spacompliance.com

State requirements

There is no national med spa law. Five questions decide what your practice may lawfully do — and every state answers them differently.

The framework

Five questions, fifty answers

Rather than publish a table of state rules that would be out of date within a quarter, we work from the questions themselves. These five determine almost everything about how a medical spa must be structured and staffed, and each one is decided at state level.

#The questionWhy the answer changes everything
1Who may own the medical practice?Determines whether your entity structure is lawful at all, and whether you need a physician-owned professional entity with a management agreement alongside it.
2Which license types may perform each treatment?Decides who on your payroll may inject, operate a laser, or start an infusion — and therefore what you can actually sell with the staff you have.
3What level of supervision is required?Sets whether the physician must be on site, immediately reachable, or generally available, and how many practitioners one physician may supervise.
4Is a good faith examination required before treatment?Establishes who must evaluate the patient, what the evaluation must cover, whether telehealth is acceptable, and when it must be repeated.
5What must the medical director document?Defines the protocols, delegation records, chart review and quality assurance evidence you must be able to produce on request.

We confirm each answer for your state, in writing, against the current statute, regulation and board position before you rely on it.

Corporate practice of medicine

Who is allowed to own the practice

A number of states prohibit a business owned by non-physicians from employing physicians to practice medicine or from owning a medical practice outright. The doctrine exists to keep clinical judgment free of commercial pressure, and it is the single structural issue most likely to affect whether your business is lawfully organized.

Where it applies, medical spas typically operate through a professional entity owned by a licensed physician, paired with a management services organization that provides everything non-clinical — premises, equipment, marketing, administration, non-clinical staff. Properly documented, this is a well-established structure. Badly documented, it invites the argument that the management company is practicing medicine and splitting fees.

The details that draw scrutiny are consistent: who controls clinical decisions, how the management fee is calculated, who owns the patient records, and whether the physician owner is genuinely in control or a figurehead.

Delegation

Who may perform the treatment

The second question is the one that shows up in daily operations, and the one owners most often get wrong by assuming the rule they learned somewhere else still applies.

Injection authority

States take materially different positions on whether a registered nurse may inject neuromodulators and fillers under delegation, or whether injection is limited to advanced practice providers and physicians. Estheticians are excluded essentially everywhere, and medical assistants face narrow limits that many practices exceed without realising it.

Laser and energy devices

Some states classify laser hair removal and other energy-based treatments as the practice of medicine with specific supervision requirements; some regulate them lightly; some have no device-specific rule at all, which is not the same as permission. Supervision may need to be on-site, immediately available, or generally available.

The good faith examination

Where an exam is required, the questions are who may perform it, what it must contain, whether telehealth is acceptable, and when it must be repeated. Practices commonly satisfy the first question and fail the last one, treating a patient for a new indication years after the original evaluation.

Supervision in practice

"Supervision" is a legal term with different meanings by state and by treatment. The practical questions are how quickly the supervising physician must be reachable, whether physical presence is required, how many practitioners one physician may supervise, and what must be documented to prove it happened.

Every state

Where your state sits on ownership

All 51 jurisdictions. 17 of them we have already checked against the state’s own statute, administrative code or medical board, and those rows carry the citation so you can read it yourself. For the rest we say so plainly rather than guess — we verify your state before you rely on anything, at the start of an engagement.

#StateOwnershipWhat that meansAuthority
1AlabamaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.
Also covered: supervision cap
Ask about Alabama
2AlaskaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Alaska
3ArizonaPermissiveLay ownership expressly allowed
Also covered: med spa rule · exam rule · supervision cap
A.R.S. §§ 10-2220(A)(4), 10-2213(C), 29-4105(B)
4ArkansasWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Arkansas
5CaliforniaStrictNo lay ownership of any percentage
Also covered: exam rule · supervision cap
Cal. Bus. & Prof. Code § 2400; Cal. Corp. Code §§ 13401.5, 13406(a); MBC med spa guidance
6ColoradoStrictPhysician owners only
Also covered: med spa rule
C.R.S. § 12-240-138(1)(d)(I), (6)(a), (1)(f)
7ConnecticutWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Connecticut
8DelawareWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Delaware
9District of ColumbiaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about District of Columbia
10FloridaEntity-dependentLay ownership allowed, but licensure may bite
Also covered: med spa rule · exam rule
Fla. Stat. §§ 400.991(1)(a), 400.9905(4)(f)-(g), 400.9935; Fla. Admin. Code 59A-33.006(14)
11GeorgiaEntity-dependentDepends entirely on the entity
Also covered: med spa rule · exam rule
O.C.G.A. §§ 14-7-5(a), 14-11-1107(f), 43-34-242; Ga. Comp. R. & Regs. 360-35-.07
12HawaiiWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Hawaii
13IdahoWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Idaho
14IllinoisStrictLicensed physicians only
Also covered: supervision cap
805 ILCS 15/13(a), (b); 805 ILCS 185/13(a)(2); 225 ILCS 60/22.2(c), (d)
15IndianaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Indiana
16IowaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Iowa
17KansasWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Kansas
18KentuckyWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Kentucky
19LouisianaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Louisiana
20MaineWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Maine
21MarylandWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Maryland
22MassachusettsEntity-dependentNo ownership bar, but licensure may biteM.G.L. c. 111, §§ 51–52; 243 CMR 2.07(4); M.G.L. c. 156A, § 10
23MichiganWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Michigan
24MinnesotaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Minnesota
25MississippiWe confirmWe verify this state against its own statute and board rules at the start of an engagement.
Also covered: supervision cap
Ask about Mississippi
26MissouriWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Missouri
27MontanaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Montana
28NebraskaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Nebraska
29NevadaEntity-dependentDepends on the entity you chose
Also covered: exam rule · supervision cap
NRS 89.070(1)(a); NRS 89.040(1)(c)
30New HampshireWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about New Hampshire
31New JerseyStrictLicensed health professionals only
Also covered: exam rule · supervision cap
N.J.A.C. 13:35-6.16(e), (f); Allstate v. Northfield Med. Ctr., 228 N.J. 596 (2017)
32New MexicoWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about New Mexico
33New YorkStrictLicensed physicians only, no exceptions
Also covered: exam rule
N.Y. Bus. Corp. Law §§ 1503, 1507(a), 1508(a); N.Y. Ltd. Liab. Co. Law §§ 1203, 1207
34North CarolinaStrictLicensee owners only
Also covered: med spa rule
N.C. Gen. Stat. §§ 55B-4(2), 55B-6(a); NCMB Position Statement 10.1.2
35North DakotaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about North Dakota
36OhioPermissiveDoctrine abolished by statute
Also covered: med spa rule
ORC § 4731.226(A)(1); ORC § 1701.03(D); Ohio Medical Board statement (2012)
37OklahomaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Oklahoma
38OregonWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Oregon
39PennsylvaniaStrictLicensed natural persons only15 Pa.C.S. §§ 102, 2923, 8996; Neill v. Gimbel Bros., 330 Pa. 213 (1938)
40Rhode IslandWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Rhode Island
41South CarolinaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.
Also covered: supervision cap
Ask about South Carolina
42South DakotaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about South Dakota
43TennesseeStrictPhysician owners only
Also covered: med spa rule
Tenn. Comp. R. & Regs. 0880-02-.20(1)(b), (1)(c); Tenn. Op. Att'y Gen. 07-116
44TexasStrictPhysician-controlled entities only
Also covered: exam rule
Tex. Occ. Code §§ 155.001, 164.052(a)(17); Tex. Bus. Orgs. Code §§ 301.003(3), 301.007, 301.012
45UtahWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Utah
46VermontWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Vermont
47VirginiaPermissiveOrdinary corporation or LLC permitted
Also covered: med spa rule · exam rule · supervision cap
Va. Code §§ 13.1-542.1, 13.1-1101.1 (2003, c. 678)
48WashingtonEntity-dependentProfessional entities are restricted
Also covered: exam rule
RCW 18.100.050, .090, .110; RCW 25.15.046; WMC Policy MD2015-06
49West VirginiaWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about West Virginia
50WisconsinWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Wisconsin
51WyomingWe confirmWe verify this state against its own statute and board rules at the start of an engagement.Ask about Wyoming

Published rows verified against primary sources on 29 September 2026 and re-verified annually. A published summary is never a substitute for confirmation against your own service menu and license types.

Verified snapshots

Five states in detail

The same question, answered at length for five states chosen to show how far apart they sit — from no lay ownership of any percentage to lay ownership expressly allowed by statute.

#StatePositionWhat the rule actually saysAuthority
1New YorkLicensed physicians only, no exceptionsProbably the strictest of any state researched, because there is no minority allowance at all. A professional service corporation may issue shares only to individuals authorized to practice the profession, and every director and officer must be licensed too. Shares, proxies and agreements issued in violation are void. State guidance states plainly that business corporations cannot hire a licensee to provide professional services.N.Y. Bus. Corp. Law §§ 1503, 1507(a), 1508(a); N.Y. Ltd. Liab. Co. Law §§ 1203, 1207
2CaliforniaNo lay ownership of any percentageThe statute is blunt: corporations and other artificial legal entities have no professional rights, privileges or powers. Shares may be issued only to licensed persons, and shares issued in violation are void. A defined list of other licensed health professionals may hold up to 49 percent in aggregate. The medical board has published guidance aimed specifically at medical spas stating that a physician acting as medical director of a lay-owned business is aiding and abetting the unlicensed practice of medicine.Cal. Bus. & Prof. Code § 2400; Cal. Corp. Code §§ 13401.5, 13406(a); MBC med spa guidance
3TexasPhysician-controlled entities onlyTexas reaches the same result by a different route: there is no single statute saying a corporation may not practice medicine. Instead it is a prohibited practice for a physician to aid or abet the practice of medicine by an unlicensed person or corporation, and the entity statutes permit only authorized persons to own a professional entity. Note the quirk: a professional corporation is statutorily unavailable for the practice of medicine, so physicians use a professional association or a PLLC. Physician assistants may hold a minority interest but may not be officers.Tex. Occ. Code §§ 155.001, 164.052(a)(17); Tex. Bus. Orgs. Code §§ 301.003(3), 301.007, 301.012
4FloridaLay ownership allowed, but licensure may biteFlorida has no general prohibition on lay ownership. The constraint is licensure rather than ownership: an entity that is not wholly owned by licensed practitioners and that bills third-party payers generally needs a health care clinic license and a medical or clinic director who accepts legal responsibility in writing. Charges by an entity that should be licensed and is not are unenforceable.Fla. Stat. §§ 400.991(1)(a), 400.9905(4)(f)-(g), 400.9935; Fla. Admin. Code 59A-33.006(14)
5ArizonaLay ownership expressly allowedThe professional corporation statute permits non-licensees to hold up to 49 percent of voting shares by default, the professional LLC article allows any person as a member unless the licensing board says otherwise, and professionals may practice through an ordinary business entity. Confirm the medical board has not narrowed this.A.R.S. §§ 10-2220(A)(4), 10-2213(C), 29-4105(B)

Verified against primary sources on 29 September 2026. Re-verified annually and at the start of every engagement.

Rules written for aesthetic practice

Some states regulate medical spas by name

Most states apply general delegation and practice-of-medicine rules. A handful have written something specifically for this industry — and where they have, the requirements are concrete enough that compliance is easy to check and easy to fail.

Tennessee — Mandatory medical spa registry

Tennessee defines a medical spa in statute and requires each one to register with the Board of Medical Examiners before operating, annually. The registering medical director must be an MD or DO with an active Tennessee license and an active Tennessee practice — telemedicine-only does not qualify — and must attest in writing that they accept responsibility for the cosmetic medical services provided. Operating unregistered is unprofessional conduct.

Tenn. Code Ann. §§ 63-1-153, 63-6-105; Tenn. Comp. R. & Regs. 0880-02-.24

Arizona — Cosmetic laser and injection statute

Arizona has a dedicated statutory scheme for cosmetic laser and injection procedures. Only a health professional with prescribing authority may administer or supervise prescription medication or prescription-only devices for cosmetic purposes. Hair removal may be supervised indirectly; every other cosmetic laser use requires direct, on-site supervision. The supervising professional, the technician's employer and the device owner are all subject to discipline.

A.R.S. §§ 32-3231 to 32-3234; A.R.S. § 32-516

Colorado — Medical-aesthetic services rule

Board rule defines medical-aesthetic services to include Class IIIb and higher lasers, radiofrequency devices, IPL, and the injection of any substance into the body. It draws an explicit line: tattooing, permanent makeup, microdermabrasion and other superficial treatments are not medical services. Every office must post the delegating physician's name and obtain a signed patient disclosure naming the unlicensed delegatee before each service.

3 CCR 713-1, Rule 1.17(D)(2)–(4), (I)(2)(c)–(d)

Florida — Office surgery registration

Florida does not have a medical spa statute, but offices performing liposuction removing more than 1,000 cc, or Level II or Level III office surgery, must register with the department and pass inspection. Each registered office needs a designated physician with a full, active, unencumbered license who actually practices there and is responsible for health and safety compliance.

Fla. Stat. § 458.328

Good faith examination

The same requirement, four different legal hooks

No state researched uses the phrase “good faith exam” in its rules. The obligation is real in each, but it comes from a different place — a cosmetic-practice rule in one state, a prescribing statute in another, a pharmacy regulation in a third. They are not interchangeable, and neither are the answers on telehealth and expiry.

Washington

Board rule, written for cosmetic practice

The most explicit rule of any state researched. Before authorizing a non-surgical cosmetic procedure or treatment with a laser, light, radiofrequency or plasma device, the physician must take a history, perform an appropriate physical examination, make a diagnosis, recommend treatment, obtain informed consent, give emergency and follow-up instructions, and prepare a medical record. Note the carve-out: intravenous therapy is expressly outside the cosmetic-procedure rule.

  • Who may perform it: Physician or physician assistant. An RN is a delegate and may not exercise independent medical judgment.
  • Telehealth: Unsettled. The rule says perform an appropriate physical examination without saying in person, and no board policy resolves whether video satisfies it.
  • How long it lasts: No interval set. The physician must be on the premises for a patient's initial laser treatment.

WAC 246-919-605(6), 246-919-606(5), (2)(e)

California

Prescribing statute, plus board guidance

California has no cosmetic-specific exam rule either. It is unprofessional conduct to prescribe, dispense or furnish a dangerous drug or device without an appropriate prior examination and a medical indication, and prescription-only energy devices fall inside that definition. Worth knowing: the clearest sources on who may perform the examination are published board guidance rather than regulation, and both are around two decades old.

  • Who may perform it: Physician, nurse practitioner under standardized procedures, or physician assistant. The Medical Board's published guidance states the examination may not be delegated to registered nurses, and that salons, spas, shopping malls and private residences do not qualify as the organized health care system a standardized procedure requires.
  • Telehealth: Permitted, and the statute is unusually explicit: the examination does not require a synchronous interaction and may be achieved by telehealth, including a self-screening tool or questionnaire, provided the standard of care is met. That final clause carries all the weight.
  • How long it lasts: None for injectables, lasers, infusions or weight management. The separate 30-day examination and written clearance rule applies only to elective cosmetic surgery — defined to include liposuction and facial cosmetic surgery — and does not reach non-surgical treatment, despite being widely quoted as though it does.

Cal. Bus. & Prof. Code §§ 2242(a), 4022, 2259.8; Medical Board and BRN guidance

Texas

Board rules, rewritten in January 2025

Texas classifies non-surgical medical cosmetic procedures — including injection for cosmetic purposes and the use of a prescription device for cosmetic purposes — as the practice of medicine. Before the delegated act a practitioner-patient relationship must be established, an adequate record made, the identity and title of whoever will perform the treatment disclosed, and somebody trained in basic life support present while the patient is on site. Each treatment room must post the delegating physician's name and Texas license number.

  • Who may perform it: Physician, or a physician assistant or advanced practice registered nurse acting under physician delegation. The rule names those three; a registered nurse is the delegate who performs the treatment afterward, not the person who establishes the relationship.
  • Telehealth: Permitted, including asynchronous store-and-forward, provided the practitioner works from clinically relevant images or the patient's relevant clinical records. Note the current rule, unlike the one it replaced in January 2025, contains no in-person requirement — advice still quoting the old rule is wrong.
  • How long it lasts: None set. The requirement attaches before each delegated act.

22 Tex. Admin. Code §§ 169.25–169.28 (eff. 9 Jan 2025); Tex. Occ. Code § 111.005(a)(3)

Florida

No express rule located — it arrives indirectly

We could not locate an express codified good faith exam requirement in Florida, and we would rather tell you that than invent one. The obligation arrives through the standard of care and through discipline: prescribing or administering a legend drug other than in the course of professional practice, and delegating to someone not qualified by training, experience or licensure, are each grounds for discipline. Laser and light-based hair removal, by contrast, is expressly regulated.

  • Who may perform it: Physicians clearly. Florida primary sources do not expressly name which other license types may perform a pre-treatment cosmetic evaluation, so we treat that as unsettled rather than assert it. For laser and light-based hair removal the rule is concrete: direct physician supervision, no more than four electrologists per physician, and telehealth supervision only within 150 miles.
  • Telehealth: Permitted, synchronous or asynchronous, though email and fax are excluded. Where the provider conducts an evaluation sufficient to diagnose and treat, there is no separate obligation to research history or examine in person.
  • How long it lasts: None located. The semiannual review under the laser rule is a review of the operator's technique and equipment, not a patient exam validity period.

Fla. Stat. §§ 458.331(1)(q), (w), 456.47, 458.348; Fla. Admin. Code r. 64B8-56.002

Supervision limits

How many providers one physician may actually cover

This is the question owners ask most often and the one that is answered worst online. States set a hard cap — and they count it differently: some by headcount, some by full-time equivalents, one by hours per week. Several also fix how often charts must be reviewed and how close the physician has to be.

#StateCapChart reviewPresence & proximity
1Nevada3
Three physician assistants, or three APRNs, or three of them combined. More requires a petition to the board showing special circumstances.
Selected charts reviewed and initialed. No percentage set.At least once a month the supervising physician must spend part of a day at each location where the practitioner works.
2New Jersey4
Four physician assistants to one physician at any one time, though the physician may hold delegation agreements with more than four.
Only if the delegation agreement says so. The agreement must state the review period — or state expressly that no countersignature is required.Supervision is continuous but does not require physical presence, provided contact is maintained electronically.
3California8
Eight physician assistants at any one time, raised from six with effect from 1 January 2026.
None. The requirement that a physician review or countersign a patient record was abolished in 2020 — it now applies only if the practice agreement itself imposes it.Not required. Availability by telephone or other electronic communication is the standard.
4MississippiNone in the board rules
No practitioner-per-physician ratio appears in the board rules, but the other requirements are among the most specific anywhere.
Ten percent of charts, or twenty charts, whichever is fewer — reviewed every month. This applies to physician assistants and to nurse practitioners alike.A 75-mile limit from the primary office, and practice beyond it needs an approved protocol filed with the board. A new physician assistant needs the supervising physician on site for 120 days, or 960 hours.

What each state adds on top

Nevada

For advanced estheticians performing non-ablative procedures, the supervising professional must stay within 60 miles or 60 minutes and be reachable in real time. Ablative procedures are prohibited to them outright.

NAC 630.495(1), 630.370(2)–(5); NRS 644A.545

New Jersey

Lasers are defined as surgery. Office procedures beyond the minor-procedure threshold fall under the office-surgery rules, and all medical records must be audited at least annually.

N.J.A.C. 13:35-2B.10(c), (f); 13:35-4A.3, 4A.4

Out of date advice

Rules that changed, and are still being quoted

Compliance guidance ages badly. Each of these was a real requirement and is not any more, yet each still circulates. If your current setup was built around one of them, it was built around a rule that no longer exists.

  • South Carolina. The 45-mile limit between physician and practitioner was repealed effective 1 July 2018 and replaced with a general proximity standard plus prior board approval for off-site arrangements.
  • California. The requirement that a physician countersign a physician assistant's charts was eliminated in 2020, and the conforming regulation was rewritten in 2024. The supervision ratio rose from six to eight on 1 January 2026.
  • New Jersey. The old on-site presence and countersignature schedule for physician assistants was deleted by amendment in 2015. Review is now whatever the delegation agreement specifies, and the agreement must say so either way.

Management arrangements

What separates a defensible structure from a sham

Where a state restricts ownership, medical spas commonly operate through a physician-owned clinical entity paired with a management company. Regulators have published, in some detail, the specific decisions that must stay with the physician. The pattern is consistent enough to test yourself against.

#DecisionDefensibleDraws scrutiny
1Clinical decisions
Which diagnostic tests are appropriate, when to refer, what treatment options the patient is offered, and overall responsibility for the patient's care.
The physician decides.The management company issues binding protocols, sets appointment lengths, or dictates how many patients are seen.
2Patient records
Ownership of the record is treated as an indicator of control over the practice itself.
The clinical entity owns the records; the manager is a custodian only.The management agreement assigns records to the management company, or lets it keep them on termination.
3Clinical staffing
Selecting, hiring and dismissing clinicians as it relates to clinical competence.
The clinical entity hires and fires clinicians; the manager may run payroll and HR admin.The management company employs the clinicians or decides who is dismissed.
4Patient fees
Who sets the price list and who may waive or modify a fee.
The clinical entity sets and modifies patient fees.The management company sets or approves pricing.
5Coding and billing
Decisions about how care is coded and billed, as distinct from the clerical work of submitting it.
The physician approves coding; the manager executes it.The management company decides the codes.
6Equipment and product
Selection of medical equipment, devices and injectable products.
The physician approves clinical device and product selection.The management company selects the devices and the injectables.
7The management fee
How the fee is calculated and whether it can be justified.
Fair market value, documented, and supportable against the manager's actual costs.A share of clinical revenue with no cost documentation behind it. Several states prohibit percentage-of-revenue fees outright.

One correction worth making, because it is widely misunderstood: a cash-pay aesthetic practice that bills no federal health care program is generally outside the federal anti-kickback statute. Its real exposure is state fee-splitting and ownership law, which is stricter in several states than the federal rule.

What changed recently

This area is moving quickly

Recent enactments that change how medical spas must be structured and staffed. If your model was set up before them, it is worth re-checking.

Indiana · Registration due 1 January 2027

The first comprehensive medical spa statute in the country

Indiana has enacted a dedicated medical spa act. It requires each spa to designate a responsible practitioner, to report serious adverse events, and to register with the Medical Licensing Board, which will publish a public registry. Most provisions took effect in July 2026; registration is due by 1 January 2027.

Ind. SB 282 (2026)

California · In force since 1 January 2026

Private equity and hedge funds barred from clinical interference

New provisions bar private equity groups and hedge funds from interfering with clinical judgment — including which diagnostic tests are appropriate, referrals, treatment options, patient volume and physician hours — and from controlling the content of medical records, clinical hiring and firing, payer contracts, coding and billing, or the selection of medical equipment. Non-compete and non-disparagement clauses are void, and the Attorney General may seek an injunction.

Cal. SB 351 (2025), ch. 409; Health & Safety Code §§ 1190–1192

Georgia · Issued 7 May 2026

How the supervising physician is paid is now squarely in issue

The Composite Medical Board has stated that it is unlawful for a physician to be the employee of a nurse practitioner the physician supervises, and it reads employee broadly — covering a physician receiving compensation of any kind from an APRN or an APRN-owned company in exchange for serving as the delegating physician. The board names collaborating-physician marketplaces specifically, and says it looks at substance and practical effect rather than contractual labels. It also states that standing orders are not an acceptable substitute for an individualized order and examination before IV therapy.

Ga. Composite Medical Board, IV Hydration and Therapy Position Statement (7 May 2026)

Texas · In force since 9 January 2025

Non-surgical cosmetic procedures rewritten into new board rules

The medical board repealed its old standing-delegation chapter and reorganized these requirements. Non-surgical medical cosmetic procedures, including injection for cosmetic purposes and use of a prescription device for cosmetic purposes, are the practice of medicine. A practitioner-patient relationship must be established before the act is performed, a signed written protocol and written order are required, somebody trained in basic life support must be present, and every public area and treatment room must post the delegating physician's name and Texas license number. Anyone performing a delegated act must wear a name tag showing identity and credentials.

22 Tex. Admin. Code §§ 169.25–169.28 (replacing former § 193.17)

A note on state summaries. Med spa regulation moves quickly — boards issue position statements, legislatures pass new acts, and enforcement priorities shift. Any published state chart, including ones you will find elsewhere, is a snapshot. We verify the current rule for your state against the primary source at the start of an engagement and re-verify it annually, and we tell you plainly when an answer is genuinely unsettled rather than guessing.

Get your state's requirements in writing.

We confirm ownership, delegation, supervision and exam rules for the state you operate in — and tell you what your current setup would need in order to satisfy them.