A med spa is a medical practice with a hospitality front end. Neurotoxins, fillers, energy-based devices, microneedling and IV therapy are medical acts, and every one of them is performed by someone acting under a physician’s authority — or not lawfully performed at all.
The failure mode is almost never the treatment. It is the paperwork behind it: a protocol that predates the current menu, a director nobody can reach on a Saturday, a delegation that quietly exceeds the injector’s license.
What we take off your desk
- A state-licensed MD or DO named as your medical director, with the availability standard your state actually sets.
- Protocols and standing orders written against your live service list, and revised when you add a device or a drug.
- Delegation documents matched to each injector’s license — RN, APRN, PA — rather than one template covering all three.
- Good faith exams performed and documented by licensed providers before anything is prescribed or injected.
- A chart review cadence that exists on a calendar rather than in an intention.
- 503A and 503B pharmacy sourcing so your product supply is defensible.
The questions that decide your structure
- Which state, and is corporate practice of medicine restricted there? The table on our medical direction page answers that for nine states.
- Who injects, and does their license permit it on delegation alone?
- Is there a facility license — Florida’s AHCA process — or a registry, like Tennessee’s?
- Is your management fee a percentage of clinical revenue? In New York that is unlawful, and everywhere else it is the first thing a plaintiff points at.
Adding a service line
Weight management is the most common addition and the one with the most exposure, because the compounded GLP-1 landscape changed materially in 2025. Hormone therapy brings controlled-substance rules with a federal deadline attached. Both are workable. Neither is a menu edit.
Frequently asked questions
Does every med spa need a medical director?
Every med spa performing medical procedures needs a physician standing behind those procedures. What the role is called, who may hold it and how available they must be varies by state — Arizona is the notable exception, where a nurse practitioner with full practice authority can lead the clinic themselves.
Can our injector work under a protocol we already have?
Only if the protocol covers the treatments you currently offer and the license of the person performing them. Most protocols we are shown are one or two menu changes out of date, which means the newest services are the ones running uncovered.
What happens if a patient has a complication?
Your medical director is responsible for the response, and in several states a serious adverse event carries a reporting obligation with a short deadline. That is precisely the moment a paper-only directorship becomes visible.
Can we add weight-loss injections to an aesthetics menu?
Yes, with a separate protocol, provider capacity for the evaluations, and defensible sourcing. It is a new service line rather than a menu item, and the compounded GLP-1 rules changed materially in 2025.
Book a call and tell us the states you operate in and what you want to offer.
General information, not legal or medical advice. Requirements differ by state and change often. Confirm your obligations with counsel licensed where you operate.