Medical director — by State
27 of 51 states require a medical director
27 of the 51 US jurisdictions (50 states plus the District of Columbia) require a medical director; the remaining 24 do not. The table below gives each state's rule in its own words, with the statute or board rule it comes from.
Medical director in all 51 US jurisdictions
| State | Medical director |
|---|---|
| Alabama | Alabama law has no statute that titles or licenses a med-spa 'medical director,' but a responsible physician is functionally required for cosmetic medical services. The cosmetic botulinum-toxin protocol requires a qualified supervising/collaborating physician (who must be physically on-site), and the laser rules require a delegating/supervising physician who retains full professional and legal responsibility for the patient. |
| Alaska | Alaska law contains no requirement that a medical spa or clinic designate a facility 'medical director.' Non-physician clinical providers instead operate under their own authority or a defined provider relationship: physician assistants must maintain a documented collaborative relationship/plan naming a supervising physician (12 AAC 40.410), whereas APRNs are licensed independent practitioners requiring no physician oversight (12 AAC 44.380). There is no facility-level medical-director statute in the Medical Practice Act (AS 08.64). |
| Arizona | Arizona has no statute requiring a med spa to appoint a titled 'medical director,' but the Board of Nursing advisory opinion effectively requires a supervising/ordering licensed practitioner (MD, DO, or NP) who orders Level II/III procedures, approves the written policies and protocols, and approves the devices used. The advisory opinion expressly contemplates an APRN serving as the medical director for an aesthetic facility, overseeing APRNs, RNs, LPNs, and unlicensed personnel. So a supervising physician or NP is functionally required, even though the specific job title and a formal written agreement are not mandated by statute. |
| Arkansas | Arkansas has no med-spa-specific statute and does not require a med spa to appoint a titled 'medical director' (a proposed 2020 Board rule addressing aesthetic oversight was withdrawn). Because injectables and lasers are the practice of medicine, however, the procedures must be prescribed and ordered by a physician or an APRN with prescriptive authority, who remains responsible and available; the medical acts of an RN require a delegating physician or supervising APRN, and those of a PA require a supervising physician. In effect a supervising/prescribing clinician is required even though no 'medical director' designation is codified. |
| California | California does not use a 'medical director' model and has no statutory med-spa medical-director designation; instead the medical practice itself must be owned and controlled by a physician (BPC 2400). The Medical Board of California's own guidance states that the practice of lay-owned businesses hiring a physician as 'medical director' is prohibited, and that a physician who acts as medical director of a lay-owned business is aiding and abetting the unlicensed practice of medicine. |
| Colorado | Colorado has no dedicated 'medical spa medical director' statute, but any med spa that delivers injections or medical (Class IIIb+) lasers through non-physicians who are not independently licensed for the act (RNs and unlicensed staff) must operate under a delegating/supervising physician who satisfies Rule 800, and the rule expressly contemplates a physician entering an agreement to serve as a medical director. A nurse practitioner with full prescriptive/practice authority may own and operate a med spa and inject without a supervising physician. |
| Connecticut | Connecticut law does not use the term 'medical director,' but CGS § 19a-903c(b) requires every med spa to employ or contract a physician, PA, or APRN who is licensed and actively practicing in the state, has training/experience in cosmetic procedures, and performs the initial in-person assessment. The mandatory oversight role may be filled by a PA or APRN — not only a physician — and the statute sets no on-site-presence requirement. |
| Delaware | Delaware imposes no statutory "medical director" requirement for a med spa. Instead, any non-physician performing delegated medical acts must be adequately supervised by a responsible physician (24 Del. Admin. Code 1700 § 11.0), and physician associates require a collaborating physician (24 Del.C. § 1771); APRNs practicing within their scope require neither because they hold full practice authority. Functionally a physician (or independent APRN) must be medically responsible, but no designated medical-director title or contract is mandated by statute. |
| District of Columbia | Any facility performing Level II or Level III aesthetic procedures (lasers, injectables, deep peels) must employ a medical director, a clinical director, and a site director (which may be the same person). The medical director must be a duly-credentialed MD or DO with training sufficient to supervise the procedures and must be physically present in the medical spa for at least 50% of the facility's weekly operating hours. |
| Florida | Florida imposes no blanket statutory 'medical director' requirement on medical spas as such. A physician/practitioner-owned practice needs no titled director, but a medspa that operates as a licensed health care clinic (non-physician-owned and billing for reimbursement) must appoint a medical director or clinic director who agrees in writing to accept legal responsibility for the clinic (400.9935), and every laser/light-based hair-removal operation must run under a supervising physician per the Board of Medicine's electrologist rule (64B8-56.002). |
| Georgia | Georgia does not use a 'medical director' title, but every non-physician provider must have a physician in a delegating, supervising, or consulting role. An APRN needs a delegating physician and a nurse protocol agreement (the physician must document on-site observation at least annually and quarterly chart reviews); a PA needs a Board-approved primary supervising physician and job description; and a cosmetic-laser facility must have a consulting physician who files name, address, credentials, and treatment protocols with the Board. The physician retains ultimate responsibility for delegated acts, so a physician relationship is effectively mandatory for a med spa offering medical services. |
| Hawaii | No Hawaii statute requires a med spa to have a designated physician medical director. Because APRNs have full, independent practice authority to diagnose, prescribe, and institute therapy (HRS 457-8.6), an APRN-led med spa needs no physician; a physician is required only to supervise or direct medical acts performed by non-independent providers such as physician assistants and registered nurses (HRS 453-2(b)(4), 453-5.3). Secondary sources asserting a mandatory 'medical director' are not supported by any primary Hawaii statute. |
| Idaho | Idaho does not use a statutory 'medical director' title, but any cosmetic treatment delivered by non-physician medical personnel requires a supervising physician who 'accepts full responsibility for cosmetic treatments provided by medical personnel and for the supervision of such treatments.' A physician overseer is therefore effectively required whenever a med spa uses delegated personnel. |
| Illinois | Illinois has no separate 'medical director' statute for medspas; instead the Medical Practice Act and corporate-practice-of-medicine doctrine require that a physician (or an APRN within their scope) actually own and be medically responsible for the practice, personally performing or delegating every medical procedure within a physician-patient relationship. The common out-of-state model of a lay-owned spa hiring a contracted medical director is not permitted, because the responsible physician must be an owner rather than merely a supervisor-for-hire. |
| Indiana | Under SB 282 every registered medical spa must designate a 'responsible practitioner' who has prescriptive authority (a physician, APRN, or PA) and education/training in the services offered; that person must be physically present at the spa a sufficient amount of time and must ensure each worker is licensed, within scope, and trained (IC 25-22.5-12.5-5). This functions as a medical-director requirement, though the term used is 'responsible practitioner,' and it applies with the registration framework (procedure set by Oct 1, 2026; registration required from Jan 1, 2027). |
| Iowa | Every Iowa medical spa must operate under a physician medical director. Only a physician (MD or DO) who holds an active, unrestricted Iowa medical license and possesses appropriate training to supervise may serve; nonphysicians may perform medical aesthetic services only after that medical director delegates them (653—13.8(2)–(3)). The medical director is ultimately responsible for all services performed at the spa and must be clearly identified in all advertising and signage. |
| Kansas | Kansas does not have a statute requiring a med spa to name a 'medical director.' Instead, every medical service must be ordered or lawfully delegated by a licensed practitioner subject to the requirements of K.S.A. 65-28,127 (active practice, written protocols, competence, and scope limits), and the entity itself must be owned by licensed practitioners (K.S.A. 65-2867 / 17-2707). In practice a supervising physician (or independent APRN) who owns or oversees the medical services functions as the de facto medical director, but there is no separately-titled medical-director mandate. |
| Kentucky | Kentucky has no statute or regulation requiring a med spa to designate a titled 'medical director,' and the three boards expressly warn that a nominal medical director who does not personally evaluate patients is legally insufficient. What the law requires instead is active involvement of a licensed prescriber (physician, PA, or APRN) who personally examines each patient, makes an individualized diagnosis, and issues the order — standing orders alone do not satisfy that prescriber's duty to the patient. |
| Louisiana | Louisiana has no med-spa-specific 'medical director' license, but because cosmetic injectables, lasers, peels, and IV therapy are the practice of medicine, any non-physician performing them must act under the direction and immediate personal supervision of a Louisiana-licensed physician who is physically present on the premises. The Board's rules bar the sham arrangement of a physician who serves 'as medical director or otherwise' in title only while an unlicensed person practices medicine, so a genuinely supervising/directing physician is effectively required. |
| Maine | Maine imposes no statutory 'medical director' requirement specific to medical spas. Medical procedures must be performed or delegated by a licensed physician (or independently by an NP/PA within scope) under 32 MRS 3270-A. A designated physician medical director appears in Maine law only as one option for satisfying a nurse practitioner's initial 24-month supervised transition-to-practice (Board of Nursing Ch. 8), not as a facility mandate. |
| Maryland | 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. |
| Massachusetts | Massachusetts does not have a statute requiring a med spa to appoint a formal 'medical director.' Medical services must be performed or ordered by a licensed prescriber, and because nurse practitioners have full practice authority (independent after two years of supervised practice, 244 CMR 4.06/4.07), a med spa may be clinically owned and led by an independent NP rather than a physician. Where physician assistants or registered nurses deliver care, a supervising/ordering physician or independent NP must be clinically responsible, since 243 CMR 2.07(4) permits delegation only to licensed individuals. |
| Michigan | Michigan law does not use the term 'medical director' or impose a formal med-spa medical-director statute, but a physician's active involvement is functionally required: med-spa services are the practice of medicine, so a licensed physician must own the practice entity (corporate practice of medicine) and must authorize and supervise the delegated medical acts under MCL 333.16215. A physician who merely lends a name without genuine oversight risks liability for negligent delegation/supervision under MCL 333.16221. |
| Minnesota | No Minnesota statute requires a med spa to designate a "medical director," because med spas are not a licensed facility category. What the law requires is that the medical services be furnished, ordered, or supervised by a licensed provider: RN-delegated models need a supervising/ordering physician (or full-practice APRN/PA), while a full-practice APRN can own and operate the practice without a physician. So a titled physician medical director is not universally mandated — the requirement is a properly credentialed ordering/supervising provider. |
| Mississippi | Mississippi has no statute requiring a titled 'medical director' or a facility license for a med spa, but physician oversight is functionally mandatory for the medical services offered: any laser or IPL use requires a physician physically on the premises, NPs must have a collaborating physician with a filed collaborative agreement, and PAs must have a Board-approved supervising physician. There is no separate medical-director designation or registration for med spas. |
| Missouri | Missouri does not require a designated 'medical director' for a medical spa as a facility. Instead, non-physician clinicians operate under a written collaborative practice arrangement with a collaborating physician who remains accountable for the delegated medical acts. |
| Montana | Montana imposes no statutory 'medical director' requirement for medical spas, and med spas as facilities are not licensed by any professional board. However, any medical or injectable service must be provided or appropriately supervised by a qualified health care provider who also prescribes the injectable, so a physician (or other authorized prescriber such as an APRN or PA) must stand behind the medical services even though no formal medical-director designation is mandated by statute or rule. |
| Nebraska | Nebraska has no med-spa-specific statute and imposes no formal 'medical director' requirement on cosmetic practices. Because injectables and lasers are the practice of medicine, the practical requirement is a licensed physician who performs or delegates and supervises those services — required for physician assistants under § 38-2047 and for a nurse practitioner's first 2,000 hours under a transition-to-practice/collaborative agreement — while an APRN who has completed that transition and works within her specialty may deliver and be responsible for the medical services independently. |
| Nevada | Nevada has no med-spa-specific statute requiring a designated 'medical director.' However, injectable and other medical procedures must be ordered and overseen by a physician (or an independent-practice APRN), an advanced esthetician who performs energy-device (nonablative) procedures must have a supervising/collaborating physician or physician assistant (NRS 644A.545), and the Board of Nursing requires aesthetic laser equipment to be FDA-labeled and 'approved by medical director' — so physician oversight is effectively required even though no statute names a medical-director role. |
| New Hampshire | New Hampshire has no statute requiring a medical spa to appoint a medical director. APRNs practice independently with no physician collaboration requirement (RSA 326-B:11), while a physician assistant with fewer than 8,000 post-graduate hours (or practicing where no NH physician is in the group) must maintain a written collaboration agreement with a NH-licensed physician who is accessible for consultation (RSA 328-D:3-b). Thus physician involvement is tied to the specific provider's licensure, not to a mandated med-spa medical director role. |
| New Jersey | New Jersey has no 'medical director' designation for med spas, but its strong corporate-practice-of-medicine rule requires a medical practice to be owned and controlled by a physician, and any delegated procedure must be ordered and supervised by that physician. In practice a physician must be the owner and the medically responsible party, which is a stronger requirement than a nominal medical-director arrangement. |
| New Mexico | New Mexico has no statute or rule requiring a med spa to appoint a physician medical director. Required oversight is role-dependent: the Board of Nursing's aesthetic-facility rule requires the facility to have a clinical supervisor who is an APRN (an RN or LPN may not serve) or another licensed independent healthcare practitioner (16.12.14.8-.9 NMAC), and the Medical Board rule requires a supervising physician only where cosmetic device or injection procedures would otherwise be delegated to a medical assistant (16.10.13 NMAC). Because full-practice-authority APRNs may both perform and supervise aesthetic procedures, a physician medical director is not categorically mandated. |
| New York | New York imposes no med-spa-specific 'medical director' designation. Because medical services must be delivered through a physician-owned professional entity (corporate-practice-of-medicine rule), the owning/supervising physician(s) are legally responsible for the medical practice; separately, physician assistants require a supervising physician and registered nurses act under the general supervision of a physician, NP, or PA. There is no statute requiring a med spa to name a medical director as such. |
| North Carolina | North Carolina has no med-spa-specific statute that names or mandates a "medical director." The requirement is functional and derives from other rules: cosmetic injectables and lasers are the practice of medicine, a business practicing medicine must be owned by NC-licensed practitioners (physician-owned corporate structure), and any supervising physician retains ultimate responsibility for the quality of care. In practice a licensed NC physician must own and/or provide medical oversight of a med spa; orders may also come from an NP or PA acting within scope, who themselves practice under physician supervision. |
| North Dakota | North Dakota does not license med spas or clinics and imposes no titled 'medical director' requirement, but it does require a supervising or collaborating prescriber for the medical work: nurse-delivered injectables and IV therapy must run under a physician/PA/APRN prescriber, and advanced estheticians performing microneedling, deeper chemical peels, or nonablative laser must have a written collaborative agreement with a supervising MD, PA, or APRN filed with the Board of Cosmetology (onsite at least four hours per week and reachable within 30 minutes). The oversight provider need not be a physician (PA/APRN qualify), so this functions as a mandatory medical-oversight relationship rather than a physician-only medical directorship. |
| Ohio | Ohio imposes no titled 'medical director' requirement on med spas, but because applying light-based devices and administering/prescribing drugs are the practice of medicine, a licensed physician is functionally required to authorize, order, and delegate the medical procedures — only a physician may delegate a medical task or the use of a light-based medical device. In practice a supervising/delegating physician (commonly called the medical director) must stand behind every medical service the spa offers. |
| Oklahoma | A supervising physician is required. A med spa is a medical practice that must operate under an MD or DO holding an active, full, unrestricted Oklahoma license, and the osteopathic guidance requires the DO to actively supervise the med spa. Physicians who serve as medical directors for one or multiple med spas are expressly subject to these guidelines; there is no separate med-director license, but the supervising physician role is mandatory. |
| Oregon | Oregon has no statute mandating a formally designated 'medical director' for a med spa. However, the Oregon Medical Board's Statement of Philosophy on Responsibilities of Medical Directors of Medical Spas holds any physician who serves in that role fully responsible: the director must treat medical-spa patients as their own patients (performing an evaluation, establishing diagnosis/treatment, obtaining informed consent, and maintaining documentation), may not delegate diagnosis or treatment-plan development to a staff member who is not licensed to exercise independent medical judgment, and is the only person who may order, own, possess, or access scheduled medications within the spa. A professional corporation organized to practice medicine must separately be physician-controlled under ORS 58.375. |
| Pennsylvania | Pennsylvania imposes no 'medical director' title requirement specific to med spas. Because cosmetic injectables and energy-device procedures are medical services, a Pennsylvania-licensed physician must own the practice and remains fully responsible for services delegated to non-physician staff, functioning as the de facto medical director (Medical Practice Act § 17; 49 Pa. Code § 18.402). A CRNP-led practice instead operates under a written collaborative agreement with a collaborating physician rather than a titled director. |
| Rhode Island | Every medical spa must appoint a medical director, who must be a physician or a certified nurse practitioner trained in the indications for and performance of the cosmetic procedures offered. The medical director is responsible for policies and procedures, delegation and supervision of procedures, and oversight and proper training of all providers; manufacturer/vendor device training alone does not satisfy the required competence. |
| South Carolina | South Carolina has no med-spa-specific 'medical director' statute, but because med-spa services are the practice of medicine a physician must be legally responsible for them: a PA must have a supervising physician, and an NP/CNM/CNS must have a written practice agreement with a collaborating physician who is readily available for consultation. A retail medical business must employ a physician, PA, or APRN who exercises exclusive authority over diagnosis and prescribing, so a physician effectively directs or collaborates on the medical care even when the facility is nurse- or lay-owned. |
| South Dakota | South Dakota law does not define or mandate a med-spa 'medical director' title. However, because injectables and lasers are the practice of medicine, the medical services must be ordered, delegated, and supervised by a licensed authorized medical provider (physician, NP, or PA) through a written, dated, signed protocol that specifies training and is reviewed periodically, and that provider bears ultimate responsibility for the delegated acts. A supervising/collaborating medical provider is therefore effectively required even though no statute uses the term 'medical director.' |
| Tennessee | Any medical spa must register a medical director or supervising physician who is a medical doctor or osteopathic physician holding an active Tennessee license and an active Tennessee medical practice, and who attests in writing that he or she assumes and accepts responsibility for all cosmetic medical services provided at the spa. |
| Texas | Texas does not use a statutory 'medical director' title for med spas, but a delegating/supervising physician is mandatory in substance: that physician is legally responsible for the delegated medical acts, must review or develop the written orders/protocols, and — under the corporate-practice-of-medicine doctrine — must own the medical entity. So physician oversight is required even though 'medical director' is not a defined statutory role. |
| Utah | Utah does not require a med spa to designate a formal 'medical director.' However, all medical services (prescribing and injecting) must be provided or ordered by a licensed prescriber: a physician or an independently-practicing APRN may serve as the responsible provider, while a physician assistant must maintain a supervising/collaborating physician. No Utah statute imposes a med-spa-specific medical-director title or ratio. |
| Vermont | Vermont imposes no statutory 'medical director' requirement for medical spas or cosmetic practices; the only 'medical director' defined in the Medical Practice Act (26 V.S.A. § 1311(4)) applies solely to health maintenance organizations. The practical physician-involvement requirement depends on staffing: a physician assistant must have a written practice agreement with a participating physician who is accessible for consultation at all times (§ 1735a), whereas a fully transitioned APRN may practice independently with no supervising or collaborating physician (§ 1613). A physician who lends supervision must remain genuinely in charge of care — § 1354(21) bars permitting one's license to be used when 'not actually in charge of, responsible for, or actively overseeing' the services. |
| Virginia | Virginia has no statute or regulation requiring a med spa to designate a 'medical director'; there is no med-spa-specific facility law at all. Instead, any medical procedure delegated to non-physician staff must be performed under the direction and supervision of a licensed practitioner (physician, or NP/PA within their authority) who retains responsibility for the delegated act under Va. Code § 54.1-2901 and the PA/NP supervision statutes, which functionally requires a supervising/delegating physician-level provider even though the term 'medical director' is not used in law. |
| Washington | Washington has no statute that requires a titled 'medical director' for a med spa. However, whenever a med spa offers delegated medical cosmetic procedures (injectables or laser) performed by RNs/LPNs or PAs, a delegating/supervising MD or DO must authorize treatment and remains ultimately responsible for patient safety under WAC 246-919-606 and 246-919-605, and DOH guidance describes a medical director's role in ensuring each person practices within scope. The exception is an ARNP-run practice: because ARNPs are independent prescribers, a physician medical director is not legally required where the NP performs and prescribes the treatments. |
| West Virginia | No West Virginia statute names a med-spa 'medical director,' but a supervising/collaborating physician is functionally required. Cosmetic medical procedures are the practice of medicine (§30-3-4); only a physician-owned corporation may be authorized to practice medicine (§30-3-15); an APRN's prescriptive authority generally requires a written collaborative agreement with a physician (§30-7-15b) unless the APRN qualifies for the three-year practice exemption; and an RN may perform treatments only on a physician's or APRN's order (§30-7-1). A med spa offering medical aesthetics therefore must have a physician owning/overseeing the medical practice. |
| Wisconsin | Wisconsin imposes no med-spa-specific 'medical director' license or registration requirement. Functionally, however, a physician must own/control any entity practicing medicine (corporate-practice doctrine) and, for cosmetology-setting medical procedures such as laser and chemical peels, a physician must direct, supervise, and inspect the services under written protocols (Cos 2.025(1)), so a supervising/delegating physician is effectively required even though no titled 'medical director' is mandated by statute. |
| Wyoming | No Wyoming statute or rule requires a medical spa to have a designated 'medical director.' The operative constraint is that the practice of medicine must be performed by a licensed physician (or independent APRN/PA), and a physician who delegates medical tasks to nonphysicians must be qualified to delegate and must appropriately supervise those tasks or face discipline (W.S. 33-26-402(a)(xv)-(xvii)); the Board is directed to develop delegation standards (W.S. 33-26-202(b)(vi)). |
Methodology & sources
Every entry is compiled from that state's own statutes, medical- and nursing-board rules, and official guidance, and each state page links the primary source behind its wording. Last reviewed 2026-07-21. Download the full dataset as CSV.
Citing this page? Use: MedSpa Standards, "Medical director by State for Med Spas," retrieved 2026-07-21, https://medspastandards.com/med-spa-regulations-by-state/medical-director-requirements
Build a compliant med spa faster
Board-ready SOPs and compliance checklists mapped to these requirements.
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.