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

If you are an APRN in Georgia thinking about opening or running a med spa, the laws in your way are different from what you may have read on Reddit, in Facebook groups, or on consulting websites that paint Georgia with the same brush as more permissive states. Georgia is its own animal. The rules are strict, the enforcement is real, and the structure that makes a med spa lawful here is narrower than most APRNs realize.

Here is what GA Code §43-34-23 actually requires, what the Georgia Composite Medical Board (GCMB) treats as the practice of medicine, and how an APRN can legitimately participate in a Georgia med spa without crossing the line.

Georgia Uses "APRN" — Not "NP"

The first thing that trips up out-of-state nurse practitioners in Georgia is terminology. Georgia's licensure framework, anchored in GA Code Title 43, Chapter 34 and Title 43, Chapter 26 (the Registered Professional Nurse Practice Act), uses the term Advanced Practice Registered Nurse — APRN — as the umbrella for nurse practitioners, certified nurse midwives, certified registered nurse anesthetists, and clinical nurse specialists.

An NP in Georgia is licensed by the Georgia Board of Nursing as an APRN with NP recognition. The terminology matters because the statutes, the protocol forms, and the GCMB rules use APRN throughout. If you are reading older blog posts that say "Georgia NP" without the APRN frame, you are missing the regulatory vocabulary the boards actually use.

The Nurse Protocol Agreement — GA Code §43-34-23

The cornerstone of APRN practice in Georgia is the nurse protocol agreement under GA Code §43-34-23. There is no version of APRN practice in Georgia that does not involve one, and the statute is the most important piece of law for any APRN entering med spa work in the state.

The statute requires that before an APRN can exercise any delegated medical act — including prescribing, ordering durable medical equipment, ordering radiographic imaging, or performing procedures that constitute the practice of medicine — the APRN must have entered into a written nurse protocol agreement with a Georgia-licensed delegating physician. The agreement must contain, at minimum:

• Identification of the delegating physician and the APRN, with current Georgia license numbers
• The specific medical acts delegated to the APRN — drugs that may be prescribed (by name or class), procedures the APRN may perform, diagnostics the APRN may order
• The conditions and circumstances under which delegation is authorized
• Provisions for the delegating physician to be available for immediate consultation
• Quality-assurance and chart-review processes
• A provision for periodic review of the protocol — typically annually at minimum

The protocol agreement is filed with the Georgia Composite Medical Board on the APRN-physician form. Without a current, signed, on-file protocol agreement, an APRN in Georgia cannot lawfully prescribe a single medication or perform a single delegated medical act, no matter how many years of experience the APRN brings.

The Delegating Physician — Not Just Any MD

The delegating physician must be an MD or DO licensed in Georgia, in good standing, and qualified by training or experience to delegate the specific acts in the protocol. GCMB Rule 360-32 sets the framework for delegation, including Rule 360-32-.05 on the scope of delegation to APRNs and PAs.

One delegating physician may have a protocol with multiple APRNs, subject to numeric limits set in the rules and in physician supervision constraints. The physician's CV, board certification, and active practice profile should support delegation of the specific procedures in the protocol — a delegating physician with no aesthetic medicine background signing a protocol covering laser surgery and advanced filler work is a regulatory red flag.

Prescriptive Authority — Real, but Bounded

Georgia has expanded APRN prescriptive authority over the past decade. Under the protocol agreement, an APRN may prescribe Schedule III–V controlled substances and, with the additional safeguards added by recent legislation, Schedule II controlled substances within defined limits. APRNs must hold a separate DEA registration to prescribe controlled substances and must operate within the formulary specified in the protocol.

For a med spa, the relevant prescriptions typically include:

• Botulinum toxin products (Botox, Dysport, Xeomin, Jeuveau)
• Hyaluronic acid and other dermal fillers (treated as prescription devices)
• GLP-1 agonists for weight management (semaglutide, tirzepatide)
• Hormone therapy products
• Topical pharmaceuticals (numbing agents, hydroquinone, prescription-strength retinoids)
• Emergency medications stocked at the facility (epinephrine, hyaluronidase)

All of these must be inside the formulary the protocol authorizes. An APRN who prescribes outside the protocol — even for a clinically reasonable indication — has stepped outside delegated authority and exposed both themselves and the delegating physician to board action.

The Critical Distinction: Practice Authority vs. Ownership

This is where most online guidance for Georgia APRNs is incomplete. A nurse protocol agreement is a scope of practice mechanism. It governs what an APRN can do clinically. It does not change who can own a medical practice in Georgia.

Those are two different bodies of law, and the protocol statute touches only one of them.

Why a Med Spa Is "Medicine" in Georgia

The Georgia Composite Medical Board has been consistent: cosmetic procedures using prescription drugs, energy-based devices, or invasive techniques are the practice of medicine. GCMB guidance and disciplinary records over the past several years show enforcement against med spas that treated cosmetic injection and laser work as something other than medical practice.

Services GCMB treats as the practice of medicine in a med spa context include:

• Botox and other neuromodulator injections
• Dermal filler injections
• Laser hair removal, IPL, fractional laser resurfacing, vascular laser
• GLP-1 prescriptions and weight-loss injections
• PRP injections
• Microneedling with topical pharmaceuticals or radiofrequency
• Chemical peels above superficial grade
• IV therapy, vitamin injections, hormone protocols

Because these are the practice of medicine, the entity offering them is engaged in medical practice — and Georgia's Corporate Practice of Medicine doctrine applies.

Corporate Practice of Medicine — GA Code §43-34-37

Georgia's CPOM rule, anchored in GA Code §43-34-37 and supported by Georgia Professional Corporation and PLLC statutes, restricts the ownership of entities engaged in the practice of medicine to physicians (MD/DO) licensed in Georgia. Lay corporations cannot practice medicine. Non-physician licensees — including APRNs — cannot own a Georgia Professional Corporation that practices medicine.

This means an APRN cannot:

• Be the sole or majority owner of a medical PC offering cosmetic medical services
• Hold equity in a medical PC in any percentage that violates ownership-licensure matching
• Use a Georgia LLC as a workaround — a standard LLC cannot practice medicine

For a fuller treatment of CPOM in the med spa context, see our Georgia ownership guide.

The Medical Director Question — APRNs Need Not Apply

A second question that comes up constantly: can an APRN serve as the medical director of a Georgia med spa? The answer is no.

Georgia Composite Medical Board policy and GCMB Rule 360-32 frame the medical director role as the supervising physician of record for the medical practice. The medical director is the licensee responsible for ensuring that medical care delivered at the facility meets the standard of care, that protocols are appropriate, and that delegation to APRNs and other staff is supervised. That role belongs to an MD or DO — not to an APRN.

In practical terms, the same MD/DO who serves as the facility's medical director typically also serves as the APRN's delegating physician under the nurse protocol agreement. The two roles align: the supervising physician for the facility and the delegating physician for the APRN are usually the same person. For details on what the medical director role actually requires, see our Georgia medical director guide.

How Georgia Compares to New York and California

APRNs moving to Georgia from a more permissive state often assume the rules port over. They do not. Here is the side-by-side:

• California: AB-890 created a path to "104 NP" independent practice authority, and limited NP ownership of cosmetic-medicine entities is increasingly viable under specific structures. See our AB-890 deep dive.
• New York: The Nurse Practitioner Modernization Act lets NPs with 3,600+ hours practice without a written collaborative agreement, though CPOM still bars NP ownership of medical PCs. See our NY 3,600-hour rule guide.
• Georgia: Every APRN — regardless of years of experience or hours practiced — must operate under a written nurse protocol agreement with a delegating physician. There is no independence pathway. CPOM applies in full. The medical director must be a physician.

Of the three large state markets that med spa operators most often compare, Georgia is the most restrictive for NP independence. That is not a defect in Georgia law — it is a deliberate policy choice the legislature has reaffirmed across multiple sessions.

What an APRN CAN Do in a Georgia Med Spa

The picture is not as restrictive as the ownership and director rules might suggest. An APRN with a properly structured nurse protocol agreement has substantial clinical authority inside a Georgia med spa.

With an active protocol agreement and proper delegation, a Georgia APRN can:

• Prescribe Botox, dermal fillers, GLP-1s, hormone therapies, and other medications within the protocol formulary
• Prescribe Schedule II–V controlled substances within the limits of GA law and the protocol
• Perform injections (neuromodulators, fillers, IV therapy, hormone injections) personally
• Perform laser and energy-based procedures consistent with manufacturer training and the protocol
• Conduct the good-faith examination required before prescribing
• Supervise RNs performing delegated treatments under standing orders
• Serve as the lead clinician, clinical operations leader, or chief clinical officer in title
• Train and onboard new clinical staff under the protocol

For more on which licensees can perform which procedures in Georgia, see our guide to who can inject Botox in Georgia.

What the APRN cannot do, regardless of experience:

• Practice without an active nurse protocol agreement
• Prescribe outside the formulary or scope of the protocol
• Own a medical PC offering cosmetic medical services
• Serve as the medical director of record
• Supervise the delegating physician (the relationship runs the other direction)
• Hold themselves out to the public as practicing "medicine"

Three Legitimate Structures for APRN Med Spa Involvement in Georgia

Here are the structures that work in Georgia for APRNs who want clinical, operational, or economic involvement in a med spa without crossing CPOM or the protocol rules.

Structure 1: Physician-Owned PC, APRN as Lead Clinician

The most common, cleanest structure. A Georgia-licensed MD or DO owns the medical PC. The APRN is employed (or engaged as an independent contractor). The same physician serves as both the facility's medical director and the APRN's delegating physician under the nurse protocol agreement filed with GCMB.

The APRN runs the daily clinical operation — performing injections, supervising RNs, managing protocols, training staff. Compensation can be salary, base plus production, or a partner-style profit-share that fairly compensates the APRN's contribution. This structure is bulletproof when the underlying documentation — the protocol, the delegation log, the chart-review records, the medical director agreement — is in order.

Structure 2: APRN-Owned Wellness Practice With Bounded Scope

An APRN can form a Georgia entity (typically a PLLC if the structure permits, or operate as a sole proprietor) offering services that fall strictly within nursing scope and do not constitute the practice of medicine — for example, basic wellness coaching or services where no prescription, no medical device, and no procedure regulated as the practice of medicine is delivered.

This structure is narrow. The moment the menu reaches Botox, fillers, laser, GLP-1s, or PRP, the entity is engaged in the practice of medicine and the structure breaks. Use this only with Georgia healthcare counsel reviewing the service list and the entity formation, and only if the business model genuinely fits within nursing scope.

Structure 3: MSO + Physician PC

The Management Services Organization model is the classic CPOM-compliant structure for non-physician participation in medical practice economics. The APRN (or any non-physician partner) forms an MSO that provides non-clinical services — administration, marketing, HR, real estate, IT, billing, equipment leasing — to a physician-owned medical PC under a fair market value management services agreement.

The physician owns the medical PC and exercises clinical authority. The MSO captures the non-clinical economics. Done correctly with arm's-length contracts, fair market value pricing, and no MSO control over clinical decisions, this works in Georgia. Done sloppily — with the MSO setting clinical policy, capturing all profit through inflated fees, or operating as a sham for non-physician ownership — it is exactly the arrangement Georgia regulators have unwound. This structure requires Georgia healthcare counsel; it is not a do-it-yourself project.

Common Myths to Debunk

Myth: "Georgia is moving toward full practice authority for NPs." Multiple bills have been introduced over the years and none have passed. As of 2026, Georgia remains a restricted-practice state for APRNs. Plan around the law that exists, not the law you wish existed.

Myth: "If my supervising MD is in another state, the protocol still works." No. The delegating physician under a Georgia nurse protocol agreement must be licensed in Georgia. Out-of-state delegation does not satisfy GA Code §43-34-23.

Myth: "I can hire a part-time medical director and own the med spa as an APRN." Hiring a medical director does not satisfy CPOM if you are the corporate owner of the medical entity. Ownership and supervision are separate requirements. The owner must be a physician.

Myth: "Other APRNs in Atlanta own med spas — clearly it's allowed." Some operate compliantly through MSO structures or as employees of physician-owned PCs. Some operate non-compliantly and have not yet been investigated. The number of operators in a market is not a legal opinion. The Georgia Composite Medical Board and the Attorney General have brought enforcement actions, and absence of enforcement is not authorization.

Myth: "My protocol can just say 'all aesthetic medications' and I'm covered." The protocol must specify drugs and procedures with enough particularity that the delegating physician's authorization is meaningful. Vague catch-all language is a frequent finding in board investigations and a common reason protocols are deemed insufficient.

Documentation Every Georgia APRN in a Med Spa Should Have

Whether you own a stake (through an MSO), lead the clinical operation, or work as an employed APRN, these documents protect you:

1. Active nurse protocol agreement on file with the Georgia Composite Medical Board, signed by both the APRN and the delegating physician, with current license numbers
2. Annual protocol review documentation showing periodic review and update of the protocol
3. Delegating physician's CV on file at the practice, supporting their qualification to delegate aesthetic medicine
4. DEA registration for the APRN if controlled substances are within the protocol
5. Employment or independent contractor agreement with the medical PC clearly defining role, scope, and compensation
6. Facility protocols for every procedure performed, signed by the medical director
7. Good-faith exam documentation for every patient before prescribing
8. Chart review and quality-assurance records per the protocol
9. Malpractice insurance covering aesthetic medicine specifically
10. License verification records for any RNs supervised under the APRN's orders

For the full operational picture, see our Georgia med spa compliance checklist.

Summary

1. Georgia uses "APRN" as the licensure umbrella; nurse practitioners are APRNs with NP recognition under the Georgia Board of Nursing
2. GA Code §43-34-23 requires every APRN to operate under a written nurse protocol agreement with a Georgia-licensed delegating physician
3. The protocol must specify delegated drugs, procedures, conditions, and provide for periodic review — and must be on file with GCMB
4. APRNs have prescriptive authority including Schedule II controlled substances under the protocol, with DEA registration
5. Georgia is a restricted-practice state — there is no independent practice pathway equivalent to California AB-890 or the NY 3,600-hour rule
6. CPOM under GA Code §43-34-37 and GCMB policy bars APRNs from owning a medical practice offering cosmetic medical services
7. The medical director of record must be an MD or DO — APRNs cannot fill that role
8. An APRN can prescribe, inject, supervise RNs, and lead clinical operations under a protocol — but cannot own the medical PC or serve as medical director
9. Three legitimate structures: physician-owned PC with APRN as lead clinician, narrow APRN-owned wellness entity, or MSO + physician PC arrangement

Disclaimer: This article is for educational purposes only and does not constitute legal advice. Georgia's APRN protocol rules, CPOM doctrine, and GCMB delegation policy involve nuanced regulatory and case-law considerations specific to your situation. Consult with a Georgia healthcare attorney before forming any med spa entity or entering into any APRN-physician protocol arrangement.