The medical spa industry in the U.S. surpassed $22 billion in annual revenue in 2024, and Texas is one of the fastest-growing states for new med spas. With so many entrepreneurs entering the space, one question comes up again and again:
Can a spa hire a medical director in Texas?
YES, but only under strict conditions.
Under the Texas Constitution and Statutes, the corporate practice of medicine doctrine, nonphysician owners cannot independently provide medical procedures or make medical decisions.
To legally offer medical spa services such as Botox injections, dermal fillers, or laser hair removal, a spa must contract with or employ a qualified medical director, a licensed physician who provides medical oversight, supervises medical professionals, and ensures the med spa complies with Texas Medical Board requirements.
The Role of a Medical Director in a Med Spa
A medical director is not just a formality in Texas. They are central to ensuring that a med spa business stays compliant.
Their responsibilities include:
- Providing medical oversight of all medical spa services classified as medical procedures under Texas law.
- Making or supervising medical decisions related to medical treatments such as Botox injections, dermal fillers, and laser hair removal.
- Delegating tasks to nurse practitioners, physician assistants, and registered nurses with proper training and physician supervision.
- Reviewing informed consent forms, infection control policies, and before-and-after photos to ensure safe patient care.
- Protecting the spa from liability by maintaining malpractice insurance, proper professional licenses, and compliance with Texas Medical Board rules.
Requirements for Medical Directors in Texas
Not just anyone can serve as a medical director in Texas. The Texas Medical Practice Act and the Texas Medical Board require that a qualified medical director must be a licensed physician (MD or DO) with an active Texas medical license.
Key requirements include:
- Only licensed physicians may act as medical directors. Nurse practitioners, physician assistants, and other advanced practice registered nurses cannot hold this role.
- The physician must have the relevant specialty training to oversee the medical spa services.
- A medical director must establish written protocols, supervise staff with proper training, and review charts to ensure safe patient care.
- The arrangement between the spa and the physician should be formalized through an independent contractor agreement, a professional limited liability company, or another compliant business structure.
- The physician is responsible for administrative oversight, including informed consent, infection control, and maintaining malpractice insurance.
Texas Med Spa Ownership Laws
Ownership of a med spa in Texas is governed by the corporate practice of medicine doctrine, which restricts nonphysician owners from directly controlling or profiting from the practice of medicine. Under Texas law, only licensed physicians can independently own a medical practice, make medical decisions, and provide medical services.
For this reason, most medical businesses in Texas operate under two structures:
- A professional limited liability company (PLLC) owned by a licensed physician, which oversees the medical services provided.
- A management service organization or medical service organization (MSO), run by nonphysicians, which handles the nonmedical aspects of the business operations such as marketing, staffing, and billing.
This arrangement allows med spa owners who are not physicians to legally run the business side while ensuring that only physicians control the medical aspects of care.
Risks of Operating Without a Medical Director
Operating a med spa in Texas without a qualified medical director is more than a compliance issue. It’s a serious legal and financial risk.
- Legal Risk: Offering medical spa services such as Botox injections, dermal fillers, or laser hair removal without proper medical oversight can be considered the unlicensed practice of medicine under the Texas Medical Practice Act. This may result in investigations by the Texas Medical Board, fines, or even criminal penalties.
- Liability Risk: Without a licensed physician overseeing medical procedures, a spa may be exposed to lawsuits if complications occur. Without adequate malpractice insurance, both the business and the owner’s personal assets may be at risk.
- Compliance Risk: Failure to maintain clear separation between business operations and medical decisions can violate the corporate practice of medicine doctrine. This includes misrepresenting services in marketing materials or failing to follow informed consent and infection control requirements.
- Reputation Risk: Patients expect safe, physician-supervised medical treatments. If a spa operates without proper oversight, it risks damaging its credibility and losing the trust needed to attract new clients and retain existing ones.
How Medical Director Co. Helps Medspa Owners
Finding a qualified medical director in Texas can be one of the biggest hurdles for nonphysician owners. At Medical Director Co., we make this process simple.
We connect med spa businesses with a licensed physician in as little as 24 hours, helping your med spa in Texas stay compliant with Texas Medical Board requirements while focusing on growing your business operations.
- No setup fees
- No long-term contracts
- Same-day MD intro call available
- Risk-free, fast, and compliant
Take the next step in protecting your med spa business in Texas and ensuring safe, compliant patient care. Contact Medical Director Co. today for your same-day medical director call.
Blaz Korosec is the CEO and co-founder of Medical Director Co., a nationwide platform that connects aesthetic and wellness professionals with licensed physicians for medical oversight, supervision, and compliance support. With a background that bridges healthcare operations, regulatory compliance, and entrepreneurial growth, Blaz has worked closely with hundreds of nurses, physician assistants, and clinic owners to help them legally launch and scale medical spas, telehealth weight loss clinics, IV hydration businesses, and aesthetic practices.
Blaz holds a degree in finance from Southern Methodist University (SMU) and has built a diverse portfolio of businesses ranging from healthcare to hospitality, including a national network of RV parks and medical clinics. Through MedicalDirector.CO, he’s developed a deep understanding of the state-by-state rules that govern collaborative agreements, PC/MSO structures, telemedicine protocols, and injectable treatments—translating complex legal frameworks into easy-to-implement solutions for clinicians and business owners.
Blaz is particularly passionate about helping nurses and mid-level providers unlock business ownership opportunities, and he’s known for designing systems that streamline operations, boost revenue, and ensure long-term legal protection. His team includes former prosecutors, senior RNs, and physicians who together support a growing number of clinics across all 50 states.
When he’s not working, Blaz enjoys mountain biking, restoring properties, and exploring the outdoors with his wife. He’s based in Texas but works with clients nationwide.
