Do CRNPs and PAs always need a written agreement?

Yes. Certified Registered Nurse Practitioners (CRNPs) must practice under a written collaborative agreement filed in the PALS system, and Physician Assistants (PAs) must maintain a written supervising physician agreement defining their scope of practice, supervision requirements, and prescribing authority.

Do agreements need to list every drug or device?

No. Collaborative and supervision agreements must describe the categories of drugs and devices authorized for use, along with prescribing conditions, consultation requirements, and quality-assurance procedures, rather than listing each specific drug or device.

Is telemedicine allowed for medical aesthetics?

Yes. Telemedicine is allowed in Pennsylvania for medical aesthetic services if a valid practitioner–patient relationship is established and the same standard of care as in-person treatment is maintained.

Michigan Medical Director Requirements for Medspas (2026 Compliance Checklist)

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 Michigan Department of Licensing and Regulatory Affairs (LARA), the Michigan Board of Medicine, and other applicable authorities, and seek advice from qualified legal counsel before making decisions or taking action.

Executive Summary

Michigan treats injectables, lasers, and IV therapy as medical acts. A licensed physician must oversee these services.
Michigan does not issue a standalone “medical spa” license. Compliance is governed by the Public Health Code and professional licensure rules enforced by LARA and the Michigan Board of Medicine.
A licensed physician (MD or DO) typically serves as the medical director responsible for clinical oversight, delegation, and supervision.
Physicians may delegate medical acts to qualified staff (RNs, APRNs, PAs) within their scope of practice, but remain professionally accountable for those acts.
Michigan law does not set a fixed physician-to-provider ratio for delegation. Supervision requirements depend on the procedure and the delegatee’s license.
Laser and energy-based treatments for dermatologic or cosmetic purposes must be performed under physician supervision.
Medical decision-making authority must remain with the physician medical director, even when the business is owned or managed by non-physicians.
Written protocols, delegation policies, training documentation, and supervision plans are critical to demonstrate compliance during audits or complaints.
Regulatory interpretations may change. Med spas should regularly monitor LARA guidance, Board of Medicine actions, and legislative updates.

Michigan Medical Director Requirements for Medspas

Michigan does not regulate medspas through a single, unified “med spa law.” Instead, compliance flows from the Michigan Public Health Code, professional licensure statutes, and delegation rules enforced by Michigan Department of Licensing and Regulatory Affairs (LARA) and the Michigan Board of Medicine. Because injectables, laser procedures, and IV therapies are treated as medical acts, gaps in supervision, delegation, or documentation can quickly turn into licensing exposure or enforcement risk.

This page pulls the moving parts together—who may serve as a medical director, how delegation works for nurses, APRNs, and PAs, what physician supervision actually requires in Michigan, and how most compliant medspas structure operations. Where it matters, operators should verify statutes, board guidance, and agency interpretations before acting.

The Michigan Quick Compliance Checklist (Medspas)

Use this as a recurring internal audit. Assign each item to a specific role (medical director, lead RN, APRN/PA, clinic manager).

Entity & Ownership Structure

Michigan does not issue a standalone med spa license. Medical services must be delivered under a licensed healthcare professional’s authority. While non-physicians may own or manage the business side, medical judgment, protocols, and delegated acts must remain under physician oversight. Business arrangements must not interfere with clinical decision-making.

Medical Director Credentials

Active, unencumbered Michigan MD or DO license. Familiarity with all cosmetic and aesthetic services offered. Availability for supervision, consultation, and quality oversight consistent with written policies and contractual commitments.

Delegation & Prescriptive Authority

Medical acts may be delegated by a physician to qualified personnel acting within their licensed scope. Prescriptive authority must align with Michigan law governing APRNs and PAs. Written delegation policies should identify permitted procedures, supervision expectations, consultation requirements, and physician accountability. Michigan does not impose a fixed numerical cap on delegated providers, but inappropriate delegation remains a disciplinary risk.

Scope of Practice Mapping

Written matrix defining who may perform which services (MD/DO, APRN, PA, RN, LPN, laser personnel). Mapping should align with Michigan statutes, board rules, and the physician’s delegation determinations. Tasks outside a provider’s legal scope are prohibited even if training is completed.

Informed Consent & Protocols

Procedure-specific clinical protocols and informed consent forms for each service offered (injectables, energy-based devices, microneedling, chemical peels, IV therapy, etc.). Include complication response plans, escalation pathways, and emergency preparedness policies approved by the medical director.

Laser & Energy-Based Device Compliance

Laser and energy-based cosmetic procedures are treated as medical services in Michigan and require physician supervision. Devices must be used consistent with medical delegation standards and manufacturer requirements. Staff training, competency verification, and supervision levels must be documented.

Marketing & Representation

Marketing materials accurately reflect provider credentials and supervision. Non-physicians are not presented as independently practicing medicine. Professional titles are used correctly. Advertising avoids implying that cosmetologists or estheticians perform medical procedures.

Quality Assurance Cadence

Regular chart review, adverse-event tracking, medication and device oversight, and protocol updates. Frequency should reflect procedure risk and volume. Medical director participation must be documented.

Recordkeeping & Access

Maintain delegation policies, supervision documentation, training records, competency assessments, incident reports, and patient records. The medical director must have timely access to records for oversight and review, including off-site access if applicable.

Change Management

When adding a new service or device, update scope-of-practice matrices, delegation policies, consent forms, training documentation, and supervision plans. Notify the medical director before implementation and retrain affected staff.

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

Who Can Be a Medical Director in Michigan?

In Michigan, a medical spa that offers services considered the practice of medicine must operate under the authority of a licensed physician. In practice, the medical director is an actively licensed Michigan MD or DO in good standing with the Michigan Board of Medicine, regulated through the Michigan Department of Licensing and Regulatory Affairs (LARA). Medical directors in aesthetic practices commonly come from backgrounds such as dermatology, plastic surgery, emergency medicine, family medicine, or internal medicine, provided they are competent to oversee the procedures offered and remain involved in supervision and quality oversight. There is no separate “med spa medical director license” in Michigan. The role exists because medical acts are being performed, not because the state formally recognizes medspas as a facility type.

Why a “Nonphysician Medical Director” Is Not Recognized in Michigan

In Michigan, only individuals licensed to practice medicine may exercise medical judgment, direct clinical care, or assume responsibility for medical acts. Medical procedures offered in a med spa, such as injectables, laser treatments, and IV therapy, fall within the practice of medicine under Michigan law. Non-physicians may not independently practice medicine or assume responsibility for medical decision-making. Even when a med spa is owned or managed by non-physicians, clinical authority must remain with a licensed physician who oversees protocols, delegation, supervision, and patient safety. Using the title “medical director” for a non-physician does not confer medical authority and does not transfer legal responsibility. If the title suggests control over medical care without the required licensure, it may increase regulatory and enforcement risk.

Collaboration & Delegation: APRNs and PAs in a Michigan Medspa

Prescriptive Authority

In Michigan, advanced practice registered nurses and physician assistants may have prescriptive authority if authorized under state law and their supervising or collaborating arrangements. A physician medical director does not automatically grant prescribing rights; those rights flow from licensure, statutory authority, and any required supervision or collaboration structures.

Written policies should clearly identify which providers may prescribe, under what circumstances, and how physician consultation occurs.

No Fixed Provider Ratio

Michigan does not impose a numeric cap on how many APRNs or PAs a physician may supervise or collaborate with. That absence does not remove physician accountability. The supervising physician remains responsible for ensuring that delegation and oversight are reasonable, appropriate, and tied to the services offered.

Excessive delegation without meaningful supervision is a common trigger for board scrutiny.

Day-to-Day Delegation

Beyond prescribing, physicians may delegate medical acts to qualified personnel if:

The act is within the delegatee’s licensed scope
The individual is properly trained and competent
The physician provides appropriate supervision

Delegation does not transfer liability or professional responsibility away from the physician. The medical director remains accountable for the systems, protocols, and supervision supporting delegated care.

Practical Tips That Survive Audits

Audits and investigations tend to focus less on theory and more on proof. Regulators and investigators commonly ask for:

Written delegation and supervision policies
Evidence of physician involvement
Recent chart reviews
Documentation of training and competency
Records showing how issues or complications are escalated

If these materials are difficult to locate or inconsistent with actual practice, compliance exposure increases quickly.

Injectables & Device Procedures: What “Legal” Looks Like in Michigan

Injectables (e.g., Neuromodulators and Dermal Fillers)

Injectables are treated as medical procedures in Michigan. They must be performed by a physician or delegated to appropriately licensed personnel acting under physician supervision. Standing orders, protocols, and training documentation should align with the services offered.

Lasers, IPL, and Energy-Based Devices

Laser and energy-based cosmetic procedures are considered medical in nature when used for dermatologic or aesthetic treatment. These services require physician supervision, with delegation and training standards appropriate to the device’s risk and complexity.

Microneedling, Chemical Peels, Threads, IV Therapy

These services should be treated as individual medical procedures, each with:

Defined eligibility criteria
Procedure-specific protocols
Informed consent forms
Escalation and emergency plans

Bundling them together under generic policies increases compliance risk.

The Paperwork Michigan Regulators Expect to See

When a complaint, audit, or payer review occurs, regulators will ask for documentation, not explanations. Michigan does not require a specific “med spa binder,” but enforcement actions typically hinge on whether required records exist, are current, and match actual practice. Keep a centralized compliance file (digital is acceptable) containing the following:

Entity Documents: Formation and governance documents for the business entity operating the spa. If clinical services are provided under a professional entity or physician-led structure, records should show that medical decision-making authority rests with the licensed physician. Management or service agreements should not interfere with clinical judgment.
Licenses & Credentials: Active Michigan licenses for all clinical personnel, including the physician medical director, APRNs, PAs, RNs, and LPNs as applicable. Maintain documentation of DEA registration for prescribing providers if controlled substances are used. Keep training and competency records tied to the procedures performed.
Delegation Policies & Supervision Records: Written physician delegation policies identifying which medical acts may be performed by each license type. Include supervision expectations, consultation triggers, and escalation pathways. Documentation should reflect physician oversight in practice, not just on paper.
Prescribing Documentation: Where APRNs or PAs prescribe medications, maintain documentation showing that prescriptive authority complies with Michigan law and applicable supervision or collaboration requirements. Records should identify permitted medications, physician involvement expectations, and any internal prescribing protocols.
Clinical Protocols & Procedure Files: Procedure-specific protocols for injectables, laser or energy-based treatments, microneedling, chemical peels, threads, IV therapy, and similar services. Include informed consent forms, complication response plans, emergency preparedness procedures, and device-use guidelines.
Laser & Energy-Based Device Records: Training and competency verification for personnel using laser or energy-based devices. Device specifications, maintenance records, treatment logs, and supervision documentation should be maintained. Michigan does not operate a separate laser licensing agency, but physician supervision and delegation requirements still apply.
Quality Assurance Records: Chart reviews, adverse-event reports, medication and device oversight logs, and documentation of physician review or corrective action when issues arise. Records should show ongoing oversight, not one-time setup.
Marketing & Representation Approvals: Documentation showing that marketing materials accurately represent provider credentials and supervision. Advertising should not imply independent medical practice by non-physicians or misstate who performs medical procedures. Retain internal approvals where clinical claims are involved.

Common Compliance Pitfalls We See in Michigan (and How to Avoid Them)

Assigning the “Medical Director” Title to a Non-Physician: Clinical leadership roles can be held by nurses or other professionals, but medical direction and responsibility for medical acts must rest with a licensed physician. Titles and organizational charts should reflect legal authority, not operational convenience.
Assuming Delegation Has No Limits Because There Is No Numeric Cap: Michigan does not set a fixed physician-to-provider ratio, but delegation must still be reasonable and supervised. Excessive delegation without meaningful physician involvement increases disciplinary exposure.
Outdated or Incomplete Protocols: Protocols that are copied, generic, or no longer reflect actual services offered create risk. Procedures, devices, and staff roles change frequently in med spas; documentation must change with them.
Treating Laser and Energy Devices as “Non-Medical” Services: Even without a separate licensing program, these procedures remain medical in nature. Lack of training documentation, supervision records, or physician involvement is a common compliance failure.
Marketing That Creates Evidence of Unlicensed Practice: Websites, social media, and ads are routinely reviewed during investigations. If marketing implies that unlicensed personnel perform medical procedures or that business owners control medical decisions, it can be used directly against the practice.

FAQs

Can a non-physician own a med spa in Michigan?

Yes. A nonphysician may own the business entity, but may not control medical decision-making, clinical policies, prescribing, or supervision, which must remain with a Pennsylvania-licensed physician.

How many APRNs or PAs can one physician supervise or collaborate with?

Michigan law does not set a fixed numerical limit. That does not remove physician accountability. Supervision and delegation must be reasonable, appropriate to the services offered, and supported by meaningful physician involvement. Excessive delegation without adequate oversight may trigger board scrutiny.

Do delegation or prescribing documents have to list every drug and device?

Michigan law does not mandate a specific format. However, written policies should clearly define the categories of medications and devices that may be used or prescribed, along with supervision, consultation, and escalation expectations. Vague or overly broad authorizations increase compliance risk.

Are estheticians allowed to perform microneedling or laser treatments?

Estheticians may only perform services that fall within their licensed scope. Procedures that penetrate the skin beyond superficial levels or are considered medical in nature require physician oversight and lawful delegation to appropriately licensed personnel. Laser and energy-based treatments used for medical or cosmetic purposes are treated as medical services and require physician supervision.

What changed recently in Michigan med spa regulation?

Michigan has not adopted a single, comprehensive med spa statute. Oversight continues to flow from the Public Health Code, professional licensure laws, and enforcement by Michigan Department of Licensing and Regulatory Affairs (LARA) and the relevant licensing boards. Operators should monitor rulemaking, board guidance, and enforcement trends, particularly around delegation and scope of practice.

Are “Botox parties” specifically regulated in Michigan?

Michigan does not have a statute commonly referred to as a “Botox party bill.” That said, injectables are medical procedures and must be performed in compliance with licensure, delegation, supervision, informed consent, and patient safety requirements. Informal or social-event administration increases risk and does not reduce regulatory obligations.

Templates and Operational Playbooks (What to Implement This Week)

Use these to build internal SOPs. They mirror what investigators often ask to see.

Physician Delegation Policy Template

Identifies the physician, covered services, eligible delegatees, supervision standards, consultation triggers, and physician accountability.

Scope-of-Practice & Delegation Matrix

Columns: Procedure | License Type Authorized | Required Training | Supervision Level | Physician Availability.

Monthly Quality Assurance Pack

Standing agenda, meeting minutes template, chart review list, findings, corrective actions, and follow-up tracking.

Laser & Energy-Based Device File

Training records, competency checklists, device specifications, maintenance logs, treatment records, and supervision documentation.

Marketing Compliance Checklist

Title usage, credential accuracy, scope-of-practice language, supervision disclosures, and internal approval workflow for clinical claims.

Building a Defensible Structure

Many Michigan med spas use a business-led operating model with physician clinical oversight, even when the business is not physician-owned. The critical factor is not the entity structure itself, but whether medical authority, delegation decisions, and patient care remain under the control of a licensed physician.

Agreements and internal policies should clearly separate business operations from medical decision-making and reflect how physician oversight functions in practice.

Implementation Plan (30/60/90 Days)

Days 1–30: Foundation & Documentation

Inventory licenses (MD/DO, APRN, PA, RN, LPN) and confirm Michigan scope compliance
Finalize physician delegation and supervision policies
Consolidate protocols, consent forms, and medication/device logs
Align the scope-of-practice matrix with Michigan law and board guidance

Days 31–60: Oversight in Practice

Begin routine chart reviews and QA documentation
Verify training and competency records for injectables and devices
Conduct an internal delegation and supervision audit
Review marketing for credential accuracy and scope representation

Days 61–90: Risk Hardening & Readiness

Complete competency-based injector and device training with sign-offs
Audit governance to confirm physician control of clinical decisions
Prepare public-facing compliance and oversight disclosures

How Medical Director Co. Supports Michigan Med Spas

Running a compliant med spa in Michigan requires more than assigning a physician title. Physician oversight must be active, documented, and aligned with Michigan licensure and delegation rules. Medical Director Co. is built to support aesthetic practices that need licensed physician oversight and defensible compliance systems.

Here’s what we provide:

Access to Qualified Michigan Physicians

We connect practices with Michigan-licensed MDs and DOs who understand aesthetic medicine and physician oversight responsibilities. Each physician is vetted for experience with injectables, energy-based devices, and cosmetic procedures so delegation and supervision are appropriate under Michigan law.

Physician Delegation & Supervision Frameworks

We provide Michigan-appropriate delegation and supervision policy templates that define which procedures may be delegated, required training, supervision levels, and escalation protocols. These frameworks support lawful delegation and physician accountability.

Ongoing Quality Assurance Support

We help establish chart review processes, QA workflows, and documentation logs that demonstrate active physician involvement. Medical directors can review and sign off remotely while maintaining an auditable oversight trail.

Laser & Energy-Based Device Compliance Support

For practices offering laser or energy-based treatments, we assist with training documentation, competency verification, supervision standards, and recordkeeping aligned with Michigan expectations.

Business & Clinical Alignment

We help practices align operational structures with clinical oversight so medical decision-making remains under physician control, even when ownership or management is non-physician. This includes guidance on internal approvals, protocol governance, and role clarity.

Regulatory Monitoring & Updates

Oversight in Michigan evolves through enforcement trends, board interpretations, and rulemaking. We monitor relevant developments and help update protocols and documentation before compliance gaps appear.

Medical Director Co. provides Michigan med spas with licensed physicians, oversight frameworks, and compliance infrastructure so practices can operate responsibly and grow with confidence.

Find a Michigan Medical Director with Medical Director Co.

Areas We Serve

Michigan Resources to Bookmark

Bolton Harris

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.