The Role of Medical Directors in Med Spas: Legal Requirements and Best Practices

As the popularity of med spas continues to grow across Texas, so does the need for proper clinical oversight. At the heart of every legally compliant med spa is a qualified medical director—a licensed physician responsible for ensuring safe, lawful, and ethical delivery of medical aesthetic services. Understanding the role of medical directors in med spas, legal requirements, and best practices is essential for both business owners and providers.

What Is a Medical Director in a Med Spa?

A medical director is a Texas-licensed physician who oversees and is ultimately responsible for the delegation and supervision of medical procedures provided within a med spa. This role is not just honorary or administrative—it involves clinical oversight, protocol development, patient safety, and legal accountability.

Legal Requirements for Medical Directors in Texas:

Texas laws and Texas Medical Board (TMB) rules are clear on the role of physicians in non-traditional settings like med spas.

Licensure

• The medical director must be a physician licensed by the Texas Medical Board.

• They do not need to be board-certified in dermatology or plastic surgery but must have relevant training or continuing education in the procedures performed.

Delegation of Medical Tasks

• Only physicians can delegate medical tasks, such as laser treatments, Botox, dermal fillers, or microneedling, to qualified staff (e.g., RNs, PAs, NPs).

• Delegation must follow TMB Rule 193.17, ensuring that the task is within the delegatee’s scope and that proper training and supervision are provided.

Supervision

• The physician must supervise all delegated medical services. This does not necessarily mean they must be on-site, but:

  • They must be available for consultation.

  • They must have protocols and standing orders in place.

  • They must periodically review records, audit charts, and ensure patient safety.

Responsibilities of a Medical Director:

Beyond legal compliance, a good medical director plays a vital role in quality control and risk mitigation. Responsibilities include:

Clinical Oversight

• Develops and approves treatment protocols

• Reviews and signs off on patient records and treatment plans

• Ensures all treatments are medically appropriate

Staff Training and Credentialing

• Verifies credentials of all clinical staff

• Provides or coordinates training for new procedures or devices

• Monitors compliance with continuing education

Patient Safety and Risk Management

• Implements and enforces infection control policies

• Investigates patient complaints or adverse outcomes

• Maintains liability insurance and ensures staff coverage

Compliance and Documentation

• Oversees compliance with HIPAA, OSHA, and TMB rules

• Ensures accurate documentation of all treatments

• Participates in audits or inspections when required

Best Practices for Med Spas and Their Medical Directors:

To build a compliant and reputable practice, consider the following best practices:

Formalize the Relationship

• Use a written agreement that outlines the duties and compensation of the medical director.

• Ensure the agreement complies with Texas laws regarding ownership and delegation.

Be Present and Involved

• Medical directors should not be “absentee” supervisors.

• Establish regular meetings, chart reviews, and training sessions—even if remote.

Stay Within Scope

• Do not allow estheticians or unlicensed staff to perform medical procedures without proper delegations in place.

• Avoid services that require higher-level licensure if the med spa doesn’t have appropriately credentialed staff.

Document Everything

• Keep detailed records of delegation protocols, staff training, patient care, and physician oversight.

• In legal or regulatory investigations, documentation is a a critical component of the defense.

Conduct Internal Audits

• Routinely review operations to identify compliance gaps.

• Address any unauthorized practices or documentation issues proactively.

Conclusion on The Role of Medical Directors in Med Spas

The role of the medical director in a Texas med spa is more than just a legal formality—it is a clinical and ethical cornerstone. By maintaining proper delegation, supervision, and training protocols, a qualified medical director protects patients, staff, and the business itself. In a highly competitive and regulated industry, compliance is not optional; it is the foundation for long-term success.

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.