An RN or LPN may administer an injection only when lawfully ordered by a qualified prescriber as part of a documented medical plan of care.
Delegation and supervision: APRN prescriptive authority runs through a collaborative agreement until the four-year threshold for non-scheduled drugs, after which it is independent for those. APRNs may order and stock non-scheduled legend drugs for the practice.
The gate that catches operators: Three chapters at once — KRS 311 (medicine), KRS 314 (nursing) and KRS 317A (cosmetology). Injectables, laser and IV therapy are the practice of medicine.
Primary sources: KRS 311; KRS 314; KRS 317A; Kentucky board advisory opinions
Last verified: 2026-09-03

The overlap is the hazard: a clinic usually asks only the chapter it already knows.

Go deeper: Medical direction in Kentucky · Kentucky’s three chapters · The four-year prescriptive threshold

Louisiana

Corporate practice of medicine: Yes. A corporation may not practise medicine except a Professional Medical Corporation owned and governed exclusively by physicians.
Who may hold the medical-director role: MD or DO. Physicians alone delegate the medical acts — neurotoxin, fillers, lasers, microneedling.
Good faith exam: A PRE-TREATMENT PHYSICAL EXAMINATION BY THE PHYSICIAN, with the prescriber physically present on the premises.
Delegation and supervision: An RN may perform light treatments, non-ablative laser, FDA-approved neurotoxin injectables and chemical peels on a prescriber’s order with a physician or NP physically present — and is EXPRESSLY PROHIBITED from dermal fillers.
The gate that catches operators: Neurotoxin and filler are not the same delegation. Book them into the same RN column and a scheduling problem reads as a scope problem.
Primary sources: LSBME Rule § 7911; LSBME Statement of Position on the corporate practice of medicine
Last verified: 2026-09-03

Split the menu by licence before you split it by price.

Go deeper: Medical direction in Louisiana · Prescriber on the premises · Why an RN may not inject filler here

Mississippi

Corporate practice of medicine: Restricted in practice through the collaboration rules rather than an ownership bar alone.
Who may hold the medical-director role: A collaborating physician within 75 MILES of the primary practice location, practising in Mississippi at least 20 hours a week or 80 hours a month.
Good faith exam: Physician, or an NP under an approved, filed collaborative agreement.
Delegation and supervision: Quality-assurance chart review of 10% or 20 charts, whichever is fewer, per quarter, documented. The agreement must be written, signed, filed with the Board of Nursing, retained on site and available for inspection at any time.
The gate that catches operators: TELEMEDICINE HOURS ARE EXPRESSLY EXCLUDED from the 20-hour count. A national network leaning on remote coverage does not meet it.
Primary sources: Mississippi Board of Nursing collaborative practice rules (75-mile radius; 20 hrs/week or 80/month; quarterly QA review)
Last verified: 2026-09-03

Mississippi is not requiring availability. It is requiring a physician with a real, physical Mississippi practice, and the physician’s specialty has to be compatible with the NP’s.

Go deeper: Medical direction in Mississippi · The Mississippi hours rule · Quarterly chart review

Oklahoma

Corporate practice of medicine: No ownership bar. A lay person or entity may own the med spa provided they do not interfere with the physician’s professional judgment.
Who may hold the medical-director role: A physician medical director genuinely involved in protocols, delegation and oversight — open ownership puts MORE weight on the role, not less.
Good faith exam: A good faith exam before treatment. An RN may administer injectables and infusions on a valid order AFTER the exam, but may not perform the exam and may not prescribe.
Delegation and supervision: Written protocols covering each delegated service. NPs participate through a collaboration or protocol arrangement and do not independently own the clinical entity. Unlicensed staff never for medical procedures.
The gate that catches operators: Nobody is forced to have the structure conversation at formation, so the arrangement becomes whatever it drifted into.
Primary sources: Okla. tit. 59 §§ 492, 519.6, 567.4c; Oklahoma State Board of Medical Licensure and Supervision guidance
Last verified: 2026-09-03

§ 492 defines the practice of medicine broadly, and the board treats injectable treatments and laser therapies as medical acts.

Go deeper: Medical direction in Oklahoma · Oklahoma has no ownership ban · Who orders the treatment

Oregon

Corporate practice of medicine: Restricted, and SB 951 is the most restrictive MSO statute in the country.
Who may hold the medical-director role: A licensed physician — or an independent nurse practitioner — actively involved in patient care and supervision. Not a name on a protocol.
Good faith exam: Every med spa patient is treated as the director’s own: an evaluation establishing the diagnosis and treatment, informed consent before treatment, and proper documentation.
Delegation and supervision: Diagnosis of a medical condition and development of a treatment plan are NON-DELEGABLE to anyone not licensed to provide independent medical judgment. Delegation otherwise only where the director has confirmed the staff member’s education and training.
The gate that catches operators: SB 951 bars dual roles between the professional entity and the MSO and bars MSO control over clinical and defined business decisions. Ownership and control rules bite 1 Jan 2026 for entities formed on or after 9 June 2025, and 1 Jan 2029 for pre-existing ones.
Primary sources: Or. SB 951 (2025); ORS ch. 677; Oregon Medical Board guidance
Last verified: 2026-09-03

Restrictive-covenant provisions applied immediately. The ownership clock is the date to diary.

Go deeper: Medical direction in Oregon · Oregon SB 951 · They are your patients · The 2029 deadline

South Carolina

Corporate practice of medicine: No ownership bar — the Board does not license or regulate corporations. A non-licensee may not control the practice of medicine or independent clinical judgment.
Who may hold the medical-director role: A South Carolina-licensed physician with genuine clinical control over medical decisions, on site for certain procedures.
Good faith exam: The physician. Initial patient examinations are expected of the director.
Delegation and supervision: NP and PA within scope under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: The Board reaches the LICENSEE, not the company. An aggressive structure transfers the exposure onto your medical director personally.
Primary sources: South Carolina Board of Medical Examiners guidance and disciplinary jurisdiction
Last verified: 2026-09-03

This is the asymmetry to explain to any physician considering a South Carolina directorship — and they are usually the last person shown the operating agreement.

Go deeper: Medical direction in South Carolina · The Board regulates your physician · On site for the initial exam

Utah

Corporate practice of medicine: Utah does not restrict ownership. It writes down, in detail, who may do what and where.
Who may hold the medical-director role: A cosmetic medical procedure supervisor: a physician with an unrestricted licence under the Medical Practice Act, or an APRN with an unrestricted licence under the Nurse Practice Act, acting within scope.
Good faith exam: The supervisor, within scope.
Delegation and supervision: Statutory delegation groups. Group A includes PAs under the Utah Physician Assistant Act, RNs, MASTER ESTHETICIANS and electrologists evaluating for or performing laser hair removal. Supervision must be of the person performing the procedure WHILE they perform it.
The gate that catches operators: The procedure may only be performed in a COSMETIC MEDICAL FACILITY — Utah regulates the venue, not just the act. Ablative procedures may not be delegated to anyone not licensed under the Medical or Osteopathic Practice Acts, subject to limited APRN exceptions.
Primary sources: Utah Code § 58-1-505; Utah Physician Assistant Act; Medical Practice Act; Osteopathic Medical Practice Act
Last verified: 2026-09-03

Master esthetician is a licence category most states do not have, and it changes who can legally be on your rota.

Go deeper: Medical direction in Utah · The cosmetic medical facility · Utah delegation groups

Wisconsin

Corporate practice of medicine: Yes. Every shareholder, director and officer must be licensed in the same field, or be a health care professional — at all times, not just at formation.
Who may hold the medical-director role: A Wisconsin-licensed physician. No person may practise medicine and surgery in Wisconsin without a licence from the Medical Examining Board.
Good faith exam: Physician or an authorised licensee. A physician using telemedicine to diagnose or treat a patient located in Wisconsin must be licensed by the Medical Examining Board.
Delegation and supervision: NP and PA within scope under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: The automatic conversion provision: if all shareholders cease at any one time and for any reason to be licensed in the field the corporation was organised for, the service corporation is converted into a business corporation by operation of law.
Primary sources: Wis. Stat. § 180.1901(2); Wis. Stat. § 448.03; Wis. Admin. Code ch. Med 24; Wis. Stat. ch. 766
Last verified: 2026-09-03

Wisconsin names CONTROL as well as ownership, which reaches arrangements that keep the share register clean but move the decisions.

Go deeper: Medical direction in Wisconsin · The automatic conversion trap · Ownership or control

Delaware

Corporate practice of medicine: Yes. A professional service corporation may be formed only by licensees of the SAME profession.
Who may hold the medical-director role: A Delaware-licensed MD or DO. Delaware grants nurse practitioners full practice authority, but the med spa director role is physician-held where the menu exceeds NP scope.
Good faith exam: A qualified practitioner must evaluate the patient and document the decision before treatment. Delegation is only as good as the documentation behind it.
Delegation and supervision: NP under full practice authority within NP scope; PA under the applicable arrangement; RN within scope on a valid order, documented.
The gate that catches operators: The same-profession rule kills mixed-licence equity. A physician and a nurse practitioner cannot co-own one Delaware professional service corporation.
Primary sources: Del. Code tit. 8 ch. 6 (Professional Service Corporations); Del. Code tit. 24 ch. 17 (Medical Practice Act); Del. Code tit. 24 ch. 19
Last verified: 2026-09-03

Delaware is where people incorporate by reflex. The general corporation law is permissive; the professional service corporation statute is not, and only the second one governs the clinical entity.

Go deeper: Medical direction in Delaware · Delaware’s same-profession ownership rule · Delegation is only as good as its documentation

Arkansas

Corporate practice of medicine: Yes. Ownership of the medical entity is physician-held.
Who may hold the medical-director role: An Arkansas-licensed MD or DO.
Good faith exam: ⚠️ Confirm the in-person examination requirement with the Arkansas State Medical Board BEFORE building a remote intake funnel. This is the single question that decides whether an asynchronous model works here.
Delegation and supervision: APRN under the applicable collaborative arrangement; RN within scope on a valid order from a practitioner who has evaluated the patient.
The gate that catches operators: A remote-first funnel designed in another state can fail on the examination question alone, after the marketing spend.
Primary sources: Ark. Code Ann. § 17-95-201 et seq.; Arkansas State Medical Board regulations
Last verified: 2026-09-03

We flag this one as a question rather than an answer on purpose. Vendors publish confident opposite claims about Arkansas telemedicine examinations, and the Board is the only source worth acting on.

Go deeper: Medical direction in Arkansas · Arkansas keeps ownership with physicians · The Arkansas in-person exam question

Iowa

Corporate practice of medicine: Yes, with exceptions.
Who may hold the medical-director role: An Iowa-licensed MD or DO.
Good faith exam: A physician evaluation and order before treatment. Iowa also regulates how the exam and the practice are ADVERTISED — the med spa rule reaches your marketing, not only your clinic.
Delegation and supervision: ARNP within scope; PA under the applicable arrangement; laser work runs through the qualified laser technician framework.
The gate that catches operators: IAC 653—13.8 is a rule written specifically about medical spas, including how they may hold themselves out. Most operators never read it because they are looking for a statute.
Primary sources: Iowa Admin. Code 653—13.8; Iowa Code ch. 148; Iowa Code ch. 152
Last verified: 2026-09-03

Iowa is one of the few states where the med spa rule names advertising. If your website describes services the licence mix cannot support, that is itself the exposure.

Go deeper: Medical direction in Iowa · Iowa regulates how you advertise the med spa · Iowa’s qualified laser technician

Nebraska

Corporate practice of medicine: No corporate practice doctrine — and oversight obligations are unaffected by that.
Who may hold the medical-director role: An MD, DO, or an independent nurse practitioner within NP scope.
Good faith exam: An evaluation and order by a practitioner permitted to make that decision. The absence of a corporate practice doctrine does nothing to relax it.
Delegation and supervision: NP independent within scope after the transition requirements; PA under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: THREE separate regulators: the Board of Medicine and Surgery, the Board of Nursing, and facility licensing at DHHS. Clearing one is not clearing the others.
Primary sources: Neb. Rev. Stat. ch. 38 art. 20 (Medicine and Surgery); ch. 38 art. 23 (Nursing); Neb. DHHS facility licensure
Last verified: 2026-09-03

“No CPOM” is the least useful fact about Nebraska. The compliance work is entirely in delegation, supervision and facility licensing.

Go deeper: Medical direction in Nebraska · Nebraska has three regulators, not one · No doctrine, still oversight

New Mexico

Corporate practice of medicine: Not actively enforced. Non-physicians may hold the business.
Who may hold the medical-director role: An MD or DO where the menu exceeds NP scope; New Mexico grants nurse practitioners full practice authority.
Good faith exam: A practitioner permitted to prescribe the treatment must evaluate the patient and issue the order. An RN may inject only on that order.
Delegation and supervision: NP independent within NP scope; PA under the applicable arrangement; RN within scope, on an order from a practitioner who evaluated the patient.
The gate that catches operators: Open ownership plus full practice authority moves the constraint entirely onto the MENU. What you offer, not who owns you, decides which licences you need.
Primary sources: NMSA 1978 ch. 61 art. 6 (Medical Practice Act); ch. 61 art. 3 (Nursing Practice Act)
Last verified: 2026-09-03

New Mexico is the clearest case for menu-driven planning. Add one service outside NP scope and a structure that needed no physician now needs one.

Go deeper: Medical direction in New Mexico · Full practice authority and the menu · An RN injects on an order, not on a title

New Hampshire

Corporate practice of medicine: No. The fee-splitting prohibition was REPEALED in 1996.
Who may hold the medical-director role: An MD, DO, or a full-practice-authority nurse practitioner within NP scope.
Good faith exam: An evaluation and order by a practitioner permitted to make the decision, before treatment.
Delegation and supervision: ⚠️ LASER use is limited to physicians and physician assistants. NP within scope otherwise; RN within scope on a valid order.
The gate that catches operators: The laser restriction. New Hampshire is permissive on structure and narrow on who may fire a device — the opposite of the usual trade.
Primary sources: N.H. RSA ch. 329 (Medicine); RSA ch. 326-B (Nursing); 1996 repeal of the fee-splitting prohibition
Last verified: 2026-09-03

Repeal of the fee-splitting ban makes New Hampshire structurally flexible. It says nothing at all about scope of practice, and operators routinely conflate the two.

Go deeper: Medical direction in New Hampshire · New Hampshire repealed its fee-splitting ban · Lasers: physicians and PAs only

Idaho

Corporate practice of medicine: RESCINDED by the Idaho Board of Medicine in 2016. Non-physicians may own.
Who may hold the medical-director role: A licensed physician — and Idaho maintains DETAILED rules on that person’s qualifications and experience, which is unusual for an open-ownership state.
Good faith exam: An evaluation and order by a practitioner permitted to make it. Idaho grants nurse practitioners full practice authority, so an NP-led model exists for services within NP scope.
Delegation and supervision: NP independent within scope; PA under the applicable arrangement; RN within scope on a valid order; written protocols throughout.
The gate that catches operators: The person, not the entity. Idaho removed the ownership constraint and specified director qualifications — verify your intended director actually meets them for YOUR service menu.
Primary sources: Idaho Board of Medicine 2016 rescission; Idaho Code ch. 54-18 (Medical Practice Act); Idaho Code ch. 54-14 (Nursing)
Last verified: 2026-09-03

Idaho is one of the very few states where the change can be dated. It was not eroded here; it was withdrawn.

Go deeper: Medical direction in Idaho · Idaho rescinded corporate practice in 2016 · Idaho cares who your medical director is

Hawaii

Corporate practice of medicine: No express prohibition in HRS ch. 453. The practical position is a physician-led ownership model.
Who may hold the medical-director role: A licensed MD or DO.
Good faith exam: Neurotoxin injections and laser treatments are MEDICAL services and must be performed by appropriately licensed professionals under the physician medical director’s supervision, following an evaluation.
Delegation and supervision: NP has full practice authority for clinical purposes — but may NOT own the med spa business; PA within scope; RN within scope on a valid order.
The gate that catches operators: Full practice authority does not carry ownership. Plans built on “the NP is independent, so the NP can own it” fail in Hawaii.
Primary sources: HRS ch. 453 (Medicine and Surgery); HRS ch. 457 (Nursing)
Last verified: 2026-09-03

A state with no written ban and a settled market answer is the hardest kind to research from a chart. Statutory silence is an unresolved question, not permission.

Go deeper: Medical direction in Hawaii · Full practice authority is not ownership · No express ban, physician-led result

Rhode Island

Corporate practice of medicine: Yes — and Rhode Island goes further, licensing the med spa itself as a healthcare facility.
Who may hold the medical-director role: A physician OR certified nurse practitioner, employed or contracted, who is TRAINED IN THE INDICATIONS AND PERFORMANCE of the cosmetic medical procedures the med spa offers. General licensure does not satisfy it.
Good faith exam: An evaluation and order by the medical director or another practitioner permitted to make it, before treatment.
Delegation and supervision: ⚠️ Licensed practical nurses, nursing assistants and MEDICAL ASSISTANTS may not provide services — it falls outside their scopes. RN within scope on a valid order.
The gate that catches operators: Facility licensure gates the OPENING DATE, and the exclusion of LPNs, NAs and MAs changes your cost per treatment against any model built in another state.
Primary sources: R.I. Medical Spas Safety Act; R.I. Dept. of Health guidance for medical spa and IV therapy businesses; R.I. Gen. Laws ch. 5-37
Last verified: 2026-09-03

The director’s qualification is tied to the procedures on the menu. Add a procedure category and you have changed what your director must evidence.

Go deeper: Medical direction in Rhode Island · Rhode Island licenses the med spa itself · Who may not work in a Rhode Island med spa

West Virginia

Corporate practice of medicine: Yes. A corporation may not practise medicine without a CERTIFICATE OF AUTHORIZATION from the Board of Medicine.
Who may hold the medical-director role: A West Virginia-licensed MD or DO exercising genuine oversight of the medical services delivered.
Good faith exam: A good faith examination and treatment plan before treatment, by a qualified practitioner, under signed protocols.
Delegation and supervision: NP and PA within scope under the applicable arrangement; RN within scope on a valid order; delegation only to practitioners whose licence and training support the task.
The gate that catches operators: § 30-3-15. Forming the entity is not the last step — the entity needs the Board’s certificate BEFORE it holds itself out as providing medical services.
Primary sources: W. Va. Code § 30-3-15; W. Va. Code ch. 30 art. 3; W. Va. Code ch. 30 art. 7
Last verified: 2026-09-03

The certificate means the Board already holds a file on your entity. Oversight evidence should be contemporaneous, not reconstructable.

Go deeper: Medical direction in West Virginia · The certificate of authorization · What the director actually owes

Maine

Corporate practice of medicine: Recognised but loosely enforced. Non-physicians, INCLUDING ESTHETICIANS, may own a medical spa.
Who may hold the medical-director role: An MD, DO, or a full-practice-authority nurse practitioner within NP scope. Not universally required.
Good faith exam: A qualified practitioner must evaluate and authorise treatment. Ownership confers NO authority to perform or to order.
Delegation and supervision: ⚠️ Maine grants NPs full practice authority only AFTER a supervised transition period — before that, a physician relationship is required, and the answer is INDIVIDUAL-SPECIFIC.
The gate that catches operators: Reading the ownership permission as a clinical one. An esthetician-owner who employs clinical staff is lawful; an esthetician-owner who injects is not.
Primary sources: Me. Rev. Stat. tit. 32 ch. 48 (Medicine); tit. 32 ch. 31 (Nursing); Maine State Board of Nursing transition-to-practice requirements
Last verified: 2026-09-03

Ownership, scope and independence are three different questions in Maine with three different answers. Conflating any two produces a plan that fails on the third.

Go deeper: Medical direction in Maine · You may own what you may not perform · When a Maine NP needs a physician

Montana

Corporate practice of medicine: Yes. Ownership of a medical or professional nursing practice is limited to physicians and to QUALIFYING nurse practitioners.
Who may hold the medical-director role: An MD, DO, or a qualifying nurse practitioner with the correct education and training, within NP scope.
Good faith exam: An evaluation and order by a practitioner permitted to make it, before treatment.
Delegation and supervision: NP has full practice authority within NP scope; PA under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: There is no third ownership category. An investor, esthetician or spa operator does not own the clinical entity — they use a management services organisation.
Primary sources: Mont. Code Ann. tit. 37 ch. 3 (Medicine); tit. 37 ch. 8 (Nursing)
Last verified: 2026-09-03

NP ownership does not expand NP scope. An NP-owned entity still needs an appropriately licensed practitioner for anything outside it.

Go deeper: Medical direction in Montana · Two ownership routes, not interchangeable · The MSO route for everyone else

Alaska

Corporate practice of medicine: No express statute. AS 10.45, the Professional Corporation Act, does the same work through licensure and a board filing.
Who may hold the medical-director role: An Alaska-licensed MD or DO.
Good faith exam: An evaluation and order by a practitioner permitted to make it. ⚠️ Alaska’s Division convened a Medical Spa Services Work Group and published a DRAFT interdisciplinary scope matrix — who may perform what is still being mapped.
Delegation and supervision: Conservative delegation only, to practitioners whose own licence clearly supports the task, under written protocols. Silence in an unsettled state is not permission.
The gate that catches operators: AS 10.45 requires a CERTIFICATE FROM THE PROFESSION’S REGULATORY BOARD, certifying every incorporator, director and shareholder is licensed, filed WITH the articles of incorporation. AS 10.45.030 limits a PC to one type of professional service.
Primary sources: AS 10.45.020; AS 10.45.030; AS 08.64 (State Medical Board); Alaska Div. of Corporations, Business and Professional Licensing, Medical Spa Services Work Group
Last verified: 2026-09-03

“No CPOM statute” is the most misleading summary in this field. There is no prohibition to point at, and there is a filing that puts your shareholder list in front of a licensing board before you open.

Go deeper: Medical direction in Alaska · A board certifies your shareholders · Alaska is still drawing its med spa map

District of Columbia

Corporate practice of medicine: Yes, through DC Code § 29-508: shareholders, directors and officers must each be licensed for the service the corporation is organized for.
Who may hold the medical-director role: A DC-licensed MD or DO.
Good faith exam: An evaluation and order by a practitioner permitted to make it, before treatment. The entity rule says nothing about how the care is supervised — that is a separate obligation.
Delegation and supervision: NP and PA within scope under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: The only unlicensed seat is the SECRETARY of a single-shareholder professional corporation, and that person may not perform professional services.
Primary sources: DC Code § 29-508(a), (b), (c); DC Code tit. 3 ch. 12 (Health Occupations)
Last verified: 2026-09-03

§ 29-508(c) expressly provides that a shareholder need not have an employment relationship with the corporation or participate in producing its income. The District has written the passive LICENSED shareholder into its code — it has not relaxed licensure.

Go deeper: Medical direction in District of Columbia · Exactly who may hold shares · The passive shareholder provision

North Dakota

Corporate practice of medicine: No express prohibition in N.D.C.C. ch. 43-17. ⚠️ Sources citing § 43-17-31 as a ban are misreading a section titled “Grounds for disciplinary action”.
Who may hold the medical-director role: A North Dakota-licensed MD or DO.
Good faith exam: ⚠️ § 43-17-02.3: the practice of medicine is DEEMED TO OCCUR IN THE STATE THE PATIENT IS LOCATED. Whoever performs the exam needs an ACTIVE North Dakota licence, wherever they sit.
Delegation and supervision: NP and PA within scope under the applicable nursing and medical rules; RN within scope on a valid order.
The gate that catches operators: Licensure by patient location. Statutory exceptions are narrow — organ harvest team, air ambulance, one-time diagnostic consult to a licensed ND physician or ≤7 days teaching, board-approved charitable, board rules. None is a business model.
Primary sources: N.D.C.C. § 43-17-02.3; N.D.C.C. § 43-17-31; N.D.C.C. ch. 43-12.1 (Nursing)
Last verified: 2026-09-03

The fee-splitting ground in § 43-17-31 carries an express carve-out: it does not affect the lawful distributions of professional partnerships, corporations, limited liability companies or associations.

Go deeper: Medical direction in North Dakota · Practice occurs where the patient is · The fee-splitting carve-out

Puerto Rico

Corporate practice of medicine: Governed by the Junta de Licenciamiento y Disciplina Médica under Ley 139-2008. A mainland licence confers nothing on the island.
Who may hold the medical-director role: An MD or DO licensed IN PUERTO RICO.
Good faith exam: An evaluation by a practitioner licensed by the Junta. ⚠️ Ley 8-2025 (approved 11 April 2025) removed the separate telemedicine CERTIFICATION for professionals already authorized to practise in Puerto Rico — practitioners licensed only in a mainland or federal jurisdiction still need it.
Delegation and supervision: Within scope under the applicable Puerto Rico rules; RN within scope on a valid order.
The gate that catches operators: Fifty-state coverage is not national coverage. A brand advertising nationwide availability with fifty licences has not covered Puerto Rico.
Primary sources: Ley 139-2008 (Junta de Licenciamiento y Disciplina Médica); Ley 168-2018 (Telemedicina), as amended by Ley 8-2025
Last verified: 2026-09-03

Spanish is the island’s language of record. Patient-facing consent and clinical materials should exist in it, as a practical necessity rather than an enhancement.

Go deeper: Medical direction in Puerto Rico · Ley 8-2025 and the certification · A mainland licence does not reach PR

South Dakota

Corporate practice of medicine: Yes — SDCL 36-4-8.1 declares it the public policy of the state, with an employment exception on three conditions.
Who may hold the medical-director role: A South Dakota-licensed MD or DO. Under SDCL 47-11-3 all officers, directors and shareholders of a medical corporation must be licensed AT ALL TIMES, and no proxy to vote shares may be given to an unlicensed person.
Good faith exam: An evaluation and order by a practitioner permitted to make it. ⚠️ SDCL 36-4-8.2: use of a LASER or ionizing radiation to cut “or otherwise alter” human tissue IS SURGERY constituting the practice of medicine.
Delegation and supervision: Delegation only to a practitioner whose licence and training support performing a surgical act, under written protocols naming device, settings, indications and contraindications.
The gate that catches operators: A physician employment agreement may not run more than THREE YEARS, renewable annually — and the corporation may take no profit from the practice of medicine itself, though facility, equipment and administrative charges are expressly allowed.
Primary sources: SDCL 36-4-8.1; SDCL 36-4-8.2; SDCL 47-11-1; SDCL 47-11-2; SDCL 47-11-3
Last verified: 2026-09-03

The laser definition decides most of a South Dakota med spa menu. Check it before the purchase order, not after the staff are trained.

Go deeper: Medical direction in South Dakota · The three-condition exception · Laser use is surgery

Vermont

Corporate practice of medicine: NEW. H.583 was signed 15 June 2026 and took effect 1 July 2026 — drafted as a CONTROL and DISCLOSURE statute rather than an ownership ban.
Who may hold the medical-director role: A Vermont-licensed MD or DO with genuine authority over clinical decisions. Vermont grants nurse practitioners full practice authority within NP scope.
Good faith exam: An evaluation and order by a practitioner permitted to make it. § 9772’s stated purpose is to keep clinical and treatment decisions EXCLUSIVELY in the hands of health care providers.
Delegation and supervision: NP independent within scope; PA under the applicable arrangement; RN within scope on a valid order.
The gate that catches operators: ⚠️ § 9773: EVERY health care facility AND EVERY management services organization must file with the Green Mountain Care Board ON OR BEFORE 1 MARCH 2027 — the full ownership report if a private equity group or hedge fund held an interest as of 1 June 2026, otherwise an ATTESTATION that none did. There is no “not applicable” option.
Primary sources: Vt. H.583 (2026), § 9772, § 9773; 26 V.S.A. ch. 23 (Medicine)
Last verified: 2026-09-03

§ 9772 enumerates four forms of interference with provider judgment and eight controls that may not be exercised or delegated — the clearest published articulation of improper MSO control in the country, and worth using as a checklist outside Vermont.

Go deeper: Medical direction in Vermont · The 1 March 2027 filing · The § 9772 control checklist

Wyoming

Corporate practice of medicine: Yes, through W.S. 17-3-101: capital stock owned EXCLUSIVELY by persons licensed to practise the profession BY THE STATE OF WYOMING.
Who may hold the medical-director role: An MD or DO licensed IN WYOMING. An out-of-state licence does not satisfy the statute.
Good faith exam: An evaluation and order by a practitioner permitted to make it. Services may be rendered only by and through licensed stockholders OR LICENSED EMPLOYEES — the treating clinicians need not be owners.
Delegation and supervision: NP and PA within scope under the applicable arrangement; RN within scope on a valid order; written protocols throughout.
The gate that catches operators: Wyoming’s permissive LLC and holding-company reputation says NOTHING about the clinical entity. A single Wyoming LLC doing both is the most common local mistake.
Primary sources: W.S. 17-3-101; W.S. tit. 33 ch. 26 (Medical Practice Act); W.S. tit. 33 ch. 21 (Nursing)
Last verified: 2026-09-03

Each licensee “remains as fully liable and responsible for his professional activities … as though practising individually rather than in a corporation”. Incorporating does not move the medical director’s personal exposure.

Go deeper: Medical direction in Wyoming · Shareholders licensed by Wyoming · Personally on the hook

The five tests a structure has to pass

Regardless of state, a review comes down to the same five questions. Most structures that fail, fail on the third or the fifth.

Who owns the entity that practises medicine? In most states the answer has to be a licensee. North Carolina requires the business to be owned in its entirety by active licensees. New York restricts it to a physician licensed under article 131 — not an RN, not an NP, not an investor. Ohio is the outlier that permits corporate ownership outright.
Who is making clinical decisions? Ownership can be correct and the structure still fail here. California’s SB 351 names the specific decisions a management company may not touch: treatment options, patient quotas, competency-based staffing. Ohio abolished corporate practice and still prohibits controlling clinical judgment under ORC 4731.22.
How is the management company paid? This is where the most common structure in the market breaks. New York prohibits fee splitting with a non-licensee, which makes a percentage-of-revenue management fee unlawful rather than merely aggressive. Fees have to be fixed, at fair market value, and agreed in writing before services are rendered.
Is delegation documented in the form the state recognises? Texas does not recognise verbal delegation and requires the physician’s name and TMB licence number posted in treatment areas. Pennsylvania requires the CRNP collaborative agreement to be filed with the State Board of Medicine, not merely signed. Ohio requires a delegate to have observed fifteen and performed twenty procedures per device type.
Is the director doing the work? North Carolina’s board has published what the failure mode looks like: a physician paid $2,000 a month, told he need not attend, over a med spa owned by a non-licensee — described as aiding the unlicensed practice of medicine. New Jersey’s Allstate v. Northfield went further and reached the people who promoted the structure.

What changed recently

Content in this market goes stale quietly. These are the changes that have moved the answer in the last eighteen months, with the effective dates that matter.

Effective	What changed	Detail
12 Feb 2026	FDA approved boxed-warning removal for the first six hormone therapy products (Prometrium, Divigel, Cenestin, Enjuvia, Estring, Bijuva). The endometrial cancer boxed warning REMAINS for systemic estrogen-only products, and none of it touches compounded preparations.	The 2026 HRT label change
1 Jan 2026	California SB 351 took effect, barring private-equity and management entities from controlling treatment options, patient quotas or competency-based staffing.	California SB 351 and MSO agreements
1 Jan 2026	Oregon SB 951 ownership and control restrictions began applying to entities formed on or after 9 June 2025 — the most restrictive MSO statute in the country. Pre-existing entities have until 2029.	Oregon SB 951
31 Dec 2026	The DEA telemedicine flexibilities expire. This is the fourth temporary extension. The Ryan Haight in-person requirement was never repealed, the proposed special registration framework has no final rule, and testosterone is Schedule III — so telehealth TRT sits inside this deadline.	The DEA telemedicine deadline
1 Sep 2025	The Texas elective IV therapy law took effect: prescribing limited to a PA or APRN under physician supervision, administration to a PA, APRN or RN, and prescriptive authority agreements count toward the cap.	Texas delegation rules
2 Jun 2025	Texas SB 378, the injectables bill, was VETOED. It never became law. It is still published as live Texas requirement on competitor sites.	The Texas SB 378 veto
7 Apr 2025	Colorado HB25-1024 added on-site signage, website and advertising disclosure, and seven-year consent retention for med spas using unlicensed individuals for delegated aesthetic services.	Colorado HB25-1024
22 May 2025	FDA enforcement discretion for 503B compounding of semaglutide and tirzepatide ended, following 503A on 22 April 2025. Tirzepatide came off the shortage list in October 2024 and semaglutide on 21 February 2025. Routine programme-wide compounding of these no longer has a shortage justification.	Compounded GLP-1s after the shortage
2 Aug 2024	Illinois SB 2979 ended per-scan damages accrual under BIPA. The Seventh Circuit held that retroactive in 2026. The underlying exposure for face-geometry scans is unchanged.	Illinois CPOM and BIPA

Eight things you will read about this that are wrong

Each of these is currently published by a company selling compliance services. Each is corrected below against the primary source. This section exists because the single most expensive mistake in this market is acting on confident content written for a different state.

“Texas SB 378 sets the rules for med spa injectables.”

SB 378 was vetoed on 2 June 2025 and never became law. Texas delegation is governed by the Medical Practice Act and 22 TAC 169.26, and what did pass in 2025 was the elective IV therapy law, effective 1 September. Read the correction.

“Arizona requires physicians to own 51% of clinical assets.”

Arizona grants nurse practitioners full practice authority. An NP may own the clinic, prescribe with the appropriate registrations, and act as their own clinical lead, and the regulator is the Board of Nursing rather than the Medical Board. The 51% claim contradicts the statute. Read the correction.

“Your medical director has to be a dermatologist or a plastic surgeon.”

Florida requires an active, unencumbered MD under chapter 458 or DO under chapter 459. There is no specialty requirement. Tennessee’s registry does not impose one either. This is a pricing myth used to justify a higher fee. Read the correction.

“Every state prohibits the corporate practice of medicine.”

Ohio has abolished the doctrine outright, and Florida does not broadly prohibit it — non-physicians may own a med spa in Florida, and the real gate there is AHCA clinic licensure. Applying California framing to a Florida operator produces advice that is wrong in both directions. Read the correction.

“A percentage-of-revenue management fee is the industry standard.”

It is common, and in New York it is unlawful. Fee splitting between a professional entity and a non-licensee is prohibited under Educ. Law § 6530(18) and (19) and 8 NYCRR § 29.1(b)(4). Fees have to be fixed, at fair market value, and agreed in writing before services are rendered. Read the correction.

“Compounded semaglutide and tirzepatide are still fine, there is a shortage.”

There is not. Tirzepatide came off the shortage list in October 2024 and semaglutide on 21 February 2025, and FDA enforcement discretion ended on 22 April 2025 for 503A and 22 May 2025 for 503B. Narrow patient-specific compounding may persist; routine programme-wide compounding does not. Read the correction.

“Retatrutide is available through a compounding pharmacy.”

There is no lawful compounding pathway for it. It is investigational, it is not a component of an approved drug, it has no USP monograph, and it is not on the 503A or 503B bulk substance lists. Our providers do not prescribe it and our protocols do not permit it. Read the correction.

“A biometric consent form is only a California problem.”

Illinois BIPA carries a private right of action with no requirement to prove harm, at $1,000 for negligent and $5,000 for intentional violations. A before-and-after photograph is not a biometric identifier; a scan of face geometry is — which is exactly what some aesthetic imaging systems produce. Read the correction.

How the fee has to be structured

This is the part operators are told least about, and it is the part that turns a compliance problem into a fraud problem. There are three constraints and they compound.

Fee splitting. Several states prohibit paying a non-licensee a share of clinical revenue. New York prohibits it outright. Because a single national structure has to survive the strictest state you operate in, MDside prices on a fixed monthly fee everywhere rather than maintaining two models.
Fair market value. The fee has to be defensible as payment for services actually rendered, at a rate an unrelated party would pay. A directorship fee that scales with the clinic’s revenue is not a fee for services; it is a share of the practice.
Written and prior. New York requires the arrangement in writing and agreed before services are rendered. Retroactive documentation is the single most common finding when an arrangement is reviewed.

What that means in practice: a fixed monthly fee per state, set in advance, tied to the scope of the menu and the number of sites rather than to revenue. No setup fee, no percentage, no per-patient cut of clinical income. If a provider quotes you a percentage, that is the whole conversation — ask which states they are prepared to operate that model in. How pricing works in detail.

What the role actually involves

A medical director is not a signature. The role carries protocol approval, delegation and supervision, chart review, adverse-event response, and personal licence exposure when something goes wrong. If the physician on your paperwork does none of the following, you have bought a name.

Protocols and standing orders written against your real service menu, and updated when the menu changes rather than when someone remembers.
Delegation that fits each receiving licence. Delegation never expands scope; it only authorises within it. Our clinical standards.
Availability during treatment hours at whatever standard the state sets — on-site, immediately available, or reachable by real-time audio-video.
Chart review at a defined cadence, documented, so that the cadence is provable a year later.
Adverse-event response, including reporting obligations that in some states attach within days of a transfer.
Good faith exams wherever a prescription or an injectable is involved. Who may perform one is not the same in every state — the answer in all fifty-two jurisdictions, with sources.
Staying current. Several of the states above changed in the last eighteen months. A director who is not tracking that is documenting to a standard that has already moved.

Can a nurse practitioner hold the role? In most of them the answer is an unambiguous no. MDside supplies MDs and DOs; NPs, PAs and RNs are your staff, practising within their own licences under protocols an MDside physician approves.

What MDside provides

A named, state-licensed MD or DO who performs the role rather than lending a name to it. How we credential them.
The professional entity and management agreement underneath them, built for the state you are actually operating in.
A network of licensed providers across the states you operate in, so coverage expands as you grow rather than being renegotiated each time.
Good faith exams, clinical review and e-prescribing on a platform we built and run, so every approval is a documented decision by a licensed provider rather than an order typed in afterwards — never an automatic clearance.
503A and 503B pharmacy relationships and in-house or reference lab draws.
Fixed, fair-market fees agreed in advance, in every state. LegitScript certified; how we handle patient data.

What onboarding covers

Four stages, and the first one is free. The full version is here.

State and menu review. We take your actual service list and the states you operate in and tell you which of the five tests above your current structure fails. No fee, and no obligation to use us for the fix.
Structure. Professional entity formation where one is needed, the management agreement, the directorship agreement, and a fee set at fair market value in writing before anything begins.
Providers and protocols. A named director matched to your state and menu, protocols and standing orders written against that menu, delegation documented in the form your state recognises, and your staff briefed on what their own licence permits.
Operating. Good faith exams and clinical review running on our platform, chart review on a documented cadence, and the paperwork updated when the law moves — which, as the table above shows, it does.

Broker, direct hire, or network

Three ways to solve this, and they fail differently. This is written to be useful even if you do not pick us.

	Hiring a local physician direct	A matching or brokerage service	MDside
Who finds the physician	You do, and you carry the credentialing and the reference checks.	They introduce you and step out of the relationship.	We credential, contract and stay in the relationship — the physician is accountable to us as well as to you.
What the fee buys	Their time, on whatever terms you negotiate.	The introduction. Compliance is then your problem.	The director, the entity and agreements, the providers, the protocols, and the platform the exams run on.
Fee structure	Whatever is agreed — often a flat retainer, sometimes a percentage.	Frequently a percentage or a per-patient cut, which is unlawful in New York.	Fixed monthly, fair market value, in writing before services begin, in every state.
Adding a second state	Start over. New physician, new entity, new agreements.	A second introduction and a second fee.	Coverage extends; the structure is built per state on the same operating model.
Good faith exams	Your problem to build or buy separately.	Usually out of scope.	Performed and documented by licensed providers on a platform we run.
When the law changes	You find out when someone tells you.	You find out when someone tells you.	We track it and update protocols and agreements — the changelog above is our own working record.
What you own	The relationship, and all of the risk.	A contact.	A structure that survives being read by a regulator, and the documentation proving it.

Every jurisdiction, with sources

All fifty states, the District of Columbia and Puerto Rico — each with a page written against statute, administrative code, a board position statement or a decided case, and each naming what it relies on. There are no coverage stubs left; the last one was retired on 2026-09-03. For most of the period this site has existed, jurisdictions we had not verified said so on the page rather than paraphrasing another vendor’s summary, and that is why this took batches rather than a weekend.

Buying exams rather than a directorship? There is a matching page for each jurisdiction covering who may perform the good faith exam there: good faith exams by state.

Explore by business type, service line and topic

The requirement changes with what you actually sell, not only with where you sell it. A gym adding weight-loss injections is running a prescription drug programme; an IV bar is administering a drug on an order; an online brand needs a licensed provider in every state it ships into.

By business type

By service line

By topic

New to the vocabulary? The glossary defines corporate practice of medicine, friendly PC, MSO, fee splitting, delegation, standing orders, good faith exam, 503A versus 503B and FDA approved as regulators use them, not as marketing uses them.

Frequently asked questions

What does a medical director actually do?

Approves protocols and standing orders, delegates within each licence’s scope, remains available at the standard the state sets, reviews charts on a defined cadence, and responds to adverse events. A director who does none of these is a signature, and a signature is what regulators look for when a case goes wrong.

Do I legally need a medical director?

It depends on two things: whether your state restricts the corporate practice of medicine, and what is on your menu. Injectables, lasers, IV therapy and prescription weight-loss programmes are delegable medical acts nearly everywhere, and a delegable medical act needs someone with the authority to delegate it. Arizona is the clearest exception, because a nurse practitioner with full practice authority can be their own clinical lead.

Can a nurse practitioner be a medical director?

In most states, no. Texas, California, New York, Georgia, New Jersey, Tennessee, North Carolina, Michigan, Missouri and Minnesota all require a physician in the role. Illinois allows an APRN with full practice authority to own and lead the clinical entity, and Arizona grants NPs full practice authority outright. The full comparison is here.

Does the medical director have to be a dermatologist or plastic surgeon?

No jurisdiction in the verified set of fifty-two requires a specialty. Florida requires an active, unencumbered MD under chapter 458 or DO under chapter 459 and nothing more. The specialty requirement is a marketing claim used to justify a higher fee.

How much does a medical director cost?

A fixed monthly fee, sized to the menu and the number of sites rather than to revenue. Anyone quoting a percentage of clinical revenue is quoting a structure that is unlawful in New York and hard to defend as fair market value anywhere. How our pricing works.

Why can’t I just pay a percentage of revenue?

Because in New York that is fee splitting with a non-licensee under Educ. Law § 6530(18) and (19) and 8 NYCRR § 29.1(b)(4), and because a fee that tracks revenue is difficult to characterise as payment for services rendered rather than a share of the practice. We do not structure fees that way in any state.

Can one physician cover multiple locations?

Usually, subject to the state’s availability standard and to any headcount cap. Georgia caps a delegating physician at four APRN protocol agreements at a time, and Texas counts prescriptive authority agreements toward a statutory cap. Model those limits against your hiring plan before you sign the next lease.

What is a friendly PC, and is it legal?

A professional corporation owned by a licensed physician, which employs the clinical staff, alongside a separate management company that provides everything non-clinical under a management services agreement. It is a recognised structure. It fails when the paperwork says one thing and the operation says another — which is what New Jersey’s Allstate v. Northfield was about. The long version.

Who owns the friendly PC, and what happens if that physician leaves?

A licensed physician owns it, and the succession terms are the part most structures get wrong. Nevada makes it concrete: NRS 89.070 prevents shares transferring to anyone not eligible to hold them, so the exit has to be planned into the documents rather than negotiated later. Nevada in detail.

What is a good faith exam and who can perform it?

A clinical evaluation by a licensed provider establishing that a treatment is appropriate for that patient, before it is given. Who may perform it varies: in Nevada an RN may not, in Pennsylvania an RN may inject only after an exam by a physician, CRNP or PA, and in Florida an RN needs a physician exam and a written order first. Who may perform it in each state, and the full requirements.

Can the good faith exam be done by telehealth?

In many states yes, subject to the state’s telehealth rules and to the standard of care for the specific treatment. It is a real clinical encounter, not a form. Where a controlled substance is involved, the DEA rules apply on top — and those expire on 31 December 2026 absent further action.

We already have a medical director. Can you review what we have?

Yes, and that is the first stage regardless. We read your menu, your delegation documentation and your management agreement against the five tests above and tell you what fails. Book the review.

Do you help with entity formation, or only supply the physician?

Both. The professional entity and the management services agreement are part of the work, because a director signed into a structure that cannot lawfully hold the practice does not solve anything. We are not a law firm and we do not replace your counsel; we build the structure and your counsel reviews it.

How fast can this be in place?

The state and menu review is same-week. Structure and agreements depend on entity formation timelines in your state. Providers and protocols follow the structure. We do not quote a universal number because the honest answer is that Delaware and California are not the same problem.

Do you cover states not on the verified list?

Yes — all fifty states plus D.C. and Puerto Rico. The verified list describes which jurisdictions have a published statute-level write-up on this site, not which we operate in. Tell us where you are and that state moves to the front of the research queue.

Can a non-physician own a med spa?

In Florida and Ohio, yes. In North Carolina the business must be owned in its entirety by active licensees. In New York only a physician licensed under article 131 may own the entity that practises medicine. In Illinois an APRN with full practice authority may. There is no national answer, which is the point of the table above.

Does a med spa have to register with the state?

Tennessee runs a public online registry under Tenn. Code Ann. § 63-6-105 that lists your medical director by name and licence number, and reaches any practice that advertises or holds itself out as a medical spa. Florida’s equivalent gate is AHCA clinic licensure or a certificate of exemption, which you apply for rather than assume.

What happens if a regulator reviews our structure?

They read the agreements, then they compare them with how the business actually runs. Ownership on paper, who signs protocols, whether chart review happened on the cadence claimed, whether the director was reachable, and how the money moves. Documentation that was created after the fact is visible, and it is usually what turns a correctable finding into an enforcement action.

Is a percentage-based MSO fee a problem outside New York?

It is a fair-market-value problem everywhere and an outright prohibition in New York. Because a multi-state operator has to survive the strictest state on its map, the practical answer is to use one defensible model rather than two.

Can you also supply the providers who see patients, not just the director?

Yes. That is the difference between a directorship and clinical infrastructure. Licensed providers in the states you operate in, performing and documenting exams on our platform, with pharmacy and lab routing behind it. How the network works.

Do you prescribe compounded GLP-1 medications?

Only where a patient-specific clinical basis exists. The shortage-era model has ended: tirzepatide came off the shortage list in October 2024, semaglutide in February 2025, and enforcement discretion ended in April and May 2025. What that changed. Our providers do not prescribe retatrutide at all — there is no lawful compounding pathway for it.

Is any of this legal advice?

No. It is a working reference maintained by an operator, with the primary source cited so you can check it. Confirm your obligations with healthcare counsel licensed where you operate, and treat any page in this market that does not cite a statute as marketing.

How this page is maintained

Every state row is verified against statute, administrative code, a board position statement or a decided case — never against another company’s blog. Where two sources disagree we go to the statute, and where the statute is genuinely unsettled we say so on the page rather than picking the answer that sells better; the California standing-orders question under SB 351 is flagged that way above, and so is the Florida Board of Nursing’s position on RN authority. Every jurisdiction is now verified; where a source is genuinely unsettled we say so on the page rather than picking the answer that sells better. Our editorial standards and corrections policy set out how that is decided and how mistakes get fixed. Last reviewed 2026-09-03 by Victor D. Cruz, MD. Corrections are welcome and get made: contact us.

Operating in a state that is not verified yet, or want your current structure read against the five tests? Book a call — the state and menu review is free and you are not obliged to use us for the fix.

General information about medical direction and practice structure, not legal advice. Requirements differ by state and change often; several of the items above changed within the last eighteen months. Confirm your obligations with healthcare counsel licensed where you operate.