Disclaimer: This resource is for educational and informational purposes only. It does not constitute legal or medical advice. Requirements may change. Always confirm with the Nevada State Board of Medical Examiners, the Nevada State Board of Nursing, and the Nevada State Board of Pharmacy, and seek guidance from qualified legal counsel before making compliance decisions.
Executive Summary
- Corporate Practice of Medicine (CPOM): Medical decision-making must remain under a Nevada-licensed MD/DO. MSOs are strictly limited to business operations (billing, marketing).
- Medical Director: Must be an actively licensed Nevada MD/DO with documented availability for supervision, emergencies, and Quality Assurance (QA).
- APRNs & PAs: APRNs may practice independently with Full Practice Authority (FPA). PAs require a current, written Supervisory Agreement with a physician, detailing scope and chart review.
- Scope of Practice Mapping: Maintain a written matrix detailing who may perform each procedure (injectables, lasers, IV therapy), verified against licensure and competency.
- Controlled Substances: Prescribers must have DEA registration and perform Nevada PMP checks before initiating or refilling Schedule II–IV medications (e.g., phentermine).
- Laser & Device Rules: Medical lasers, IPL, and RF devices may only be operated by licensed clinicians. Estheticians cannot use medical lasers in Nevada.
- Quality Assurance (QA): Requires documented chart reviews, QA meetings, competency sign-offs, and clear incident-tracking to show active physician oversight.
- Injections/Procedures: Procedures like injectables and IV therapy are medical acts and require physician oversight or orders; follow all informed consent and complication protocols.
- Telehealth Compliance: Telehealth is permitted but must adhere to Nevada’s standard of care, identity verification, and consent rules. Controlled substance prescribing requires specific DEA/PMP compliance.
- Required Paperwork: Regulators expect to see current licensure files, PA Supervisory Agreements, written protocols, QA logs, PMP documentation, and compliant marketing materials.
- Common Mistakes: Frequent errors include lack of physician control, using unlicensed staff (like estheticians) for medical procedures, and missing or outdated supervisory agreements/QA records.
- Implementation: Establish CPOM governance first, then launch documented QA workflows, and finally complete staff competency checks and update all protocols.
The Nevada Quick Compliance Checklist
- Clinical authority must remain under a Nevada-licensed physician (MD/DO), consistent with CPOM enforcement through NRS 630.301 and NRS 630.306 (unprofessional conduct + improper delegation).
- MSOs may manage non-clinical operations (HR, billing, marketing) but cannot influence diagnosis, treatment, or provider supervision.
- Must hold an active, unrestricted Nevada MD/DO license in good standing.
- Must maintain competence in delegated procedures and fulfill supervisory duties under NRS 630.3062 (failure to supervise).
- Must keep a documented plan for consultation availability, emergency coverage, and QA oversight.
Advanced Practice Registered Nurses (APRNs)
- APRNs may diagnose, treat, and prescribe independently once they meet Full Practice Authority (FPA) requirements under NRS 632.237.
- Controlled-substance prescribing requires DEA registration + Nevada PMP checks under NRS 453.162.
- In medspas, written protocols for injectables, devices, and emergency care are strongly recommended even for independent APRNs.
Physician Assistants (PAs)
- Must work under a Supervisory Agreement with a Nevada physician, per NRS 630.271 & NAC 630.810–630.830.
PA Licensure & Rules – Nevada Medical Board
https://medboard.nv.gov/Professionals/ - The agreement must define scope, prescribing limits, and chart-review requirements.
- PAs require explicit board-approved authorization for controlled-substance prescribing.
Registered Nurses (RNs)
- May perform injections, IV therapy, and device assistance only under orders from an MD/DO, APRN, or PA.
Estheticians
- Limited to non-medical cosmetic services under Nevada State Board of Cosmetology rules.
- Cannot legally perform lasers, IPL, injectables, or IV therapy because these constitute medical procedures affecting living tissue.
- Maintain a written scope matrix listing:
- who may perform each service (injectables, lasers, RF, IV therapy)
- training/competency verification
- supervision level required
- Update whenever a new device, treatment, or staff member is introduced.
- Use procedure-specific consents for:
- Botox®, dermal fillers, threads
- Microneedling, RF/microneedling
- Lasers/IPL
- IV therapy
- Protocols must include complication management (vascular occlusion, burns, anaphylaxis) and escalation steps consistent with NAC 630 supervision standards.
- Lasers, IPL, RF, and similar devices used on living tissue are regulated as medical acts under NRS 630.
- Only MD/DO, APRN, PA, or RN may operate medical lasers under physician-approved protocols.
- Maintain:
- laser safety training certificates
- device maintenance/calibration logs
- emergency procedures
- Nevada does not permit estheticians to operate medical lasers.
- Advertising must be truthful and comply with:
- NRS 630.306 (false or misleading medical advertising)
- Nevada Deceptive Trade Practices Act (NRS 598.0903–598.0999)
- Staff titles must accurately reflect licensure; non-physicians may not use “doctor.”
- Ads must not imply MSO or layperson control over clinical decisions.
- Conduct scheduled QA meetings with documented minutes.
- Maintain chart-review logs (required for PAs; recommended for APRNs as risk-management best practice).
- Document staff competency evaluations, safety drills, and incident reports.
- Ensure compliance with physician-supervision obligations under NRS 630.3062.
The Legal Frame: CPOM + Who Can Be a “Medical Director”?
Who Can Be a Medical Director in Nevada?
Corporate Practice of Medicine (CPOM) in Nevada
Delegation & Supervision in Nevada Medspa
- APRNs may diagnose, treat, and prescribe independently only if they hold Nevada Full Practice Authority under NRS 632.237.
- Without FPA, APRNs must practice under a Collaborative Agreement with a physician.
- Regardless of FPA status, APRNs must follow scope-of-practice, training, and competency requirements for aesthetic procedures.
- PAs must practice under a written Supervisory Agreement with a Nevada-licensed physician as required by NRS 630.271.
- The agreement must specify permitted procedures, prescribing privileges, chart review expectations, and supervision levels (direct/indirect).
- This agreement must be maintained and updated with the Nevada State Board of Medical Examiners.
- RNs may perform injections, IV therapy, and device-based procedures only under orders from a physician, APRN, or PA, consistent with the Nevada Nurse Practice Act (NRS Chapter 632).
- RNs may not diagnose, prescribe, or independently select treatments.
Injectables & Device Procedures: Nevada Standards
Injectables (Botox®, Fillers, Threads)
- Injectables are medical procedures in Nevada and may be performed only by physicians (MD/DO), APRNs, or PAs, with RNs administering under their orders.
- Clinics must maintain protocols for patient evaluation, informed consent, lot-number tracking, and complication management (consistent with NRS 630.301 “unprofessional conduct”).
Lasers, IPL, RF Devices
- Nevada treats lasers/IPL/RF used on living tissue as medical procedures; therefore only MD/DOs, APRNs, PAs, or RNs may operate them under physician-approved protocols.
- Operators must have documented training, laser safety certification, and competency evaluations per Nevada rules and laws expectations.
- Estheticians cannot use medical lasers in Nevada because these fall under the medical practice definition (NRS 630).
IV Therapy & Wellness Procedures
- IV hydration, vitamin infusions, and wellness injections are considered medical treatments and require physician/APRN/PA orders.
- Clinics must maintain standing protocols, staff competency records, and emergency preparedness including access to emergency medications and crash-cart supplies.
Telehealth in Nevada
General Telehealth Rules
- Telehealth may be performed by Nevada-licensed MD/DOs, APRNs, and PAs, following the same standard of care required for in-person visits.
- A valid provider–patient relationship must be established, including identity verification and documentation.
Prescribing via Telehealth
- GLP-1 medications (semaglutide, tirzepatide) may be prescribed via telehealth if clinically appropriate.
- Controlled substances (including phentermine) require an in-person medical evaluation, except in specifically allowed situations under federal DEA telemedicine rules.
- Nevada law (NRS 453.164) requires PMP checks before issuing or refilling Schedule II–IV prescriptions.
Paperwork Nevada Regulators Expect
- Entity documents: PC/PLLC records showing physician control and MSO agreements that do not influence clinical decisions.
- Delegation documents: PA Supervisory Agreements (required under NRS 630) and any APRN protocols or collaborative materials used for medspa procedures.
- Licensure files: Current MD/DO, APRN, PA, and RN licenses; DEA registrations for controlled-substance prescribers; Nevada PMP enrollment proof.
- Clinical protocols: Updated procedure packets for injectables, lasers, IV therapy, and weight-loss medications, including consents and complication plans.
- QA documentation: Chart-review logs, QA meeting minutes, incident reports, and corrective-action notes demonstrating ongoing physician oversight.
- Device documentation: Laser/IPL training certificates, operator competency records, safety procedures, and device maintenance logs.
- Marketing compliance: Internal approval records confirming truthfulness, proper use of licensure titles, and adherence to NAC 630 advertising standards.
Practical Tips for Nevada Compliance
- Maintain all PA Supervisory Agreements and any APRN documentation onsite and available for Nevada State Board of Medical Examiners or Board of Nursing review.
- Do not delegate injectables, lasers, IPL, or RF devices to unlicensed staff; estheticians are limited to cosmetic, non-medical services.
- Keep QA meeting minutes, chart-review logs, and incident documentation readily accessible for inspections.
- Update written protocols immediately when new treatments, devices, or medications are introduced.
- Ensure remote-supervision setups document how the medical director reviews records, provides oversight, and maintains timely availability.
Common Mistakes in Nevada Medspas
- Allowing estheticians or medical assistants to perform injectables, IV therapy, or laser/IPL procedures—considered unlicensed practice under NRS 630.
- Missing, incomplete, or outdated Supervisory Agreements for PAs.
- APRNs practicing without confirming their independent practice status or failing to follow required prescribing and PMP rules.
- Lack of QA documentation, including missing chart reviews, competency records, or incident follow-up.
- Marketing language implying medical independence by non-physicians or using titles that misrepresent credentials.
30/60/90 Day Implementation Plan
Days 1–30: Foundation
- Confirm the practice structure maintains physician control over medical decision-making to satisfy Nevada CPOM enforcement.
- File or update PA Supervisory Agreements and any APRN collaborative/oversight documentation (if the APRN is not recognized as an independent practitioner).
- Verify active licenses, DEA registrations (if prescribing controlled substances), and Nevada PMP enrollment for all prescribers.
Days 31–60: QA in Motion
- Begin documented chart reviews and QA meetings demonstrating ongoing physician oversight, especially for PAs and delegated clinical procedures.
- Conduct a mock internal audit based on Nevada State Board of Medical Examiners and Board of Nursing requirements.
- Review marketing and titles for compliance with NRS 630 rules prohibiting misleading or deceptive medical advertising.
Days 61–90: Harden & Scale
- Complete direct-observation competency sign-offs for injectors, laser/device operators, and IV therapy staff to document safe delegation.
- Set up renewal reminders for PA/ APRN agreements, competencies, and license/DEA expirations.
- Introduce new treatments only after updating protocols, consent forms, and supervisory/delegation documents in alignment with Nevada practice rules.
FAQs
Can non-physicians own medspas in Nevada?
Yes. Non-physicians may own the MSO, but only a Nevada-licensed physician may control medical services.
Can estheticians perform injectables or lasers?
No. These are medical procedures and must be performed by licensed medical professionals only.
Do APRNs need collaborative agreements?
Only if they do not have Full Practice Authority. Even with FPA, written protocols are expected for aesthetic procedures.
Do PAs need supervisory agreements?
Yes. A written Supervisory Agreement with a Nevada physician is required.
Is telehealth permitted in Nevada?
How Medical Director Co. Supports Nevada Medspas
Medical Director Co. provides Nevada medspas with physician-led oversight, compliance structures, and documentation systems that satisfy Nevada State Board of Medical Examiners (NSBME) expectations. We help clinics operate legally, safely, and efficiently under proper medical delegation and supervisory rules.
- Nevada-licensed physicians for compliant medical directorship
We connect practices with MDs/DOs experienced in aesthetics, supervision, and Nevada CPOM enforcement to ensure all clinical authority stays with a licensed physician. - APRN collaborative agreements and PA supervisory agreements
We provide Nevada-compliant agreements outlining scope, prescribing limits, chart review standards, and supervision requirements consistent with NRS 630 and NRS 632. - Quality Assurance (QA) systems and documentation
Our templates include chart-review logs, incident tracking forms, training checklists, and structured QA meeting agendas expected during NSBME reviews. - Laser, injectable, and IV therapy protocols
We supply physician-approved procedure protocols, safety standards, and competency sign-off sheets for medical lasers, injectables, and wellness/IV services. - MSO contract review for CPOM compliance
We ensure MSO arrangements do not cross into clinical control, protecting the practice from CPOM violations and board scrutiny. - Regulatory monitoring and compliance updates
We track Nevada Medical Board, Nursing Board, and Pharmacy Board changes and provide proactive updates on rules affecting medspas and wellness practices.
- Nevada-licensed physicians for compliant medical directorship
Find a Nevada Medical Director with Medical Director Co.
Medical Director Co. connects Nevada medspas with licensed physicians who provide compliant oversight, supervision, and protocol support across the state. We help practices operate safely and legally while scaling services under proper medical governance.
Areas We Serve in Nevada:
Nevada Resources to Bookmark
- DEA Diversion Control Division: https://www.dea.gov/press-releases/2025/01/16/dea-announces-three-new-telemedicine-rules-continue-open-access
- Nevada Revised Statutes – Justia: https://law.justia.com/codes/nevada/2024/
- Nevada Medical Board: https://medboard.nv.gov/
- Nevada Public Law Statutes: https://nevada.public.law/statutes
- Nevada Admin Code – Legal Information Institute: https://www.law.cornell.edu/regulations/nevada/
Bolton M. Harris, J.D., is a seasoned attorney with a formidable background in criminal law and a focus on healthcare law and compliance. As the in-house legal counsel at Medical Director Co., Harris brings a unique blend of prosecutorial experience and regulatory expertise to support healthcare professionals across Texas. Her career spans roles as a prosecutor in multiple counties and now as a trusted advisor on the legal intricacies of medical practice operations.
Education & Early Career
Bolton Harris completed her undergraduate studies at Southern Methodist University (SMU) in 2013. During her time at SMU, she was not only a dedicated student but also a competitive athlete on the university’s women’s swimming team. She went on to earn her Juris Doctor from Texas A&M University School of Law in 2016 and became a member of the Texas Bar that same year. Armed with a strong academic foundation and discipline honed as a student-athlete, Harris embarked on a career in criminal law immediately after law school.
Prosecutorial Experience in Texas
Bolton Harris began her legal career in public service as a criminal prosecutor. She served as an Assistant District Attorney in multiple jurisdictions, where she quickly rose through the ranks and handled a broad spectrum of cases. Some highlights of her prosecutorial career include:
- Assistant District Attorney, Dallas County, Texas: Prosecuted a high volume of criminal cases in one of the state’s busiest DA offices, gaining extensive trial experience in both misdemeanor and felony courts.
- Assistant District Attorney, Ellis County, Texas: Continued to hone her courtroom advocacy skills, known for meticulous case preparation and a tenacious pursuit of justice on behalf of the community.
- Assistant District Attorney, Navarro County, Texas: Broadened her legal expertise by handling diverse criminal matters in a smaller county, working closely with law enforcement and community leaders to uphold the law.
Through these roles, Harris built a reputation for being a tough but fair advocate. She brought numerous cases to trial and developed an in-depth understanding of the criminal justice system. This distinguished prosecutorial background laid a strong foundation for the next phase of her career in the private sector.
Healthcare Law & Compliance at Medical Director Co.
After her tenure as a prosecutor, Harris shifted her focus to healthcare law, applying her legal acumen to the medical field. She recognized that the same attention to detail and tenacity that served her in criminal law could benefit healthcare providers navigating complex regulations. Embracing this new direction, Harris became well-versed in the intricate laws governing medical practices – from licensing requirements to patient safety and privacy standards – and is passionate about helping practitioners stay compliant.
In her current role as the in-house attorney for Medical Director Co., Bolton Harris oversees all legal and compliance matters for the organization and its clients. Medical Director Co. is a nurse-owned firm that connects nurse practitioners (NPs), physician assistants (PAs), and registered nurses with qualified medical directors and collaborating physicians, offering fast placements and comprehensive compliance support for healthcare practices. Harris ensures that each of these partnerships and clinical ventures adheres to all applicable state and federal laws. She is responsible for drafting and reviewing collaborative practice agreements, advising on regulatory requirements, and providing ongoing legal counsel as clients establish and grow their clinics. Drawing on her prosecutorial eye for risk management, Harris proactively identifies potential legal issues and addresses them before they escalate, giving healthcare professionals peace of mind.
Bolton M. Harris’s multifaceted expertise – spanning high-stakes courtroom litigation to detailed healthcare compliance – makes her a formidable legal ally. Whether advocating in front of a jury or guiding a medical practice through regulatory hurdles, she remains committed to the highest standards of the legal profession. Her blend of courtroom-tested skill and healthcare law knowledge ensures that clients of Medical Director Co. receive elite-level counsel and steadfast protection in an ever-evolving legal landscape.
