Maryland Med Spa Regulations
Maryland has no med-spa-specific statute; medical aesthetic services are regulated by the Board of Physicians as "cosmetic medical procedures" under COMAR 10.32.09, which requires a licensed physician to personally assess each patient and to delegate or supervise any non-physician who injects, operates lasers, or otherwise treats living tissue.
Last reviewed: 2026-07-21
Who can inject Botox and dermal fillers in Maryland?
Maryland has no injector-specific med-spa statute; injections are 'cosmetic medical procedures' governed by the Board of Physicians (COMAR 10.32.09). A Maryland-licensed physician (MD/DO) may perform them or delegate to a physician assistant, or assign to any other licensed health care provider — a nurse practitioner (CRNP) under their own advanced-practice scope, or a registered nurse by delegation — whose own licensing board has determined the procedure falls within that provider's scope of practice.
Source: COMAR 10.32.09.04 — Qualifications of Individual to Whom Acts May Be Delegated and Assigned, COMAR 10.32.09.02 — Definitions (injection = cosmetic medical procedure)
Does Maryland require a good-faith exam before treatment?
Yes. Before a delegated cosmetic medical procedure, 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' (COMAR 10.32.09.05). 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 via telehealth — though the cosmetic rule's demand that the physician 'personally' assess and the hands-on nature of injectables make an in-person exam the safer practice.
Source: COMAR 10.32.09.05 — physician shall personally perform initial assessment and prepare written treatment plan, COMAR 10.32.05.05 — telehealth clinical evaluation before treatment/prescription
Does a med spa in Maryland need a medical director?
Maryland does not use the statutory term 'medical director,' but a Maryland-licensed physician must direct all cosmetic medical procedures: the physician must be licensed and trained before performing, delegating, assigning, or supervising them (COMAR 10.32.09.03), must personally assess each patient, maintain written office protocols, and retain responsibility for the delegated acts (COMAR 10.32.09.05). A non-physician cannot own or run the medical side without a supervising physician.
Source: COMAR 10.32.09.03 — physician must be licensed and trained before performing/delegating/supervising, COMAR 10.32.09.05 — physician retains responsibility, protocols, supervision
Can a non-physician own a med spa in Maryland?
Maryland enforces the corporate practice of medicine doctrine. Only an individual licensed by the Board may practice medicine in Maryland (Health Occ. §14-301), and a corporation may render professional (medical) services only through individuals licensed to render them (Corps. & Assns. §5-105); a lay corporation therefore cannot practice medicine or employ physicians to deliver clinical care, and a medical practice entity must be a physician-owned professional corporation (limited hospital/HMO exceptions aside). Ownership of the medical practice is effectively restricted to licensed physicians.
Source: Md. Health Occ. §14-301 — only a licensed individual may practice medicine, Md. Corps. & Assns. §5-105 — professional services rendered only through licensed individuals
What supervision does Maryland require for med-spa procedures?
The physician must provide on-site supervision whenever a non-physician performs a cosmetic medical procedure or uses a cosmetic medical device (COMAR 10.32.09.05). One relaxation exists: for a Board-approved delegation agreement with a physician assistant, the physician may supervise on an 'immediately available' basis after having evaluated the patient and developed a written treatment plan. Non-physicians must first be trained to competency under the delegating physician's direct, present observation (COMAR 10.32.09.07).
Source: COMAR 10.32.09.05 — on-site supervision; PA delegation-agreement exception, COMAR 10.32.09.07 — training under direct, present supervision to competency
What can an esthetician legally do in Maryland?
Estheticians are licensed by the Maryland Board of Cosmetologists (Dept. of Labor), not a health board, and their scope is limited to superficial, non-medical skin care: massaging (beautification/cleansing of skin), exfoliating (removing dead skin cells), toning via facials, masks and wraps, and cosmetic microneedling only with a non-medical device whose needles are no longer than 1 mm and do not penetrate beyond the epidermis (COMAR 09.22.01.04). Anything that penetrates or ablates living tissue — injections, ablative peels, laser/IPL — is a cosmetic medical procedure outside an esthetician's scope and requires a Department of Health license.
Source: COMAR 09.22.01.04 — esthetician scope; microneedling limited to <=1mm not beyond epidermis
Who can operate a cosmetic laser in Maryland?
Lasers, intense pulsed light, and radiofrequency devices are 'cosmetic medical devices' and their use is a 'cosmetic medical procedure' under COMAR 10.32.09.02. Their operation is therefore regulated exactly like injections: performed by a physician, or delegated to a physician assistant, or assigned to another licensed health care provider (NP, RN) whose licensing board deems it within scope, with physician training and supervision. Estheticians and unlicensed technicians may not operate them.
Source: COMAR 10.32.09.02 — laser/IPL/RF are cosmetic medical devices, COMAR 10.32.09.04 — delegation/assignment to PA and other licensed providers
What are the rules for IV therapy and vitamin drips in Maryland?
Maryland has no med-spa-specific IV statute. Infusion (IV) therapy is defined by the Board of Nursing as 'the initiation and administration of medication, fluids, and nutrients via an intravenous access device' (COMAR 10.27.20.02) and is a regulated nursing act requiring documented education and competency. Because it administers prescription fluids and drugs, it is the practice of medicine/nursing that must be ordered by an authorized prescriber (physician, NP, or PA) after a valid patient evaluation, with RNs (and LPNs in limited settings) administering under that order; a lay 'drip bar' without a prescriber is unlawful.
Source: COMAR 10.27.20.02 — definition of infusion therapy (Board of Nursing)
Does a med spa have to register or hold a license in Maryland?
Maryland has no dedicated med-spa facility license or registration. A medical spa is regulated indirectly: the practice must be physician-owned/directed under the corporate-practice-of-medicine rules, and all cosmetic medical procedures are governed by the Board of Physicians under COMAR 10.32.09, which requires physician licensure, patient assessment, written protocols, and delegation/supervision compliance. Estheticians and beauty salons operating alongside need Board of Cosmetologists licensure, and providers need their respective health-board licenses; there is no separate 'med spa' permit.
Source: COMAR 10.32.09.01 — Scope: chapter governs cosmetic medical procedures by/under a physician
What are the penalties for practicing outside scope in Maryland?
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 (COMAR 10.32.09.09A). A non-physician who performs a cosmetic medical procedure without proper authorization is guilty of practicing medicine without a license and subject to a fine of not more than $50,000 (COMAR 10.32.09.09B–C). At the statutory level, Health Occ. §14-606(a)(4) confirms that violating the unlicensed-practice statute (§14-601) is both a felony — fine up to $10,000 and/or imprisonment up to 5 years — and separately subject to a civil fine of not more than $50,000 levied by a disciplinary panel, so the criminal and civil-fine exposure are cumulative, not alternatives. Independent of those penalties, a Board disciplinary panel may also issue a cease-and-desist order or obtain injunctive relief against anyone practicing medicine without a license or falsely representing that they are authorized to practice medicine (Health Occ. §14-206(e)).
Source: COMAR 10.32.09.09 — Grounds for physician discipline (A); non-physician unlicensed practice fine up to $50,000 (B-C), Md. Health Occ. §14-606(a)(4) — Violating §14-601 (unlicensed practice) is a felony (fine up to $10,000/5 yrs) and separately subject to a $50,000 civil fine levied by a disciplinary panel, Md. Health Occ. §14-206(e) — Disciplinary panel may issue a cease-and-desist order or obtain injunctive relief against unlicensed or misrepresented practice of medicine
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This information is provided for general educational purposes only and is not legal advice. Regulations change — verify current requirements with your state medical/nursing board before acting.