What Is the Role of a Medical Director at a Med Spa?
Running a med spa in Texas involves more than just offering cosmetic treatments and creating a luxurious experience. Behind every legally compliant and well-managed med spa is a Medical Director.
A Medical Director is a licensed physician responsible for overseeing medical services and ensuring the operations of the med spa follow state laws.
If you’re launching or managing a med spa, understanding the role and legal responsibilities of your Medical Director is essential.
Why Does a Med Spa Need a Medical Director?
In Texas, medical spas are more than just salons. They are medical practices. Many of the services offered (like Botox, fillers, laser hair removal, and IV therapy) are considered medical procedures under Texas law. That means they must be performed under the supervision of a licensed physician.
Because of this, med spas must either be owned by a physician or structured to comply with the Corporate Practice of Medicine Doctrine, which prohibits non-physicians from owning a medical practice.
A Medical Director helps bridge this gap by offering both clinical oversight and legal structure.
Core Responsibilities of a Med Spa Medical Director in Texas
The role of a Medical Director goes far beyond signing paperwork or allowing their license to be used. Their responsibilities include:
Oversight of Medical Services
The Medical Director is responsible for ensuring that all treatments provided at the med spa are medically appropriate, safely administered, and within the scope of each practitioner’s license.
Delegation and Supervision
In Texas, non-physician providers such as nurse practitioners, physician assistants, and registered nurses may perform certain procedures, but only under the delegation and supervision of a licensed physician. The Medical Director must establish written protocols, provide appropriate training, and be available for consultation when services are rendered.
Compliance with Texas Medical Board Regulations
The Medical Director helps ensure the med spa complies with:
Texas Medical Board rules
HIPAA and patient privacy standards
Proper recordkeeping and informed consent procedures
Failure to comply can result in fines, license suspension, or even criminal penalties.
Staff Training and Credentialing
The Medical Director may also be involved in credentialing the clinical staff and ensuring ongoing education or training in new procedures.
Review of Complications or Adverse Events
If a client experiences a negative reaction or result, the Medical Director is responsible for reviewing the case and ensuring proper care is provided, along with documentation and reporting.
What a Medical Director Is Not
The Medical Director is not just a figurehead. Simply “renting” a license without proper involvement puts both the physician and the med spa at risk. This type of arrangement can violate state law and lead to enforcement actions by the Texas Medical Board.
How Should a Med Spa Structure Its Relationship with a Medical Director?
Texas law requires careful structuring of the business entity, contracts, and day-to-day operations. Most compliant med spas in Texas are set up under a Management Services Organization (MSO) model, where the business side is handled by a non-physician entity, and the medical side is operated under the control of a licensed physician.
This separation helps avoid violations of the Corporate Practice of Medicine Doctrine, but only if implemented correctly.
What You Need to Know
The Medical Director at a med spa is the linchpin of legal and clinical compliance. If you’re starting or operating a med spa in Texas, having the right Medical Director in place, and structuring that relationship properly, is critical for protecting your business, your license, and your patients.
At LDG PLLC, we help med spa owners and physicians navigate Texas regulations, draft compliant MSO agreements, and avoid common legal pitfalls. If you have questions about Medical Directors or need help structuring your med spa legally, our team is here to help.