Disclaimer: This content is provided for educational and informational purposes only and is not intended as legal advice, medical advice, or formal regulatory guidance. North Carolina medical director requirements, delegation rules, and prescribing regulations may change over time, and interpretations can vary based on clinic structure and services offered. Always confirm current requirements directly with the North Carolina Medical Board, North Carolina Board of Nursing, and North Carolina Board of Pharmacy, and consult qualified healthcare legal counsel before making operational or compliance decisions.
Executive Summary
- The medical director must be a North Carolina–licensed physician (MD/DO) with clinical control over medical decision-making. Business owners may manage operations through administrative or management arrangements, but they may not control the practice of medicine.
- Physicians may delegate medical acts and support prescribing by APRNs and PAs through written collaborative or supervisory arrangements. These arrangements should address scope of services, physician availability, consultation and escalation expectations, emergency coverage, and quality oversight, and they should be kept current as services or staffing change.
- North Carolina compliance is governed by board rules and standards of care. Oversight focuses on supervision, documentation, controlled substance prescribing, and whether clinical workflows reflect written policies. Clinics should confirm their structure and practices against current board guidance.
- Injectables, lasers, and other energy-based procedures are treated as medical services. Clinics are expected to maintain physician-approved protocols, documented training and competency, supervision arrangements, and device records tied to physician oversight.
- North Carolina has not enacted a single aesthetics-specific statute in recent years, but enforcement activity has increased around who performs injectable procedures, how supervision is structured, and how clinics represent physician involvement in marketing. This trend underscores the importance of clear delegation, documentation, and accurate advertising.
North Carolina compliance is shaped by four intersecting authorities:
- North Carolina Medical Board: Physician practice, delegation, supervision, and telemedicine standards.
- North Carolina Board of Nursing: APRN scope of practice, collaboration, and prescribing.
- North Carolina Board of Pharmacy: Medication and controlled substance oversight.
- Corporate Practice of Medicine principles: Restrictions on lay control of medical judgment.
If you are building or scaling outpatient care in North Carolina, including medspas, telehealth, psychiatry, weight management, or wellness and IV services, this guide explains how the regulatory pieces fit together and highlights the documentation regulators expect you to maintain.
Quick Compliance Checklist
Use this monthly and assign each item to a responsible person (medical director, NP/PA lead, RN lead, clinic manager).
Clinical care flows through a physician-led clinical entity with documented physician control over medical decision-making; any MSO or management agreement avoids lay control of diagnosis, treatment, prescribing, supervision, or clinical policies, consistent with North Carolina corporate practice restrictions enforced by the North Carolina Medical Board.
Active, unencumbered North Carolina MD/DO license for the medical director, plus current APRN, PA, RN, and other applicable clinical licenses issued by North Carolina boards; DEA registration where controlled substances are prescribed.
Written delegation and supervision documents define who may perform which clinical services (injectables, devices, IV therapy, diagnostics), required training and competency verification, escalation procedures, and physician oversight; supervising or collaborating physician approval is documented.
Required collaborative practice agreements or supervisory arrangements for APRNs and PAs are written, signed, current, and reflect North Carolina law, including authorized medications, communication and consultation expectations, referral triggers, and quality oversight such as chart or case review.
Documentation supports active medical oversight, including chart or case review records, supervision or review meeting notes, incident and adverse-event tracking, device maintenance logs, and staff competency sign-offs.
Physician-approved protocols, documented supervision, staff training records, and device maintenance logs are maintained for laser and energy-based procedures, consistent with guidance from the North Carolina Medical Board.
Marketing and advertising do not imply unlicensed practice or lay control of medicine; titles, credentials, and claims accurately reflect licensure, supervision, and delegation, recognizing that North Carolina regulators may review marketing materials during scope-of-practice investigations.
The Legal Frame: CPOM + Who Can Be a “Medical Director”
What Is CPOM?
North Carolina applies restrictions on the Corporate Practice of Medicine (CPOM) that prohibit lay individuals or business entities from practicing medicine or controlling medical judgment. Although CPOM in North Carolina is not set out in a single statute, it is enforced through Medical Board positions, case law, and professional discipline. In practice, this means clinical decisions, physician supervision, prescribing authority, and medical records must remain under physician control. Business entities or MSOs may manage nonclinical functions such as space, staffing, marketing, and administrative support under agreements that avoid clinical control, consistent with enforcement expectations of the North Carolina Medical Board.
Who Can Be a Medical Director?
A medical director in North Carolina must be a North Carolina-licensed MD or DO in good standing. Specialty is less important than the physician’s competence to oversee the services provided, the tasks delegated, and the quality assurance obligations assumed. The title “medical director” alone is not determinative. What matters is actual control over medical policies, delegation and supervision arrangements, and the existence of written agreements and a documented QA trail supporting those responsibilities.
Delegation & Prescriptive Authority (APRNs/PAs): The Documents that Matter
North Carolina regulates delegation and prescriptive authority through board rules and required written collaboration or supervision arrangements.
- Delegation of medical acts: Physicians may delegate medical acts to APRNs and PAs within their scope of licensure and training. Written policies should define which clinical services may be performed, required training and competency, supervision expectations, and physician responsibility for delegated care.
- Prescriptive authority through collaborative or supervisory agreements: Prescribing authority for APRNs and PAs is established through written collaborative practice agreements or supervisory arrangements as required by North Carolina law. These agreements should outline authorized medications, physician availability, consultation and referral requirements, emergency coverage, and quality oversight such as chart or case review.
Practical Tips That Survive Audits
- Don’t over-promise chart review or meeting frequency. Pick a cadence you can consistently meet and keep basic proof such as chart review notes, sign-in sheets, or meeting minutes.
- Keep a supervision and collaboration index. Track supervising or collaborating physicians, APRN/PA names, start dates, scope of services, and any changes. When roles change or services expand (for example, adding new devices), update agreements and protocols the same week.
- Require signed competency checklists. Every injector or device operator should have a signed competency checklist tied directly to the applicable clinical protocol.
Program-Specific Spotlight
Medspas (Injectables, Energy Devices, Skin Procedures)
- Injectables (for example, onabotulinumtoxinA/Botox® and dermal fillers) are medical procedures in North Carolina. Delegation policies and clinical protocols should address patient evaluation, dosing parameters, product and lot tracking, adverse-event management (such as anaphylaxis or vascular occlusion), and clear escalation to a physician when complications arise.
- Laser and energy-based procedures are not governed by a separate facility licensing program in North Carolina, but they remain medical in nature. Clinics should maintain physician-approved protocols, documented staff training and competency, supervision arrangements, and device maintenance records. Device acquisition and use should be tied to physician oversight and written clinical policies consistent with expectations of the North Carolina Medical Board.
- Regulatory environment: North Carolina regulators continue to scrutinize who performs aesthetic procedures, how supervision is structured, and how services are marketed. Even without a single aesthetics-specific statute, enforcement actions often focus on delegation, documentation, and advertising that suggests unlicensed or unsupervised practice.
Telehealth (Virtual Primary Care, Psychiatry, Weight Management)
- Supervision and delegation in remote settings: Physicians may oversee and collaborate with remote APRNs and PAs in North Carolina if supervision, communication channels, and quality oversight are real and documented. Written collaboration or supervision arrangements and clinical policies should account for telehealth workflows, physician accessibility, and how patient records are accessed for chart or case review.
- Prescribing via telemedicine: Prescribing through telehealth must meet North Carolina standards of care and applicable state and federal prescribing requirements. Video workflows, informed consent, documentation, and e-prescribing practices should align with collaborative or supervisory arrangements, particularly for psychiatry and weight management services.
Psychiatry & Behavioral Health
- Collaboration and supervision in psychiatry and behavioral health follow North Carolina scope-of-practice rules and applicable standards of care. Clinics should implement safeguards for controlled substances, including appropriate DEA registration, Prescription Drug Monitoring Program checks, emergency plans for crisis escalation, and periodic case reviews documented in quality assurance records.
Weight Loss & Wellness (GLP-1s, Phentermine, IV Therapy)
- Ensure written clinical policies define which medications and treatment classes are authorized or excluded, including GLP-1 agents and controlled substances such as phentermine, consistent with expectations of the North Carolina Medical Board and the North Carolina Board of Pharmacy. Protocols should specify baseline evaluations, follow-up intervals, and adverse-event response. For IV therapy, maintain medication logs, physician-approved treatment protocols, and anaphylaxis response plans with documented staff training.
The Paperwork North Carolina Regulators Actually Ask to See
When there is a complaint, payer audit, or board inquiry, investigators focus on documentation, not intent. Your compliance “binder” (digital is acceptable) should include:
- Entity & Governance: Clinical entity documents showing physician control over medical decision-making; any MSO or management agreement demonstrating administrative support without lay control of diagnosis, treatment, or supervision, consistent with expectations of the North Carolina Medical Board.
- Licenses & Registrations: Active North Carolina MD/DO license, current APRN, PA, RN licenses, DEA registrations where applicable, and any facility or service-related registrations required for the services offered.
- Collaborative or Supervisory Agreements: Current written collaboration or supervision arrangements for APRNs and PAs supporting prescribing and clinical oversight, including scope of services, physician availability, consultation expectations, and quality oversight activities. Agreements should be readily producible upon request.
- Delegation & Scope Matrix: Written scope-of-practice documentation identifying who may perform each procedure, required training or prerequisites, direct-observation or competency sign-offs, and review or renewal dates.
- Protocols & Consents: Procedure-specific protocols and patient consent forms for injectables, devices, IV therapy, and other services, including complication management pathways and emergency response requirements.
- Device & Procedure Records (if applicable): Training and competency documentation, device maintenance logs, treatment records, and continuing education records tied to physician-approved protocols for laser or energy-based procedures.
- QA Trail: Quality assurance documentation such as chart or case review records, meeting agendas or summaries, incident logs, and corrective actions demonstrating ongoing medical oversight.
- Marketing Approvals: Internal review and approval records for marketing and advertising materials to ensure titles, credentials, and claims do not imply unlicensed practice or lay control of medicine, an area commonly reviewed during North Carolina investigations.
North Carolina Telehealth Documentation Standards
- Verify and record patient identity, informed consent, clinical findings, and treatment decisions.
- Telehealth prescribing must follow the same clinical and documentation standards as in-person care.
- Medical records must be maintained securely and be available for physician review.
Delegation in Telehealth
- Written collaboration or supervision arrangements should address prescribing and clinical oversight in telehealth settings.
- Escalation pathways must be defined for red-flag situations, including psychiatric emergencies and medication-related complications.
- Supervising or collaborating physicians must have remote access to medical records for quality oversight and review.
Telehealth Weight Loss Prescribing
- GLP-1 medications: May be prescribed via telehealth when a valid practitioner–patient relationship is established and documented.
- Phentermine: May be prescribed but carries higher risk due to its controlled status; documentation should include Prescription Drug Monitoring Program checks and appropriate follow-up.
- Best practice: At least one in-person or real-time video evaluation is recommended before initiating controlled substances for weight management.
Avoid These Common North Carolina Mistakes
- Assuming the medical director role is symbolic. If the physician is not actively setting clinical policies, overseeing delegation, and participating in quality oversight, the arrangement may raise concerns under North Carolina’s corporate practice and unlicensed practice rules. Administrative entities cannot influence clinical decision-making.
- Failing to update supervision or collaboration documents. Adding new services, devices, or changing staff responsibilities without revising written agreements and clinical policies creates a mismatch between documentation and actual practice, which is a frequent issue in board reviews.
- Minimal or inconsistent quality oversight records. When documentation of chart review, case discussion, or physician oversight is missing or sporadic, regulators often infer that supervision is not occurring. Oversight processes should be realistic, repeatable, and consistently recorded.
- Downplaying the medical nature of aesthetic services. Procedures involving injectables, lasers, or energy-based devices are treated as medical services in North Carolina and require physician-approved protocols, appropriate training, and documented supervision.
- Using imprecise marketing language. Descriptions that suggest greater physician involvement than actually exists can draw scrutiny. Public-facing claims should align closely with licensure, delegation, and supervision realities to reduce regulatory risk.
Step-by-Step: Building a Defensible North Carolina Setup (30/60/90 Plan)
Days 1–30: Foundation
- Assess the practice structure: Confirm that medical decision-making authority rests with a North Carolina–licensed physician and review any MSO or management agreements to ensure they do not grant non-clinical parties control over diagnosis, treatment, prescribing, or supervision, consistent with expectations of the North Carolina Medical Board.
- Verify licenses and registrations: Inventory all required credentials, including North Carolina MD/DO licensure, APRN/PA/RN licenses, and DEA registrations where controlled substances are prescribed. Confirm that current licenses align with the services being offered and address any gaps before expanding care.
- Formalize clinical documentation: Draft or update written delegation policies, collaboration or supervision arrangements, and procedure-specific protocols. Ensure these documents address communication, escalation, emergency coverage, and quality oversight and reflect how care is actually delivered in practice.
Days 31–60: QA in Motion
- Establish the oversight rhythm: Hold your initial quality oversight meeting, select a chart or case review volume that is realistic, and document findings along with any corrective actions taken.
- Conduct internal compliance reviews: Perform a mock review against North Carolina expectations for delegation, supervision, and quality oversight, including a separate review of protocols and training for aesthetic or device-based services if applicable. Address identified gaps promptly.
- Align public-facing materials: Review websites, advertisements, and patient-facing content to ensure titles, credentials, and service descriptions accurately reflect licensure, delegation, and supervision. Consider publishing a brief patient safety or medical oversight statement to reinforce transparency.
Days 61–90: Harden & Scale
- Document clinical competency: Maintain direct-observation sign-offs for injectors and device operators, along with training records and renewal tracking to demonstrate ongoing competency.
- Ensure audit readiness: Confirm the medical director or supervising physician can access patient records remotely for chart or case review in a timely manner if requested by North Carolina regulators or payers.
- Control service expansion: Before launching a new service or modality, finalize the training plan, update clinical protocols and supervision arrangements, and review marketing materials to ensure claims align with licensure and scope of practice.
FAQs
Can a nonphysician own a clinic in North Carolina?
Yes, a nonphysician may own or invest in a clinic, but they cannot control the practice of medicine. Medical judgment, clinical policies, supervision, and prescribing must remain under physician authority. Many practices use management or administrative agreements to separate business operations from clinical decision-making, consistent with expectations of the North Carolina Medical Board.
Who is eligible to serve as a medical director in North Carolina?
A medical director must be a North Carolina–licensed MD or DO in good standing. Specialty training is less important than the physician’s ability to oversee the services offered, approve delegation and supervision arrangements, and participate meaningfully in quality oversight and clinical availability.
What written agreements are required for APRN or PA prescribing in North Carolina?
Prescribing authority for APRNs and PAs is supported through written collaborative or supervisory arrangements that reflect scope of practice, physician accessibility, consultation expectations, emergency coverage, and ongoing clinical oversight. These documents should remain current and align with how care is delivered in practice.
Do aesthetic services such as laser hair removal require separate paperwork?
North Carolina does not operate a standalone laser facility licensing program, but aesthetic and energy-based procedures are still treated as medical services. Clinics should maintain physician-approved protocols, documented staff training and competency, supervision arrangements, and device maintenance records, which are commonly reviewed during board inquiries.
Have North Carolina regulators increased attention on injectables and medspas?
Yes. In recent years, regulators have shown more interest in how injectable and aesthetic services are delivered. Reviews typically focus on ensuring procedures are performed by appropriately licensed clinicians, supervision is clearly defined, and marketing accurately reflects provider roles. Clinics that maintain clear protocols, documentation, and oversight are generally well positioned.
How Medical Director Co. Fits into North Carolina Compliance
Medical Director Co. supports clinics in building practical, well-documented compliance structures that align with North Carolina expectations.
- North Carolina–licensed physicians familiar with outpatient care models, including medspas, telehealth, behavioral health, and weight management.
- Collaboration and supervision support: Assistance with written collaborative or supervisory arrangements and clinical policies that reflect scope of practice, physician availability, and day-to-day workflows.
- Sustainable quality oversight: Tools and templates for chart or case review, meeting agendas, and documentation processes that are realistic to maintain and align with regulator expectations.
- Aesthetic and procedure-based guidance: Support for protocol development, training documentation, competency tracking, and oversight structures for injectables, lasers, and energy-based services where applicable.
- Practice structure alignment: Review of management and governance arrangements to help ensure clinical decision-making remains under physician control, consistent with corporate practice considerations in North Carolina.
- Regulatory awareness: Ongoing monitoring of North Carolina Medical Board, Board of Nursing, and Board of Pharmacy developments, with guidance on when updates to policies or workflows may be appropriate.
Areas We Serve
We provide licensed medical directors and compliance support for clinics across North Carolina, including major metros:
North Carolina Resources & References
- North Carolina Medical Board Rules and Guidance
- North Carolina General Statutes (Medical Practice Act)
- North Carolina Board of Nursing Rules and Scope of Practice
- North Carolina Board of Pharmacy Rules and Controlled Substance Guidance
- North Carolina Controlled Substances Act
- North Carolina Medical Society CPOM and Practice Structure Resources
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.
