Question 1

Who can inject Botox and dermal fillers in Tennessee?

Accepted Answer

Injecting neuromodulators and dermal fillers is the practice of medicine in Tennessee, so it may be performed by a physician (MD/DO) or delegated to an NP or PA who holds prescriptive authority and is working under the required physician collaboration/supervision. An RN may administer or inject only pursuant to a valid order from a prescriber and cannot serve as the prescriber. There is no separate 'who may inject' statute; authority flows from the Medical Practice Act, the medical-spa registration rule, and the APRN/PA scope rules.

Question 2

Does Tennessee require a good-faith exam before treatment?

Accepted Answer

Before any drug is prescribed or dispensed, the treating physician (or a supervised NP/PA under protocols) must perform an appropriate history and physical examination, make a diagnosis, and formulate a therapeutic plan; prescribing 'based solely on answers to a set of questions' is a prima facie violation for both physicians (0880-02-.14(7)) and APRNs (1000-04-.08). The exam may be conducted via telemedicine, because a valid physician-patient relationship can be established without an in-person encounter under the Board's telemedicine rule.

Question 3

Does a med spa in Tennessee need a medical director?

Accepted Answer

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.

Question 4

Can a non-physician own a med spa in Tennessee?

Accepted Answer

Tennessee follows the corporate-practice-of-medicine doctrine: only licensed physicians (or the narrowly enumerated healthcare-professional combinations authorized by T.C.A. Sec. 48-101-610) may form and own shares of a medical professional corporation or PLLC that renders medical services, and no owner may exercise more authority over a physician's diagnosis, treatment, or referral decisions than an 'employing entity' may under T.C.A. Sec. 63-6-204(f). A cosmetic medical practice must therefore be physician-owned and physician-controlled.

Question 5

What supervision does Tennessee require for med-spa procedures?

Accepted Answer

A physician assistant works under a supervising physician with jointly developed written protocols that are reviewed biennially, and the supervising physician must personally review at least 20% of the PA's charts every 30 days. An APRN who prescribes must have a collaborating physician who complies with joint Board Rule 0880-06. Any cosmetic procedure performed with a laser must be under the supervision of a licensed physician.

Question 6

What can an esthetician legally do in Tennessee?

Accepted Answer

A licensed aesthetician's scope is limited to non-medical skin care of the epidermis: facials and masks that do not require prescriptions (absent medical supervision), exfoliation of only the uppermost, non-living layers of skin, and salon alphahydroxy-acid products not exceeding 30% concentration at pH 3.0 or above. Techniques that affect the living dermis, coagulate tissue, or remove moles/warts are prohibited, so injections, prescription-strength peels, and medical laser procedures fall outside esthetician scope and constitute the practice of medicine.

Question 7

Who can operate a cosmetic laser in Tennessee?

Accepted Answer

Any procedure within the statutory definition of the practice of medicine that is performed with a laser is itself the practice of medicine, and any person performing it must be under the supervision of a licensed physician (limited cosmetology and osteopathic exceptions apply). Tennessee does not name a specific license required to operate the device; the operative requirement is physician supervision, so a physician may perform the procedure or delegate it to a trained NP, PA, RN, or other qualified personnel under that supervision.

Question 8

What are the rules for IV therapy and vitamin drips in Tennessee?

Accepted Answer

Tennessee has no med-spa- or IV-specific statute; IV hydration and vitamin-drip therapy are medical acts. The fluids and drugs must be ordered by a physician, NP, or PA after a good-faith history and physical examination, and an RN may administer them only pursuant to that valid order and within the RN scope of practice. There is no independent authority for unlicensed personnel to order or administer IV therapy.

Question 9

Does a med spa have to register or hold a license in Tennessee?

Accepted Answer

Yes. A medical spa (any entity offering cosmetic medical services, or a physician office that advertises as a med spa or where more than 50% of patients in the preceding 12 months received an elective cosmetic medical service) must register with the Tennessee Board of Medical Examiners before operating, submitting the supervising physician's name/license and a non-refundable $175 registration fee. Registration is valid for 12 months and must be renewed annually.

Question 10

What are the penalties for practicing outside scope in Tennessee?

Accepted Answer

Operating a medical spa without current registration constitutes unprofessional conduct and is grounds for disciplinary action against the medical director or any supervising physician providing services there. More broadly, violations of the Medical Practice Act expose licensees to discipline and civil penalties under T.C.A. Sec. 63-6-214, and a non-physician who performs cosmetic medical procedures (injections, medical lasers) without proper authority or supervision commits the unlicensed practice of medicine.

Tennessee Med Spa Regulations