Washington has a rule that quietly disqualifies the absentee medical director, and it does it in one clause.
Under the Washington Medical Commission’s rules on nonsurgical medical cosmetic procedures — WAC 246-919-606, under RCW 18.71 — a physician must be fully and appropriately trained in the procedure before performing it or delegating it. A physician who has never been trained on your device cannot lawfully delegate it, whatever the agreement says.
What Washington actually requires
- A physician trained in the specific procedure before performing or delegating it.
- Delegation only to a properly trained physician assistant, registered nurse or licensed practical nurse.
- A written office protocol containing, at minimum: the identity of the physician responsible for the delegation, selection criteria to screen patients for appropriateness, and a description of appropriate care and follow-up for common complications, serious injury and emergencies.
- Attention to the Washington Board of Nursing’s advisory position on cosmetic, aesthetic and dermatologic procedures, which speaks to the nursing side of the same work.
- For medical assistants under RCW 18.360: an MA-C may establish IV lines without administering medication, and may give IV injections only under direct visual supervision.
Who may do what in Washington
| Licence | What they may do |
|---|---|
| MD or DO | Independent; may delegate only procedures they are themselves trained in |
| Physician assistant | Delegable under WAC 246-919-606 when properly trained |
| Registered nurse | Delegable under WAC 246-919-606 when properly trained |
| Licensed practical nurse | Delegable under WAC 246-919-606 when properly trained |
| Medical assistant-certified | May establish IV lines without administering medication; IV injections only under direct visual supervision (RCW 18.360) |
| Unlicensed staff | Not for medical procedures |
Washington’s Department of Health has run a Med Spa and Esthetic Services Work Group and published guidance for businesses offering esthetic services. Read it alongside the Medical Commission rule; the two are not identical in emphasis.
What MDside provides in Washington
- A Washington-licensed MD or DO as medical director, doing the work rather than lending a name.
- The professional entity and management agreement built to Washington rather than to a national template.
- Licensed physicians for the good faith exams behind prescriptions and injectables.
- Protocols and delegation written against your live service list, and revised when it changes.
- 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 Washington
Frequently asked questions
Can a Washington physician delegate a procedure they have not been trained in?
No. WAC 246-919-606 requires the physician to be fully and appropriately trained in a nonsurgical medical cosmetic procedure before performing or delegating it.
Who may perform delegated cosmetic procedures in Washington?
A properly trained physician assistant, registered nurse or licensed practical nurse, under a written office protocol that meets the rule’s content requirements.
Can a medical assistant give an IV injection in Washington?
A medical assistant-certified may establish IV lines without administering medications, and may administer IV injections only under direct visual supervision of a health care practitioner.
General information about Washington 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 Washington.