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Medical Director Services in Utah

Utah is permissive about ownership and unusually structured about everything that happens afterwards.

Utah defines a cosmetic medical procedure in statute at § 58-67-102: the use of cosmetic medical devices to perform ablative or nonablative procedures. The definition excludes treatment of the ocular globe including refractive surgery, superficial procedures as defined at § 58-1-102, permanent make-up, and photo therapy or lasers used for neuromusculoskeletal treatment by a licensee acting within scope.

What Utah actually requires

  • A cosmetic medical procedure supervisor under § 58-1-505: 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 their scope.
  • Supervision of anyone authorised to perform a cosmetic medical procedure while they perform it.
  • Performance only in a cosmetic medical facility — Utah defines the venue, not just the act.
  • Attention to the statutory delegation groups. Group A includes physician assistants acting under the Utah Physician Assistant Act, registered nurses, master estheticians, and electrologists evaluating for or performing laser hair removal.
  • No delegation of an ablative cosmetic medical procedure to anyone not licensed under the Medical Practice Act or Osteopathic Medical Practice Act, subject to limited APRN exceptions.

Who may do what in Utah

Licence What they may do
MD or DO Independent; may act as cosmetic medical procedure supervisor
APRN (unrestricted licence) May act as supervisor within their scope
Physician assistant Delegation group A, under the Utah Physician Assistant Act
Registered nurse Delegation group A
Master esthetician Delegation group A — a licence category most states do not have
Electrologist Delegation group A, for evaluating or performing laser hair removal
Anyone not licensed under the Medical or Osteopathic Practice Acts May not perform ablative procedures, with limited APRN exceptions

Utah is the clearest example in our coverage of a state that gave up on restricting ownership and instead wrote down, in detail, who may do what and where. If your compliance model is built around ownership questions, Utah will feel easy right up until the delegation-group question arrives.

What MDside provides in Utah

  • A Utah-licensed MD or DO as medical director, doing the work rather than lending a name.
  • A delegation map by service against Utah’s statutory groups, including where a master esthetician does and does not fit.
  • The professional entity and management agreement built to Utah 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 Utah

Frequently asked questions

Can anyone own a med spa in Utah?

Utah neither expressly permits nor prohibits the corporate practice of medicine, and non-physician ownership is common. A supervisor and a medical director arrangement are still required.

What is a cosmetic medical facility?

Utah requires cosmetic medical procedures to be performed in a cosmetic medical facility — the statute regulates the venue as well as the act. Confirm the definition applies to your premises.

Who may supervise cosmetic medical procedures?

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.

Can a master esthetician perform laser treatments?

Master estheticians appear in delegation group A. What they may perform depends on the procedure and on the ablative limits, so map it service by service.


General information about Utah 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 Utah.