Medical Director Co. main logo
Hire Medical Director
(214) 227-9886
Medical Director Co. main logo
Hire Medical Director
(214) 227-9886

Florida Medical Director Requirements for Medspas (2025 Compliance Checklist)

Florida Medical Director Requirements for Medspas (2025 Compliance Checklist)

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

  • Clinical control: Non-physicians may own clinics, but a Florida-licensed MD/DO must be medical/clinic director with authority over protocols, supervision, and records. MSOs handle business only.
  • Medical director duties: Must ensure compliance, licensure checks, recordkeeping, and QA. Define availability, supervision, and escalation in policy/contract.
  • Delegation: Physicians may delegate medical acts (injectables, devices) only to licensed, trained staff within scope. Use written protocols and competency records.
  • APRNs:
    • Non-autonomous: require written physician protocol.
    • Autonomous (§464.0123): may practice in primary care only; aesthetics/devices still need physician oversight.
  • PAs: Must practice under a physician with a written supervision agreement (§458.347). Prescribing limited by formulary rules.
  • Telehealth: Florida licensees may practice; out-of-state clinicians must register. Same standard of care, records, and prescribing rules apply.
  • Controlled substances: DEA registration required; E-FORCSE PDMP checks mandatory for controlled prescribing (≥16).
  • Lasers/devices: Medical procedures in Florida. Laser hair removal only by licensed electrologists with training under physician supervision. No facility license required.
  • QA & documentation: No set chart-review quota, but directors must maintain records, QA meeting minutes, incident logs, and updated protocols/consents.
  • Common structure: Physician-directed clinical entity paired with MSO for nonclinical operations, preserving physician control and avoiding fee-splitting.

The Florida Quick Compliance Checklist

Entity & Ownership Structure

  • CPOM in Florida: Florida does not have an absolute “physician-only” ownership rule. Under the Health Care Clinic Act, non-physicians may own a clinic, but the clinic must appoint a medical director (MD/DO) who is legally responsible for compliance.
  • MSO contracts: Best practice is to keep MSO functions (marketing, staffing, nonclinical operations) separate and not allow them to intrude on clinical decision-making.
  • Documentation: Keep governance agreements and MSO contracts on file; regulators look for evidence that the physician retains control over protocols, records, and treatment decisions.

Medical Director Credentials

  • License: Must be a Florida-licensed MD or DO in good standing.
  • Duties: The medical director is responsible for ensuring the clinic complies with statutes, rules, and recordkeeping requirements (see F.S. §400.9935 under the Health Care Clinic Act).
  • Policies: Availability for supervision, coverage, and QA expectations should be defined in internal policies and contracts.

Delegation & Prescriptive Authority

APRNs

  • Protocols: If not registered for autonomous practice, APRNs must work under a written protocol with a physician (F.S. §464.012). Protocols cover scope, drugs/devices, consultation/escalation.
  • Autonomous practice: APRNs who qualify under F.S. §464.0123 (from HB 607, 2020) may practice independently in primary care, but still need written protocols for medical acts such as aesthetics/lasers.
  • Board rules: APRN practice standards appear in FAC 64B9-4.

Physician Assistants (PAs)

  • Statute: PAs must practice under a supervising physician per F.S. §458.347 (MDs) or §459.022 (DOs).
  • Agreements: Written supervision/delegation agreement is required, defining duties, prescribing authority, and chart-review or availability standards.
  • Formulary limits: PAs may not prescribe drugs prohibited under the PA formulary (FAC 64B8-30.008).

Controlled Substances (All Prescribers)

  • PDMP use: Florida’s PDMP is E-FORCSE®, and prescribers must consult it before prescribing or dispensing a controlled substance for patients ≥16 (with narrow exceptions) (F.S. §893.055(8)).
  • DEA: Federal DEA registration is required to prescribe controlled substances.

Scope of Practice, Protocols & Supervision

Supervision Limits

Physicians may supervise up to 10 PAs under F.S. §458.347. APRNs have no numeric cap, but must follow either a physician protocol under F.S. §464.012 or autonomous practice requirements under F.S. §464.0123 and applicable Board of Nursing rules.
 🔗 Florida Statutes – §458.347 Physician Assistants

Scope of Practice Mapping (Best Practice)

Maintain a written matrix of who may do what (MD/DO, APRN—autonomous vs. protocol, PA, RN, electrologist/laser operator) tied to statutes and delegation rules. This is not mandated in statute but supports compliance with Title XXXII, Professions & Occupations.
 🔗 Florida Statutes – Title XXXII Professions & Occupations

Informed Consent & Protocols

Protocols must comply with statutory authority in Ch. 456, 458, 459, 464, 893, F.S. and Board rules under 64B8 (Medicine) and 64B9 (Nursing). Procedure-specific consents (Botox®, microneedling, IV therapy, etc.) are not listed in statute but are consistent with the standard of care and required medical records adequacy.
 🔗 Florida Board of Medicine – Statutes & Rules

Laser / Energy-Device Compliance

Florida requires that laser and light-based hair removal be performed by a licensed electrologist with proper training, under the direct supervision and responsibility of a physician, per FAC 64B8-56.002. There is no separate facility license like in Texas.
 🔗 Florida Department of Health – Electrolysis / Laser Hair Removal

Marketing & Representation

Florida law prohibits false, deceptive, or misleading advertising. Titles must reflect actual licensure (e.g., no use of “doctor” by non-physicians). This is enforced under F.S. §456.072(1)(a).
 🔗 Florida Statutes – §456.072 Disciplinary Grounds

Best Practice with Statutory Backing

Florida does not mandate universal chart-review quotas, but the medical director/clinic director must ensure adequate records and compliance with adverse incident reporting under FAC 64B8-9.001 and discipline standards in F.S. §458.331. Document chart reviews, adverse events, device/medication logs, and QA meetings.
 🔗 Florida Statutes – §458.331 Grounds for Disciplinary Action

Recordkeeping & Access

All clinics must maintain patient records in compliance with F.S. §456.057, including protocols, supervision documents, training logs, and incident reports. Records must be accessible to the medical/clinic director and available to regulators.
 🔗 Florida Statutes – §456.057 Ownership & Control of Patient Records

Statutory Duty Framed as Best Practice

Florida does not use the term “change management” in rules. However, under F.S. §400.9935, the medical/clinic director is responsible for ensuring compliance with all statutes and rules whenever services are provided. When adding new modalities (e.g., RF microneedling), directors should:

  • Update protocols and consents.
  • Re-train and document staff competency.
  • Maintain device logs and QA documentation.
  • Ensure changes are reflected in APRN/PA protocols and delegation agreements.

 🔗 Florida Statutes – §400.9935 Medical Director Responsibilities

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

Who can be a Medical Director in Florida?

A Florida-licensed MD or DO in good standing; the role (for clinics licensed under the Health Care Clinic Act) and its duties are spelled out in F.S. §400.9935. Specialty is not prescribed by statute; competence/oversight responsibilities are.

Why a “Non-Physician Medical Director” isn’t a thing in Florida?

Florida allows non-physician ownership of clinics, but clinical control must remain with licensed practitioners. A clinic must appoint a physician medical/clinic director with statutory compliance duties (e.g., licensure verification, records, contracts). Unlicensed practice is prohibited and physicians can be disciplined for aiding unlicensed practice. Use this framing instead of “physician-owned entity.” Medical/clinic director duties: F.S. §400.9935 Unlicensed practice prohibition: F.S. §456.065 Physician discipline (incl. aiding unlicensed practice): F.S. §458.331

Collaboration & Delegation: APRNs and PAs in a Florida Medspa

Prescriptive Authority (APRNs)

  • Non-autonomous APRNs: Must practice under a written protocol with a supervising physician per F.S. §464.012. The protocol defines scope, authorized drugs/devices, consultation triggers, and procedures for escalation.
  • Autonomous APRNs: Under F.S. §464.0123 (HB 607, 2020), APRNs may qualify for autonomous practice in primary care, family medicine, general pediatrics, internal medicine, or midwifery. This authority does not extend to medical spa services (injectables, laser/energy devices, or aesthetics). For those services, physician-approved protocols remain the standard of care and are expected by the Board of Nursing and Board of Medicine.

Physician Assistants (PAs)

  • Supervision & protocols: PAs must practice under physician supervision and a written agreement under F.S. §458.347. This agreement sets duties, prescriptive privileges, and supervision parameters.
  • Chart review: Florida law does not impose a mandatory percentage or quota for chart reviews. The supervising physician determines the appropriate review process, but written expectations are strongly advised for compliance and QA. Also read Florida Board of Medicine – PA Prescribing Guidance.

Day-to-Day Delegation

  • Delegation authority: Physicians may delegate medical acts if they are within the delegate’s scope of license, training, and competence. Delegation must also be within the supervising physician’s own scope.
  • Written protocols & QA: Florida law requires protocols and clear supervision records. While not explicitly mandated in rule, best practice is to tie device and procedure privileges to named staff with documented training, competency checklists, and renewal dates. This demonstrates compliance with the physician/clinic director’s statutory responsibility for quality assurance and patient safety.

🔗 FAC 64B8-30.012 – Tasks Delegated to PAs
🔗 Florida Statutes – Title XXXII Professions & Occupations.

Practical Tips: That Survive Florida: Audits

  • Don’t over-promise QA. Pick a chart-review cadence and meeting frequency you can sustain; keep sign-in sheets and written findings/remediations.
  • Index your agreements. Maintain a roster for APRNs and PAs (start/renewal dates, scope, alternates).
  • Competency = protocol-tied. For each injector/device operator, keep a signed checklist tied to the procedure packet (including ocular protection for lasers and hyaluronidase use for vascular occlusion).
  • Update fast. Add new modalities (RF microneedling, PDO threads, GLP-1 programs) to protocols before launch, then train and document.
  • E-FORCSE discipline. Save PDMP query confirmations for controlled prescriptions: E-FORCSE login.

Injectables and Device Procedures: What “Legal” Looks Like in Practice

Florida Medical Director Requirements-min

Injectables (e.g., Botox®, Fillers, Biostimulators)

  • Considered medical procedures. Your packets should cover assessment, dose ranges, lot/chain-of-custody documentation, photography policy, aftercare, and event algorithms (e.g., hyaluronidase dosing, anaphylaxis, vascular occlusion).
  • Staff must have documented training and competency; define physician availability and escalation.

Lasers, IPL, RF, and Other Energy Devices

  • Treated as medical devices. Operators should be MD/DO/NP/PA/RN with device-specific training under physician-approved protocols.
  • Keep laser safety training, eye-protection policies, test-spot documentation, parameter rationale, and maintenance logs.
  • Rule index for physicians: 64B8, F.A.C

Microneedling, Chemical Peels, Threads, and IV Therapy

  • Build procedure-specific checklists and consent forms.
  • For IV therapy, keep compatibility charts, crash-cart checklists, and anaphylaxis drill logs.

Telehealth (Virtual Aesthetics Triage, Primary Care, Psych, Weight Management)

  • Florida licensees: Florida-licensed MDs, DOs, APRNs, and PAs may provide telehealth to Florida patients without additional registration (F.S. §456.47).
  • Out-of-state clinicians: Must register with the Florida Telehealth Provider Registration Program before treating Florida patients.
  • Standards: Telehealth visits must meet the same standard of care as in-person visits, including recordkeeping (§456.057), patient identity verification, and informed consent.
  • Prescribing: E-prescribing (§456.42) and PDMP checks (§893.055, E-FORCSE) apply in telehealth exactly as they do in person.

🔗Florida Telehealth Provider Registration Program

The Paperwork Florida Actually Asks to See

Entity Documents

  • Clinics must designate a Florida-licensed MD/DO as medical/clinic director (§400.9935).
  • Ownership may be physician or non-physician; MSO agreements must not intrude on clinical decisions.

🔗 F.S. §400.9935 – Clinic Responsibilities (Online Sunshine)

Licenses & Credentials

  • Active licenses for MD/DO, APRN, PA, RN.
  • DEA registration if controlled substances are prescribed.
  • Telehealth registration for out-of-state clinicians.

🔗 F.S. §456.47 – Telehealth (Online Sunshine)

APRN/PA Agreements

  • APRNs: written physician protocol (§464.012) or autonomous registration (§464.0123).
  • PAs: written supervision agreement required (§458.347).

🔗 Florida Board of Nursing – APRN Protocols & Autonomous Practice

Delegation & Scope Matrix (Best Practice)

  • Written matrix of who performs which procedure; supports compliance with delegation rules.

🔗 Florida Statutes – Title XXXII Professions & Occupations

Protocols & Consents

  • Maintain procedure-specific protocols (injectables, lasers/IPL/RF, microneedling, IV therapy).
  • Must meet standards of practice and records adequacy.

🔗 FAC 64B8-9.001 – Standards of Practice for Medical Doctors 

Device Folder

  • Keep purchase orders, vendor training, competency files, safety policies, test-spot logs, and maintenance records.
  • Laser hair removal only by electrologists with training, under physician supervision.

🔗 FAC 64B8-56.002 – Supervision of Electrologists

QA Trail (Best Practice with Statutory Anchor)

  • Document chart reviews, QA meetings, incident logs, and corrective actions.
  • Adverse incident reporting is required.

🔗 F.S. §458.331 – Grounds for Disciplinary Action (Online Sunshine)

Prescribing Compliance

  • PDMP checks required for controlled substances (§893.055).
  • E-prescribing required with limited exceptions (§456.42).

🔗 E-FORCSE – Florida PDMP Program

Marketing Approvals

  • Ads must not be false, deceptive, or misleading (§456.072).
  • Internal sign-offs for ad compliance are best practice.

🔗 F.S. §456.072 – Disciplinary Grounds (Online Sunshine)

Common Florida Pitfalls and How to Avoid Them

“Medical Director” in Title Only

If the MSO dictates protocols or staffing of clinicians, that risks aiding unlicensed practice (§456.065, F.S.) and can trigger discipline under §458.331, F.S. Clinical control must remain with the licensed physician designated as medical/clinic director under §400.9935, F.S.
 🔗 F.S. §400.9935 – Clinic Responsibilities (Online Sunshine)

Stale Protocols

APRN protocols (§464.012, F.S.) and PA agreements (§458.347, F.S.) must accurately reflect services offered. While not bound to “one week,” protocols must be updated promptly and be available to the Board within 3 business days upon request.
 🔗 F.S. §464.012 – Advanced Practice Registered Nurses (Online Sunshine)

Under-Documented QA

The medical/clinic director is responsible for ensuring QA under §400.9935, F.S. and standards of practice (FAC 64B8-9.001). Missing minutes, chart reviews, or incident logs can be cited as inadequate supervision.
 🔗 FAC 64B8-9.001 – Standards of Practice for Medical Doctors

Improper Device Delegation

Laser hair removal may only be performed by licensed electrologists with laser training, under the direct supervision and responsibility of a physician (FAC 64B8-56.002). Injectables are medical procedures and cannot be performed by unlicensed staff.
 🔗 FAC 64B8-56.002 – Supervision of Electrologists

PDMP Gaps

Prescribers must check Florida’s PDMP (E-FORCSE) before prescribing or dispensing controlled substances for patients ≥16, unless an exception applies (§893.055, F.S.). Missing or poorly documented checks are a common source of discipline.
 🔗 F.S. §893.055 – Prescription Drug Monitoring Program (Online Sunshine)

Templates & Operational Playbooks (Implement This Week)

APRN/PA Agreement Pack

  • APRNs: Written physician protocol (§464.012) unless autonomous under §464.0123.
  • PAs: Written supervision agreement required (§458.347).

🔗 F.S. §458.347 – Physician Assistants (Online Sunshine)

Delegation & Scope Matrix (Best Practice)

Maintain a matrix of who may perform each procedure, required training, supervision level, and renewal dates. This isn’t mandated in statute, but it aligns with delegation and scope rules under Title XXXII.
 🔗 Florida Statutes – Title XXXII Professions & Occupations

Monthly QA Pack (Best Practice with Statutory Support)

Keep agendas, sign-in sheets, chart-review logs, incident reports, and remediation notes. While not mandated in all settings, this supports the medical director’s statutory QA duties (§400.9935) and adverse incident reporting rule (FAC 64B8-9.001).
 🔗 F.S. §400.9935 – Clinic Responsibilities (Online Sunshine)

Device Safety Binder

Maintain laser/IPL protocols, operator training certificates, eye-protection SOPs, test-spot logs, and maintenance records. Florida specifically regulates laser hair removal under FAC 64B8-56.002.
 🔗 FAC 64B8-56.002 – Supervision of Electrologists

Marketing Compliance Checklist

Advertising must not be false, deceptive, or misleading under §456.072(1)(a). Title usage and “doctor-supervised” claims must reflect actual licensure and delegation. Internal sign-offs are a best practice.
 🔗 F.S. §456.072 – Disciplinary Grounds (Online Sunshine)

Building a Defensible Florida Structure (the Physician Entity + MSO Model)

Florida’s safest medspa setup keeps clinical control with the licensed physician (through a physician-owned entity or as the designated medical/clinic director under the Health Care Clinic Act) while business functions remain in the MSO.

Your MSO agreement should:

  • Clearly state that medical judgment and hiring/supervision of clinicians remain with the physician.
  • Avoid revenue-sharing terms that could be construed as fee-splitting for patient referrals.
  • Permit audits and policy updates driven by the medical director (e.g., E-FORCSE workflows, protocol changes, device training).

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

Days 1–30: Foundation & Paperwork

  • Confirm the structure clearly places medical authority with the physician; review the MSO contract.
  • Inventory licenses and DEA registrations; enroll prescribers in E-FORCSE.
  • Draft/update APRN protocols and PA supervision documents.
  • Compile device protocols and build your scope matrix.

Days 31–60: QA in Action

  • Hold your first QA meeting; set a sustainable chart-review process by service line and document findings/remediations.
  • Run a mock inspection against Board of Medicine expectations and your APRN/PA documentation.
  • Scrub website/ads to match licensure, supervision, and telehealth statements.

Days 61–90: Risk Hardening & Growth

  • Complete direct-observation sign-offs for injectors and device operators; set automated renewal reminders.
  • Validate remote record access for the medical director to respond to board requests.
  • For each new service: training plan → protocol update → competency sign-offs → marketing review → launch.

FAQs

Can a non-physician own my Florida medspa?

Yes, but not the practice of medicine. Use a physician-owned professional entity for clinical services and an MSO for business operations. The MSO must not control medical judgment.

If not registered for autonomous practice under §464.0123, yes—APRNs must work under written protocols with a physician. Even for autonomous APRNs, strong procedure/device protocols are best practice in aesthetics.

Under §458.347, F.S., with a written protocol/supervision agreement. The supervising physician must be readily available; chart review and duties are set in writing.

Yes, if you meet Florida standards of care, documentation, and informed consent. Out-of-state practitioners must register.

No separate laser facility license like Texas’s TDLR. Device use is medical and falls under physician protocols and board rules.

How Medical Director Co. Supports Florida Medspas

Running a compliant medspa in Florida isn’t about checking boxes, it’s about documented control of medicine plus repeatable QA. Medical Director Co. provides:

  • Florida-licensed physicians experienced in aesthetics, telehealth, psychiatry, and weight management.
  • Turnkey APRN protocols and PA supervision agreements built with Florida-specific requirements (scope, prescribing, communication, escalation, QA) and workflows to keep them current.
  • QA systems you can actually maintain – chart-review processes, meeting agendas, incident logs, and audit-ready documentation.
  • Laser/device compliance support – protocol templates, operator competency checklists, eye-safety policies, and maintenance logs.
  • Structure alignment – we review MSO agreements to confirm physicians retain clinical authority, consistent with the Health Care Clinic Act and Florida’s prohibition on unlicensed practice.
  • Legislative and rule monitoring – track Board of Medicine and Board of Nursing guidance, plus telehealth and prescribing updates, and tell you what to adjust before it becomes an issue.
Find a Florida-Licensed Medical Director for Your Clinic Today

Find a Florida Medical Director with Medical Director Co.

We place licensed medical directors and build compliance frameworks for medspas across Florida.
Miami
Orlando
Tampa
Jacksonville
Fort Lauderdale
St. Petersburg
West Palm Beach
Tallahassee

Florida Resources You Should Bookmark

Scroll to Top

Same-Day Medical Director Match

Same-Day Medical Director Match

Fast. Easy. Compliant.

Trusted by 300+ clinics nationwide

Same-day
intro call

No setup fees ·
Cancel anytime

All compliance documents included

  • Same-day intro call
  • No setup fees · Cancel anytime
  • All compliance documents included

Save $200 on your first month — Limited Time

Save $200 on your first month

Limited Time

5/5 Rating from 300+ Clinics

Nationwide Medical Directors • Fully Compliant • Easy Onboarding