Georgia Med Spa Medical Director Requirements 2026: GCMB Rules, Supervision & Delegation

Every Georgia med spa performing medical procedures needs a medical director. Not "should have." Must have. There is no exception, no workaround, and no way to soften it.

Compared with New York or California, Georgia's regulatory environment looks lighter on paper — but that's a misread. The Georgia Composite Medical Board (GCMB) actively investigates med spa complaints, and Chapter 360-32 of its rules sets out delegation standards that, when ignored, generate license actions and unauthorized-practice findings. The board has been signaling for years that nominal medical director arrangements will not survive scrutiny.

This guide covers exactly what Georgia requires: who qualifies, what GCMB enforces, what your agreement must include, what compensation structures are legal, and the documentation an investigator will request first.

Why Georgia Med Spas Must Have a Medical Director

The legal foundation comes from three places: Georgia Code Title 43, Chapter 34 (the Medical Practice Act), the corporate practice of medicine principles embedded in §43-34-37, and the GCMB's delegation rules in Rule Chapter 360.

GA Code §43-34-1 defines the practice of medicine to include "diagnosing, treating, operating on, or prescribing for any human disease, pain, injury, deformity, or physical or mental condition." The moment a med spa offers a procedure that meets that definition — and most popular med spa services do — the facility is engaged in the practice of medicine. That triggers a long list of consequences, the most important being that only licensed physicians can practice medicine and only physicians can delegate medical acts under Chapter 360-32.

Georgia recognizes a corporate practice of medicine doctrine through §43-34-37 and related provisions. Non-physicians can own a med spa LLC for the spa-side services, but the clinical entity that delivers medical procedures must be physician-controlled in substance, even when the corporate structure looks creative. For more on ownership structure, see our deep dive on who can own a med spa in Georgia.

Procedures that require a medical director:

• Neuromodulators (Botox, Dysport, Xeomin, Daxxify)
• Dermal fillers of any kind
• Laser treatments and IPL
• RF microneedling and microneedling with PRP
• Chemical peels at medical-grade depths
• GLP-1 and other compounded weight loss injections
• IV vitamin therapy and IV hydration
• PRP and PRF treatments
• Sclerotherapy and other vein treatments
• Anything involving prescription drugs, devices, or skin penetration beyond cosmetic depth

Who Can Serve as a Georgia Medical Director

The Only Qualifying Path: Active GA-Licensed MD or DO

The medical director must be:

1. Licensed as an MD or DO in Georgia by the Georgia Composite Medical Board, with an active license in good standing
2. Free of restrictions, probation, or pending GCMB actions — a license under discipline cannot anchor a med spa
3. Genuinely available to provide appropriate supervision over the facility's clinical operations under Rule 360-32
4. Carrying current malpractice insurance that covers the scope of medical director services

Verify any prospective director's license at the Georgia Composite Medical Board license verification portal, and check the public disciplinary history while you're there.

Who Cannot Be Medical Director

This is where Georgia's rules deserve close reading — the state is more flexible than New York on some delegation questions, but the medical director question itself is not flexible:

• Advanced practice registered nurses (APRNs / NPs) — APRNs in Georgia practice nursing under a delegating physician through a nurse protocol agreement. They can perform medical acts under that protocol when properly delegated, but they cannot serve as the sole medical director of a med spa offering medical procedures. See our Georgia NP protocol agreement guide for the structure detail.
• Physician assistants (PAs) — PAs in Georgia must practice under a physician's job description and supervision. They cannot be the supervisor.
• Out-of-state physicians — Even an MD with a clean record in Florida, Tennessee, or Alabama cannot be your director. A Georgia license is required, no exceptions.
• Registered nurses, LPNs, chiropractors, naturopaths, dentists — None of these license types qualify, regardless of additional certifications.
• Physicians with restricted, probationary, or surrendered GA licenses — Discipline status disqualifies.

What "Appropriate Supervision" Actually Means

Georgia statute does not list a required visit frequency or a minimum chart review percentage. The standard is set by the GCMB's delegation rules in Chapter 360-32, including Rule 360-32-.05 on APRN delegation, and by enforcement actions the board takes against physicians who delegate without supervising. The phrase "appropriate supervision" appears throughout these rules and is interpreted contextually.

Here is what appropriate supervision looks like in practice — and what regulators look for during an investigation.

Core Responsibilities

Protocol development and approval: The medical director must review and sign off on written treatment protocols and standing orders for every procedure offered. Protocols define patient selection, pre-treatment assessment, dosing ranges, contraindications, and adverse event response. Standing orders authorize qualified staff (RNs, APRNs) to perform procedures on properly screened patients. No protocol means no delegation, which means staff are practicing medicine without authorization.

Delegation and scope oversight: The medical director defines who at the facility can perform what — and under what conditions. RNs, APRNs, PAs, and aestheticians each have distinct scopes under Georgia law. The director's job is to ensure each provider is working within the limits of their license. See our Georgia scope of practice for injectables guide for the provider-by-provider breakdown.

Chart review: Documented periodic review of patient records — typical practice is 10–25% of charts on a monthly basis. The actual percentage matters less than the documentation: dates reviewed, charts pulled, observations made, and any corrective feedback given to staff.

Quality assurance and adverse event review: The medical director investigates complications, monitors patterns, and adjusts protocols when needed. Every adverse event documented in the chart should be reviewed by the director.

Availability: Reachable during operating hours for clinical questions. Not in a different time zone for weeks at a time. Not unreachable on weekends if the practice operates weekends.

On-site presence: Regular, documented visits to the facility. Georgia doesn't specify the cadence, but monthly visits with written records of what was reviewed is the practice that withstands scrutiny.

What Doesn't Count as Appropriate Supervision

GCMB enforcement actions repeatedly identify the same patterns as inadequate:

• Signing protocols once and never reviewing them again
• Never visiting the facility
• Reviewing zero charts during the term of the engagement
• Being unreachable when staff have urgent clinical questions
• Acting as nominal director for so many practices that real involvement at any of them is impossible
• Claiming supervision while spending most of the year in a different state

The Medical Director Agreement — What It Must Include

A written agreement is non-negotiable. It is the first document a GCMB investigator will request, and it is the principal piece of evidence used to determine whether the arrangement is real or a sham. A handshake or verbal agreement provides zero protection.

Required Elements

1. Parties and credentials: Full legal names, GA medical license number for the director, the entity name and EIN for the facility, effective dates, and renewal terms.

2. Scope of services: The procedures being overseen, the specific facility location(s) covered, and the operating hours during which the director is responsible.

3. Supervision structure: The supervision protocol for each provider type at the facility (RNs, APRNs with nurse protocol agreements, PAs, aestheticians), chart review frequency and method, communication standards, and the on-site visit cadence the director commits to.

4. Protocol approval process: How the director reviews, approves, and updates treatment protocols. Annual review at minimum; reviews triggered by new procedures, new devices, or new providers.

5. Compensation: Payment amount, payment schedule, and an explicit statement that compensation reflects fair market value for services rendered and is not tied to revenue, referrals, or procedure volume.

6. Malpractice coverage: Coverage requirements for each party, minimum coverage amounts, and tail-coverage responsibility upon termination.

7. Termination provisions: Notice period (typically 60–90 days), immediate termination triggers (license suspension, GCMB action, fraud), and transition obligations covering patients, protocols, and records.

Compensation — What's Legal and What Isn't

Georgia stacks two sets of fee-splitting and anti-kickback rules on top of each other. Federal anti-kickback rules apply to any practice that takes Medicare or Medicaid (and broadly to commercial insurance under state law). GA Code §43-34-9 prohibits a licensed physician from dividing fees with anyone who is not a partner in the same practice, and the GCMB treats certain revenue-sharing arrangements between physicians and non-physicians as a form of unprofessional conduct. Both rule sets apply to medical director compensation.

Structures That Create Legal Risk

• Percentage of revenue — Direct violation of fee-splitting rules. Prohibited.
• Per-procedure fees — Creates incentive for unnecessary care. Avoid.
• Bonus tied to patient volume or referrals — Anti-kickback exposure. Avoid.
• Below-market or token compensation — Suggests a sham relationship designed to circumvent CPOM principles. GCMB notices.
• "Free" director for friends or family — Looks like an undocumented quid pro quo and invites scrutiny.

Compliant Compensation Structures

• Flat monthly retainer — Most common. Fixed amount for a defined scope.
• Hourly rate for documented time — Works well for lower-volume facilities.
• Hybrid retainer plus hourly — Retainer covers baseline oversight; hourly handles chart review surges or extra training events.

Document fair market value with reference to comparable arrangements. If GCMB ever questions the relationship, the lack of FMV documentation is what turns a borderline arrangement into a finding.

What Market Rates Look Like in 2026

Georgia medical director compensation runs slightly below New York and California metro rates and roughly in line with Texas. Atlanta and the surrounding metro carry the highest rates; smaller markets like Macon, Augusta, Columbus, and Savannah trend lower.

Typical 2026 ranges for Georgia:

• Part-time monthly retainer: $2,500–$6,000/month, with metro Atlanta at the higher end
• Hourly rate (chart review, consults): $200–$400/hour
• Full-time employed physician: $250,000–$450,000+/year (rare for stand-alone med spas)

Factors that affect your rate:

• Number of locations covered
• Procedure mix and complexity (GLP-1 and IV therapy push rates up)
• Visit and chart review intensity
• Geographic market — metro Atlanta versus secondary markets
• Specialty (dermatologists and plastic surgeons command more)

Framing matters: a $4,000/month medical director costs $48,000 a year. The cost of one GCMB investigation — attorney fees, fines, possible facility closure, lost revenue — exceeds that several times over. It is not optional spending.

Common Medical Director Problems Georgia Operators Hit

The "Ghost" Medical Director

The setup: A physician signs the agreement, the practice uses their name on protocols and marketing, the physician is paid monthly. They never visit. They review no charts. They are functionally unreachable.

The risk: This is the single most common pattern GCMB cites in med spa enforcement actions. Investigators ask for chart review logs, site visit records, and proof of communication. When those don't exist, the arrangement is documented as nominal — and both the physician and the facility face consequences. The physician can lose their license. The facility owner faces unauthorized-practice-of-medicine exposure under §43-34-26.

The Over-Extended Director

The setup: A physician serves as medical director for 12, 18, or 25 med spas across metro Atlanta. They cannot meaningfully supervise that many.

The risk: Georgia has no hard cap on how many practices a physician can oversee, but GCMB evaluates whether real supervision is occurring. A director with 20+ practices and zero documented chart review at most of them is a default GCMB target. Ask any prospective director how many facilities they currently cover, and walk away if the number is large.

The Out-of-State Director

The setup: An MD licensed in Florida, Tennessee, or another state agrees to serve as director — often at a discount.

The risk: Illegal. The facility is operating without a qualifying medical director under Georgia law, regardless of how solid the out-of-state physician's credentials are. Every procedure performed during the engagement is unauthorized practice of medicine.

Compensation Structure Problems

The setup: Medical director compensation is structured as 5% of monthly revenue, or as a per-procedure consult fee.

The risk: Direct violation of GA Code §43-34-9 fee-splitting prohibitions and federal anti-kickback rules. The agreement itself becomes evidence in any GCMB matter. Restructure to a flat retainer or documented hourly before signing.

The Departing Director Without a Replacement

The setup: The medical director resigns, retires, or has their license restricted. The facility keeps operating "while we find someone."

The risk: Every day of operation without a qualifying medical director is a day of unauthorized practice of medicine. Have a transition plan and a list of backup physicians before you ever need it.

Where to Find a Georgia Medical Director

Where to Look

1. Medical Association of Georgia — The state medical society. Member directories and specialty sections.
2. County and regional medical societies — Atlanta, Cobb, DeKalb, Gwinnett, and Chatham (Savannah) all have active local societies with referral channels.
3. Aesthetics conferences — AAFE, AMWC, IMCAS, and ASLMS attract physicians who already do this work.
4. Atlanta-area dermatology and plastic surgery practices — Physicians at these practices have natural overlap and sometimes welcome part-time medical director roles for additional income.
5. Medical director staffing firms — Several specialize in Southeast placements. Vet them carefully — some firms recycle the same handful of over-extended physicians.
6. Hospital-affiliated physicians — Particularly emergency medicine, family medicine, and internal medicine attendings looking for supplemental side income.

Questions to Ask Before Signing

1. How many med spas are you currently medical director for?
2. How often will you visit our facility, and will you document those visits?
3. What percentage of charts will you review monthly?
4. What's your response time for clinical questions during business hours?
5. Do you have hands-on experience with the procedures we offer?
6. Have you ever been the subject of a GCMB complaint or investigation?
7. What malpractice coverage do you carry, and does the policy explicitly cover medical director services?

Red Flags

• Quotes a number well below Georgia market rates
• Says on-site visits are "not really necessary"
• Already covers a large number of practices
• Won't share license number or malpractice certificate
• Suggests revenue-percentage compensation
• Has any pending GCMB matters or restrictions

What GCMB Investigators Check First

Based on enforcement patterns, the first six items an investigator will ask for:

1. Medical Director Agreement — Signed, current, with specific scope and supervision terms
2. Treatment protocols and standing orders — Signed by the director, current, covering every procedure offered
3. Chart review logs — Dates, charts reviewed, observations, corrective actions
4. Site visit records — Dates, what was reviewed, what was discussed
5. Staff credentials and nurse protocol agreements — Current GA licenses for all clinical staff and any APRN protocol agreements on file
6. Advertising materials — All marketing must comply with GA rules; see our GA advertising rules guide for the specifics

Documentation You Must Keep on File

1. Medical Director Agreement — signed original
2. Director's current GA medical license
3. Director's current malpractice certificate
4. Entity formation documents (LLC, PC, or PLLC) and any required filings
5. Signed treatment protocols and standing orders for every service
6. Nurse protocol agreements for any APRNs at the facility
7. Chart review logs (monthly)
8. Site visit records (monthly minimum)
9. Delegation/supervision protocols for RNs, APRNs, PAs
10. Adverse event log and director review notes
11. Staff license verification records
12. DEA registration if controlled substances are stocked or prescribed

For a complete pre-inspection checklist, see our Georgia med spa compliance checklist.

How Georgia Compares to New York and California

If you're operating in multiple markets — or considering expansion — the rules diverge meaningfully. New York's Office of Professional Medical Conduct enforces a strict Corporate Practice of Medicine doctrine and broader fee-splitting prohibitions under Public Health Law §238-a; for the New York side of the comparison, see our New York medical director requirements guide. California requires Medical Board registration of certain office-based facilities and now permits qualified 104 NPs to serve in expanded roles under AB-890 — Georgia does not extend equivalent independent authority to APRNs, who must continue to operate under a delegating physician's nurse protocol agreement. Georgia is generally the lighter-touch jurisdiction of the three, but "lighter touch" means less defined paperwork — not less enforcement. Investigations still happen, and the fact patterns the board pursues mirror those in New York and California.

What Happens Without a Qualifying Medical Director

Operating a Georgia med spa without a qualifying medical director — or with a documented sham arrangement — is not a paperwork issue.

Immediate exposure:

• Unauthorized practice of medicine under §43-34-26 (potentially criminal)
• Fee-splitting violations under §43-34-9 if compensation is structurally improper
• Malpractice insurance often voids when proper supervision is absent
• Anti-kickback exposure on the federal side
• Patient complaints that escalate directly to GCMB

Likely consequences:

• GCMB investigation of the medical director, with potential license suspension or revocation
• Action against any licensed staff (RNs, APRNs, PAs) involved
• Cease-and-desist orders
• Civil penalties and fines
• Permanent facility closure in serious or repeated cases
• Criminal referral for sustained unauthorized practice

The math here doesn't work in any direction other than getting the arrangement right from day one.

Summary

1. Every Georgia med spa offering medical procedures must have a Georgia-licensed MD or DO as medical director
2. APRNs, PAs, and out-of-state physicians cannot be the sole medical director under Georgia law
3. "Appropriate supervision" under GCMB Chapter 360-32 means real involvement: protocol approval, documented chart review, regular on-site visits, and availability for clinical questions
4. The Medical Director Agreement must be written, specific, and include scope, supervision schedule, fair-market-value compensation, and termination terms
5. Compensation cannot be tied to revenue, referrals, or procedure volume — flat retainer or hourly only, consistent with §43-34-9
6. Atlanta market rates run $2,500–$6,000/month for part-time oversight; cheaper than that is a red flag
7. GCMB enforces against ghost directors, over-extended physicians, fee-splitting, and out-of-state arrangements
8. Keep documentation organized — agreement, protocols, chart review logs, site visit records, license verifications, nurse protocol agreements

Disclaimer: This article is for educational purposes only and does not constitute legal advice. Medical director arrangements involve complex regulatory considerations specific to your practice, location, and procedure mix. Consult a Georgia healthcare attorney before entering into any medical director arrangement.