Can a nonphysician own a clinic or medspa in Pennsylvania?

Yes. A nonphysician may own the business entity, but cannot control or influence medical decision-making. All clinical judgment, diagnosis, treatment protocols, and supervision must remain under a Pennsylvania-licensed physician to prevent unlicensed practice of medicine.

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.

Colorado Medical Director Requirements for Medspas (2026 Compliance Checklist)

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 Colorado Medical Board and the Colorado Board of Nursing and consult qualified legal counsel before making decisions or taking action.

Executive Summary

Only licensed medical professionals can direct or supervise medical-aesthetic procedures. In Colorado, cosmetic injectables and many device-based treatments are considered medical procedures and must be performed by appropriately licensed providers or delegated under physician oversight.
Physicians commonly act as medical directors responsible for protocols, delegation, and clinical supervision. Colorado allows delegation of certain medical-aesthetic services to qualified staff, including RNs, PAs, APRNs, or trained assistants, when the supervision and training requirements of Colorado Medical Board Rule 800 are met.
Injectables and prescription-based treatments require a licensed prescriber (MD/DO, NP with prescriptive authority, or PA within scope). Estheticians or unlicensed assistants cannot independently inject or prescribe.
Colorado added new disclosure requirements through HB 25-1024. When medical-aesthetic services are delegated to unlicensed individuals, practices must provide signage, advertising disclosures, and written informed consent identifying the supervising practitioner.
APRNs and physician assistants operate under specific collaborative or supervisory frameworks. PAs must have a supervising physician agreement that outlines the scope, evaluation, and communication processes, while APRNs must meet prescriptive authority requirements before independently prescribing.
Supervision levels vary by procedure and provider qualifications. Colorado rules emphasize training, written protocols, patient assessment, and documentation rather than rigid on-site ratio limits found in some other states.
Telehealth oversight is permitted when the medical director holds an active Colorado license and maintains the same standard of care as in-person treatment.

Colorado Medical Director Requirements for Medspas

Colorado’s medical-aesthetic space is governed primarily by the Colorado Medical Practice Act, Colorado Medical Board Rule 800, and state licensing laws that define delegation, supervision, and prescriptive authority. Cosmetic injectables, many laser treatments, and advanced aesthetic procedures are considered medical services, which means they must be performed by licensed providers or delegated under proper physician or qualified prescriber oversight.

Medical directors in Colorado are responsible for ensuring that delegation meets Rule 800 standards, including training verification, supervision, and maintaining “personal and responsible direction” over medical services. Written protocols, documentation practices, and patient safety processes must align with Board expectations to avoid unprofessional conduct allegations.

Colorado also introduced enhanced transparency requirements through HB 25-1024. When medical-aesthetic services are delegated to unlicensed personnel, practices must provide visible disclosures, transparent advertising, and updated informed consent that identifies the supervising practitioner.

This page brings together the essential moving parts who can act as a medical director, how supervision and delegation work under Rule 800, what injectables require from a prescriptive standpoint, and the operational safeguards medspas use to stay compliant with Colorado regulations.

The Colorado Quick Compliance Checklist

Use this as your monthly audit. Assign each item to a specific person (medical director, APRN/PA, RN lead, clinic manager).

Entity & Ownership Structure

Clinical services must be delivered by appropriately licensed healthcare professionals operating within their scope. The medical director maintains authority over clinical decisions, delegation, and patient safety processes tied to medical services.

Medical Director Credentials

Active, unrestricted Colorado MD/DO license with oversight responsibilities aligned to services offered. The medical director verifies training, competency, and compliance with Rule 800 delegation standards and maintains availability for supervision and quality assurance.

Delegation & Prescriptive Authority

Written protocols must define how medical services are delegated to licensed staff or trained unlicensed assistants. Prescriptive treatments such as injectables require a Colorado-licensed prescriber (MD/DO, APRN with prescriptive authority, or PA within a supervising physician agreement).

Scope of Practice Mapping

Maintain a written matrix clarifying which procedures each role may perform (physician, APRN, PA, RN, medical assistant, aesthetician). Delegation decisions must reflect education, training, and supervision requirements outlined in Rule 800.

Informed Consent & Protocols

Procedure-specific consent forms must reflect delegation disclosures where applicable. Under HB 25-1024, patients must receive written acknowledgment when an unlicensed individual performs delegated medical-aesthetic services, and practices must retain these records for at least seven years.

Delegation Disclosures & Marketing Transparency

If unlicensed assistants provide delegated services, clinics must post signage identifying the supervising practitioner, include disclosures in advertising and online materials, and ensure informed consent documents mirror those disclosures.

Marketing & Representation

Advertising must accurately represent provider credentials and supervision. Medical-aesthetic procedures should not be marketed as independent services by unlicensed personnel or individuals outside their professional scope.

Quality Assurance Cadence

Ongoing chart review, adverse event monitoring, and protocol updates support compliance with the “personal and responsible direction” requirement outlined in Rule 800.

Recordkeeping & Access

Maintain delegation documentation, supervision agreements, training logs, consent forms, and disclosure materials. The medical director should have remote access to patient records for oversight and review when supervision is not on-site.

Change Management

When adding new technologies or procedures, update delegation protocols, training records, and consent language. Ensure new services align with the medical director’s oversight structure and applicable Board rules.

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

Who Can Be a Medical Director in Colorado?

A Colorado-licensed physician (MD or DO) typically serves as the medical director for aesthetic practices that provide medical services. The physician oversees delegation, supervision standards, training validation, and clinical protocols. Rule 800 requires that delegated medical services remain under the physician’s personal and responsible direction. Advanced practice registered nurses and physician assistants may provide treatments within their legal scope, but prescriptive authority and supervision agreements must be in place when required by state licensing rules.

Why Non-Licensed Individuals Cannot Serve as Medical Directors

Colorado law treats injectables and many aesthetic procedures as medical services. Because only licensed healthcare professionals may practice medicine or direct medical care, unlicensed owners, estheticians, or business managers cannot oversee clinical decision-making or act as medical directors. Delegated services must remain under licensed medical supervision with proper documentation and disclosures.

Collaboration and Delegation: NPs and PAs in a Colorado Medspa

Colorado regulates collaboration and delegation through the Medical Practice Act, the Nurse Practice Act, and Colorado Medical Board Rule 800. In medical-aesthetic settings, injectables, device treatments, and other clinical services must be performed by licensed providers or delegated to licensed personnel under proper medical oversight, with documented training and supervision.

Prescriptive Authority

Advanced practice registered nurses (APRNs) and physician assistants may prescribe medications within their legal authority and practice agreements. Physician assistants operate under physician collaboration or supervision frameworks, and prescriptions must align with Board rules and supervising physician relationships where required.

Delegation decisions must reflect each provider’s education, training, and scope. Colorado focuses less on numeric limits and more on ensuring that prescribing and clinical decision-making meet accepted medical standards and documented oversight expectations.

Day-to-Day Delegation

Physicians may delegate medical services — including aesthetic procedures — when they maintain “personal and responsible direction” over care and confirm that the delegatee is properly trained and competent. Delegated services cannot be re-delegated, and the supervising physician must evaluate qualifications before allowing the service.

APRNs and physician assistants may also provide or supervise treatments within their own scope, but written protocols, training documentation, and escalation pathways remain essential for compliance.

Practical Tips That Survive Audits

Colorado investigations often focus on documentation rather than titles or marketing language. Clinics should maintain clear delegation protocols, training verification, and informed consent records that demonstrate active oversight — not just policies that sit unused.

Injectables and Device Procedures: What “Legal” Looks Like in Practice

Injectables (e.g., OnabotulinumtoxinA/Botox®, Dermal Fillers)

Injectables are considered medical services under Colorado law. They must be performed by licensed healthcare professionals or delegated under Rule 800 standards with appropriate supervision, patient assessment, and documentation.

Protocols should outline patient eligibility, contraindications, dosing guidance, product tracking, post-procedure care, and emergency response plans. Unlicensed assistants may only perform delegated medical-aesthetic services when disclosure and consent requirements are met under HB 25-1024.

Lasers, IPL, and Energy Devices

Colorado does not use a separate licensing system for cosmetic lasers, but Rule 800 governs delegation and supervision. Physicians must determine whether the operator’s training, licensure, and experience match the device’s risk level and intended treatment. Written protocols and competency verification help demonstrate responsible direction during audits.

Microneedling, Peels, Threads, IV Therapy

Many aesthetic services qualify as medical acts when they involve prescription products, deeper tissue penetration, or clinical risk. Clinics should maintain procedure-specific checklists, written protocols, and complication pathways tied to the medical director’s oversight responsibilities.

The Paperwork Colorado Actually Expects to See

When a complaint or audit occurs, investigators typically ask for proof of supervision, delegation, and patient disclosures. Maintain a structured digital compliance binder that includes:

Entity Documents: Practice ownership records, clinical oversight agreements, and policies showing that licensed professionals direct medical care.
Licenses & Credentials: Medical director license, APRN or PA credentials, RN licenses, and documentation showing competency for each delegated procedure.
Delegation Protocols & Training Logs: Written protocols outlining which procedures may be delegated, training verification, and competency assessments demonstrating that delegatees meet Rule 800 standards.
Disclosure & Consent Records: Signage, website disclosures, and signed informed consent forms are required when unlicensed assistants provide delegated medical-aesthetic services. Records must be retained for at least seven years under HB 25-1024.
Quality Assurance Documentation: Chart review notes, complication tracking, incident reports, and policy updates that show ongoing clinical oversight.
Marketing Approvals: Proof that advertising accurately reflects provider credentials and supervision relationships, including disclosures when delegated services are performed by non-licensed individuals.

Common Pitfalls We See (and How to Avoid Them)

Assuming supervision is optional once staff are trained. Delegated medical services must remain under a licensed professional’s responsible direction, even when staff are experienced.
Missing disclosure requirements for delegated services. Colorado law requires visible signage, advertising transparency, and written patient consent when unlicensed assistants perform delegated medical-aesthetic procedures.
Incomplete delegation documentation. Investigations often focus on whether the supervising practitioner verified training and maintained oversight records. Maintain organized protocols, competency checklists, and QA notes.
Marketing that blurs clinical roles. Advertising should clearly identify licensed providers and avoid implying that unlicensed personnel independently provide medical treatments.

FAQs

Can a nonphysician own my medspa?

Colorado law requires that medical services be controlled by licensed medical professionals. Professional medical entities must be owned by licensed physicians, with limited exceptions that allow physician assistants to serve as minority shareholders while physicians retain majority ownership.

Business partners who are not licensed clinicians may participate through management or administrative structures, but they cannot control medical decision-making or practice medicine.

How many APRNs/PAs can one physician supervise or collaborate with?

Colorado law focuses on competency, supervision, and safe delegation rather than fixed numerical caps. Supervising physicians must maintain “personal and responsible direction” and ensure that delegated services remain within each provider’s scope and training. Written protocols and oversight documentation are typically expected during audits.

Do delegation protocols need to list every drug or device?

Colorado rules emphasize clear written protocols and documented training rather than rigid template requirements. Clinics should maintain detailed procedure guidelines, prescribing policies, and supervision expectations that match the services offered and the medical director’s oversight responsibilities.

Are estheticians allowed to perform microneedling or lasers?

Estheticians may perform services that fall within the cosmetology scope, but treatments that qualify as medical procedures must be performed by licensed healthcare professionals or delegated under Rule 800 supervision standards. When services are delegated to unlicensed assistants, Colorado law requires signage, advertising disclosures, and patient consent identifying the supervising practitioner.

What changed in 2025 with Colorado’s medical-aesthetic laws?

HB 25-1024 introduced new disclosure rules for delegated medical-aesthetic services. Practices must provide visible office signage, a website, and advertising disclosures, and written informed consent explaining that services are being performed under the delegation of a licensed medical professional.

Are there new laws affecting injectables or “Botox party” events?

Colorado continues to treat injectables as medical procedures that require licensed oversight and proper delegation. Clinics should monitor guidance from the Colorado Medical Board and maintain supervision, documentation, and patient safety protocols that reflect current standards of care.

Templates and Operational Playbooks (What to Implement This Week)

Use these frameworks to build internal SOPs. They reflect documentation investigators often request during a complaint review or Board inquiry.

Delegation Protocol Template

Define supervising practitioner, procedures covered, training prerequisites, supervision level, escalation pathways, emergency plans, and quality assurance processes. Include documentation expectations that demonstrate responsible direction under Rule 800.

Delegation & Scope Matrix

Monthly QA Pack

Meeting agenda and minutes; chart review summaries; adverse-event tracking; protocol updates signed by the supervising practitioner; device maintenance and sterilization logs.

Disclosure & Consent Binder

Maintain copies of signage language, website disclosures, advertising statements, and informed consent forms required under HB 25-1024, along with signed patient acknowledgments retained for the required recordkeeping period.

Marketing Compliance Checklist

Confirm accurate title usage, provider credentials, disclosure language for delegated services, and clear explanations of who performs each treatment. Avoid implying independent practice by unlicensed individuals.

Building a Defensible Structure (Professional Entity + Management Model)

Many Colorado medical-aesthetic practices use a dual-structure approach to separate clinical care from business operations.

A physician-owned professional medical entity delivers clinical services, maintains patient records, and controls treatment protocols. Colorado statutes require that shareholders in professional medical corporations be licensed physicians, with physician assistants permitted only as minority owners while physicians retain majority ownership.

A separate management organization may handle nonclinical operations such as staffing, marketing, and administrative support. The legal framework is designed to preserve clinical independence and prevent non-licensed individuals from influencing medical judgment.

Implementation Plan (30/60/90 Days)

Days 1–30: Foundation & Paperwork

Inventory provider licenses, delegation protocols, training records, and informed consent forms.
Update signage and marketing disclosures required for delegated medical-aesthetic services.
Align ownership documents and governance policies with Colorado professional-entity requirements.

Days 31–60: Quality Assurance in Action

Launch recurring chart reviews and documentation audits.
Conduct a mock compliance inspection focusing on delegation records, supervision policies, and disclosure materials.
Review marketing content to ensure credential transparency.

Days 61–90: Risk Hardening & Growth

Train injectors and device operators using documented competency checklists tied to written protocols.
Audit governance practices to demonstrate that licensed professionals maintain clinical control.
Publish a public compliance statement outlining medical oversight and patient-safety standards.

How Medical Director Co. Supports Colorado Medspas

Operating a compliant medical-aesthetic practice in Colorado requires more than hiring a physician. Medical Director Co. provides licensed oversight, documentation frameworks, and operational support designed to align with Colorado Medical Board expectations and current disclosure laws.

Here’s what we provide:

Access to Qualified Colorado Physicians

We connect clinics with Colorado-licensed MDs and DOs experienced in injectables, laser treatments, and medical-aesthetic delegation. Each physician supports protocol development, supervision, and clinical governance.

Delegation Protocols and Compliance Templates

Our team provides customizable delegation frameworks, consent structures, and disclosure language aligned with Colorado requirements, including HB 25-1024 patient transparency rules.

Ongoing Quality Assurance Support

We help implement chart review workflows, QA meetings, and documentation systems that create a clear oversight trail while allowing medical directors to review cases remotely.

Disclosure and Documentation Guidance

We assist clinics in implementing required signage, advertising disclosures, and consent workflows for delegated services, reducing risk during audits or Board investigations.

Business Structure Alignment

We help practices organize professional medical entities and management agreements that support compliant operations while preserving licensed clinical control.

Monitoring Regulatory Updates

Colorado medical-aesthetic regulations continue to evolve. Our team tracks legislative and Board developments so your protocols stay current without constant re-writes.

Medical Director Co. provides Colorado medspas with licensed medical oversight, compliance systems, and operational infrastructure designed to support safe growth and regulatory alignment.

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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.