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 Tennessee Board of Medical Examiners, Tennessee Board of Nursing, and other applicable state regulators, and seek advice from qualified legal counsel before making decisions or taking action.
Executive Summary
- The medical director must be a Tennessee-licensed physician (MD/DO) who maintains responsibility for medical decision-making, supervision, and delegation of clinical services. Non-physicians cannot make medical judgments, although business owners may oversee administrative functions through compliant management structures.
- Tennessee follows a reduced-practice model for advanced practice providers. Nurse practitioners (APRNs) must maintain a written collaborative agreement with a physician, and physician assistants must practice under a formal supervisory agreement approved by the appropriate regulatory bodies. These agreements must define the scope of services, prescriptive authority, consultation standards, and oversight expectations.
- Delegation rules place legal responsibility on the supervising physician. Aesthetic procedures, such as injectables, microneedling, and laser services, are considered medical acts and may be performed or delegated only under written physician oversight.
- Tennessee also enforces specific transparency rules for medical spas. Clinics that advertise cosmetic medical services must clearly identify the supervising physician or medical director and disclose their certification status in signage and marketing materials.
- Recent legislative activity has increased scrutiny on medical spa oversight and public transparency, including proposals to create state registries listing medical directors and certification information. Operators should expect continued enforcement attention in aesthetic medicine, telehealth supervision, and collaborative practice structures moving into 2026.
Tennessee combines several regulatory layers that shape medical director compliance:
- Tennessee Board of Medical Examiners (TBME): Oversees physician licensure, delegation authority, supervision requirements, telemedicine rules, and disciplinary standards governing medical practice.
- Tennessee Code Title 63: Defines collaboration requirements, medical spa supervision standards, and physician responsibility for delegated medical services.
- Collaborative Practice & Supervisory Agreements: APRNs and PAs may prescribe and perform delegated services only within formal written agreements that define scope, oversight, and communication requirements.
- Corporate Practice of Medicine (CPOM) Principles: Tennessee restricts non-physicians from controlling clinical decisions. Many clinics use MSO-style arrangements to separate business operations from medical oversight while preserving physician authority.
If you’re launching or expanding outpatient healthcare services in Tennessee, including medspa, telehealth, psychiatry, weight loss, IV therapy, or wellness clinics, this guide explains how physician supervision, collaboration rules, and advertising transparency requirements fit together within the state’s regulatory framework.
Quick Compliance Checklist
Use this monthly and assign each item to a responsible person (medical director, APRN/PA lead, RN lead, clinic manager).
Structure/Ownership
Clinical services must remain under physician oversight. The medical director or supervising physician must hold an active Tennessee license and accept responsibility for cosmetic medical services provided at the clinic. Administrative operations may be managed through compliant business structures, but medical decision-making stays with the physician.
Licenses & Credentials
Verify active Tennessee MD/DO licensure for the medical director and current licenses for APRNs, PAs, and nursing staff. APRNs require a written collaborative agreement with a physician, while PAs must maintain a formal supervisory agreement defining delegated duties and prescribing authority.
Delegation Memos & Protocols
Written protocols should define which procedures may be performed by each license type, including injectables, laser procedures, and other cosmetic services. Tennessee treats these as medical acts that must be performed or delegated by a physician under documented supervision.
Collaborative & Supervisory Agreements
APRNs and PAs must operate under signed agreements that describe the scope of services, communication expectations, chart review practices, and emergency escalation procedures. These agreements should be reviewed regularly and updated whenever services expand or staffing changes occur.
QA Evidence
Maintain chart-review documentation, competency checklists, incident logs, and meeting records that demonstrate active physician oversight. Tennessee expects the supervising physician to accept responsibility for cosmetic medical services delivered at a registered medical spa.
Medical Spa Registration & Signage
Medical spas must register annually with the Tennessee Board of Medical Examiners and disclose the supervising physician’s name and certification status in signage and advertising materials.
Marketing Guardrails
Advertising must accurately represent licensure, supervision, and certification status. Tennessee law requires transparency about the supervising physician in media and promotional materials.
The Legal Frame: Corporate Practice Principles & Who Can Be a “Medical Director”?
What Is CPOM in Tennessee?
Tennessee maintains restrictions that prevent non-physicians from exercising control over medical judgment. In practice, the supervising physician retains authority over protocols, standing orders, and delegation decisions. Business entities may handle administrative functions, but clinical oversight remains with the physician responsible for patient care.
Who Can Be a Medical Director?
The supervising physician must be an MD or DO with an active Tennessee medical license and an active medical practice in the state. Tennessee rules also require the medical director to assume responsibility for cosmetic medical services and ensure the medical spa maintains current registration with the Board of Medical Examiners.
Delegation & Prescriptive Authority (APRNs/PAs): The Documents That Matter
Tennessee organizes supervision through collaborative and supervisory agreements:
- Delegation of Medical Acts: Physicians may delegate cosmetic procedures and other medical services through written protocols that outline training requirements, supervision expectations, and escalation pathways. The supervising physician remains responsible for services delivered under delegation.
- Prescribing Authority Through Collaboration or Supervision: APRNs prescribe under collaborative practice agreements approved by a physician, while PAs prescribe under supervisory agreements approved by the Tennessee Board of Medical Examiners. Agreements should clearly list medication categories, consultation requirements, and chart-review expectations.
Practical Tips That Survive Audits
- Choose chart-review and meeting schedules that your team can realistically maintain. Tennessee regulators expect documentation that reflects active oversight rather than theoretical supervision.
- Maintain a centralized agreement index showing collaborating physicians, APRNs, and PAs, including start dates, renewal dates, and scope details. Update agreements promptly when services expand or when new procedures are introduced.
- Tie every injectable provider and device operator to a written competency checklist aligned with your clinic’s protocol packet. Tennessee medical spa rules require the supervising physician to accept responsibility for services, so clear documentation strengthens your compliance position.
Program-Specific Spotlight
- Injectables and energy-based procedures are considered medical services in Tennessee and must be performed or delegated under physician supervision. Medical spas must register annually with the Board of Medical Examiners, and the supervising physician must ensure compliance with signage and advertising requirements.
- Clinics must also disclose the supervising physician’s certification status in promotional materials, reinforcing Tennessee’s focus on transparency in cosmetic medicine.
- Physicians may supervise APRNs and PAs remotely as long as communication channels, documentation workflows, and chart-review access remain active. Telehealth services must follow Tennessee telemedicine laws and maintain physician availability for consultation when delegated providers deliver care remotely.
- Collaborative and supervisory agreements should define prescribing safeguards, documentation expectations, and escalation procedures for behavioral health services. Controlled substance prescribing requires appropriate DEA registration and compliance with Tennessee standards governing collaborative practice.
- Protocols should clearly define which medications or treatment categories fall within delegated authority. Tennessee expects written agreements to outline prescribing scope, consultation requirements, and oversight responsibilities, especially when clinics expand into wellness or metabolic programs.
The Paperwork Tennessee Actually Asks to See
When there’s a complaint, payer audit, or board investigation, regulators look for documentation that shows real physician oversight and active compliance. Your compliance binder (digital is fine) should include:
- Entity & Governance: Practice documents showing physician supervision over clinical services and clear separation between administrative operations and medical decision-making. Tennessee rules require the supervising physician to accept responsibility for cosmetic medical services performed at a medical spa.
- Licenses & Registrations: Active Tennessee MD/DO license for the medical director or supervising physician, plus APRN, PA, RN, and other professional licenses where applicable. Medical spas must maintain current annual registration with the Tennessee Board of Medical Examiners.
- Collaborative & Supervisory Agreements: Signed agreements between physicians and APRNs or PAs defining scope, prescribing authority, consultation expectations, and chart-review responsibilities. Agreements should reflect actual services offered and be updated when clinical roles change.
- Delegation & Scope Matrix: A written matrix showing which licensed providers may perform injectables, device procedures, or other cosmetic services, along with training requirements and competency sign-offs.
- Protocols & Consents: Procedure-specific protocol packets that include patient screening, informed consent, complication management, and emergency response procedures. Tennessee requires the supervising physician to accept responsibility for cosmetic medical services delivered under these protocols.
- Medical Spa Registration File: Registration confirmation, supervising physician information, certification disclosures, and renewal records demonstrating annual compliance with Board requirements.
- QA Trail: Chart-review documentation, meeting minutes, incident tracking logs, and corrective-action records that show active supervision rather than passive oversight.
- Marketing & Signage Approvals: Copies of advertisements, website pages, and in-clinic signage confirming that supervising physician information and certification disclosures meet Tennessee transparency rules.
Tennessee Medical Spa & Telehealth Documentation Expectations
Core Medical Spa Documentation
- Tennessee requires medical spas offering cosmetic medical services to register annually and disclose the supervising physician’s information. The supervising physician must attest to accepting responsibility for services performed at the practice.
- Investigations often focus on whether delegation protocols, provider training, and supervision structures match what is advertised publicly. Keeping protocol packets and competency checklists organized makes inspections smoother.
Delegation in Telehealth
- Physicians may supervise APRNs and PAs in telehealth settings when collaborative or supervisory agreements define communication expectations, chart-review access, and escalation pathways. Documentation should show how remote providers access medical records and how the supervising physician performs quality review.
- Telehealth policies should also document patient identity verification, informed consent, diagnosis documentation, and secure record retention to meet Tennessee standards for medical practice.
Telehealth Weight Loss Prescribing
- Weight-management programs delivered through telehealth should maintain clear documentation of the practitioner-patient relationship, medical evaluation, and follow-up planning. Controlled substances require additional documentation, including monitoring processes and appropriate prescribing safeguards.
- Best practice in Tennessee includes maintaining consistent video or in-person evaluations when prescribing medications that require closer supervision or monitoring.
Avoid These Common Tennessee Mistakes
- Treating “medical director” as a title only. Tennessee requires the supervising physician to accept responsibility for cosmetic medical services. If protocols, delegation, and oversight are missing, the practice risks disciplinary action.
- Operating without a current medical spa registration. Annual renewal is required, and operating without active registration can be considered unprofessional conduct by the supervising physician.
- Outdated collaborative or supervisory agreements. Adding new injectables, devices, or wellness services without updating agreements creates gaps between actual practice and written supervision structures.
- Weak QA documentation. Regulators expect proof of chart review and oversight activity. Missing records suggest that physician supervision may not be occurring as required.
- Unclear advertising disclosures. Tennessee law requires transparency around supervising physicians and certification status in marketing materials and signage.
Step-by-Step: Building a Defensible Tennessee Setup (30/60/90 Plan)
Days 1–30: Foundation
- Confirm that a Tennessee-licensed physician is formally designated as the supervising physician or medical director and accepts responsibility for cosmetic medical services. Review entity structure, collaborative agreements, and medical spa registration status.
- Inventory all professional licenses and ensure APRNs, PAs, and nursing staff operate within written agreements that reflect current services.
- Develop or update procedure protocols, informed-consent packets, and delegation matrices tied to actual clinic offerings.
Days 31–60: QA in Motion
- Hold the first quality-assurance meeting and establish a sustainable chart-review cadence. Document findings, training updates, and remediation steps.
- Conduct an internal mock inspection focusing on medical spa registration requirements, signage disclosures, and physician oversight documentation.
- Review website language, titles, and service descriptions to confirm alignment with Tennessee supervision rules.
Days 61–90: Harden & Scale
- Complete competency evaluations and direct-observation sign-offs for injectors and device operators. Maintain renewal reminders tied to training and credential updates.
- Ensure the supervising physician can access patient records remotely for chart review and oversight responsibilities.
- Before launching new services, update protocols, collaborative agreements, training documentation, and marketing materials to reflect the expanded scope of practice.
FAQs
Can a nonphysician own a clinic in Tennessee?
A nonphysician may participate in administrative or business operations, but medical judgment and supervision must remain with a Tennessee-licensed physician. Tennessee medical spa rules require a supervising physician to assume responsibility for cosmetic medical services provided at the practice.
Who can serve as “medical director”?
A medical director or supervising physician must be an MD or DO with an active Tennessee license and an active medical practice in the state. The physician must accept responsibility for the cosmetic medical services performed at the clinic.
What agreements are required for APRNs and PAs?
APRNs and PAs must practice under written collaborative or supervisory agreements that outline scope of services, prescribing authority, and consultation expectations. These agreements must be maintained at the practice site and available to regulators upon request.
Do medical spas need special registration in Tennessee?
Yes. Any practice offering cosmetic medical services must register with the Tennessee Board of Medical Examiners and renew the registration annually. Operating without current registration may be considered unprofessional conduct for the supervising physician.
What does the supervising physician have to disclose publicly?
Tennessee law requires medical spas to include supervising physician information and certification disclosures in signage and advertising materials. These transparency rules apply to both in-clinic displays and marketing content.
How Medical Director Co. Fits into Tennessee Compliance
Medical Director Co. helps clinics build supervision structures that align with Tennessee medical spa rules and physician oversight requirements. We provide:
- Tennessee-licensed physicians experienced in outpatient models such as medspa, telehealth, psychiatry, and wellness clinics.
- Collaborative and supervisory agreement frameworks designed around Tennessee delegation and prescribing standards, with workflows that help teams keep documentation current.
- Quality-assurance structures built around realistic chart-review cadence, meeting templates, and oversight documentation that reflects active physician supervision.
- Medical spa registration support, including supervising physician attestations, signage guidance, and protocol alignment with the Tennessee Board of Medical Examiners expectations.
- Structural review of governance and operational workflows to help ensure physician responsibility and supervision remain clear across services.
- Ongoing monitoring of Tennessee regulatory updates affecting medical spas, telehealth supervision, collaborative practice agreements, and physician oversight requirements.
Areas We Serve
We provide licensed medical directors and compliance support for clinics across Tennessee — including major metro areas:
