Semaglutide Best Practices in Texas Med Spas

Semaglutide (found in FDA-approved drugs like Wegovy and Ozempic) has become very popular in medical weight loss programs, including at med spas. Demand has also grown for compounded versions, especially when brand-name drugs are scarce or expensive. With popularity comes increased risk—especially legal, regulatory, and safety. In Texas, med spas must navigate both state medical board rules and federal drug regulations. Semaglutide best practices for med spas help ensure patient safety, maintain compliance, and protect reputations.

Clinical Best Practices:

Patient Evaluation and Selection

• Conduct a thorough medical history, including comorbidities such as diabetes, cardiovascular disease, kidney disease, pancreatitis, gallbladder disease, etc.

• Check contraindications (e.g. personal/family history of medullary thyroid carcinoma or Multiple Endocrine Neoplasia syndrome type 2 for semaglutide).

• Evaluate BMI, weight history, prior weight loss efforts, diet, lifestyle, medications.

• Perform baseline labs: e.g., HbA1c (if diabetic or pre-diabetic), kidney & liver function, thyroid, lipid panel, possibly B12 levels; ensure no risk for malabsorption.

Dosing Protocols and Titration

• Start at a low dose to mitigate side effects (nausea, gastrointestinal upset) and increase gradually per approved or clinically supported protocol.

• Monitor weight loss, side effects, and patient tolerance at each dose level.

• Provide lifestyle/diet/exercise support: semaglutide is an adjunct to behavior change, not a substitute.

Monitoring and Follow-up

• Regular follow-ups (weekly or biweekly initially, then monthly) to assess response, side effects, adherence.

• Monitor for adverse effects: gastrointestinal issues, risk for pancreatitis, hypoglycemia (especially if combined with other glucose-lowering agents), gallbladder issues.

• Adjust dose or pause treatment if severe side effects occur.

Duration of Therapy and Maintenance

• Discuss expectations: weight loss pace varies; weight regain risk if therapy stops and lifestyle changes don’t persist.

• Plan for maintenance dosing or whether treatment will continue indefinitely, taper, or stop.

Product Quality and Source

• Use FDA-approved semaglutide products when available.

• If using compounded semaglutide: ensure the compounding pharmacy is licensed and meets sterility, potency, and purity standards. In addition, in February 2025 the FDA issued a notice that there was no longer a shortage of semaglutide. As of April 25, 2025 compounding is only allowed on a patient-by-patient basis with a showing of specific medical necessity set out in the prescription itself.

• Be aware that compounded versions are not FDA-approved and may carry higher risk.

• Avoid or clearly disclose use of semaglutide sodium vs. semaglutide base forms; there are differences in bioavailability and regulatory concern.

Legal, Regulatory, and Ethical Best Practices in Texas:

Oversight and Supervision

• Ensure that prescribers are licensed physicians, nurse practitioners, or physician assistants, as permitted under Texas law, and that they act within their scope.

• If non-physician staff are involved, have explicit delegation protocols and ensure supervising physician oversight.

Informed Consent

• Disclose whether a drug is FDA-approved or compounded and explain the differences, risks, and benefits.

• Explain the expected side effects, what is known/unproven, and potential long-term implications.

• Document consent with signed forms in the medical record. Ethical clarity helps reduce litigation risk.

Compliance with Advertising and Marketing Laws

• Avoid using brand names like Ozempic, Wegovy, etc., in marketing if you are not sourcing the FDA-approved product from the original manufacturer. Misuse of brand names can lead to legal action.

• Do not claim that compounded drugs are FDA-approved.

• Avoid guarantees, overly strong results promises, “miracle” language. Use realistic language and disclose limitations.

• Ensure that all advertising clearly states who is supervising, that medical supervision exists, and that outcomes vary.

• Comply with Texas Deceptive Trade Practices Act (DTPA) and rules from the Federal Trade Commission (FTC).

Ownership Structure & Medical Board Rules

• Texas prohibits the corporate practice of medicine: med spas must have a physician medical director or be physician owned. Non-physician owners must have physician oversight.

• Ensure staff classification (employee vs contractor) is accurate—this matters for liability and regulatory compliance.

Telemedicine and Remote Services

• If consultations, follow-ups, or prescriptions are done via telemedicine, comply with Texas Medical Board rules for telemedicine. Ensure provider has valid Texas license and that remote visits meet GFE (“good faith examination”) requirements.

Recordkeeping and Audits

• Maintain complete medical records: patient evaluation, labs, dosing records, follow-ups, side effects, consent forms.

• Retain records per Texas regulations.

• Perform periodic internal audits of safety, marketing, adverse event reporting, and product sourcing.

Risk Management

• Have emergency protocols in place (e.g. for severe allergic reactions).

• Ensure malpractice/liability insurance covers the specific practices, including compounded products when used.

• Have systems for reporting adverse events, following manufacturers’ and FDA requirements.

Operational & Business Best Practices:

Staff Training

• Ensure all medical staff administering semaglutide (or supervising injections) are properly trained in its pharmacology, dosing, side effects, and how to respond to emergencies.

• Training on ethical communication, marketing compliance, and consent.

Patient Education & Engagement

• Set realistic expectations: weight loss is a journey, with fluctuations; semaglutide can help but lifestyle changes are critical.

• Provide dietary, exercise, behavior-modification support. Some combination of coaching or nutritionist support increases outcomes.

• Ensure follow-up and support to help with adherence and side effects.

Pricing Transparency

• Be very clear about cost: medication (if compounded vs branded), provider fees, injection/administration fees, follow-ups, labs etc.

• Disclose cancellation policies, packaging (e.g. weekly vs monthly doses), what’s included/excluded.

Quality Assurance of Compounding Agents

• If using compounded semaglutide, work only with pharmacies that are properly licensed and that have validated sterility, potency, and stability testing.

• Maintain documentation of lot numbers, certificate of analysis, storage/shipping conditions.

• Store semaglutide per manufacturer or compounding pharmacy recommendations.

Conclusion on Semaglutide Best Practices in Texas Med Spas

Semaglutide offers powerful benefits in weight loss and metabolic health, but in the med spa setting, particularly in Texas, there are many regulatory, clinical, and ethical pitfalls. Med spas that implement strong protocols, ensure legal compliance, and focus on patient safety and realistic outcomes are best positioned to succeed and avoid risk.

Feel free to reach out if you need more specific information or further clarification.

Weitz Morgan is a leading law firm in Texas in providing comprehensive advice and guidance to med spas. With a deep understanding of the unique challenges and complexities faced by this rapidly growing industry, our team of experienced attorneys is dedicated to helping med spas navigate the legal landscape successfully.

We recognize that med spas operate at the intersection of healthcare and beauty, which necessitates a multifaceted approach to representation. Our firm offers a range of services, including a flat-fee med spa formation package and an outside general counsel subscription, tailored to meet the specific needs of med spas, ensuring compliance, mitigating risks, protecting licenses, and fostering a legally sound business environment.