Can a Nurse Practitioner Run a Med Spa in Georgia? The Protocol Agreement Rule

If you are an APRN in Georgia weighing whether to open or run a med spa, most of what you will find online is written for a full-practice-authority state or is quietly out of date. Georgia is neither. It is a restricted-practice state with an unusually specific delegation statute, an imaging restriction no other state has, and — since spring 2026 — a contested argument about whether an APRN may own the business at all.

This guide is Georgia only. It walks the protocol agreement clause by clause, states the prescribing limits with the numbers attached, gives licence-by-licence verdicts, and marks where the answer is unresolved rather than papering over it. Our SOP and compliance library is the operational companion; everything else Georgia starts at the Georgia resource hub.

The Short Answer: What a Georgia NP Can Run — and What They Cannot

Can an APRN perform and prescribe the full med spa menu? Substantially, yes. Neurotoxins, filler, GLP-1s, IV therapy, laser work, microneedling and PRP are all delegable, provided each is written into the protocol and the APRN is trained for it. Georgia keeps no list of procedures reserved to physicians in an aesthetic setting.

Can an APRN do any of it without a physician? No — not one prescription, not one delegated act. Georgia has no experience-based off-ramp and no independent-practice tier. An APRN whose delegating physician resigns on Monday has no prescriptive authority on Tuesday unless a backup was already named.

Can an APRN be the medical director? No — and the framing is slightly wrong. Georgia does not license med spas as facilities or use "medical director" as a statutory role. The statutes name a delegating physician for an APRN, a supervising physician for a PA, and a consulting physician for a laser practitioner. Each must be a physician.

Can an APRN own the med spa? This is what moved in 2026, and it turns on how the Medical Board's reading of the physician-employment prohibition settles. Structures routine in 2024 are under active scrutiny. The ownership section below separates fixed law from Board interpretation from what is still open.

Georgia Has No Independent APRN Practice, and No Near-Term Path to It

Georgia is among the most restrictive states in the country for advanced practice nursing, and has stayed that way through repeated legislative attempts to change it. There is no Georgia analogue to California's AB-890 pathway or New York's 3,600-hour waiver. Every APRN here, on day one and in year thirty, practises under a written agreement with a physician. The fifty-state survey of where NPs may practise and own independently lives in our national NP ownership guide; what matters here is the mechanism Georgia uses instead.

Georgia Says "APRN," Not "NP" — and the Vocabulary Matters

Georgia uses Advanced Practice Registered Nurse as the umbrella covering nurse practitioners, midwives, anesthetists, and clinical nurse specialists. A nurse practitioner here is an APRN authorised by the Georgia Board of Nursing in the NP role. The statutes, forms, and registration portal all say APRN. If a consultant's paperwork says "collaborative practice agreement," it was drafted for another state.

Authorisation sits with the Board of Nursing under its Chapter 410-11 rules: a master's degree or higher from an accredited advanced practice programme, current national certification, and either graduation within four years of application or 500 documented hours, with 30 hours of CE per renewal. That makes you an APRN. It is not what lets you prescribe.

Two Regulators, Two Halves of the Same Career

Your licence comes from the Board of Nursing, under the Secretary of State's Professional Licensing Boards Division. Your authority to do medicine comes from a physician's delegation, regulated by the Georgia Composite Medical Board — which does not license you and cannot discipline you directly, but reviews and can invalidate the document your prescriptive practice rests on. Add GDNA and the DEA for anything controlled, and a Georgia NP-run med spa answers to four regulators before it answers to a patient.

Inside the Nurse Protocol Agreement: What § 43-34-25 Actually Requires

The protocol agreement is the whole ballgame. Get it right and an APRN has broad clinical latitude. Let it lapse and every prescription written under it is an unauthorised act.

Get the Citation Right: § 43-34-25, Not § 43-34-23

Both sections are real and routinely confused, including in earlier versions of this page. O.C.G.A. § 43-34-23 is the general provision, "Delegation of authority to nurse or physician assistant." It supplies the vocabulary — defining administer and order — and provides that ordering under delegation is not prescribing and that acts done in conformity with the section are not the practice of medicine.

O.C.G.A. § 43-34-25 is the APRN section: delegation of medical acts to an APRN, the conditions of the nurse protocol, and the issuance of prescription drug orders. Its implementing rules are Medical Board Chapter 360-32, titled "Nurse Protocol Agreements Pursuant to O.C.G.A. Section 43-34-25." A template anchoring your obligations to § 43-34-23 points at the definitions rather than the requirements.

What the Agreement Must Contain

A nurse protocol agreement is a written document mutually agreed and signed by an APRN and a physician, delegating authority to perform certain medical acts — which may include ordering drugs, devices, treatments, diagnostic studies, or radiographic imaging tests. Statute and rule require it to:

• Identify both parties, with current Georgia licence numbers and the APRN's Board of Nursing authorisation
• Pair the APRN with a delegating physician in a comparable specialty area or field
• Specify the drugs that may be ordered, by name or class, and the procedures and diagnostic studies delegated
• State the parameters of delegation, expressly including the number of refills, the kinds of diagnostic studies, and the extent of any radiographic imaging tests
• Provide for immediate consultation with the delegating physician, and name an alternate when that physician is unavailable
• Set out the quality-assurance and record-review process, including the physician's review obligations
• Provide for periodic review of the protocol itself

Two drafting failures cause most of the trouble. The catch-all formulary — "all aesthetic medications and devices" — delegates nothing identifiable. And refill silence: the statute requires the agreement to state the number of refills, so a protocol that never mentions them has authorised none.

Filing: 30 Days, and What Happens If You Miss It

This is not a private document between two clinicians. It must be received by the Medical Board within 30 days of execution, and any amendment within 30 days of its own execution, through the Board's protocol registration portal with a fee. An incomplete protocol on file more than three months is deemed invalid, and a new protocol and fee are required to start over. A physician terminating an agreement must notify the Board within ten working days. There is no grace period in which an APRN prescribes on a signed-but-unfiled document.

Review, Amendment, and the May 25, 2026 Rule Changes

Amended Rules 360-32-.01, .02, and .03 took effect on May 25, 2026. A protocol substantially similar to the Board's standard form is now deemed valid on submission rather than waiting for affirmative approval — but staff and the Board still review it, and approval may be rescinded. That is a shift from "wait for approval" to "proceed at risk": faster to launch, more dangerous to get wrong. The same package requires delegating physicians to ensure their APRNs receive annual pharmacology training and the relevant biennial CE, with disciplinary exposure for the physician who delegates without it.

Re-execute annually at minimum, and whenever the menu changes or either party's licence status does. Adding GLP-1s or a new energy device without amending the protocol is the most common way a compliant practice quietly becomes a non-compliant one.

Delegating-Physician Limits: Who Qualifies, and How Many APRNs

The delegating physician is not a signature. Georgia constrains who may hold the role and how many advanced practitioners one physician may carry.

The Numbers: Four, Eight, and the 2026 Combined Cap

The long-standing rule in Chapter 360-32 is that a delegating physician may not enter nurse protocol agreements with more than four APRNs at any one time. A physician at a location maintaining evidence-based clinical practice guidelines and accredited by a Board-approved accrediting body — the Joint Commission being the usual example — may hold up to eight, while still supervising no more than four at once. The 2026 changes recast this as a combined ceiling of eight APRN protocol agreements and PA job descriptions under § 43-34-25(g), (g.1), and (g.2). The practical point is blunt: a physician already carrying seven advanced practitioners has little headroom for you.

Specialty Comparability — the Aesthetic Practice's Real Problem

No physician may enter a protocol agreement with an APRN whose specialty area or field is not comparable to their own. In aesthetics this is the requirement that most often fails, because the delegating physician is frequently an emergency physician, anaesthesiologist, or general internist with no cosmetic practice, recruited because they were available and cheap.

There is no Georgia list of "aesthetic-comparable" specialties, so this is judgement, not arithmetic. A defensible file holds the physician's CV showing relevant cosmetic training, documented device- and injectable-specific training, and a protocol whose delegated procedures match what that physician actually does. A physician with no aesthetic background signing off on ablative resurfacing and advanced filler invites the question the Board will eventually ask.

Availability, Alternates, and What Happens When the Physician Leaves

The protocol must provide for immediate consultation. Georgia imposes no mileage radius, but the physician or a named alternate must be reachable when the APRN needs them, and the Board has been explicit that absentee delegation is itself the violation.

Departure is where practices get hurt. If the delegating physician dies or leaves, the APRN must notify the Board within seven days. Without a designated backup, prescriptive authority ceases until a new agreement is submitted. Where a backup was designated in advance, that physician may act as delegating physician for up to 60 days while the new agreement works through. That is the whole case for naming an alternate on day one: a single-physician protocol is a business with one point of failure, and the failure mode is that everyone in the building stops being able to prescribe. For what the relationship costs and how to paper it, see our guides to Georgia medical director requirements and medical director cost and agreement terms.

Prescriptive Authority Under Protocol — Real, and Narrower Than Advertised

Georgia has expanded APRN prescribing over the last decade and the authority is genuine. It is also more bounded than most protocol-template vendors suggest.

What an APRN May Order: Dangerous Drugs and Schedules III–V

An APRN authorised by the Board of Nursing, in good standing, operating under a filed protocol may issue prescription drug orders for dangerous drugs and for Schedule III, IV, and V controlled substances without the delegating physician's co-signature. For a med spa that covers the whole ordinary formulary: botulinum toxins; hyaluronic acid fillers and biostimulators, regulated as prescription devices; GLP-1 and dual-agonist weight-management drugs, which are not controlled; testosterone and other anabolic steroids, Schedule III; phentermine, Schedule IV; topical anaesthetics, hydroquinone, prescription retinoids; and emergency stock such as epinephrine and hyaluronidase.

All of it must sit inside the formulary the protocol names. Prescribing outside the protocol is not a technicality even when clinically obvious: it is an act outside delegated authority, exposing the APRN to the Board of Nursing and the physician to the Medical Board.

The Schedule II Carve-Out Is Much Narrower Than You Have Been Told

This is the most misreported item in Georgia APRN guidance, and earlier versions of this page got it wrong too. Georgia APRNs may not prescribe Schedule I or Schedule II controlled substances. The 2024 expansion did not change that generally. It created a narrow emergency carve-out under § 43-34-25(d.1) for hydrocodone, oxycodone, and compounds thereof, with every condition attaching at once:

• The situation must be an emergency
• At least one year of post-licensure clinical experience, in good standing
• The authority must be expressly included in the protocol agreement — it is not automatic
• The APRN must have directly evaluated the patient
• An initial prescription only, not exceeding a five-day supply, with no refill
• One hour of continuing education biennially on the appropriate ordering of those drugs
• The delegating physician must provide the APRN's DEA number to the Board within 30 days of issuance

Clinically this is near-irrelevant in aesthetics, but it matters for how you read vendor claims. A consultant telling a Georgia APRN they have "full Schedule II authority under protocol" is describing a different state.

Refill Limits: 12 Months, and 24 for Hormone Therapy

An APRN may not authorise refills of any drug more than 12 months from the date of the original order. The exceptions run to 24 months and are specific: oral contraceptives, hormone replacement therapy, and prenatal vitamins. Georgia pharmacy rules layer on a separate cap for Schedules III–V — no fill or refill more than six months after issue, and no more than five refills.

The Quarterly Physician Evaluation That Reshapes Hormone and Weight-Loss Practices

Here is the provision almost no Georgia med spa business plan accounts for. A patient receiving a prescription drug order for any controlled substance under a nurse protocol agreement must be evaluated or examined by the delegating physician — or another physician they designate — at least quarterly. That physician must also review and sign 100 percent of records for controlled-substance patients, at least quarterly. Work that through an actual menu:

• Neurotoxin and filler patients: not controlled substances, so no quarterly physician evaluation is triggered. A Botox-and-filler practice is genuinely light-touch here.
• GLP-1 patients on semaglutide or tirzepatide: also not controlled. Same answer.
• Weight-loss patients on phentermine: Schedule IV. Every one needs a quarterly physician evaluation and 100 percent physician chart review.
• Testosterone and anabolic hormone patients: Schedule III. A Georgia TRT programme under an APRN protocol needs a physician physically evaluating every patient quarterly.

That is the difference between a physician who signs a protocol and one who must personally see a rolling panel every quarter. It is why many Georgia APRN-led practices keep the controlled side of the menu small — GLP-1s rather than phentermine, TRT referred out. Our Georgia compliance checklist covers where these records belong.

DEA, GDNA, and the Two Registrations People Forget

Federal DEA registration in the APRN's own name is required for any controlled substance, and the delegating physician must supply that number to the Medical Board within 30 days of issuance under the 2026 rules. Georgia separately requires a state controlled substance registration through the Georgia Drugs and Narcotics Agency, which inspects facilities that handle or dispense pharmaceuticals before granting the permit. Timelines stack: DEA typically four to six weeks, GDNA two to four, with the state registration following the federal. GDNA also administers Georgia's prescription drug monitoring programme, and APRN prescribers are within it.

Ordering Labs and Imaging: Georgia's One-of-a-Kind Restriction

Labs and Routine Diagnostics

Diagnostic studies are generally delegable, and § 43-34-23 confirms that selecting a study through delegation is ordering rather than prescribing. The protocol must state which kinds are delegated. For a med spa the ordinary workups sit inside an APRN's authority — metabolic panel, lipids, HbA1c and fasting insulin for weight management, testosterone and oestradiol and PSA for hormone work, CBC before PRP — provided the protocol names them with enough particularity to be a real delegation.

The Radiographic Imaging Restriction — Georgia Stands Alone

Georgia is the only state with a statutory restriction of this kind, and it turns on a defined term. A radiographic imaging test means computed tomography, magnetic resonance imaging, positron emission tomography, or nuclear medicine. Those four, an APRN under a protocol agreement may order only in a life-threatening situation. Where a physician does authorise imaging, the agreement must specify that such tests are read by a physician trained in that specialty and that a copy of the report goes to the delegating physician.

The practical reading for aesthetics: plain radiography and ultrasound fall outside that four-item definition and are ordinary diagnostic studies — which matters, because ultrasound is increasingly used for vascular mapping before filler and for assessing suspected occlusion afterward. CT and MRI are off the table absent a life-threatening presentation, and a complication that has genuinely become limb- or vision-threatening is a transfer to an emergency department, not an imaging order written from a treatment room.

Ownership: What an NP May Actually Own in Georgia

This topic carries the most misinformation on the page, in both directions — some sources say ownership is flatly barred by a corporate-practice-of-medicine statute, others that Georgia has no CPOM doctrine at all. Both are wrong. The accurate answer separates what the statutes say, what the Board interprets them to mean, and what is unresolved.

Georgia Repealed Its Standalone CPOM Statute in 1982

Start with the correction, because this page previously carried the error. Georgia's express prohibition on the corporate practice of medicine — the former O.C.G.A. § 43-34-37 — was repealed in 1982, and no standalone statute has banned corporate medical practice since. The section carrying that number today covers improper professional relationships, assisting unauthorised practice, and fee-splitting for referrals. Citing it as Georgia's CPOM rule cites the wrong law.

What survives are CPOM principles spread across other provisions: § 43-34-22 on practising medicine without a licence, § 43-34-26 on the licence requirement, and the definitions in § 43-34-21. Georgia's CPOM position is therefore weaker and less codified than California's or New York's — which is why the analysis has to run through the delegation statute instead.

The Real Bar: A Physician May Not Be an APRN's Employee

Here is the operative provision, far more specific than any CPOM generality. Except for practice settings identified in § 43-34-25(g)(7), it is unlawful for a physician to be an employee of an APRN, alone or in combination with others, if the physician is required to supervise the employing APRN. Breach is sanctionable by the Board of Nursing as to the APRN and the Medical Board as to the physician.

The mechanics are narrower than "APRNs cannot own med spas" and stranger. The provision does not prohibit an APRN from owning a business; it prohibits a relationship — the supervisor being the employee of the supervised. An APRN-owned entity that must engage a delegating physician runs straight into it, because the money flows the wrong way up the supervisory line.

The May 7, 2026 Position Statement — and the Walk-Back

On May 7, 2026 the Georgia Composite Medical Board issued a position statement addressing the delegating physician/APRN relationship, the supervising physician/PA relationship, and IV hydration requirements. On ownership it took the broadest available reading: the Board interprets the employment prohibition to extend beyond W-2 or 1099 classification to any compensation, monetary or non-monetary, paid by an APRN or APRN-owned entity to a physician for serving in the delegating role. It also took aim at third-party staffing and physician-matching entities used to paper over that relationship.

If that reading holds in full it reaches a very large share of Georgia's APRN-owned med spas, IV lounges, and wellness clinics, because nearly all of them pay their delegating physician somehow. The Board appears to have recognised as much: a public notice dated May 26, 2026 acknowledged the significant questions and concerns raised by APRNs, PAs, and physicians, and a further statement on June 5, 2026 addressed the IV hydration statement. We cover it and the remediation steps in our Georgia 2026 regulatory update, and the structural response in the Georgia NP playbook.

What an APRN Can Definitely Own

One point is settled and frequently missed. Under Georgia's Professional Corporation Act the professions that may organise a professional corporation include both medicine and surgery and registered professional nursing, and shareholders, officers, and directors must be licensed in the profession the corporation practises. So a Georgia APRN may own a professional corporation to practise registered professional nursing. What that entity may not do is practise medicine — and the cosmetic med spa menu is the practice of medicine here.

Beyond that, an APRN may own real estate or equipment and lease it to the practice, own a management services organisation providing genuinely non-clinical services under a fair market value agreement, and own any non-medical retail line. Arm's-length contracts, defensible pricing, and no MSO control over clinical decisions separate a lawful MSO from a sham. Our Georgia ownership guide works through the entity mechanics.

Where the Answer Is Genuinely Unsettled — Said Plainly

We will not pretend to more certainty than exists. As of August 2026:

• No Georgia appellate court has decided whether the § 43-34-25 prohibition reaches an MSO fee paid by an APRN-owned management company to a physician-owned practice, as opposed to direct payment to the physician.
• That reading is a position statement, not a rule adopted through notice-and-comment rulemaking, and the Board's own later notices signal its final scope is still being worked out.
• No published Board guidance draws a bright line between a compliant APRN-owned MSO and a prohibited arrangement, and no safe-harbour fee structure has been blessed.
• Legislative activity on APRN scope continues each session, and none of it has yet changed the underlying statute.

Anyone quoting a definitive answer on APRN-owned structures in Georgia right now is quoting an opinion, ours included. What is defensible is to structure conservatively, document heavily, and obtain a Georgia healthcare attorney's written opinion dated after the May and June 2026 Board statements — a 2024 opinion letter was written about a different regulatory posture.

Does an NP-Run Med Spa Still Need a Medical Director?

Yes in substance, and the framing deserves correcting because the correction is useful.

"Medical Director" Is Not a Georgia Licensure Category

Georgia does not license or register med spas as facilities, and no statute creates a med spa "medical director" licence, registration, or filing. What the law names are three physician roles: a delegating physician for an APRN under a filed protocol agreement; a supervising physician for a PA under a Board-approved job description; and a consulting physician for a cosmetic laser practitioner. "Medical director" is the industry term wrapped around whoever holds those roles. That person must be an MD or DO with an active Georgia licence — an out-of-state physician cannot fill it, and neither can an APRN.

How the Director Role Differs from the Protocol Agreement

The protocol agreement governs one APRN's clinical authority. The medical director function is facility-level: approving treatment protocols, setting the standard of care, overseeing delegation to every category of staff, signing off on device protocols, owning the emergency response plan. One physician usually holds both, but they are different instruments and a protocol agreement does not discharge the facility-level obligations.

Note the awkward loop for an APRN-owned practice: the physician you need as medical director is the physician you may not employ if they supervise you. It is why the two questions cannot be answered separately in Georgia.

Licence by Licence: Who May Do What in an NP-Run Georgia Med Spa

An APRN running a Georgia med spa is staffing it, and the delegation questions do not stop at their own licence. Deeper treatment of injector scope is in our guide to who can inject Botox in Georgia.

Physician and Physician Assistant

The physician is unrestricted within their training and the standard of care; in an APRN-led practice they are usually present as the delegating physician rather than a treating provider. A PA operates under a Board-approved job description with a supervising physician — a parallel instrument to the protocol agreement, filed separately — and may inject and operate energy devices within it. Because the 2026 cap counts PA job descriptions and APRN protocols against the same eight slots, a practice staffing both competes for headroom on one licence.

Registered Nurse and Licensed Practical Nurse

An RN may administer injections, including neurotoxins and filler, on a valid patient-specific order from an authorised prescriber. What an RN may never do is generate the order: they cannot perform the authorising evaluation, cannot select product or dose independently, and cannot treat on a standing order never individualised to the patient in front of them.

LPN scope is narrower and supervision-dependent. On IV therapy the Board was explicit in 2026: an LPN may participate only under supervision by an RN, physician, NP, or PA, and only once an individualised order exists. Treat aesthetic injection by an LPN as outside the safe zone.

Esthetician

Georgia's definition of esthetician excludes lasers, and estheticians may not inject. The lane is superficial — facials, peels within cosmetology scope, dermaplaning, product-based treatments — and stepping outside it is unlicensed practice, not a scope disagreement. An esthetician who wants to run energy devices must obtain laser licensure in their own right.

Cosmetic Laser Practitioners — Georgia's Separate Licence

Georgia is unusual in licensing the laser operator directly, under the Cosmetic Laser Services Act at O.C.G.A. §§ 43-34-240 through 43-34-253, with Board rules in Chapter 360-35. Section 43-34-244 creates two levels:

• Senior laser practitioner: must hold, or have previously held, licensure as a PA, nurse, or medical practitioner; at least three years of clinical or technological medical experience; and three years licensed or nationally board certified. May practise with indirect supervision under a consulting physician's protocols.
• Assistant laser practitioner: meets minimum educational requirements and practises under the on-site supervision of a senior laser practitioner. This is the route open to an esthetician.

An APRN is well placed to hold senior laser practitioner licensure, and in an NP-led practice that is often the cleanest configuration: the APRN as senior practitioner supervising assistants on site, with the consulting physician's laser protocols behind them.

Medical Assistants and Unlicensed Staff

No injections, no energy devices, no evaluations. A physician may not delegate injection to a medical assistant; doing so is unprofessional conduct under the Board's Chapter 360-3 discipline rules and unlicensed practice on the assistant's part. Unlicensed staff belong in intake, scheduling, room turnover, photography, and retail. A med spa that has drifted from that carries criminal, not merely administrative, exposure.

Procedure by Procedure: What Changes When an NP Is Running It

The menu does not shrink because the owner-operator is an APRN. What changes is which document authorises each item.

Neurotoxins and Dermal Filler

Fully available to an APRN whose protocol names the products. These are dangerous drugs and prescription devices rather than controlled substances, so no quarterly physician evaluation attaches — only the evaluation before treatment, the named formulary, and a physician-approved hyaluronidase-and-transfer emergency protocol. This is the least encumbered part of a Georgia APRN med spa.

Lasers and Energy Devices

Two permissions stack here and practices routinely obtain only one. Operating the device requires cosmetic laser licensure; treating the patient requires an order and evaluation from an authorised prescriber. An APRN with senior laser practitioner licensure satisfies both; one without it has the clinical authority but not the operator credential. See our Georgia laser safety guide for the Class 3B and 4 safety programme.

Microneedling and PRP

Superficial microneedling sits at the boundary; once depth reaches the dermis, or the device is radiofrequency, or a prescription topical is applied under it, it is a medical procedure needing the protocol behind it. PRP is unambiguously medical — venipuncture, centrifugation, reinjection — and belongs to the APRN, PA, physician, or an RN acting on their individualised order.

IV Therapy

The Board's May 2026 IV position statement removed the remaining ambiguity: IV therapy is the practice of medicine. Those who may order it are physicians, APRNs with an active prescriptive protocol, and PAs with an appropriate job description; those who may administer it are RNs, or LPNs under appropriate supervision, once an individualised order exists. The same statement carried the compensation restriction — APPs who own or operate IV hydration businesses cannot employ or otherwise compensate the supervising physician for those services. Georgia's IV lounge sector is where the ownership question is being litigated in practice.

GLP-1, Medical Weight Loss, and Hormone Therapy

Semaglutide and tirzepatide are not controlled substances, so an APRN may prescribe them under protocol without triggering quarterly physician evaluation. Name them explicitly rather than relying on a "weight management medications" catch-all, and state the refill parameters. Compounded versions raise separate federal sourcing questions outside Georgia delegation law. The moment phentermine enters the programme, the Schedule IV consequences attach to every patient on it.

Hormone therapy is the most operationally demanding item on an APRN-led Georgia menu. Testosterone is Schedule III, so quarterly physician evaluation and 100 percent chart review attach to the whole hormone panel. Price the physician's time accordingly.

The Patient Evaluation — Who May Perform It, and When

Georgia does not use California's "good faith examination" phrase in statute, and it is worth being accurate rather than importing another state's vocabulary. What Georgia requires is a proper practitioner-patient relationship and an evaluation by someone authorised to prescribe, before treatment.

Who May Perform It

Only a physician, an APRN under a nurse protocol agreement, or a PA under an approved job description. An RN cannot. An esthetician cannot. A laser practitioner cannot, in that capacity. In an APRN-led practice the APRN typically performs every evaluation personally, which is lawful and cleanest — but it makes their calendar the practice's throughput ceiling.

What It Must Cover, and the Telemedicine Limits

The evaluation should establish the indication, review allergies, contraindications, and current medications, document consent, and produce an individualised patient-specific order rather than a standing menu item. The Medical Board's telemedicine rule requires an in-person examination before an initial prescription for controlled substances or dangerous drugs, and diligent efforts to ensure the patient is examined in person annually by a Georgia-licensed physician, PA, or nurse practitioner; an intake questionnaire or audio-only call is unlikely to establish the relationship. Because neurotoxins and fillers are dangerous drugs, that reaches a first-visit Botox patient: a Georgia med spa cannot run a fully remote intake into a first injectable appointment.

The Protocol File: What a Georgia NP-Run Med Spa Must Produce on Demand

Two boards, GDNA, and a plaintiff's attorney can all ask for the file, and the practice that assembles it afterward is already behind. All of this should exist before the first patient:

1. The executed protocol agreement with current licence numbers, proof of filing within 30 days, and Board registration confirmation for it and every amendment
2. The APRN's Board of Nursing authorisation and current national certification
3. The physician's Georgia licence verification and CV, evidencing specialty comparability for the delegated procedures
4. The named alternate physician and their written acceptance of that role
5. Annual protocol review documentation — dated, signed, showing what changed
6. Pharmacology and CE records, including the annual training the 2026 rules put on the physician to ensure
7. DEA and GDNA registrations plus PDMP enrolment, if any controlled substance is stocked or prescribed
8. Quarterly physician evaluation and 100 percent chart review records for every controlled-substance patient
9. Written treatment protocols for every procedure on the menu, physician-approved
10. Cosmetic laser licences for every operator, with device protocols, maintenance logs, and the Class 3B/4 safety programme
11. Evaluation, consent, and individualised order documentation in every chart
12. Emergency protocols and drugs for anaphylaxis, vascular occlusion, and hypoglycaemia, with in-date stock and training records
13. Staff agreements with scope defined, and malpractice coverage naming aesthetic procedures

Enforcement: Which Board Disciplines Whom, and For What

The split-jurisdiction structure means one arrangement can generate two proceedings. The Board of Nursing disciplines the APRN — practising outside the protocol, prescribing without a current agreement, exceeding schedule limits. The Composite Medical Board disciplines the physician — absentee delegation, delegating outside their specialty, exceeding the APRN and PA count, delegating to unqualified personnel, or being unlawfully employed by the APRN they supervise. GDNA and the DEA act on controlled substance handling, records, and PDMP compliance. Unlicensed practice is a criminal matter for prosecutors.

What Actually Draws Action in Aesthetics

• The absent delegating physician. A signature and no contact — the most common finding of all.
• Specialty mismatch. A physician with no aesthetic background on a protocol covering advanced injectables or ablative laser.
• Delegation to unlicensed staff. Medical assistants injecting — criminal exposure for the assistant, unprofessional conduct for the physician.
• Unfiled or lapsed protocols. Every prescription under a protocol never filed, or invalid after three months incomplete, is unauthorised.
• The evaluation that never happened. Treating from an intake form, or on a standing order never individualised.
• Missed quarterly physician evaluations. The requirement almost nobody diaries — and the one that leaves a trail showing exactly when it stopped.
• Compensation flowing from an APRN-owned entity to the delegating physician — the 2026 focus, and the reason to have your structure reviewed now.

Absence of enforcement in your ZIP code is not authorisation. Investigations in aesthetics are complaint-driven — a bad outcome, a departing employee, a competitor — so a practice can operate outside the rules for years and then be examined against them retroactively.

The Practical Sequence for an NP Opening in Georgia

Order matters, because several of these have lead times that stack rather than overlap.

1. Confirm your own credentials first — Georgia RN licence, APRN authorisation, current national certification.
2. Get a written structural opinion before you form anything. After the May and June 2026 Board statements this is the highest-risk decision here and the most expensive to unwind. Ask specifically who may pay the delegating physician.
3. Recruit the delegating physician on specialty comparability, not price. Ask how many APRNs and PAs they carry against the eight-slot cap, and ask for the CV before the rate.
4. Name the alternate physician in the same conversation. Not later. This is your continuity plan.
5. Draft the protocol against the actual menu — every drug by name or class, every procedure, device, and diagnostic study, and the refill parameters — not a template's default list.
6. Execute and file within 30 days. Track the filing date, and remember that deemed-valid is not the same as approved.
7. Start DEA and GDNA registrations early if anything controlled will be stocked — four to six and two to four weeks respectively, state following federal.
8. Obtain laser licensure for yourself and every operator before the device arrives, not after.
9. Write and have the physician approve the treatment and emergency protocols.
10. Build the compliance calendar — annual protocol review, quarterly controlled-substance evaluations, CE cycles, licence renewals, device maintenance — then re-verify at 90 days, because menus drift fastest in the first quarter.

For a fuller launch timeline see the Georgia NP playbook; to compare against another state, our 51-state regulations database gives the citation behind each rule.

Myths and Corrections

Myth: the protocol agreement statute is § 43-34-23. It is § 43-34-25. Section 43-34-23 is the general delegation and definitions provision. We carried this error ourselves and have corrected it.

Myth: Georgia bans APRN ownership under a CPOM statute. That statute was repealed in 1982. The operative constraint is § 43-34-25's prohibition on a physician being the employee of an APRN they must supervise, as the Board currently reads it.

Myth: Georgia APRNs have full Schedule II prescriptive authority. They do not. Schedule I and II remain prohibited except for a narrow emergency hydrocodone and oxycodone carve-out capped at an initial five-day supply.

Myth: an APRN can order an MRI to work up a filler complication. CT, MRI, PET, and nuclear medicine are orderable only in a life-threatening situation. A serious complication is a transfer, not an imaging order.

Myth: "all aesthetic medications" is an adequate formulary. The statute requires the agreement to identify the parameters of delegation, including refills. A catch-all delegates nothing identifiable. Relatedly, an out-of-state delegating physician is never sufficient — the licence must be Georgia.

Myth: other APRNs in Atlanta own med spas, so it must be allowed. Some are structured compliantly; some have not yet been examined. Market prevalence is not a legal opinion.

Myth: a signed protocol is enough — filing is administrative. Unfiled is unauthorised, and incomplete for three months is invalid and starts over with a new fee.

Disclaimer: This article is for educational purposes only and does not constitute legal advice. Georgia's APRN protocol rules, entity-structure law, and Composite Medical Board delegation policy involve nuanced regulatory considerations specific to your situation, and several of the 2026 developments described here remain unsettled. Consult a Georgia healthcare attorney before forming any med spa entity or entering into any APRN-physician protocol arrangement.