Disclaimer: This guide is for educational purposes only and does not constitute legal or medical advice. Laws and interpretations may change. Always verify directly with the Georgia Composite Medical Board, the Georgia Board of Nursing, and the Georgia Board of Pharmacy, and consult qualified legal counsel before making compliance decisions.
Executive Summary
- Physician Control: Georgia requires all medical services, including aesthetic and wellness treatments, to be delivered through a physician-owned or physician-controlled entity. Non-physician MSOs may manage business functions but cannot influence medical judgment or patient care.
- Medical Director Oversight: The medical director must be a Georgia-licensed MD or DO with active, unrestricted status. They are responsible for all delegated acts, chart reviews, QA meetings, and protocol supervision.
- Delegation & Prescriptive Authority: Nurse Practitioners (APRNs) must practice under a filed Nurse Protocol Agreement (NPA), and Physician Assistants (PAs) under a Delegation Agreement (DA), both compliant with O.C.G.A. §§ 43-34-25 and 43-34-103. Agreements must define duties, prescribing limits, and chart review.
- Scope & Supervision: Procedures such as injectables, IV therapy, and laser treatments require physician delegation and written protocols. RNs may perform tasks under physician orders but cannot independently diagnose or prescribe.
- Laser & Device Rules: Governed by the Georgia Cosmetic Laser Services Act (O.C.G.A. §§ 43-34-240–248). Only licensed or certified practitioners may operate lasers or IPL devices. Estheticians cannot legally perform injectables or laser treatments.
- Quality Assurance & Documentation: Clinics must maintain chart-review logs, QA meeting minutes, competency files, and training records. QA programs must show active physician involvement and timely remediation.
- Telehealth Compliance: Telemedicine requires a Georgia license and adherence to GCMB Rule 360-3-.07. The same standard of care applies as in-person care. Controlled-substance prescribing requires DEA registration and PDMP documentation.
- Advertising & Representation: Marketing must truthfully reflect credentials and supervision. Misleading claims or use of the title “Doctor” by non-physicians violate O.C.G.A. § 43-34-8 and GCMB Rule 360-3-.02 on unprofessional conduct.
- Inspection Readiness: Keep a compliance binder with entity filings, NPAs/DAs, GCMB and DEA licenses, QA documentation, device safety records, and approved marketing materials accessible within three business days upon request.
- Common Pitfalls: Frequent Georgia violations include missing or unfiled NPAs/DAs, unauthorized staff performing medical procedures, incomplete QA documentation, misleading advertising, and MSO contracts that intrude on clinical control.
- Implementation Roadmap: (Days 1–30) Establish structure and file agreements. (Days 31–60) Launch QA, perform a mock audit, review advertising. (Days 61–90) Verify competencies, update protocols, and strengthen telehealth and PDMP systems.
The Georgia Quick Compliance Checklist (2025)
Entity & Ownership Structure
Medical services must be delivered through a physician-owned or physician-controlled professional entity, preserving physician authority over all clinical decisions.
Non-physicians may participate via a Management Services Organization (MSO) for administrative functions (billing, HR, marketing), but MSOs cannot influence medical judgment, patient care, or clinical profits.
Via Georgia Composite Medical Board – Rules & Laws
Medical Director Credentials
The Medical Director must hold an active, unrestricted Georgia medical license (MD/DO) issued by the GCMB.
The director must maintain oversight of all delegated acts, including chart reviews, QA meetings, and supervision of injectables, lasers, and IV procedures.
Adequate, documented training and continuing education in aesthetic or procedural medicine is recommended for all supervising physicians.
Delegation & Prescriptive Authority
Nurse Practitioners (APRNs):
Must practice under a written Nurse Protocol Agreement (NPA) with a delegating physician, as required by O.C.G.A. §43-34-25 and GCMB Rule 360-32.
The NPA defines scope of practice, prescriptive limits, chart review frequency, and communication procedures.
The signed agreement must be filed with the GCMB and reviewed annually or upon any change in scope.
Physician Assistants (PAs):
Must work under a Delegation Agreement (Job Description) approved by the supervising physician, as required by O.C.G.A. §43-34-103.
The agreement must specify delegated duties, supervision structure, and prescribing parameters, including any controlled substances.
The document must be retained for inspection by the GCMB and reviewed periodically.
Registered Nurses (RNs):
May perform procedures under physician orders but cannot independently diagnose, treat, or prescribe.
Delegated tasks must fall within the RN’s training, competency, and Board of Nursing scope of practice.
Scope of Practice Mapping
Maintain a written delegation matrix listing every procedure (e.g., injectables, IV therapy, microneedling, laser treatments).
Identify who is authorized to perform each task, under what supervision level (direct, indirect, or tele-supervision).
Cross-reference each duty to relevant Georgia statutes, NPAs, or PA Delegation Agreements on file with the GCMB.
Informed Consent & Clinical Protocols
Develop procedure-specific protocol packets for all aesthetic and medical treatments (e.g., injectables, lasers, IV therapy, peels, threads, microneedling).
Each packet must include:
- Signed informed consent and patient education materials.
- Emergency procedures for adverse events such as vascular occlusion, anaphylaxis, or infection.
Protocols should be reviewed annually by the supervising physician and updated as standards evolve.
Laser & Energy Device Compliance
Laser use is governed by the Georgia Cosmetic Laser Services Act (O.C.G.A. §§43-34-240 through 43-34-248).
Only licensed physicians or certified laser practitioners (Level 1 or 2) may operate laser or intense pulsed light (IPL) devices.
Estheticians may not legally perform injectables, IPL, or laser procedures.
All devices must have documented safety training, eyewear compliance, maintenance records, and supervision by a consulting physician.
Marketing & Representation
Advertising must accurately represent credentials and who performs each procedure.
Non-physicians may not use the title “doctor” or make claims implying physician status.
Avoid false or misleading claims such as “guaranteed results” or “permanent outcomes.”
Misrepresentation violates O.C.G.A. §43-34-8 and GCMB Rule 360-3-.02 on unprofessional conduct.
Quality Assurance (QA) & Supervision
Conduct regular chart reviews consistent with delegation agreements or NPAs, and document physician sign-off.
Hold monthly or quarterly QA meetings to review cases, complications, and protocol adherence.
Maintain training logs, competency assessments, and staff certifications for all delegated services.
Retain all QA documentation for inspection by the GCMB or upon request by other regulatory agencies.
The Legal Frame: CPOM + Who Can Be a “Medical Director”?
Who Can Be a Medical Director in Georgia
Corporate Practice of Medicine (CPOM)
Delegation & Prescriptive Authority in Georgia Medspas
Nurse Practitioners (APRNs)
- Must practice under a written Nurse Protocol Agreement (NPA) with a delegating physician, as required by O.C.G.A. §43-34-25 and GCMB Rule 360-32.
- The NPA must define authorized medical acts, prescriptive authority, QA and chart-review standards, and communication procedures.
- The signed agreement must be filed with the Georgia Composite Medical Board (GCMB) and reviewed at least annually or whenever the scope of practice changes.
Physician Assistants (PAs)
- Must practice under a Delegation Agreement (Job Description) approved by a supervising physician, per O.C.G.A. §43-34-103 and GCMB PA rules.
- The agreement must specify the scope of delegated duties, prescriptive limits, supervision structure, and physician availability.
- It must be kept on file and available for inspection by the GCMB and reviewed regularly for accuracy and compliance.
Registered Nurses (RNs)
- May administer medications and aesthetic treatments only under a physician’s order or established protocol, consistent with the Georgia Nurse Practice Act and Board of Nursing standards.
- RNs may not diagnose, prescribe, or independently select treatments; they may only carry out tasks within their licensure and physician-approved delegation.
Practical Tips That Survive Georgia Audits
- File and retain delegation agreements properly:
File all Nurse Protocol Agreements (NPAs) and Physician Assistant Delegation Agreements (DAs) promptly with the Georgia Composite Medical Board (GCMB) and keep signed copies onsite and electronically accessible for inspection. - Restrict procedures to licensed medical personnel:
Only licensed physicians, PAs, APRNs, or RNs may perform medical or aesthetic procedures. Estheticians may not inject, diagnose, or operate medical lasers or IPL devices, per the Georgia Cosmetic Laser Services Act (O.C.G.A. §§ 43-34-240–248). - Maintain complete QA documentation:
Keep chart-review logs, QA meeting minutes, and competency checklists signed by the supervising physician. Missing or outdated QA records are among the most frequent GCMB audit findings. - Update and re-file protocols when expanding services:
Revise and re-sign all NPAs and DAs before offering any new treatments or devices to ensure delegation and supervision align with GCMB scope-of-practice rules. - Market truthfully and within licensure limits:
Advertising must accurately reflect credentials and delegation. Avoid implying physician supervision or medical authority if none exists; false or misleading claims violate O.C.G.A. § 43-34-8 and GCMB Rule 360-3-.02 on unprofessional conduct.
Injectables & Device Procedures in Georgia
Injectables (Botox®, Fillers, Threads)
- Considered medical procedures under Georgia law and require physician oversight and delegation.
- May be performed by licensed NPs, PAs, or RNs only when authorized in a written Nurse Protocol Agreement (NPA) or Delegation Agreement (DA) approved by a supervising physician.
- Supervising physicians must ensure patient assessment, informed consent, lot-number documentation, and adverse-event response protocols (e.g., vascular occlusion, infection).
- All delegated injectors must have documented competency and ongoing training records maintained for inspection.
Lasers, IPL, and RF Devices
- Governed by the Georgia Cosmetic Laser Services Act (O.C.G.A. §§43-34-240 – 248) and GCMB Rule 360-35.
- Only licensed physicians, NPs, PAs, or RNs may operate or be delegated to operate medical-grade laser, IPL, or radiofrequency devices.
- Non-medical personnel, including estheticians, may not use lasers, IPL, or similar energy devices.
- All operators must have certified laser-safety training, and practices must maintain device maintenance, calibration, and safety logs signed by the supervising physician.
IV Therapy & Wellness Treatments
- Licensure Requirement:
Telehealth and telemedicine services are permitted in Georgia only when the provider holds an active Georgia medical license (MD or DO). Out-of-state physicians must be licensed in Georgia to diagnose, treat, or prescribe for patients located in the state. - Standard of Care:
The same standard of care applies as for in-person visits. Providers must establish a valid physician–patient relationship, perform an adequate evaluation, and document history, assessment, and treatment consistent with GCMB Rule 360-3-.07. - Prescribing Restrictions:
Prescribing medications, including controlled substances, via telehealth is allowed only after a proper exam and within the prescriber’s authority.
Controlled substances require a valid DEA registration and compliance with Georgia’s PDMP (Rule 360-38) and federal teleprescribing rules. - Documentation and Security:
All telehealth encounters must include informed consent, secure data transmission, and complete clinical documentation. Providers must ensure privacy consistent with HIPAA and GCMB supervision standards.
IV Therapy & Wellness Treatments
- IV hydration and wellness infusions are considered medical treatments requiring physician-approved written protocols and qualified staff under delegation.
- Treatments must be performed by a licensed physician, NP, PA, or RN acting under a valid NPA or DA.
- Maintain emergency supplies, including crash kit, epinephrine, and adverse-reaction management procedures, as required for delegated medical procedures.
- Document each infusion with patient assessment, medication verification, and post-procedure monitoring.
Paperwork Georgia Regulators Expect
Nurse Protocol Agreements (NPAs)
- Signed and filed with the Georgia Composite Medical Board per O.C.G.A. §43-34-25.
- Define scope, prescribing limits, and QA/chart-review rules.
- Review and re-sign annually or when services expand.
Physician Assistant Delegation Agreements (DAs)
- Written agreement outlining duties, supervision, and prescribing authority per O.C.G.A. §43-34-103.
- Maintain copies for GCMB inspection.
- Update with any scope or staffing changes.
Licenses & DEA Registrations
- Active GCMB licenses for all physicians, PAs, and APRNs.
- Current DEA registration for controlled-substance prescribers.
- Keep renewal confirmations and verification records.
Quality Assurance (QA) Documentation
- Chart-review logs and QA meeting minutes signed by the supervising physician.
- Competency checklists and incident-tracking forms.
- Store QA records per GCMB retention guidance.
Device & Procedure Training Certificates
- Proof of training and laser-safety certification under GCMB Rule 360-35.
- Maintain maintenance and calibration logs for all devices.
- Keep operator credentials readily accessible.
Marketing & Advertising Compliance Files
- Copies of approved marketing materials showing accurate titles and credentials.
- Avoid misleading terms like “Doctor” for non-physicians.
- Follow GCMB Rule 360-3-.02 and O.C.G.A. §43-34-8 on truthful advertising.
Common Georgia Mistakes
- Not filing required Nurse Protocol or Delegation Agreements
APRNs and PAs must have current, signed Nurse Protocol Agreements (NPAs) or Delegation Agreements (DAs) filed with or available for inspection by the Georgia Composite Medical Board (GCMB) per O.C.G.A. §§ 43-34-25 and 43-34-103. - Allowing estheticians to perform medical procedures
Only licensed physicians, PAs, APRNs, or RNs may inject, diagnose, or operate medical lasers.
Estheticians cannot legally perform injectables, IPL, or laser services under the Georgia Cosmetic Laser Services Act (O.C.G.A. §§ 43-34-240–248). - Missing or incomplete QA documentation
Failing to maintain chart-review logs, QA meeting records, and competency documentation violates GCMB supervision standards and is among the most common deficiencies found in audits. - Advertising that implies non-physician control or medical authority
Marketing that suggests non-physicians supervise or control medical services can violate GCMB Rule 360-3-.02 and O.C.G.A. § 43-34-8 prohibiting false or misleading advertising and unprofessional conduct. - MSO contracts that interfere with medical judgment
Management Services Organizations (MSOs) may handle business operations but may not influence treatment protocols, prescriptive authority, or clinical staffing decisions, consistent with Georgia’s Corporate Practice of Medicine (CPOM) restrictions.
Days 61–90: Verify Competency & Strengthen Operations
- Complete direct-observation competency sign-offs for all delegated personnel performing injectables, IV therapy, or laser procedures, maintaining signed training records.
- Expand or add new services only after updating NPAs, DAs, and clinical protocols, and documenting physician approval.
- Establish redundancy for telehealth workflows, PDMP checks, and QA documentation to ensure inspection readiness under GCMB Rule 360-3-.07 (Telemedicine) and Rule 360-38 (Controlled Substances).
FAQs
When a complaint, audit, or payer review happens, you’ll be asked for documents, not good intentions. Keep a clean “compliance binder” (digital is fine) with:
Can a non-physician own a Georgia medspa?
Can estheticians do Botox® or laser treatments?
Do NP and PA agreements have to be filed?
Yes. Both must be filed and approved by the Georgia Composite Medical Board.
Is telehealth permitted in Georgia?
How Medical Director Co. Supports Georgia Medspas
Medical Director Co. services provide Georgia medspas with physician-led compliance, supervision, and documentation frameworks that meet Georgia Composite Medical Board (GCMB) standards. We help practices operate safely, legally, and efficiently under physician control and delegation.
- Georgia-licensed physicians for compliant medical directorship and supervision.
- Turnkey Nurse Protocol Agreements (NPAs) and Physician Assistant Delegation Agreements (DAs) drafted to satisfy O.C.G.A. §§ 43-34-25 and 43-34-103.
- Quality Assurance (QA) frameworks with chart-review logs, competency tracking, and meeting templates aligned with GCMB oversight rules.
- Device protocols and injectables oversight designed around the Georgia Cosmetic Laser Services Act (O.C.G.A. §§ 43-34-240–248).
- MSO agreement review to maintain physician control and avoid Corporate Practice of Medicine (CPOM) violations.
- Ongoing regulatory monitoring and alerts covering GCMB, Board of Nursing, and Department of Public Health updates.
Find a Georgia Medical Director with Medical Director Co.
Georgia Resources to Bookmark
Georgia Composite Medical Board: https://medicalboard.georgia.gov/
DEA Diversion Control Division: https://medicalboard.georgia.gov/
FindLaw: https://www.findlaw.com/
Georgia Board of Nursing: https://sos.ga.gov/georgia-board-nursing
IntelyCare – Georgia Nurse Practice Act: https://www.intelycare.com/facilities/resources/georgia-nurse-practice-act-facility-guide/
Georgia Department of Public Health: https://dph.georgia.gov/pdmp
Rules and Regulations of the State of Georgia: https://rules.sos.ga.gov/
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.
