Do CRNPs and PAs require written agreements?

Yes. Certified Registered Nurse Practitioners (CRNPs) must have written collaborative agreements that are current and filed in the Pennsylvania Licensing System (PALS). Physician Assistants (PAs) must have written supervising physician agreements that outline delegated tasks, supervision methods, and chart review protocols.

Can RNs perform injectables or laser procedures?

Potentially, yes—if properly delegated. Registered Nurses (RNs) in Pennsylvania may perform medical procedures such as injectables or laser treatments under physician or CRNP orders, provided they have appropriate training, written protocols, documented competency, and direct or indirect supervision. Independent performance of these procedures is not permitted.

Is telemedicine permitted for weight-loss medications?

Yes. Telemedicine is allowed in Pennsylvania, but the same standard of care applies. A valid practitioner–patient relationship and adequate clinical evaluation must be established before prescribing. PDMP checks are mandatory when prescribing controlled substances, including medications like phentermine.

Are laser technicians licensed in Pennsylvania?

No. Pennsylvania does not license laser technicians as a separate profession. The use of lasers and other energy-based devices is classified as a medical act requiring physician or CRNP oversight, formal protocols, verified training, and supervision.

Michigan Medical Director Requirements & Compliance Rules (2026 Guide)

Disclaimer: This material is provided for educational and informational purposes only. It does not constitute legal, medical, or regulatory advice. Requirements and interpretations may vary and change over time. Always verify current rules directly with the Michigan Department of Licensing and Regulatory Affairs (LARA) and the Michigan Board of Medicine, and consult qualified legal counsel before making decisions or taking action.

Executive Summary

The medical director is typically a Michigan-licensed physician (MD/DO) who maintains clinical authority over medical decisions. Business operators may manage non-clinical functions, but Michigan’s Corporate Practice of Medicine (CPOM) framework restricts non-physicians from making diagnoses, providing treatment, or prescribing.
Physicians may delegate certain medical acts under the Michigan Public Health Code, provided the task is appropriate to the delegatee’s education and training. Physician Assistants (PAs) practice under a written supervision agreement that outlines scope, communication, and oversight. Nurse Practitioners (NPs) have full practice authority in Michigan, including prescriptive authority, and do not require a physician collaboration agreement, though facilities may impose internal protocols.
Michigan law sets conditions and limits on delegation, supervision, and prescribing authority. These requirements are primarily governed by the Michigan Public Health Code and enforced through LARA, the Michigan Board of Medicine, and the Michigan Board of Osteopathic Medicine and Surgery. Practices must confirm that their delegation and supervision structures align with current statutory and board guidance.
Laser and energy-based treatments, including laser hair removal, are generally treated as medical procedures in Michigan. Device ownership, use, and delegation must be tied to a licensed physician, supported by written protocols, appropriate training, and documented supervision. Improper delegation and unlicensed practice remain common enforcement triggers.
Michigan has increased regulatory scrutiny around telehealth prescribing, advertising claims, and non-physician control of clinical services. While no single statute mirrors high-profile bills in other states, enforcement actions reflect growing attention to how outpatient, aesthetic, and virtual care practices are structured and marketed.

Michigan compliance operates at the intersection of several authorities:

Michigan Department of Licensing and Regulatory Affairs (LARA): Oversees professional licensing, investigations, and enforcement across healthcare occupations.
Michigan Board of Medicine & Michigan Board of Osteopathic Medicine and Surgery: Regulate physician licensure, delegation standards, and professional conduct.
Michigan Public Health Code: Establishes the statutory framework for the scope of practice, delegation, supervision, and healthcare facility operations.
Michigan Board of Pharmacy: Governs prescribing, dispensing, compounding, storage, and advertising of prescription medications.
Corporate Practice of Medicine Doctrine: Limits non-physician ownership and control over medical practices and clinical decision-making.

If you are building or scaling outpatient care in Michigan, this guide explains how these rules fit together and highlights the regulatory expectations state authorities will assume you understand.

Quick Compliance Checklist

If you are building or scaling outpatient care in Michigan, this guide explains how these rules fit together and highlights the regulatory expectations state authorities will assume you understand.

Structure / Ownership

Clinical care flows through a physician-owned professional entity permitted under Michigan law, with documented physician control over diagnosis, treatment, and prescribing. Any MSO or management agreement avoids lay control of medical judgment and complies with Michigan’s Corporate Practice of Medicine (CPOM) restrictions.

Licenses & Credentials

Active, unencumbered Michigan MD/DO license for the medical director; current Michigan licenses for NPs, PAs, RNs, and LPNs as applicable; DEA registration where controlled substances are prescribed; facility and provider compliance with requirements enforced by the Michigan Department of Licensing and Regulatory Affairs.

Delegation Memos & Protocols

Written delegation and supervision documents define who may perform specific services (injectables, laser or energy-based treatments, IV therapy, diagnostics) and under what training and supervision. Physician approval and periodic review are documented and retained.

PA Supervision & NP Oversight

Written PA supervision agreements are current and reflect scope, communication, and physician oversight. NPs practice under full practice authority in Michigan, but internal clinical protocols and medical director oversight are clearly documented where required by facility policy or risk management standards.

Prescribing & Pharmacy Compliance

Prescribing authority aligns with licensure and scope of practice. Medication storage, dispensing, compounding, advertising, and recordkeeping comply with requirements enforced by the Michigan Board of Pharmacy, including controlled substance rules and telehealth prescribing standards.

QA & Compliance Evidence

Maintain chart review records, peer review or QA meeting notes, incident reports, adverse event logs, device maintenance records, and competency assessments. Documentation is organized and readily available in the event of a regulatory inquiry.

Laser & Device Use (if applicable)

Laser and energy-based devices are tied to a licensed physician, supported by written protocols, training records, supervision documentation, and treatment logs. Enforcement in Michigan commonly focuses on improper delegation and unlicensed practice rather than technician credential labels.

Marketing & Advertising Guardrails

Marketing materials, titles, and claims accurately reflect licensure, scope of practice, and delegation. No content implies unlicensed practice, independent diagnosis by non-physicians where not permitted, or lay control of medical services. Telehealth and weight-loss advertising aligns with Michigan enforcement expectations.

The Legal Frame: CPOM + Who Can Be a “Medical Director”?

What Is CPOM?

Michigan follows a Corporate Practice of Medicine (CPOM) doctrine that restricts lay individuals and entities from practicing medicine or exercising control over medical judgment. While Michigan law does not codify CPOM in a single statute, it is enforced through the Michigan Public Health Code and professional licensing authority exercised by Michigan Department of Licensing and Regulatory Affairs. In practice, this means clinical decision-making, diagnosis, treatment, prescribing, and control of medical records must remain with a physician-owned professional entity permitted under Michigan law. Non-physician owners may participate through compliant structures such as management services organizations (MSOs), but management agreements must avoid any direct or indirect control over clinical care, clinician hiring for medical roles, or treatment protocols.

Who Can Be a Medical Director?

A Michigan-licensed MD or DO in good standing. Specialty training is less important than demonstrated competence for the services offered and the scope of delegation involved. The title “medical director” itself carries no independent legal authority; regulators focus on who actually controls medical decisions, how delegation is documented, and whether quality assurance and supervision obligations are met in practice.

Delegation & Prescriptive Authority (NPs/PAs): The Documents That Matter

Michigan approaches delegation and prescribing differently than states that rely on prescriptive authority agreements.

Delegation of medical acts: Physicians may delegate certain medical tasks when the act is within the delegatee’s education, training, and experience, and when appropriate supervision is maintained. Delegation standards arise from the Michigan Public Health Code and are enforced by the physician licensing boards. Written protocols and competency documentation are critical for demonstrating compliant delegation.
Physician Assistants (PAs): PAs must practice under a written supervision agreement that defines scope of practice, physician availability, communication methods, and oversight responsibilities. The supervising physician remains responsible for delegated medical acts.
Nurse Practitioners (NPs): Michigan grants full practice authority, including independent prescriptive authority. No physician collaboration agreement is required by law. However, organizations may still implement internal clinical protocols or medical director oversight for risk management, especially in higher-acuity or procedural settings.

Practical Tips That Survive Audits

Avoid committing to supervision, chart review, or meeting cadences that cannot be consistently met. Regulators look for evidence of follow-through, not aspirational language.
Maintain a centralized supervision and delegation file (medical director → PA roster, scope descriptions, start dates, updates). Update documentation immediately when services expand or roles change.
Ensure every injector or device operator has a signed competency checklist tied to the applicable protocol and training materials.

Program-Specific Spotlight

Medspas (Injectables, Energy Devices, Skin Procedures)

Injectables (e.g., botulinum toxin products, dermal fillers) are medical procedures in Michigan. Delegation protocols should address patient selection, dosing parameters, documentation of product and lot numbers, adverse-event management (such as vascular occlusion or allergic reactions), and escalation pathways to a physician.
Laser and energy-based treatments are generally treated as medical services in Michigan. While Michigan does not license laser technicians through a standalone program, regulators focus on whether device use is properly delegated, supported by physician-approved protocols, adequate training, and supervision. Enforcement actions often cite unlicensed practice or improper delegation rather than missing certifications.
Regulatory environment: Michigan has not passed a single, high-profile aesthetics statute comparable to bills proposed in other states, but enforcement activity reflects increased scrutiny of injector qualifications, delegation boundaries, and marketing claims.

Telehealth (Virtual Primary Care, Psychiatry, Weight Management)

Physicians may oversee and delegate care in telehealth settings when documentation, communication pathways, and quality assurance processes are real and functional. Supervision agreements and internal protocols should explicitly address remote workflows, access to medical records for review, and escalation procedures.

Prescribing via telemedicine must meet Michigan standards of care and comply with controlled substance rules enforced by the Michigan Board of Pharmacy. Informed consent, identity verification, and e-prescribing workflows should align with provider scope and licensure.

Psychiatry & Behavioral Health

Oversight and delegation follow the same Michigan framework. Practices should add safeguards for controlled substances, including DEA registration, prescription monitoring program checks, crisis escalation plans, and documented case reviews reflected in quality assurance records.

Weight Loss & Wellness (GLP-1s, Phentermine, IV Therapy)

Medication protocols should clearly define which agents or drug classes are authorized, baseline assessment requirements, follow-up intervals, and adverse-event response. IV therapy programs should maintain medication and device logs, emergency response protocols, and documented staff training for reactions such as anaphylaxis.

The Paperwork Michigan Actually Asks to See

When there’s a complaint, a payer audit, or a regulatory inquiry, Michigan investigators request documents. Your compliance “binder” (digital is acceptable) should include:

Entity & Governance: Physician-owned professional entity documents permitted under Michigan law, plus any MSO or management agreement clearly showing business support without control over diagnosis, treatment, prescribing, or clinical staff. Regulators assess control, not labels.
Licenses & Registrations: Active, unencumbered Michigan MD/DO license; current Michigan licenses for NPs, PAs, RNs, and LPNs as applicable; DEA registration where controlled substances are prescribed. Licensing and enforcement authority sits with the Michigan Department of Licensing and Regulatory Affairs.
PA Supervision Agreements: Signed and current PA supervision agreements defining the scope of practice, communication methods, physician availability, and oversight responsibilities. Maintain executed copies and prior versions to show continuity over time.
Delegation & Scope Matrix: Written documentation identifying who may perform each procedure or service, required training, competency sign-offs, supervision level, and renewal or reassessment dates. Michigan regulators routinely evaluate delegation appropriateness during investigations.
Protocols & Consents: Procedure-specific protocols (injectables, energy-based devices, IV therapy, diagnostics) paired with informed consent forms. Include complication management pathways and emergency response standards consistent with the services offered.
Laser / Energy-Based Device Folder (if applicable): Physician-approved protocols, training and competency records, supervision documentation, device logs, and treatment records. Michigan does not issue separate laser technician licenses, but enforcement focuses on improper delegation and unlicensed practice.
QA Trail: Chart review records, peer review or QA meeting agendas and minutes, incident or adverse-event logs, corrective actions, and follow-up documentation. Michigan boards expect evidence that QA is active and ongoing, not symbolic.
Marketing & Advertising Approvals: Internal approval process and retained copies of marketing materials, titles, and credential usage guidelines. Documentation helps demonstrate that advertising does not imply unlicensed practice, physician oversight that does not exist, or lay control of medicine.

Delegation in Telehealth Settings

PA supervision agreements should explicitly address telemedicine workflows if PAs provide remote care or prescribing.
Define escalation pathways for red-flag cases (psychiatric crises, adverse medication reactions, abnormal labs).
Ensure supervising physicians have remote access to medical records for chart review and quality assurance.

Telehealth Weight Loss Prescribing

GLP-1 medications: Permitted via telehealth when a valid practitioner-patient relationship exists and prescribing meets the standard of care.
Phentermine and other controlled substances: Allowed only with appropriate licensure, DEA registration, and Michigan Prescription Drug Monitoring Program (PDMP) checks. Risk is higher due to controlled status and enforcement scrutiny.
Compliance best practice: Require at least one live video or in-person evaluation before initiating controlled substances, and document follow-up intervals and response monitoring carefully.

Avoid These Common Michigan Mistakes

Treating “medical director” as a title only. In Michigan, regulators focus on actual control, not titles. If the physician does not meaningfully control medical policies, delegation, prescribing, and quality assurance, the structure risks violating Corporate Practice of Medicine (CPOM) principles. MSOs may support operations, but they cannot steer clinical judgment or medical decision-making.
Outdated PA supervision or delegation documents. When services expand, modalities change, or staffing shifts, supervision agreements and delegation materials must be updated immediately. Michigan enforcement actions often reveal gaps where documentation no longer reflects real-world practice.
Weak or inconsistent QA documentation. If chart reviews, meeting notes, or corrective actions cannot be produced, regulators typically assume QA is not occurring. Michigan boards expect evidence of ongoing oversight, not informal or undocumented review.
Minimizing laser or energy-based services as “non-medical.” Michigan treats these as medical services. Improper delegation, insufficient training, or lack of physician oversight commonly triggers enforcement, even without a standalone laser licensing regime.
Loose or aspirational marketing language. Claims such as “physician-led” or “doctor-supervised” invite scrutiny if they are not accurate in practice. Michigan regulators evaluate whether marketing aligns with licensure, delegation, and actual physician involvement.

Step-by-Step: Building a Defensible Michigan Setup (30/60/90 Plan)

Days 1–30: Foundation

Diagnose the structure: Confirm that a physician-owned professional entity permitted under Michigan law controls diagnosis, treatment, and prescribing. Review MSO or management agreements for any language that could imply lay control of medicine.
License inventory: Verify active Michigan licenses for MD/DO, NP, PA, RN, and LPN roles as applicable, plus DEA registration where controlled substances are prescribed. Address gaps before expanding services. Oversight and enforcement sit with Michigan Department of Licensing and Regulatory Affairs.
Paper the program: Draft or refresh delegation documents, supervision agreements, and procedure protocols. Ensure documentation reflects current services, training requirements, and escalation pathways.

Days 31–60: QA in Motion

Start the cadence: Hold initial QA or peer review meetings. Select a chart-review volume that can be consistently maintained. Document findings, remediation steps, and follow-up actions.
Mock regulatory review: Conduct an internal audit focused on delegation, supervision, prescribing practices, and documentation. If laser or energy-based services are offered, include device use and training records. Correct deficiencies promptly.
Marketing scrub: Review websites, ads, and social media for alignment with licensure and scope of practice. Remove language that could imply unlicensed practice or physician oversight that does not exist.

Days 61–90: Harden & Scale

Competency proof: Complete and retain direct-observation or skills validation sign-offs for injectables, devices, IV therapy, and other delegated services. Track renewal or reassessment dates.
Audit readiness: Ensure the medical director can access patient records remotely and promptly for chart review or board inquiries. Michigan investigations often hinge on responsiveness and access to documentation.
Service expansion protocol: Before adding any new modality, complete training plans, update protocols and delegation materials, confirm supervision coverage, and review marketing language. Do not launch until documentation is complete.

FAQs

Can a nonphysician own a clinic in Michigan?

Yes. A nonphysician may own the business entity, but may not control medical decision-making. Clinical judgment, diagnosis, treatment protocols, and supervision must remain under a Pennsylvania-licensed physician to avoid unlicensed practice.

Who can serve as a “medical director”?

A Pennsylvania-licensed MD or DO in good standing. No specialty is required, but the physician must be competent to supervise the services offered and exercise actual clinical control, not merely hold the title.

Do we need a Prescriptive Authority Agreement in Michigan?

Yes. CRNPs must have written collaborative agreements that are kept current and filed in PALS. PAs must have written supervising physician agreements specifying delegated tasks, supervision, and chart review.

Do laser or energy-based services require different paperwork?

Potentially, if properly delegated. RNs may perform certain medical procedures pursuant to physician or CRNP orders, with appropriate training, written protocols, documented competency, and supervision. Independent practice is not permitted.

Did Michigan “ban” nonphysician injectors?

Yes. Telemedicine is permitted, but the standard of care applies. A valid practitioner–patient relationship and adequate clinical evaluation are required. PDMP checks are required when prescribing controlled substances (e.g., phentermine).

How Medical Director Co. Fits into Michigan Compliance

Medical Director Co. supports Michigan clinics with practical, regulator-aware compliance. We provide:

Michigan-licensed physicians experienced in outpatient care models, including medspas, telehealth, psychiatry, weight loss, and wellness services.
PA supervision and delegation frameworks aligned with Michigan law, including scope definitions, communication standards, and update workflows.
Quality assurance systems you can sustain, including chart-review structures, meeting templates, and documentation trails that stand up in audits.
Laser and device compliance support, including physician protocols, training documentation, and delegation alignment for Michigan enforcement expectations.
Structural alignment reviews, including MSO and governance sanity checks to ensure physician control remains intact under CPOM principles.
Regulatory awareness, tracking enforcement patterns, and board guidance from the Michigan Department of Licensing and Regulatory Affairs so clinics can adjust before issues arise.

Find a Licensed Pennsylvania Medical Director for Your Clinic Today

We provide licensed medical directors and compliance support for clinics across Michigan, including major metros:

Michigan Resources & References

Bolton Harris

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.