Michigan Med Spa Regulations
Michigan has no med-spa-specific statute; med-spa services are regulated as the practice of medicine under the Public Health Code (Act 368 of 1978), where injectables, lasers, and IV therapy are physician-controlled acts that may be delegated to qualified licensed or unlicensed individuals under physician (or NP/PA) supervision, and the practice entity must be physician-owned under the corporate-practice-of-medicine doctrine.
Last reviewed: 2026-07-21
Who can inject Botox and dermal fillers in Michigan?
Michigan has no med-spa-specific injection law; injecting Botox or dermal filler is the practice of medicine governed by the Public Health Code. A physician (MD under part 170 or DO under part 175) may inject directly or, under MCL 333.16215, delegate the act to a licensed or unlicensed individual (e.g., NP, PA, RN, or trained aesthetic staff) who is qualified by education, training, or experience and works under the physician's supervision. Nurse practitioners (APRNs) may prescribe the non-controlled prescription drug themselves under MCL 333.17211a and PAs may prescribe under a practice agreement per MCL 333.17548, while an RN administers only as a delegated act.
Source: MCL 333.16215 — Delegation of acts, tasks, or functions, MCL 333.17211a — APRN prescribing authority, MCL 333.17548 — Physician's assistant prescribing / practice agreement
Does Michigan require a good-faith exam before treatment?
Michigan has no explicit statutory 'good faith exam' mandate for med spas. Because injectables and other cosmetic-medical treatments require a prescription drug, a prescriber must be acting within his or her scope of practice, and delegated care must be authorized and supervised by a physician (or NP/PA within scope) — failure to properly evaluate a patient is negligent delegation/care actionable under MCL 333.16221. Michigan expressly permits the evaluation and prescribing to occur via telehealth under MCL 333.16285, provided the prescriber acts within scope and arranges appropriate follow-up.
Source: MCL 333.16285 — Telehealth service; prescribing conditions, MCL 333.16215 — Delegation requires physician authorization/supervision, MCL 333.16221 — Grounds for discipline (negligent delegation/care)
Does a med spa in Michigan need a medical director?
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.
Source: MCL 333.16215 — Delegation/supervision by physician required, MCL 450.1284 — Professional corporation ownership limited to licensees, LARA — Use of Laser Equipment by Health Professionals (laser use is the practice of medicine)
Can a non-physician own a med spa in Michigan?
Michigan follows the corporate-practice-of-medicine doctrine. Under MCL 450.1284, a professional corporation providing a service subject to Article 15 of the Public Health Code must have every shareholder licensed to provide that same service — so a medical practice (and thus a med spa offering medical services) must be owned by physicians (MD/DO), with only limited co-ownership by other listed licensees such as physician's assistants (and only alongside a physician). Lay investors and unlicensed managers cannot hold equity; LARA's position statement confirms medical/laser services must be organized as a PC or PLLC.
Source: MCL 450.1284 — Professional corporation shareholders must be licensed, LARA — Use of Laser Equipment by Health Professionals (must organize as PC/PLLC)
What supervision does Michigan require for med-spa procedures?
Delegated med-spa acts are performed under physician 'supervision' as defined in MCL 333.16109, which requires continuous availability of direct communication (in person, phone, or telecommunication), regular review of the delegatee's practice, and predetermined procedures/drug protocols — but does NOT require the physician's on-site physical presence for ordinary (non-surgical) delegated acts. On-site physical presence of a physician is required only where a physician delegates a procedure using surgical instrumentation to an unlicensed individual (MCL 333.16215(2)-(4)). NPs prescribing scheduled controlled substances do so only as a delegated act of a physician (MCL 333.17211a), and PAs act under a written practice agreement (MCL 333.17548).
Source: MCL 333.16215 — Delegation & physical-presence rule for surgical instrumentation, MCL 333.16109 — Definition of 'supervision', MCL 333.17548 — PA practice agreement
What can an esthetician legally do in Michigan?
Estheticians are licensed under the Occupational Code (Article 12) and, per MCL 333.1203a, may perform only 'skin care services' and no other cosmetology service unless separately licensed. Skin care is limited to non-medical, non-invasive care of the skin; estheticians may not perform injections, prescribe, penetrate the dermis, or operate medical lasers, all of which are the practice of medicine outside the esthetician scope.
Source: MCL 339.1203a — Cosmetology/esthetician scope of license, LARA — Use of Laser Equipment by Health Professionals (laser = practice of medicine)
Who can operate a cosmetic laser in Michigan?
Per LARA's (Dept. of Community Health) position statement, the use of lasers by health professionals constitutes the practice of medicine. Accordingly a physician (MD/DO) must own the entity and either perform or delegate laser procedures under MCL 333.16215; delegatees such as NPs, PAs, and RNs may operate lasers only under physician supervision and if qualified. Estheticians and cosmetologists may not perform cosmetic laser or IPL procedures regardless of vendor training, because that falls outside their occupational license.
Source: LARA — Use of Laser Equipment by Health Professionals, MCL 333.16215 — Delegation of medical acts under physician supervision
What are the rules for IV therapy and vitamin drips in Michigan?
Michigan has no IV-therapy-specific statute. Administering IV fluids/vitamins and the drugs they contain requires a prescription/order from a physician (or an NP/PA prescribing within scope), and the administration is a medical/nursing act that may be delegated under MCL 333.16215 to an RN or other individual qualified by education, training, or experience and working under physician supervision. It cannot be performed independently by unlicensed spa staff without a valid order and supervision.
Source: MCL 333.16215 — Delegation of medical acts to qualified individuals, MCL 333.17211a — APRN prescribing authority
Does a med spa have to register or hold a license in Michigan?
Michigan has no med-spa-specific registration, permit, or licensing regime. A med spa that provides medical services is regulated as a medical practice: it must be organized as a professional corporation (PC) or professional limited liability company (PLLC) whose owners are licensed to provide the service (MCL 450.1284), as confirmed by LARA's position statement that laser/medical services may only be delivered through a PC or PLLC. Individual practitioners still hold their own professional licenses, but the facility itself is not separately registered as a 'med spa.'
Source: MCL 450.1284 — Professional corporation for Article 15 services, LARA — Use of Laser Equipment by Health Professionals (PC/PLLC requirement)
What are the penalties for practicing outside scope in Michigan?
Practicing a health profession — or holding oneself out as practicing — without a license, or outside the delegation permitted by MCL 333.16215, is a felony under MCL 333.16294. Other violations of Article 15 are misdemeanors under MCL 333.16299: up to 90 days and/or a $100 fine for a first offense, and up to 6 months and/or a $200-$500 fine for subsequent offenses. Licensees also face disciplinary action (fines, limitation, suspension, or revocation) under MCL 333.16221 for negligence, negligent delegation/supervision, or practicing outside scope.
Source: MCL 333.16294 — Unlicensed practice is a felony, MCL 333.16299 — Misdemeanor penalties for other violations, MCL 333.16221 — Grounds for disciplinary action
Cite this page
Build a compliant med spa faster
Board-ready SOPs and compliance checklists mapped to these requirements.
SOP kits by topic: Injectables · Skin & Laser · Operations & Compliance · Body & Wellness · Weight Loss · Hormone Therapy · Emergency Protocols
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.