October 5, 2026 28 min read

Maryland Med Spa Compliance Checklist (2026): The Physician-Chain Audit

An eleven-section audit for Maryland med spas, built around one idea: every treatment has to trace back to a trained, Maryland-licensed physician. Each item states the requirement, the document that proves it, and who signs it.

Quick Answer

Maryland has no med spa license, so a compliance audit tests whether every treatment traces to a physician. The medical practice is physician-owned. A trained, Maryland-licensed physician personally assesses each patient, writes the treatment plan, keeps written office protocols, and is on site whenever a non-physician injects or uses a laser, IPL, or radiofrequency device. The one exception is a physician assistant under a Board-approved delegation agreement. PAs, nurse practitioners (CRNPs), and registered nurses treat only by delegation or assignment after training to competency. Estheticians, medical assistants, and unlicensed owners never do.

Maryland has no med spa statute, no facility license, and no registry. What it has instead is one Board of Physicians chapter, COMAR 10.32.09, written as a set of duties for physicians. Every other license in the building reaches cosmetic work through a physician, so every item below asks a version of the same question: can the file show the physician?

This audit works through ownership, the physician's own qualifications, delegation and supervision, the pre-treatment assessment, the procedure matrix, consent and records, lasers, IV therapy, emergencies, advertising, and board inquiries. The legal points trace to our Maryland record, last reviewed July 21, 2026, which you can read with its citations on the Maryland med spa regulations page. The role-by-role answers match our guide to who can inject Botox in Maryland, which explains each verdict at length.

In short

A Maryland med spa passes this audit when its file shows seven links in one chain. A physician owns the medical practice. That physician is licensed in Maryland and trained in cosmetic procedures. Written office protocols cover every service. The physician personally assessed each patient and wrote a plan. Each PA, CRNP, and RN holds a documented delegation or assignment and a competency sign-off. A physician was on site for every non-physician treatment, with the PA exception documented where it is used. And nobody outside those licenses treated anyone. Unauthorized cosmetic procedures expose the non-physician to a fine of up to $50,000 and the physician to Board discipline.

Reading the Maryland Audit: Codes, Labels, and Signers

Each item carries a code from MD-A1 to MD-K5, so a finding can be logged and tracked without rewriting the requirement. Under the requirement sit two fields. Proof names the document a reviewer would ask for. Signed by names the person who should put their name to it, which is usually the physician, because Maryland puts the duties on the physician.

Each item also carries one of three labels. MD record means the requirement comes from our Maryland record and its citations. MD injector guide means it is a practice step our Maryland who-can-inject guide recommends to show a record requirement is met, such as a supervision log. Good practice means our record is silent and the item reflects ordinary compliance discipline, not a Maryland rule. We have not imported any other state's requirement to fill a silence.

Run Sections C and D monthly. They hold the requirements that drift fastest in a busy clinic: who was on site, and who assessed the patient. The calendar near the end sets a rhythm for the rest.

Section A. Ownership: A Physician-Owned Medical Practice

Start the Maryland audit with the entity, because a defect here cannot be fixed by good clinical work later. According to our Maryland record, the state enforces the corporate practice of medicine doctrine. Only an individual licensed by the Board may practice medicine in Maryland under Health Occupations §14-301, and under Corporations and Associations §5-105 a corporation may render professional services only through individuals licensed to render them. The record concludes that a lay corporation cannot practice medicine or employ physicians to deliver clinical care, and that the medical practice entity must be a physician-owned professional corporation, with limited hospital and HMO exceptions.

Our record also confirms that Maryland has no med spa facility license or registration. That cuts both ways. No permit has to be renewed, but no permit stands in for the ownership structure either. If the Board of Physicians ever asks who owns the practice that delivered a cosmetic injection, the answer has to be a Maryland physician, and the formation documents have to show it.

Business and clinical layers

Many Maryland operators separate a physician-owned practice that delivers medical care from a business that holds the lease, the brand, or the retail products. Our record addresses who may own the medical practice. It does not address how a lay-owned business may contract with one, and we make no claim that any particular management structure is permitted. Treat that boundary as a question for Maryland health care counsel before any money changes hands.

Maryland is generally described as a full practice authority state for nurse practitioners. Our Maryland record, which is specific to cosmetic medical procedures, still describes a physician-owned and physician-directed model and states that a non-physician cannot run the medical side without a supervising physician. Build the entity on that structure until a Maryland source says otherwise.

Section A items

  1. MD-A1The entity that delivers cosmetic medical procedures is owned by Maryland-licensed physicians, or falls within one of the limited hospital or HMO exceptions

    MD record

    Proof
    Proof: Articles of incorporation, ownership ledger, and a current Maryland license verification for each owner
    Signed by
    Signed by: Each physician owner

  2. MD-A2No lay owner, investor, or manager practices medicine or directs clinical decisions, including product selection, dosing, and delegation

    MD record

    Proof
    Proof: Organizational chart separating clinical authority from business authority, plus a signed acknowledgment from each non-physician owner
    Signed by
    Signed by: Physician owner; each non-physician owner

  3. MD-A3Any arrangement with a lay-owned company for space, staffing, marketing, or management has been reviewed before signing

    Good practice

    Proof
    Proof: Counsel's written review and the executed agreement, filed together
    Signed by
    Signed by: Physician owner; Maryland health care counsel

  4. MD-A4The compliance file states that no Maryland med spa license exists and lists the licenses the practice actually relies on

    MD record

    Proof
    Proof: One-page authority memo: physician licenses, provider licenses, and any Board of Cosmetologists licenses
    Signed by
    Signed by: Physician owner

  5. MD-A5Estheticians or salon services operating alongside the medical practice hold Board of Cosmetologists licensure

    MD record

    Proof
    Proof: Current license copies with expiration dates
    Signed by
    Signed by: Practice manager

  6. MD-A6Every clinician holds a current license from their own health board before the first shift

    MD record

    Proof
    Proof: Dated verification printouts, refreshed at each renewal
    Signed by
    Signed by: Credentialing lead; reviewed by the physician

Section B. The Physician: Licensure, Training, Protocols, and Responsibility

Maryland does not use the statutory term “medical director,” but our record makes a Maryland-licensed physician the person who directs every cosmetic medical procedure. Under COMAR 10.32.09.03, the physician must be licensed and trained before performing, delegating, assigning, or supervising a cosmetic medical procedure. Under COMAR 10.32.09.05, the physician must maintain written office protocols and retains responsibility for the acts delegated or assigned.

Training is a separate condition from licensure

A Maryland medical license does not by itself show cosmetic training. Our record names no course or case count that satisfies COMAR 10.32.09.03. What the rule fixes is the order of events: training comes before the physician injects, delegates, assigns, or supervises, so a physician joining a med spa should arrive with dated evidence of it.

Out-of-state physicians

The chapter speaks of physicians licensed by the Maryland Board. A physician licensed only in Virginia, Delaware, or the District of Columbia is not a Maryland physician for this purpose, because only an individual licensed by the Board may practice medicine in Maryland under Health Occupations §14-301. Practices near the state line should check this item first.

Section B items

  1. MD-B1Every physician who performs, delegates, assigns, or supervises a cosmetic medical procedure holds an active Maryland license

    MD record

    Proof
    Proof: Board of Physicians license verification, dated
    Signed by
    Signed by: Physician; credentialing lead

  2. MD-B2Each of those physicians has cosmetic training that predates the first procedure they performed or supervised at the practice (COMAR 10.32.09.03)

    MD record

    Proof
    Proof: Training certificates and a dated CV entry for each cosmetic procedure the physician oversees
    Signed by
    Signed by: Physician

  3. MD-B3Written office protocols exist for every cosmetic procedure on the menu (COMAR 10.32.09.05)

    MD record

    Proof
    Proof: Protocol binder with a version number and effective date on each protocol
    Signed by
    Signed by: Physician

  4. MD-B4Protocols are reviewed on a fixed cycle and whenever a product, device, or service is added

    Good practice

    Proof
    Proof: Protocol review log showing the date, the change, and the reviewer
    Signed by
    Signed by: Physician

  5. MD-B5A written agreement names the physician as responsible for delegated and assigned acts and states the hours the physician will be on site

    MD record

    Proof
    Proof: Signed physician agreement; responsibility clause and on-site schedule attached
    Signed by
    Signed by: Physician; practice entity

  6. MD-B6No physician licensed only outside Maryland acts as the supervising physician for any Maryland session

    MD record

    Proof
    Proof: Physician roster with each physician's Maryland license number
    Signed by
    Signed by: Physician owner

Section C. Delegation, Assignment, and On-Site Supervision

This is the section most Maryland practices fail, and the one most worth auditing monthly. COMAR 10.32.09.04 uses two verbs. Our record describes a physician who may delegate a cosmetic medical procedure to a physician assistant, or assign it to another licensed health care provider whose own licensing board has determined that the procedure falls within that provider's scope. The record names the nurse practitioner (CRNP), acting under the CRNP's own advanced-practice scope, and the registered nurse as providers who fit that description.

Then comes supervision. Under COMAR 10.32.09.05, as our record describes it, the physician must provide on-site supervision whenever a non-physician performs a cosmetic medical procedure or uses a cosmetic medical device. One relaxation exists: for a physician assistant under a Board-approved delegation agreement, the physician may supervise on an “immediately available” basis after having evaluated the patient and developed a written treatment plan. Our record describes no matching exception for a CRNP or an RN.

Before anyone treats independently, COMAR 10.32.09.07 requires training to competency under the delegating physician's direct, present observation. The observer is the physician who will delegate or assign, the observation is in person, and the standard is competency rather than a fixed number of cases.

What the PA exception does and does not change

The exception changes where the physician is while a PA treats. It does not change who assesses the patient. A PA under an approved agreement may treat a patient the physician has already assessed and planned, with the physician immediately available instead of in the building. A new patient still needs the physician's personal assessment first. Our record does not define “immediately available” in minutes or miles, so write the practice's own definition into the PA's protocols and make sure it describes how the clinic actually runs.

Section C items

  1. MD-C1Each PA's delegation is documented and lists the specific cosmetic procedures delegated

    MD record

    Proof
    Proof: Delegation record per PA, naming procedures and the delegating physician
    Signed by
    Signed by: Delegating physician; PA

  2. MD-C2Any PA treating with the physician “immediately available” works under a Board-approved delegation agreement, and only on patients the physician has already assessed and planned

    MD record

    Proof
    Proof: Board approval on file, plus the practice's written definition of immediate availability: contact method, maximum response time, and backup coverage
    Signed by
    Signed by: Physician; PA

  3. MD-C3Each CRNP and RN assignment is documented, lists the procedures, and notes the provider's licensing-board position on scope

    MD record

    Proof
    Proof: Assignment record per provider, with a copy of the Board of Nursing position kept in the compliance file
    Signed by
    Signed by: Assigning physician; CRNP or RN

  4. MD-C4A physician is on site whenever a CRNP, an RN, or a PA without an approved agreement performs a cosmetic procedure or uses a cosmetic device

    MD record

    Proof
    Proof: Daily supervision log (physician, arrival, departure) reconciled against the treatment log
    Signed by
    Signed by: On-site physician, each day

  5. MD-C5Each non-physician was trained to competency under the delegating physician's direct, present observation before treating independently (COMAR 10.32.09.07)

    MD record

    Proof
    Proof: Observed-case log and a signed competency determination listing the procedures covered
    Signed by
    Signed by: Delegating physician; the trainee

  6. MD-C6A competency determination is extended in writing before an injector adds a product, a treatment area, or a device

    MD injector guide

    Proof
    Proof: Competency addendum with new observed cases
    Signed by
    Signed by: Delegating physician

  7. MD-C7The clinic's hours policy states that CRNP and RN cosmetic work ends when the last supervising physician leaves the premises

    MD injector guide

    Proof
    Proof: Written hours policy and the posted staff schedule
    Signed by
    Signed by: Physician; practice manager

  8. MD-C8Each location operating at the same time has its own on-site physician for CRNP and RN sessions

    MD record

    Proof
    Proof: Location-by-location physician schedule for the month
    Signed by
    Signed by: Physician owner

Section D. The Personal Assessment and the Written Treatment Plan

Maryland names who performs the pre-treatment examination: the physician. Under COMAR 10.32.09.05, as our record quotes it, the physician must “personally perform the initial assessment of each patient” and “prepare a written treatment plan for each patient, including diagnosis and planned course of treatment.” The PA, CRNP, or RN who will inject carries out that plan. They do not write it.

A practice that has its nurse practitioner perform intake assessments for new neurotoxin patients, with the physician countersigning, is relying on a reading of the rule our record does not support.

Telehealth and the word “personally”

Our record notes that Maryland's telehealth rule, COMAR 10.32.05.05, permits a synchronous or asynchronous clinical evaluation appropriate to the patient before treatment or prescribing, so the required evaluation can generally be done by telehealth. It also flags the tension with the word “personally” and the hands-on nature of injectables, and calls an in-person exam the safer practice. Because the on-site rule puts the physician in the building on treatment day anyway, the simplest compliant workflow is an in-person assessment that same day.

Returning patients

Our record does not say how often a returning patient must be reassessed or when a written plan lapses. Set an interval, and require a new physician assessment whenever the history or the treatment areas change.

Section D items

  1. MD-D1The physician personally performed the initial assessment of each patient before any delegated or assigned procedure

    MD record

    Proof
    Proof: Assessment note authored by the physician and dated before the first treatment
    Signed by
    Signed by: Physician

  2. MD-D2Each patient has a written treatment plan containing a diagnosis and a planned course of treatment

    MD record

    Proof
    Proof: Treatment plan in the chart
    Signed by
    Signed by: Physician

  3. MD-D3Each plan is specific enough for the injector to follow: areas, product, dose range, follow-up interval, and stop-and-call conditions

    MD injector guide

    Proof
    Proof: Plan template plus a quarterly sample of completed plans
    Signed by
    Signed by: Physician

  4. MD-D4Where an assessment is done by telehealth, the encounter is documented as such and a written policy says when an in-person visit is required

    MD record

    Proof
    Proof: Telehealth policy and the telehealth encounter note
    Signed by
    Signed by: Physician

  5. MD-D5The protocol sets a reassessment interval and triggers for returning patients

    Good practice

    Proof
    Proof: Reassessment section of the protocol
    Signed by
    Signed by: Physician

  6. MD-D6Injectors escalate rather than modify: anything outside the plan goes back to the physician

    MD injector guide

    Proof
    Proof: Escalation entries in the chart, with the physician's response
    Signed by
    Signed by: Injector; physician

  7. MD-D7No new cosmetic patient is booked directly with a PA, CRNP, or RN before the physician's assessment

    MD injector guide

    Proof
    Proof: Monthly scheduling audit of new-patient appointments
    Signed by
    Signed by: Practice manager

Section E. Who May Perform Which Procedure in Maryland

Every row in this matrix is drawn from our Maryland record and agrees with our guide to who can inject Botox in Maryland. The definitions section, COMAR 10.32.09.02, classifies injection as a cosmetic medical procedure and classifies lasers, intense pulsed light, and radiofrequency equipment as cosmetic medical devices whose use is itself a cosmetic medical procedure. Injectables and energy devices therefore follow the same chain. Physician supervision applies to every “yes” for a non-physician, on site except for a PA under a Board-approved agreement.

Maryland procedure matrix. Every non-physician “yes” requires the physician's assessment and plan, training to competency, and supervision.
LicenseInjectables (neurotoxin, filler)Laser, IPL, RFMicroneedlingIV therapyInitial assessment for a delegated procedure
Physician (MD, DO)Yes, once licensed and trainedYesYesOrdersYes, personally
Physician assistantYes, by delegationYes, by delegationBeyond the epidermis, by delegationMay orderNo
Nurse practitioner (CRNP)Yes, by assignmentYes, by assignmentBeyond the epidermis, by assignmentMay orderNo
Registered nurseYes, by assignmentYes, by assignmentBeyond the epidermis, by assignmentAdministers on an orderNo
Licensed practical nurseTreat as noTreat as no (not listed)Treat as noLimited settings onlyNo
EstheticianNoNoOnly a non-medical device, needles 1 mm or shorter, not beyond the epidermisNoNo
Medical assistant or unlicensed staffNoNoNoNoNo

Three rows need a note. For the LPN, assignment under COMAR 10.32.09.04 requires a licensing-board determination that the procedure is within scope. Our record does not list LPNs, and we did not locate a Board of Nursing determination for cosmetic injection, so treat it as no until the Board answers in writing. For the esthetician, COMAR 09.22.01.04 limits the license to superficial, non-medical care: massage for beautification and cleansing, exfoliation, toning through facials, masks, and wraps, and microneedling with a non-medical device whose needles are no longer than 1 mm and do not penetrate beyond the epidermis. For the medical assistant, the cosmetic chapter offers no route at all, and our record states that unlicensed technicians may not operate cosmetic medical devices. “Laser tech” is a job title, not a Maryland license.

Section E items

  1. MD-E1A signed role matrix matching the one above is posted in the clinical area and matches the current staff roster

    MD record

    Proof
    Proof: Role matrix with roster attached, re-signed whenever staffing changes
    Signed by
    Signed by: Physician

  2. MD-E2No LPN injects or operates a cosmetic device unless the practice holds a written Board of Nursing determination that the procedure is within LPN scope

    MD injector guide

    Proof
    Proof: Either the Board's written determination, or an LPN job description that excludes cosmetic procedures
    Signed by
    Signed by: Physician; each LPN

  3. MD-E3Esthetician services stay within COMAR 09.22.01.04, and any esthetician microneedling device is non-medical with needles of 1 mm or less that do not pass the epidermis

    MD record

    Proof
    Proof: Service menu by provider type and the device specification sheet
    Signed by
    Signed by: Each esthetician; practice manager

  4. MD-E4Medical assistants and other unlicensed staff do not inject or operate lasers, IPL, or radiofrequency devices

    MD record

    Proof
    Proof: Job descriptions and a signed duties attestation
    Signed by
    Signed by: Each staff member; practice manager

  5. MD-E5Owners and managers without a qualifying license perform no cosmetic procedure, including on a short-staffed day

    MD record

    Proof
    Proof: Signed owner and manager acknowledgment
    Signed by
    Signed by: Each owner and manager

  6. MD-E6Protocols cover every injectable product the practice stocks, not only the neurotoxin brand named on the menu

    MD injector guide

    Proof
    Proof: Product list cross-referenced to protocols
    Signed by
    Signed by: Physician
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Section F. Consent and Patient Records

Our Maryland record does not set the content of a cosmetic consent form or a records-retention period, so every item in this section is labelled good practice. That does not make it optional. In Maryland the chart is also the evidence of the physician chain. A Board reviewer reading a neurotoxin chart should be able to see the physician's assessment, the written plan, the injector who carried it out, the physician who was on site, and the patient's consent, in that order.

What our record does not answer

We have not published a Maryland retention period, a Maryland consent statute, or a Maryland rule on before-and-after photography, because none of those appears in our record. Set those policies with Maryland health care counsel rather than borrowing another state's numbers.

Section F items

  1. MD-F1Informed consent for each procedure is signed before treatment and names the procedure, the product, and the person performing it

    Good practice

    Proof
    Proof: Procedure-specific consent form in the chart
    Signed by
    Signed by: Patient; clinician obtaining consent

  2. MD-F2Each treatment note references the physician's plan and names both the injector and the on-site supervising physician

    Good practice

    Proof
    Proof: Treatment note template with both fields required
    Signed by
    Signed by: Injector; supervising physician

  3. MD-F3Product, lot number, expiration, dose, and injection sites are recorded for every injectable treatment

    Good practice

    Proof
    Proof: Treatment note
    Signed by
    Signed by: Injector

  4. MD-F4Photography for marketing has its own written consent, separate from treatment consent

    Good practice

    Proof
    Proof: Photo and marketing consent form
    Signed by
    Signed by: Patient

  5. MD-F5A records-retention and destruction policy has been set with counsel

    Good practice

    Proof
    Proof: Written retention policy with counsel's sign-off date
    Signed by
    Signed by: Physician owner

Section G. Lasers, IPL, and Radiofrequency Devices

In Maryland, operating a laser is regulated exactly like giving an injection. Our record states that lasers, intense pulsed light, and radiofrequency devices are cosmetic medical devices under COMAR 10.32.09.02 and their use is a cosmetic medical procedure. A physician operates them, or delegates to a PA, or assigns to a CRNP or RN whose licensing board deems it within scope, with physician training and supervision. Estheticians and unlicensed technicians may not operate them.

Laser hair removal, often staffed by technicians elsewhere, therefore runs on the same chain as the injection room in Maryland.

What the record leaves to the practice

Our record does not address laser safety officers, eyewear standards, room signage, device registration, or maintenance intervals. Those are equipment-safety questions that a practice should still answer in writing. The items below mark them as good practice.

Section G items

  1. MD-G1Every laser, IPL, and radiofrequency device is on an inventory and treated as a cosmetic medical device

    MD record

    Proof
    Proof: Device inventory with model, serial number, and location
    Signed by
    Signed by: Physician

  2. MD-G2Each device is operated only by a physician, a PA by delegation, or a CRNP or RN by assignment

    MD record

    Proof
    Proof: Operator roster per device
    Signed by
    Signed by: Physician

  3. MD-G3Each operator's competency was established on that device under the delegating physician's direct, present observation

    MD record

    Proof
    Proof: Device-specific competency record
    Signed by
    Signed by: Delegating physician; operator

  4. MD-G4A physician is on site for every non-physician device session, except a PA under a Board-approved agreement

    MD record

    Proof
    Proof: Supervision log matched to the device session log
    Signed by
    Signed by: On-site physician

  5. MD-G5A written laser safety program covers eyewear, room access, signage, and the device manufacturer's maintenance schedule

    Good practice

    Proof
    Proof: Laser safety policy and maintenance records
    Signed by
    Signed by: Physician; designated operator

Section H. IV Therapy, Drugs, and Storage

IV therapy runs on a separate track from the cosmetic chapter. Our record cites the Board of Nursing's definition of infusion therapy at COMAR 10.27.20.02: the initiation and administration of medication, fluids, and nutrients via an intravenous access device. It is a regulated nursing act requiring documented education and competency. An authorized prescriber, meaning a physician, CRNP, or PA, orders it after a valid patient evaluation, and RNs administer it, with LPNs only in limited settings our record does not spell out. A drip bar with no prescriber is unlawful.

Drug handling

Our record is silent on drug storage, sourcing, and compounding for Maryland med spas. Keep those controls anyway. A locked, temperature-logged drug store and a purchasing file that shows where each product came from are the first things any reviewer asks to see once a complaint mentions a medication.

Section H items

  1. MD-H1Every IV traces to an order from a physician, CRNP, or PA written after a documented patient evaluation

    MD record

    Proof
    Proof: Evaluation note and order in the chart, dated before administration
    Signed by
    Signed by: Ordering prescriber

  2. MD-H2IVs are administered by RNs with documented infusion education and competency

    MD record

    Proof
    Proof: Infusion competency record per RN
    Signed by
    Signed by: RN; ordering prescriber or physician

  3. MD-H3No LPN starts or manages an IV until the practice has confirmed in writing that its setting is one where an LPN may do so

    MD record

    Proof
    Proof: Written Board of Nursing answer, or a job description excluding IV work
    Signed by
    Signed by: Physician

  4. MD-H4No menu-driven or walk-in IV is given without a prescriber's evaluation

    MD record

    Proof
    Proof: Intake workflow document and a monthly sample of IV charts
    Signed by
    Signed by: Practice manager; prescriber

  5. MD-H5Drugs are stored locked, temperatures are logged, and expirations are checked on a schedule

    Good practice

    Proof
    Proof: Storage log and expiry check sheet
    Signed by
    Signed by: Designated nurse

  6. MD-H6Every drug and fluid is purchased through a documented supply chain

    Good practice

    Proof
    Proof: Invoices and supplier records, filed by month
    Signed by
    Signed by: Physician

Section I. Emergency Preparedness

Our Maryland record does not set emergency-equipment or drill requirements for med spas, so this section is good practice throughout. Maryland's supervision rule does make one part easier: for CRNP and RN sessions, the physician is on site, so the emergency plan can name that physician as the first responder. The gap to plan for is the PA working under an approved agreement with the physician immediately available rather than present.

Write a response for each serious complication the menu can produce. For a national template that covers supplies, roles, and drills, work through our med spa emergency protocol checklist and adapt it to the Maryland supervision pattern.

Section I items

  1. MD-I1Written emergency protocols exist for each serious complication the service menu can cause

    Good practice

    Proof
    Proof: Emergency protocol set, versioned
    Signed by
    Signed by: Physician

  2. MD-I2Emergency supplies are stocked, in date, and checked on a fixed schedule

    Good practice

    Proof
    Proof: Supply check log
    Signed by
    Signed by: Designated nurse

  3. MD-I3The plan names the on-site physician as first responder and gives PA immediate-availability sessions a written escalation path

    Good practice

    Proof
    Proof: Emergency role card per session type
    Signed by
    Signed by: Physician; each PA

  4. MD-I5Every adverse event is recorded and reviewed by the physician

    Good practice

    Proof
    Proof: Adverse-event log with review notes
    Signed by
    Signed by: Physician

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Section J. Advertising and Holding Out

Maryland's sharpest advertising tool in our record is not an advertising rule at all. Under Health Occupations §14-206(e), as our record describes it, a Board disciplinary panel may issue a cease-and-desist order or seek injunctive relief against anyone practicing medicine without a license or falsely representing that they are authorized to practice medicine. Marketing that presents an esthetician, a medical assistant, or an unlicensed owner as a provider of cosmetic medical procedures invites exactly that kind of order.

Our record contains no Maryland rule on before-and-after photographs, testimonials, or pricing claims. Keep claims accurate and substantiated, and keep patient consent for any image you publish.

Section J items

  1. MD-J1Every person named in marketing as performing a service is a lawful Maryland performer of that service under Section E

    MD record

    Proof
    Proof: Marketing review log comparing named providers to the role matrix
    Signed by
    Signed by: Physician; marketing lead

  2. MD-J2Titles are accurate: no “injector” for an LPN or esthetician, no “laser specialist” for unlicensed staff, no “doctor” for non-physicians

    Good practice

    Proof
    Proof: Approved titles list used in bios and on badges
    Signed by
    Signed by: Practice manager

  3. MD-J3No advertising suggests treatment without a physician, such as “no doctor visit needed”

    MD injector guide

    Proof
    Proof: Copy review sign-off for each campaign
    Signed by
    Signed by: Physician

  4. MD-J4No advertising implies a state med spa license, permit, or certification

    MD record

    Proof
    Proof: Copy review sign-off
    Signed by
    Signed by: Marketing lead

Section K. Board Inquiries, Complaints, and Penalty Exposure

Maryland splits oversight across three bodies, so the first step in any inquiry is knowing which board is asking. The Board of Physicians licenses physicians and wrote COMAR 10.32.09. The Board of Nursing licenses RNs, LPNs, and CRNPs. The Board of Cosmetologists, part of the Maryland Department of Labor rather than the health department, licenses estheticians. Our record describes no med spa facility inspection program, so scrutiny usually starts with a complaint about a person.

What is at stake

Our record sets out three kinds of exposure. Improperly delegating, assigning, or supervising a cosmetic medical procedure, or letting an unqualified person perform one, is grounds for Board of Physicians discipline against the physician under COMAR 10.32.09.09A. A non-physician who performs a cosmetic medical procedure without proper authorization is practicing medicine without a license and faces a fine of not more than $50,000 under COMAR 10.32.09.09B and C. At the statutory level, Health Occupations §14-606(a)(4) makes unlicensed practice a felony carrying a fine of up to $10,000, imprisonment of up to five years, or both, and separately subject to a civil fine of up to $50,000 levied by a disciplinary panel. Our record notes the criminal and civil exposure are cumulative. The cease-and-desist and injunction power in §14-206(e) sits on top.

Section K items

  1. MD-K1All proof documents for Sections A through J are indexed in one place and can be produced the same day

    Good practice

    Proof
    Proof: Compliance file index with locations
    Signed by
    Signed by: Compliance lead

  2. MD-K2A named person receives board correspondence, and Maryland health care counsel is identified in advance

    Good practice

    Proof
    Proof: Contact sheet
    Signed by
    Signed by: Physician owner

  3. MD-K3Staff know which board licenses them and which board would hear a complaint about their work

    MD record

    Proof
    Proof: Board-to-license map in the staff handbook
    Signed by
    Signed by: Compliance lead

  4. MD-K4Patient complaints are logged, triaged by the physician, and closed with a written response

    Good practice

    Proof
    Proof: Complaint log
    Signed by
    Signed by: Practice manager; physician

  5. MD-K5Every staff member has been briefed on the unlicensed-practice penalties

    MD record

    Proof
    Proof: Signed penalty briefing acknowledgment
    Signed by
    Signed by: Each staff member

Trace One Appointment Through the Checklist

The fastest way to test a Maryland file is to pick one recent appointment and walk it backward through the codes. Here is a new patient booked for neurotoxin with a registered nurse, the most common Maryland appointment and the one with the most links to check.

  1. Booking. The appointment was scheduled after a physician assessment, not before it. Check D7 and the scheduling audit.
  2. Assessment. The chart holds the physician's own assessment note, dated before treatment. If the assessment was done by video, the note says so and the telehealth policy covers it. Check D1 and D4.
  3. Plan. A written plan with a diagnosis and planned course of treatment exists, with enough detail for the RN to follow. Check D2 and D3.
  4. Injector authority. The RN's assignment lists neurotoxin, the Board of Nursing position is on file, and the competency determination was signed by the assigning physician after observed cases. Check C3 and C5.
  5. Presence. The supervision log shows a Maryland physician, with dated cosmetic training, on site for the full appointment window. Check C4, B1, and B2.
  6. Consent and record. Consent was signed before treatment, and the treatment note names the product, lot, doses, sites, the RN, and the on-site physician. Check F1 through F3.
  7. Entity. The practice that billed the visit is the physician-owned professional corporation, not the lay-owned company that holds the lease. Check A1 and A2.

If any step fails, the appointment was not documented as compliant, whatever the clinical outcome. Each quarter, repeat the trace for one PA appointment, adding C2, and one laser session.

A Maryland Audit Calendar

This calendar groups the codes by when they can go wrong.

WhenCodes (MD-)Why then
Every treatment dayC4, C7, C8, G4Physician presence is the item most likely to drift, so reconcile the supervision log against the treatment log daily.
Every new patientD1, D2, D3, D7, F1The assessment and plan come before the first treatment, every time.
Every new clinicianA6, B1, B2, C1, C3, C5, E1No first shift until license, delegation or assignment, and competency are on file.
Every new product, device, or serviceB3, B4, C6, E6, G1, G3Protocol first, competency extension second, menu last.
MonthlyD7, H4, H5, I2, K4Scheduling, IV intake, storage, supplies, and complaints.
QuarterlyD3, appointment trace, J1Run the trace above and a marketing review.
AnnuallyA1 to A5, B5, F5, G5, K1 to K3Entity, agreements, retention, laser safety, and the inquiry file.

Where the Maryland Record Stops

Our Maryland record, last reviewed July 21, 2026, answers the core questions. It leaves the following open, and we have not filled them with another state's rules.

  • LPN scope. No LPN determination for cosmetic injection or device work. Treat as no until the Board of Nursing answers in writing.
  • Independent CRNP cosmetic practice. No Maryland source in our record resolves whether a CRNP may perform cosmetic procedures with no physician involved.
  • “Immediately available”. Undefined in time or distance for the PA exception.
  • Reassessment. No interval for returning patients and no expiry for a written plan.
  • Training standard. No course or case count for the physician's training or the non-physician's competency.
  • Management arrangements. The record covers who may own the medical practice, not how a lay business may contract with it.
  • Consent, records retention, photography. No Maryland-specific content or periods in our record.
  • Laser safety and drug storage. No Maryland med spa rules in our record.
  • Advertising. Nothing beyond the holding-out power in Health Occupations §14-206(e).

For each gap, send a written question to the relevant board and have Maryland health care counsel review the answer.

Questions Maryland Operators Ask About This Checklist

Does Maryland require a med spa license? + −
No. Maryland has no med spa facility license or registration. A med spa is regulated through the Board of Physicians' cosmetic procedure chapter, COMAR 10.32.09, through the corporate practice of medicine rules that make the medical practice physician-owned, and through each provider's own licensing board. Estheticians working alongside need Board of Cosmetologists licensure.
Does a Maryland med spa need a medical director? + −
Maryland does not use that statutory term, but a Maryland-licensed physician must direct all cosmetic medical procedures. Under COMAR 10.32.09.03 and .05, the physician must be licensed and trained, personally assess each patient, maintain written office protocols, and retain responsibility for delegated acts. A non-physician cannot run the medical side alone.
Does a physician have to be on site at a Maryland med spa? + −
Yes, whenever a non-physician performs a cosmetic medical procedure or uses a cosmetic medical device, under COMAR 10.32.09.05. The one exception is a physician assistant under a Board-approved delegation agreement, who may be supervised on an immediately available basis after the physician has evaluated the patient and written a treatment plan.
Who can own a med spa in Maryland? + −
The medical practice must be owned by Maryland-licensed physicians, according to our record. Maryland enforces the corporate practice of medicine doctrine under Health Occupations section 14-301 and Corporations and Associations section 5-105, so a lay corporation cannot practice medicine or employ physicians for clinical care, with limited hospital and HMO exceptions.
Who performs the exam before treatment at a Maryland med spa? + −
The physician. COMAR 10.32.09.05 requires the physician to personally perform the initial assessment of each patient and prepare a written treatment plan with a diagnosis and planned course of treatment. Maryland's telehealth rule permits a remote evaluation, but our record calls an in-person assessment the safer practice.
Can estheticians work in a Maryland med spa? + −
Yes, within their license. COMAR 09.22.01.04 limits estheticians to superficial, non-medical care such as facials, exfoliation, and microneedling with a non-medical device whose needles are 1 mm or shorter and do not pass the epidermis. They may not inject or operate lasers, IPL, or radiofrequency devices, even under a physician's supervision.
What happens if a Maryland med spa lets unlicensed staff treat patients? + −
The staff member is practicing medicine without a license, with a fine of up to $50,000 under COMAR 10.32.09.09 and felony exposure under Health Occupations section 14-606. The physician who allowed it faces Board of Physicians discipline under COMAR 10.32.09.09A, and a disciplinary panel may seek a cease-and-desist order or injunction.

MedSpa Standards publishes this checklist as general information, not legal or medical advice. In Maryland, cosmetic procedure, scope, and supervision questions belong to the Board of Physicians, the Board of Nursing, and the Board of Cosmetologists, and the answer for your practice depends on your facts and on rules that change. Confirm the current position with the board that licenses each person involved, and have a Maryland health care attorney review ownership, staffing, or supervision changes before you make them.

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