With the growing popularity of aesthetic treatments, wellness services, and medical spas in Texas, more nurse practitioners (NPs) are exploring leadership roles beyond direct patient care. Nationwide, the medical aesthetics industry continues to surge, growing from 8,899 locations in 2022 to 10,488 in 2023. This steady expansion reflects both strong consumer demand and an increasing number of providers looking to enter or lead in this lucrative field.
The short answer: No, a nurse practitioner cannot legally serve as a medical director in Texas. The role of a medical director involves responsibilities that, under state law, require a licensed physician. However, this doesn’t mean NPs cannot own or operate a med spa. They just need to work under a compliant structure involving physician supervision.
In this guide, we’ll clarify why only physicians can serve as medical directors in Texas, the scope of practice for NPs, and how you can still legally run a clinic while ensuring compliance with state law.
What Does a Medical Director Do in Texas?
A medical director in Texas is a licensed physician responsible for overseeing the medical aspects of a healthcare facility or medical spa. This includes:
- Signing off on prescriptive authority agreements.
- Supervising advanced practice registered nurses and physician assistants.
- Approving protocols for laser treatments, Botox, and nonsurgical cosmetic procedures.
- Ensuring patient safety, infection control, and adherence to state regulations.
- Making final medical decisions and supervising medical staff.
Why NPs Can’t Serve as Medical Directors in Texas
Under Texas law, a nurse practitioner is not a licensed physician, which is a requirement to serve as a medical director. While NPs have expanded practice authority in many areas, Texas maintains stricter requirements.
Medical direction involves high-level oversight and is legally tied to physician delegation of medical tasks. That includes responsibility for:
- Medical malpractice liability
- Supervising physicians’ obligations
- Signing collaborative agreements
- Directing or reviewing medical spa services
Even if an NP has full certification requirements, they are still under the regulatory authority of the Texas Board of Nursing, not the Texas Medical Board, which governs medical directors.
Can an NP Open or Operate a Med Spa in Texas?
Yes. A nurse practitioner can open a med spa in Texas, but they cannot independently provide certain medical services without physician oversight. NPs can manage daily operations, marketing, and patient education, but they must partner with a collaborating physician for any services that require medical decision-making, prescriptive authority, or supervision.
To remain compliant:
- A collaborative agreement must be in place.
- A licensed physician must delegate medical tasks as needed.
- NPs must adhere to their scope of practice as defined by the Board of Nursing.
- All medical procedures must have clear documentation of physician involvement.
It’s also critical that marketing materials accurately reflect the NP’s title. Only a licensed physician should be listed as the medical director.
Common Legal Risks When NPs Act as De Facto Medical Directors
If an NP advertises themselves as the “medical director” of a facility in Texas, they risk violating Texas Medical Board rules and state law. Using the title without proper licensing can lead to:
- Disciplinary action from the Texas Board of Nursing
- Fines and sanctions for false representation
- Insurance coverage gaps in malpractice insurance
- Risk of noncompliance with informed consent, Health Insurance Portability and Accountability Act (HIPAA), and Occupational Safety and Health Administration (OSHA).
What Can NPs Do in a Medical Leadership Role?
Although NPs cannot serve as medical directors, they can still hold powerful roles in the med spa industry and beyond, including:
- Owning a Management Services Organization (MSO)
- Hiring and working with a supervising physician
- Acting as a clinic manager
- Training staff on patient care and treatment protocols
- Overseeing day-to-day medical spa operations
When structured correctly, NPs can operate successful, fully compliant clinics while maintaining their professional license and expanding their reach in the healthcare and aesthetics industries.
What the Law Requires: Summary
| Requirement | Nurse Practitioner | Licensed Physician |
|---|---|---|
| Serve as medical director | ❌ Not allowed | ✅ Required |
| Prescribe independently | ❌ Needs collaborative agreement | ✅ Allowed |
| Open a med spa | ✅ With oversight | ✅ With or without oversight |
| Interpret diagnostic tests | ✅ Within scope | ✅ |
| Sign collaborative agreement | ❌ Needs a physician | ✅ |
| Medical spa oversight | ❌ Cannot supervise staff | ✅ Required |
How Medical Director Co. Helps
At Medical Director Co., we work with NPs across Texas to help them launch and grow compliant med spas, telehealth practices, and aesthetic clinics with the proper physician partnerships in place.
Our team:
- Matches you with a qualified medical director.
- Handles your collaborative agreement and compliance paperwork.
- Includes malpractice insurance with every placement.
- Ensures your business stays aligned with Texas Medical Board and Board of Nursing guidelines.
So if you’re launching your first med spa or expanding statewide, we help you stay compliant, scale with confidence, and focus on patient care, not paperwork.
Hire a medical director with us today and build your practice the right way.
FAQs
Can a nurse practitioner be a medical director in Texas?
No. Only a licensed physician can be a medical director in Texas. NPs can own clinics but must operate under physician supervision and have a collaborative agreement in place.
Can an NP prescribe medications independently in Texas?
No. NPs must have a prescriptive authority agreement with a supervising physician to prescribe in Texas.
Can an NP open a med spa in Texas?
Yes, but only with a licensed medical director overseeing all medical spa services and performing or delegating tasks like Botox, laser treatments, or diagnostic procedures.
What title should an NP use if they run a MedSpa?
NPs can use titles like “owner” or “clinic director,” but not “medical director” unless they are a licensed physician.
How can I find a collaborating physician or medical director in Texas?
Medical Director Co. specializes in helping nurse practitioners find licensed medical directors for compliance, patient safety, and practice growth across Texas.
Written By:
Kiara DeWitt, BSN, RN, CPN
Kiara DeWitt is a nationally recognized Registered Nurse, Certified Pediatric Nurse (CPN), and founder of InjectCo—a rapidly expanding medical aesthetics brand with eight thriving clinic locations across Texas. With over a decade of clinical experience, Kiara began her career in pediatric neurology, serving as the Lead Clinical Educator for the Neurosurgery and Neurology Unit at Cook Children’s Pediatric Hospital, one of the most respected children’s hospitals in the country. There, she specialized in training nurses and clinicians in high-stakes neurological care, combining clinical rigor with compassionate patient advocacy.
Her transition into the aesthetics field was fueled by a passion for ethical care and a vision to transform the patient experience in cosmetic medicine. Since launching InjectCo in 2021, Kiara has grown it into a multi-location business—spanning six clinics in Dallas–Fort Worth, one in Houston, and one in Austin—anchored by her commitment to safety, education, and integrity.
As the founder of the Texas Academy of Medical Aesthetics, she also leads one of the most comprehensive hands-on training programs in the country, offering a 100+ hour injector internship where students shadow across all InjectCo clinics. Her approach has earned acclaim not only from patients but also from providers who see her as a mentor and reliable voice in a growing industry.
Kiara’s unique combination of pediatric neurological expertise, clinical leadership, and entrepreneurial success makes her a trusted authority in both medical and aesthetics circles. She is frequently sought after for insight on clinical operations, patient safety, and scaling compliant, ethics-driven practices.
