Oregon is the most demanding state in our coverage, and it is demanding from two directions at once.
On the structural side, SB 951, signed June 9, 2025, is the most restrictive corporate practice law in the country. On the clinical side, the Oregon Medical Board publishes a statement on the Responsibilities of Medical Directors of Medical Spas that removes the usual ambiguity: medical directors must view med spa patients as their own patients, treated the same as a patient in any other medical facility.
What Oregon actually requires
- A medical director who is a licensed physician (or an independent nurse practitioner) actively involved in patient care and supervision — not a name on a protocol.
- Treatment of every med spa patient as the director’s own: an evaluation to establish the diagnosis and treatment, informed consent obtained before treatment, and proper documentation and confidentiality.
- No delegation of the diagnosis of a medical condition or the development of a treatment plan to any staff member not licensed to provide independent medical judgment. That core is non-delegable.
- Delegation only where the director has confirmed the staff member’s education and training, with supervision delivered as oversight, direction, evaluation and guidance.
- A structure built against SB 951: no prohibited dual roles between the professional entity and the MSO, and no MSO control over clinical or the defined business decisions. Restrictive covenant provisions applied immediately; ownership and control rules bite on January 1, 2026 for entities formed on or after June 9, 2025 and on January 1, 2029 for pre-existing ones.
Who may do what in Oregon
| Licence | What they may do |
|---|---|
| MD or DO | Independent; the medical director role, and the non-delegable diagnosis and treatment plan |
| Independent nurse practitioner | May serve as medical director where actively involved in patient care and supervision |
| Physician assistant | Under delegation pursuant to ORS ch. 677 and the board’s rules |
| Staff not licensed for independent judgment | May never receive delegation of diagnosis or treatment planning |
| MSO | Administration only, and subject to SB 951’s control and dual-role restrictions |
Read the board’s framing carefully. “Your patients” is not encouragement; it sets the standard of care, the documentation expectation and the consent duty at the level of any other medical practice. It is very hard to satisfy from another state on a monthly retainer.
What MDside provides in Oregon
- A Oregon-licensed MD or DO as medical director, doing the work rather than lending a name.
- A structure reviewed against SB 951’s dual-role ban before the 2029 date, rather than after a buyer’s counsel finds it.
- The professional entity and management agreement built to Oregon rather than to a national template.
- Licensed physicians for the good faith exams behind prescriptions and injectables.
- 503A and 503B pharmacy relationships and lab draws.
See what is included, or book a call and tell us which states you operate in.
Read the detail on Oregon
Frequently asked questions
Who may be a medical director in Oregon?
A licensed physician, or an independent nurse practitioner, who is actively involved in patient care and supervision.
Can the medical director delegate diagnosis?
No. The diagnosis of a medical condition and the development of a treatment plan may not be delegated to a staff member who is not licensed to provide independent medical judgment.
When do SB 951’s restrictions apply?
Restrictive covenant provisions applied on signing, June 9, 2025. MSO ownership and control restrictions apply from January 1, 2026 for entities formed on or after that date, and from January 1, 2029 for entities that already existed.
General information about Oregon practice structure and med spa regulation, not legal advice. Statutes, board rules and scope-of-practice requirements change. Confirm your obligations with healthcare counsel licensed in Oregon.