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 applicable state agencies and seek advice from qualified legal counsel before making decisions or taking action.
Executive Summary
- The medical director must be a Colorado-licensed physician with authority over clinical decisions and delegation of medical services. Non-clinical owners may participate through a management services organization (MSO), but Colorado’s corporate practice of medicine framework restricts non-physicians from controlling medical judgment or the practice itself.
- Colorado permits professional corporations and PLLCs for medical practices, but ownership must remain with licensed physicians, with limited exceptions allowing physician assistants to hold minority ownership while physicians retain majority control.
- Physicians may delegate certain medical acts to physician assistants and collaborate with advanced practice registered nurses (APRNs) in accordance with Colorado Medical Board rules. Delegation must follow written agreements, a defined scope of practice, and ongoing oversight consistent with sound medical practice.
- APRNs seeking prescriptive authority complete a mentorship process with structured physician or qualified mentor involvement before independent prescribing privileges are granted.
- Aesthetic procedures, laser services, IV therapy, and telehealth services must operate under physician oversight and comply with professional scope-of-practice requirements. Only licensed physicians may delegate medical procedures, and supervision models must align with board rules and documented protocols.
Colorado combines several regulatory layers that shape how medical director arrangements work:
- Colorado Medical Board: Oversees physician licensure, delegation authority, physician assistant supervision, and professional discipline.
- Colorado Revised Statutes Title 12, Article 240: Defines the practice of medicine, delegation authority, and professional ownership structures.
- Prescriptive Authority Framework: Establishes mentorship and collaboration requirements for APRNs and supervision standards for physician assistants.
- Corporate Practice of Medicine (CPOM): Requires physician ownership and preserves independent medical judgment, limiting lay control over clinical decisions.
If you’re opening or scaling outpatient care in Colorado, including medspas, telehealth clinics, weight-loss programs, IV therapy, or wellness practices, this guide explains how physician oversight, ownership structures, and delegation rules fit together under current law.
Quick Compliance Checklist
Use this monthly and assign each item to a responsible person (medical director, NP/PA lead, RN lead, clinic manager).
Clinical services flow through a physician-controlled professional entity consistent with Colorado’s corporate practice of medicine framework. Non-clinical owners may participate through MSO agreements, but contracts must avoid control over diagnosis, treatment plans, or supervision decisions.
Colorado MD/DO license in active standing, plus APRN, PA, RN, or other professional licenses as applicable. Supervisory or collaborative relationships must align with Colorado Medical Board rules, and any DEA registrations must match prescriptive authority roles.
Written delegation agreements outline which services may be performed by nurses, physician assistants, or unlicensed staff. Colorado rules require delegated medical-aesthetic services to be routine technical tasks that do not require a physician’s specialized judgment.
Physicians delegating medical acts must maintain written supervisory structures for PAs and delegated services. Delegation must reflect “personal and responsible direction and supervision,” not oversight through intermediaries.
Maintain chart review logs, training records, incident reports, treatment protocols, and written supervision documentation. Evidence of ongoing oversight supports compliance with Colorado Medical Board expectations.
Use of Class IIIb or higher lasers and light-based devices constitutes the practice of medicine under Colorado law. Delegation must occur under physician authority with documented protocols and appropriate facility oversight.
Advertising must reflect actual licensure and delegation. Colorado’s recent legislation on medical-aesthetic delegation increased expectations around disclosures, signage, and patient consent when services are delegated to unlicensed personnel.
The Legal Frame: CPOM + Who Can Be a “Medical Director”
What Is CPOM?
Colorado follows a corporate practice of medicine framework that protects physician control over clinical judgment. While Colorado permits professional corporations and structured collaborations, medical decisions, including delegation, supervision, and treatment planning, must remain under licensed physician authority rather than lay management.
In practice, this means the physician-led entity maintains responsibility for clinical staff oversight and medical records, while an MSO may provide administrative support such as staffing, marketing, billing, and facilities management, as long as those services do not influence medical decision-making.
Who Can Be a Medical Director?
A Colorado-licensed physician (MD or DO) in good standing typically fulfills the medical director role. The title itself is less important than the underlying responsibilities: oversight of delegation, supervision of medical services, and accountability for quality assurance.
Colorado statutes allow physicians to delegate medical acts, including prescribing authority to physician assistants, but only under personal supervision and within the scope of accepted medical practice.
The medical director’s effectiveness depends on documented supervision relationships, written protocols, and active involvement in clinical governance rather than the job title alone.
Delegation & Prescriptive Authority (APRNs/PAs): The Documents that Matter
Colorado organizes delegation and prescribing authority through professional scope-of-practice statutes, Medical Board rules, and licensure requirements. Documentation should clearly show how clinical authority, training, and oversight are structured within the practice.
- Delegation of medical acts (who can perform procedures, operate devices, and respond to complications). Colorado Medical Board Rule 800 allows physicians to delegate medical services that are routine and technical when the delegatee has appropriate education, training, or experience. Written protocols should define qualifications, supervision expectations, treatment limits, and physician responsibility for delegated services. Use of lasers and tissue-altering devices is considered the practice of medicine and must occur under physician authority and approved protocols.
- Prescriptive authority and collaboration for APRNs and PAs. Advanced practice registered nurses obtain prescriptive authority through licensure requirements that include mentorship documentation and defined collaboration processes during the provisional phase. Physician assistants prescribe under physician delegation consistent with Colorado statutes and supervision standards. Practices should maintain written agreements or policies that outline prescribing scope, communication expectations, and clinical escalation procedures.
Practical Tips That Survive Audits
- Choose supervision and chart-review cadences that match real workflows and maintain written proof, such as meeting notes or review logs.
- Maintain a centralized roster that lists supervising physicians, APRNs, and PAs, along with their start dates, scopes of services, and credential renewal timelines.
- When new services are introduced, such as adding energy devices or expanding injectable treatments, update protocols, competency checklists, and training records immediately.
- Ensure each injector or device operator has a signed competency validation tied to the written protocol packet.
Program-Specific Spotlight
Medspas (Injectables, Energy Devices, Skin Procedures)
- Injectables and laser-based treatments are medical procedures under Colorado law. Delegation protocols should address patient selection criteria, dosing parameters, product documentation, adverse-event response plans, and physician escalation pathways.
- Medical Board Rule 800 classifies the use of Class IIIb or higher lasers and similar energy-based devices as the practice of medicine, requiring physician oversight and written delegation protocols.
- Colorado disclosure laws for delegated aesthetic services require practices to maintain accurate advertising, signage, and informed-consent language reflecting who performs treatments and under whose authority.
Telehealth (Virtual Primary Care, Psychiatry, Weight Management)
- Physicians may supervise or collaborate with APRNs and PAs providing remote services when documentation, communication channels, and access to patient records allow meaningful clinical oversight. Delegation protocols should describe how remote encounters are reviewed, how consultations occur, and how patient charts remain available for quality assurance activities.
- Prescribing through telehealth must meet Colorado’s professional standard of care and align with the prescriber’s licensure scope, mentorship status (if applicable), and documentation policies.
Psychiatry & Behavioral Health
- Delegation and collaboration structures for behavioral health follow the same licensure and prescriptive authority rules applied to other specialties. Practices should maintain documentation supporting controlled-substance prescribing requirements, including DEA registration, prescription monitoring program checks, and documented clinical review intervals.
Weight Loss & Wellness (GLP-1s, Stimulants, IV Therapy)
- Written protocols should define which medications or treatment categories are permitted within the practice and identify monitoring expectations such as baseline labs, follow-up intervals, and adverse-event response procedures.
- IV therapy programs should maintain medication logs, emergency response protocols, and competency records for staff performing infusions or injections under physician delegation.
The Paperwork Colorado Regulators Actually Ask to See
When there’s a complaint, payer audit, or board investigation, regulators ask for documentation — not intentions. Your compliance “binder” (digital is fine) should include:
- Entity & Governance: Physician-controlled professional entity documents and any MSO agreements showing administrative support without control over medical judgment or supervision decisions.
- Licenses & Registrations: Active MD/DO license, APRN/PA/RN credentials where applicable, DEA registration for controlled-substance prescribing, and documentation showing prescriptive authority status for APRNs.
- Delegation Agreements & Lists: Written agreements between the delegating physician and each delegatee, including a detailed list of authorized medical-aesthetic services and documentation of training and qualifications. Colorado Medical Board Rule 800 requires physicians to maintain these records and provide them upon request.
- Delegation & Scope Matrix: A written matrix showing which clinician or staff member may perform each delegated procedure, along with training prerequisites, competency verification, and supervision expectations.
- Protocols & Consents: Procedure-specific written protocols created by the delegating physician, along with emergency procedures, disclosure language, and informed-consent documentation. Colorado regulations require written protocols and patient disclosures whenever medical services are delegated.
- Medical-Aesthetic Disclosure Documentation (if applicable): Office signage, website disclosures, and signed patient consent forms identifying the delegating practitioner when services are delegated to unlicensed personnel, consistent with Colorado’s disclosure legislation.
- QA Trail: Chart-review documentation, monitoring logs, competency records, incident tracking, and meeting notes showing ongoing physician oversight. Rule 800 expects regular monitoring of delegated services and documentation supporting quality review.
- Marketing & Advertising Approvals: Internal sign-off workflows that ensure titles, credentials, and clinical claims align with licensure and delegation policies, especially where delegated aesthetic services are advertised.
Documentation Expectations Under Colorado Medical Board Rule 800
- Written procedure protocols must be created by the delegating physician and be available whenever delegated services occur.
- Emergency protocols and informed-consent documentation must be maintained for delegated medical services.
- Patient disclosures identifying the delegating physician and the delegated nature of services must be documented and retained in the patient record.
- Offices providing delegated aesthetic services must post the delegating physician’s contact information in a visible area.
Delegation in Telehealth
- Remote care must meet the same professional standard of care as in-person treatment, and documentation practices should support chart review and physician oversight.
- Delegation protocols should define communication pathways, escalation processes, and how supervising clinicians access records for quality assurance.
- Written policies should address how patient identity, consent, and treatment decisions are documented during virtual encounters.
Telehealth Prescribing & Electronic Prescribing Requirements
- Colorado requires electronic prescribing for most Schedule II–IV controlled substances unless an exception applies.
- Prescribers must maintain documentation supporting telehealth consent, confidentiality disclosures, and patient access to records.
- Practices should align telehealth workflows with licensure scope, prescriptive authority status, and standard-of-care expectations.
Avoid These Common Colorado Compliance Mistakes
- Treating “medical director” as a title only. The delegating physician must maintain real oversight through written protocols, monitoring, and documented quality review — not just nominal supervision.
- Incomplete delegation documentation. Rule 800 requires written agreements, lists of delegatees, and competency verification records that can be produced to the Board upon request.
- Missing disclosure requirements for delegated aesthetic services. Practices must maintain signage, advertising disclosures, and patient consent forms identifying the delegating practitioner when services are performed by unlicensed staff.
- Weak documentation of protocols and emergency procedures. Colorado regulations specifically require written protocols and emergency plans created by the delegating physician.
- Assuming telehealth documentation standards are lighter. Virtual care must meet the same standard of care as in-person treatment, including consent, access to records, and clinical documentation.
Step-by-Step: Building a Defensible Colorado Setup (30/60/90 Plan)
Days 1–30: Foundation
- Diagnose the structure: Confirm a physician-controlled professional entity maintains authority over medical decision-making. Review MSO agreements to ensure administrative support does not interfere with supervision, delegation, or treatment decisions.
- License inventory: Verify active Colorado MD/DO licenses, APRN and PA credentials, RN licensure where applicable, and DEA registration for controlled-substance prescribing. Confirm prescriptive-authority status for APRNs and supervision documentation for PAs.
- Paper the program: Draft or refresh written delegation agreements, supervision policies, and procedure protocols. Colorado Medical Board Rule 800 requires written protocols and disclosure documentation when medical services are delegated.
Days 31–60: QA in Motion
- Start the cadence: Hold your first documented quality-assurance meeting. Establish a realistic chart-review process, document findings, and log corrective actions as part of ongoing physician oversight.
- Mock inspections: Conduct an internal review of delegation records, patient disclosures, and supervision documentation required under Rule 800. Confirm emergency protocols, informed consent forms, and competency files are complete.
- Marketing scrub: Update website content, advertising language, and staff titles to match licensure and delegation structures. Colorado disclosure rules require transparency when services are performed by delegated personnel.
Days 61–90: Harden & Scale
- Competency proof: Maintain direct-observation sign-offs and competency validation for injectors and device operators. Keep renewal reminders tied to training and credential timelines.
- Audit access: Ensure supervising physicians can access patient records remotely for chart review and quality-assurance activities. Colorado telehealth rules require secure documentation and continuity of oversight.
- Service expansion protocol: Before adding a new modality, prepare a training plan, an updated written protocol packet, revised delegation documentation, and a marketing review that reflects the new service accurately.
FAQs
Can a nonphysician own a clinic in Colorado?
Administrative ownership structures are allowed, but medical decision-making must remain under physician authority. Professional entities and contracts must preserve independent clinical judgment consistent with corporate practice of medicine principles.
Who can serve as a medical director?
A Colorado-licensed physician (MD or DO) in good standing who maintains responsibility for delegation, supervision, and quality-assurance oversight.
What documentation supports prescriptive authority?
APRNs must complete mentorship and licensure requirements before independent prescribing. Practices should maintain mentorship documentation, collaboration records during provisional phases, and DEA registration when prescribing controlled substances.
Do aesthetic procedures require specific paperwork?
Yes. Rule 800 requires written delegation agreements, procedure protocols, emergency plans, patient disclosures, and competency documentation when medical-aesthetic services are delegated.
Are nonphysician injectors allowed?
Delegation is permitted when performed under physician authority and consistent with written protocols, training requirements, and disclosure rules. Oversight documentation must demonstrate active supervision and quality review.
How Medical Director Co. Fits into Colorado Compliance
Medical Director Co. helps clinics build compliant physician-led oversight models through:
- Colorado-licensed physicians familiar with medspa, telehealth, psychiatry, and weight-management programs.
- Delegation protocol templates aligned with Colorado Medical Board Rule 800 requirements.
- Quality-assurance workflows, chart-review structures, and documentation processes designed for real-world operations.
- Guidance on supervision frameworks, prescriptive-authority documentation, and competency validation for delegated services.
- Governance alignment to help ensure physician control of clinical decisions within MSO structures.
- Ongoing regulatory monitoring so clinics can update protocols when Colorado Medical Board rules or disclosure requirements evolve.
Areas We Serve
We provide licensed medical directors and compliance support for clinics across Colorado — including major metro areas:
Colorado Resources & References
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.
