- Is a Medical Director required for every Med Spa?
Yes. Nearly every state requires a licensed Medical Director to oversee any Med Spa offering medical or aesthetic treatments such as Botox, fillers, or IV therapy.
- Can a nurse own or operate a Med Spa?
In CPOM (Corporate Practice of Medicine) states, non-physicians like nurses cannot own a Med Spa directly. They must form an MSO (Management Services Organization) that contracts with a physician-owned entity.
- What’s the difference between a GFE and a PSO?
A Good Faith Exam (GFE) is an initial assessment determining patient suitability for treatment. A Patient-Specific Order (PSO) is the medical order that authorizes the treatment—required by law in many states.
- How often should delegation agreements be updated in a Med Spa?
Best practice is to update all delegation agreements annually or whenever there are new staff members, new treatments, or changes in location.
- Can telehealth providers act as Medical Directors for Med Spas?
No. Telehealth providers can conduct Good Faith Exams or write Patient-Specific Orders, but every Med Spa still requires its own Medical Director licensed in the state of operation.
The Medical Director is responsible for clinical oversight, delegation agreements, and compliance with state medical and CPOM laws. Telehealth is a tool for care delivery, not a substitute for medical direction.