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Florida Medical Director Compliance Rules & Requirements (2025 Guide)

Florida Medical Director and collaborating physician Compliance Rules & Requirements-min

Disclaimer: This material is provided for educational and informational purposes only. It does not constitute legal or medical advice or regulatory guidance. Requirements and interpretations may vary and change over time. Always verify current rules directly with the Florida Board of Medicine, Florida Board of Osteopathic Medicine, Florida Board of Nursing, and the Florida Board of Pharmacy, and seek advice from qualified legal counsel before making decisions or taking action.

Executive Summary

  • In Florida, the medical director must be a Florida-licensed physician (MD or DO) with ultimate authority over medical decisions. Non-physicians may operate business functions via an MSO, but may not practice medicine or override clinical judgment.
  • Physicians may delegate medical tasks and may authorize prescriptive activity for Advanced Practice Registered Nurses (APRNs) and Physician Assistants (PAs) through written protocols/agreements consistent with scope and supervision rules. These documents should specify scope, prescriptive limits, communication/consultation, emergency procedures, and QA measures (e.g., chart review cadence and meetings) and be kept current and available to regulators upon request.
  • Florida law sets boundaries on prescriptive delegation, including controlled-substance limits, required training, and registration where applicable. Most relevant provisions appear in F.S. Chapter 456 (telehealth, professional standards), Chapters 458 & 459 (medical/osteopathic practice and delegation), Chapter 464 (APRN scope & autonomous practice), Chapter 893 (controlled substances/PDMP), and implementing rules in the Florida Administrative Code (Title 64B).
  • Medical aesthetics (e.g., laser hair removal, injectables/Botox®, energy devices) require physician oversight and written protocols. Non-medical personnel cannot independently perform medical procedures; laser hair removal specifically must be performed by a licensed electrologist under the direct supervision and responsibility of a physician (with permitted conditions for in-person or telehealth supervision).
Florida Medical Director Compliance Rules & Requirements

Florida combines four realities that make compliance both critical and nuanced:

  • Florida Boards of Medicine & Osteopathic Medicine: Physician delegation, supervision, standards, advertising rules.
  • Florida Statutes (Chs. 456, 458, 459, 464, 893): Practice framework, delegation, telehealth, APRN authority, and controlled substances.
  • PDMP (E-FORCSE) under F.S. 893.055: Mandatory checks before prescribing/dispensing controlled substances for patients ≥16 (with narrow exceptions).
  • Corporate Practice of Medicine (CPOM) principles: Bar lay control of medical decision-making; MSO contracts must not intrude on clinical judgment.

If you’re building or scaling outpatient care in Texas (medspa, telehealth, psychiatry, weight loss, wellness/IV), this hub explains how the pieces fit and links to the source material regulators will expect you to know.

If you are building or expanding outpatient services in Florida (medspas, telehealth, weight management, behavioral health, or wellness clinics), this guide explains how the key compliance pieces fit together — with references to the agencies and statutes regulators expect you to know.

Quick Compliance Checklist

Use this monthly and assign each responsibility to a physician medical director, APRN/PA lead, RN lead, or clinic administrator.

Structure & Ownership

Confirm medical services flow through a physician-owned entity; MSO contracts must not interfere with clinical judgment.

Licenses & Credentials

Licenses & Credentials: Active Florida MD/DO license in good standing, APRN/PA/RN licenses, DEA where applicable.

Delegation Protocols

Written and signed scope of practice documents for injectables, devices, diagnostics, and IV therapies.

Prescriptive Protocols

Collaborative agreements or protocols covering drugs/devices, communication methods, referral rules, and QA requirements. Must be available within three business days if requested.

Quality Assurance Documentation

Chart reviews, staff training records, competency checklists, meeting minutes, and device maintenance logs.

Laser & Device Use

Device purchase/use tied to physician order; protocols must specify qualifications, emergency procedures, and documentation.

Marketing Guardrails

Advertising must not suggest lay ownership of medicine or imply unlicensed practice; all provider titles must reflect actual licensure and delegation.

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

What Is CPOM?

Florida enforces the Corporate Practice of Medicine doctrine through statutory and case law. The doctrine bars non-physicians from practicing medicine or exercising control over clinical decisions. In practice, this means: Medical judgment rests solely with a physician-owned entity. MSOs may provide space, staff, billing, and marketing but cannot influence treatment plans, prescriptive authority, or protocols. Violations can trigger penalties, license actions, or contract invalidation.

Who Can Be a Medical Director?

A Florida-licensed MD or DO in good standing may serve as medical director. Specialty is less important than competence and willingness to provide oversight in writing. The “medical director” title carries legal weight only if the physician maintains clinical control, valid delegation documents, and a verifiable QA process.

Delegation & Prescriptive Authority (APRNs/PAs): The Documents that Matter

Florida divides physician collaboration with Advanced Practice Registered Nurses (APRNs) and Physician Assistants (PAs) into two main categories: delegation of medical acts and delegation of prescriptive authority.

Physician Assistants (PAs) 

  • Delegated Authority: A PA’s ability to prescribe, order, and dispense medications is contingent on the supervising physician delegating this authority to them.
  • Supervision: PAs must practice under a physician’s supervision and can only perform tasks delegated by that physician.
  • Medication Formulary: PAs are generally not permitted to prescribe the specific types of medicinal drugs listed in the Florida formulary, though this can be subject to changes in law.

Advanced Registered Nurse Practitioners (ARNPs)

  • Physician Protocol: ARNPs are generally required to practice under a supervisory protocol with a physician within the same group practice to implement their advanced nursing practice. 
  • Medication Authorization: The supervisory protocol defines the scope of practice for the ARNP, which can include the authority to prescribe, dispense, administer, or order any drug. 
  • Independent Practice: Recent legislation (CS/CS/HB 607) has expanded the scope of practice to allow certain ARNPs to practice and provide primary care services without physician supervision or a protocol, provided they meet specific qualifications. 

Practical Tips: That Survive Florida: Audits

  • Be realistic: Set achievable chart-review quotas and meeting schedules, then keep sign-in sheets and review logs.
  • Track protocols: Maintain a master index of delegation/protocol agreements by staff name, start date, renewal date, and scope.
  • Tie training to protocols: Every injector or device operator must have a signed competency checklist tied to your written delegation.
  • Update promptly: Add new modalities (e.g., RF microneedling, semaglutide prescribing) to your protocols immediately.

Program-Specific Spotlight

Medspas & Aesthetics

Florida Medical Director Compliance Rules-min
  • Injectables (Botox®/fillers). These are medical acts and must be performed by a licensed practitioner acting within scope (MD/DO, PA, APRN, or—case-by-case—RN under physician order/supervision via Board of Nursing declaratory guidance). Protocols should spell out patient selection, dosing ranges, documentation, supervision, and escalation. Florida has used declaratory statements to clarify RN participation; supervision and training are pivotal. 
  • Laser hair removal. Florida regulates laser/light hair removal under physician responsibility. If performed by someone other than an MD/DO, it must be done by a licensed electrologist with required laser training and under the direct supervision and responsibility of a physician; recent rulemaking allows direct supervision in-person or via telehealth with conditions. 
  • Legislative environment. Lawmakers are actively looking at medspa rules. 2025 bills would define “medspa” and require public posting of the supervising physician’s information—an indicator of increasing scrutiny. Track SB 1638 / HB 625 (2025).

Telehealth

  • Florida permits telehealth under F.S. 456.47. Florida-licensed practitioners may provide telehealth to Florida patients; out-of-state clinicians must register under the Florida Telehealth Provider Registration Program. Delegation/prescribing must still follow scope, protocols, and standards of care.

Psychiatry & Behavioral Health

  • Collaboration follows the same prescriptive framework (protocols/scope). PDMP (E-FORCSE) checks are mandatory before prescribing or dispensing a controlled substance for patients ≥16 years (with narrow exceptions). DEA registration is required federally for controlled substances. Maintain clear documentation, including rationale, monitoring, and escalation/consultation plans per standard of care.

Weight Loss & Wellness

  • GLP-1s (semaglutide, tirzepatide) & other non-controlled agents. In Florida, semaglutide and tirzepatide must be prescribed by a licensed health care provider and filled through a state-licensed pharmacy or an FDA-registered outsourcing facility. State rules also place some limits on how these GLP-1 medications can be used for weight loss. Typically, patients must have a body mass index (BMI) of 30 or higher, provide informed consent, and return for follow-up visits at least every three months. As of May 2025, compounded versions are no longer permitted. This change follows the FDA’s decision to end enforcement discretion once the national supply became stable.
  • Phentermine (Schedule IV). Controlled-substance precautions apply: PDMP check required prior to prescribing/dispensing for patients ≥16, appropriate follow-up, and compliance with Chapter 893. (PAs and APRNs also must follow their profession-specific controlled-substance limits and training.) 
  • IV therapy services. In Florida, IV therapy is legally considered the practice of medicine. While state law does not explicitly define whether determining the need for IV therapy constitutes a medical diagnosis, in practice it is treated as medical judgment. For that reason, IV therapy should only be ordered or approved by a licensed practitioner, such as a physician, nurse practitioner, or physician assistant, following appropriate protocols. Any business offering IV services must appoint a physician as Medical Director, unless the owner is a licensed physician, to ensure proper oversight and compliance.

The Paperwork Florida Actually Asks to See

Entity & Governance

  • MSO/ownership docs: Florida does not require physician ownership of clinics. Under the Health Care Clinic Act, clinics must have a medical or clinic director with defined duties; ownership may be non-physician. Keep governance/MSO contracts, but “proof of physician-owned structure” is not a requirement. Read Online Sunshine.
  • MSO contract avoiding clinical interference: Wise risk control (corporate practice concerns), but this is best practice, not a specific statutory document regulators list.

Licenses & Registrations

  • MD/DO/APRN/PA/RN active licenses: Required. The medical/clinic director must ensure all practitioners hold current, unencumbered licenses. View Online Sunshine.
  • DEA registration (if prescribing/dispensing controlled substances): Required under federal/Florida law when applicable (not a clinic-wide requirement if no CS activity).
  • Telehealth registration (if applicable): Out-of-state providers must register; Florida telehealth standards apply to all telehealth care (evaluations, records, etc.).

Protocols / Collaborative Agreements

  • APRN protocols or autonomous registration: If the APRN is not registered for autonomous practice, a physician protocol and notice are required; autonomous APRNs (limited to primary care/midwifery) follow 464.0123. Visit The Florida Senate.
  • PA supervision / scope & notice: Physicians must delegate only within their own scope; certain duties are non-delegable; documentation belongs in the medical record. Notice requirements and delegation limits are set by statute/rule. Check the Florida Board of Medicine.
  • QA/communication/prescriptive-limits inside agreements: Prudent and commonly expected, but the exact headings aren’t prescribed. The notice and having an established protocol (where required) are what’s explicit. Visit Online Sunshine. 

Delegation Scope Matrix

  • Good idea (maps who can do what + training). Not named in statute, but supports compliance with delegation rules and survey questions. See Florida Board of Medicine 

Procedure Protocols & Consents

  • Standardized protocols and informed consents: Expected under standards of practice and medical records adequacy rules; specific mandated consent forms exist for some services (e.g., medical marijuana), but in general you must maintain adequate records and informed consent consistent with the standard of care. See list of regulations at Justia.

QA Documentation

  • Adverse incident reporting + keeping incident reports + corrective actions: Required for physician offices under FAC 64B8-9.001. Clinics must also ensure compliance with adverse-incident and office-surgery/recordkeeping requirements. Maintain incident logs and evidence of corrective action. Stay updated at Online Sunshine.
  • Chart reviews / staff meetings: Strong QA practice; certain specialty settings require them, but not universally specified for all clinics. Still helpful during inspections to demonstrate oversight. Read Online Sunshine

Marketing Approvals

  • Keep copies of ads/claims/titles: Florida’s Boards prohibit false, deceptive, or misleading ads and restrict board-certification claims. Retaining final, approved copies is best practice to prove compliance, though the rule doesn’t mandate a “marketing file.” More information at Justia.

Bonus items regulators often check under the Clinic Director statute

  • Records ownership & compliance with recordkeeping standards. Online Sunshine
  • Billing reviews to prevent unlawful/fraudulent charges (document your periodic reviews). Online Sunshine
  • Posting requirements (e.g., director signage; cash-price schedules for urgent care clinics; insurance-fraud reward sign). Online Sunshine

Avoid These Common FLorida Mistakes

  • Treating “medical director” as a title only while ceding control to an MSO. Even though Florida doesn’t have a blanket CPOM ban, physicians can be disciplined for aiding unlicensed practice and related conduct. Medical judgment and supervision must remain with the licensee, and unlicensed practice is a felony. 
  • Failing to update collaborative protocols after adding new services or staff. APRN and PA protocols must exist and reflect current practice; keep them current when roles/services change (best practice; expected by boards and inspectors). See APRN protocol guidance and PA supervision rules.
  • Missing chart reviews or failing to keep written QA documentation. Florida does not impose a universal chart-review/cosign requirement for PAs (statute expressly says a supervising physician “may not be required to review and cosign charts”), but QA/peer review is still expected by many payors/accreditors and for higher-risk settings (e.g., office surgery). Document QA policies and follow them. 
  • Allowing unlicensed/inadequately trained staff to operate lasers or injectables. Laser hair removal must be performed by a licensed electrologist under the direct supervision and responsibility of a physician (in-person or telehealth under specific conditions). Injectables are medical acts and must be performed within license scope with proper delegation/training. 
  • Using misleading advertising (e.g., “doctor-supervised” without documentation). The Board permits advertising only if not false, deceptive, or misleading. Keep supervision/credentials claims accurate and provable. 

Step-by-Step: Building a Defensible Florida Setup (30/60/90 Plan)

Days 1–30: Foundation

Days 1–30: Foundation

  • Confirm governance & contracts. Ensure the practice structure and MSO agreements preserve physician control over medical decisions; avoid arrangements that could be construed as aiding unlicensed practice.
  • Inventory licenses & registrations. Verify practitioner licenses; if delivering to Florida patients via telehealth, confirm F.S. 456.47 compliance (Florida license or out-of-state telehealth registration).
  • Draft/refresh protocols. Finalize APRN/PA practice and prescriptive protocols aligned to current services; keep copies ready for inspection.

Days 31–60: QA in Motion

  • Launch QA/peer review and log it. While routine PA chart cosign isn’t mandated, adopt risk-based chart reviews and QA meetings; document minutes/findings. Elevate cases per protocol.
  • Mock inspections. Test against Board rules (e.g., office-surgery standard of care if applicable), equipment maintenance to manufacturer specs, emergency readiness.
  • Marketing scrub. Review website/ads for title use, claims (“doctor-supervised”), specialties, and disclosures under the advertising rule.

Days 61–90: Harden & Scale

  • Competency & renewals. Finalize competency checklists for injectables/lasers/IV therapy; set renewal and CME reminders (including controlled-substance CME where applicable).
  • Telehealth records. Ensure remote access for supervision and audits; retain records consistent with F.S. 456.47 and your protocols.
  • Change control. Add services only after updating protocols, training, device logs, and marketing materials; for lasers, confirm electrologist + physician-supervision requirements are met.

FAQs

Can a non-physician own a medical clinic in Florida?

Yes, but they cannot practice medicine or control clinical decisions. Clinical services must flow through a physician-owned entity, while the MSO handles business functions.

Only Florida-licensed MDs/DOs in good standing. Specialty matters less than demonstrated competence and willingness to oversee delegation and QA.

Authorized/excluded drugs, scope of practice, communication methods, consultation/referral rules, QA measures, and annual review requirements.

They are considered medical procedures requiring physician oversight and protocols. There is no standalone TDLR-like agency in Florida.

Certain APRNs may practice independently under the 2020 law if eligibility requirements are met. Otherwise, prescribing must follow written protocols.

How Medical Director Co. Fits into Florida Compliance

Medical Director Co. provides more than “check-the-box” oversight. We offer:

  • Florida-licensed physicians with experience in medspas, telehealth, weight management, and behavioral health.
  • Turnkey protocols and collaborative agreements tailored to Florida’s requirements.
  • QA frameworks with chart-review templates, meeting agendas, and audit-ready documentation.
  • Device compliance packages including laser/energy device protocols and staff competency checklists.
  • MSO structure reviews to ensure physician control complies with CPOM.
  • Legislative updates monitoring Florida rule changes and providing proactive compliance adjustments.
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