Can a nonphysician own a clinic or medspa in Pennsylvania?

Yes. A nonphysician may own the business entity, but cannot control or influence medical decision-making. All clinical judgment, diagnosis, treatment protocols, and supervision must remain under a Pennsylvania-licensed physician to prevent unlicensed practice of medicine.

Do CRNPs and PAs require written agreements?

Yes. Certified Registered Nurse Practitioners (CRNPs) must have written collaborative agreements that are current and filed in the Pennsylvania Licensing System (PALS). Physician Assistants (PAs) must have written supervising physician agreements that outline delegated tasks, supervision methods, and chart review protocols.

Can RNs perform injectables or laser procedures?

Potentially, yes—if properly delegated. Registered Nurses (RNs) in Pennsylvania may perform medical procedures such as injectables or laser treatments under physician or CRNP orders, provided they have appropriate training, written protocols, documented competency, and direct or indirect supervision. Independent performance of these procedures is not permitted.

Is telemedicine permitted for weight-loss medications?

Yes. Telemedicine is allowed in Pennsylvania, but the same standard of care applies. A valid practitioner–patient relationship and adequate clinical evaluation must be established before prescribing. PDMP checks are mandatory when prescribing controlled substances, including medications like phentermine.

Are laser technicians licensed in Pennsylvania?

No. Pennsylvania does not license laser technicians as a separate profession. The use of lasers and other energy-based devices is classified as a medical act requiring physician or CRNP oversight, formal protocols, verified training, and supervision.

North Carolina Medical Director Requirements for Medspas (2026 Compliance Checklist)

Disclaimer: This material is provided for educational and informational purposes only. It does not constitute legal advice, medical advice, or regulatory guidance. Requirements, interpretations, and enforcement practices may vary and are subject to change. Always verify current requirements directly with the North Carolina Medical Board, the North Carolina Board of Nursing, and the North Carolina Board of Pharmacy, and consult qualified healthcare legal counsel before making decisions or taking action.

Executive Summary

Only a North Carolina–licensed physician (MD/DO) may serve as the medical director for medical procedures. Nonphysicians may own the business entity, but they may not practice medicine or control medical decision-making. Most medspas use a physician-led clinical structure for medical services, with a separate administrative or management entity handling business operations.
Physicians may delegate medical acts, including injectables and device-based services, to qualified staff and may support prescribing by APRNs and PAs through written collaborative or supervisory arrangements. North Carolina does not impose a fixed numerical cap on supervised providers, but oversight must be appropriate to the services offered and consistent with board expectations.
Collaboration or supervision arrangements should be in writing and address authorized services, consultation and referral processes, communication expectations, and quality oversight such as chart or case review.
The North Carolina Medical Board issues position statements and guidance that shape delegation, telemedicine, and supervision standards. Clinics should ensure written policies align with current board expectations and actual practice.
North Carolina does not operate a separate statewide laser facility licensing program. However, injectables and energy-based procedures are treated as medical services and require physician-approved protocols, documented training, supervision, and device records.
While North Carolina has not enacted a single aesthetics-specific statute in recent years, regulators have increased scrutiny of injectables, supervision structures, and marketing practices. Clinics should monitor board updates and ensure delegation, documentation, and advertising remain accurate and compliant.

North Carolina medspa compliance can be complex due to corporate practice considerations, physician supervision expectations, and board oversight of delegation and prescribing. Between limits on who may control medical decision making, requirements for physician involvement in aesthetic procedures, and evolving scrutiny of injectables and device based services, it is easy for clinics to overlook an obligation that later becomes a board inquiry or insurance issue.

This page brings the key elements together for North Carolina medspas, including who may serve as a medical director, how collaboration and supervision work for NPs and PAs, what delegation looks like in day to day practice, what is permitted with injectables and aesthetic devices, and the practice structures commonly used to remain compliant. Where helpful, we reference the state boards and resources that regulators expect clinics to understand.

The North Carolina Quick Compliance Checklist

Use this as a monthly internal audit. Assign each item to a specific person, such as the medical director, NP or PA lead, RN lead, or clinic manager.

Entity & Ownership Structure

Clinical services are delivered under a structure that preserves physician control over medical decision-making. Any management or administrative agreement separates business operations such as marketing, staffing, and nonclinical assets from the practice of medicine in line with North Carolina corporate practice principles.

Medical Director Credentials

The medical director holds an active, unrestricted North Carolina MD or DO license, is familiar with the cosmetic and aesthetic services offered, and is available for supervision and quality oversight as outlined in clinic policies and agreements.

Delegation & Prescriptive Authority

Written collaboration or supervision arrangements support delegation and prescribing by NPs and PAs. These arrangements reflect the scope of services, physician availability, consultation and escalation processes, emergency coverage, and ongoing clinical review consistent with North Carolina expectations.

Scope of Practice Mapping

A written scope matrix clearly defines which services may be performed by each role, including MD or DO, NP, PA, RN, esthetician, or other clinical staff, and aligns with licensure, training, and physician delegation policies.

Informed Consent & Protocols

Procedure-specific protocols are maintained for injectables, energy-based devices, microneedling, chemical peels, thread lifts, IV therapy, and related services. Documentation includes informed consent, complication management plans, emergency medications, and escalation pathways.

Laser Hair Removal Compliance

If laser or energy-based services are offered, physician-approved protocols, staff training records, competency documentation, supervision arrangements, and device maintenance logs are kept current and accessible.

Marketing & Representation

Advertising and website content accurately reflect licensure, delegation, and supervision. Titles are used correctly, and marketing does not suggest independent medical practice by nonphysicians or imply that unlicensed personnel perform medical procedures.

Quality Assurance Cadence

The clinic maintains an ongoing quality oversight process that may include chart or case reviews, adverse event tracking, medication and device logs, and periodic protocol updates based on clinical findings.

Recordkeeping & Access

Collaboration or supervision agreements, delegation policies, training records, competency sign-offs, incident reports, and quality oversight documentation are maintained and accessible. The medical director can review records remotely when needed.

Change Management

When new services or modalities are added, such as new devices or treatment offerings, the clinic updates scope matrices, protocols, consent forms, training materials, and supervision documentation, and ensures affected staff are retrained before launch.

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

Who Can Be a Medical Director in North Carolina?

A medical director must be a North Carolina licensed MD or DO in active, good standing status. In medspa settings, medical directors commonly include physicians with backgrounds in dermatology, plastic surgery, family medicine, or emergency medicine who are trained in aesthetic procedures.

Why a Nonphysician Medical Director Is Not Recognized in North Carolina

Corporate practice principles in North Carolina prohibit nonphysicians from practicing medicine or controlling medical decision-making, even when they own the medspa business entity. Clinical authority, delegation, and supervision must remain under physician control, consistent with expectations of the North Carolina Medical Board.

Collaboration and Delegation: NPs and PAs in a North Carolina Medspa

Prescribing Authority

Prescribing by NPs and PAs is supported through written collaborative or supervisory arrangements with a North Carolina licensed physician. These arrangements reflect scope of practice, physician availability, consultation expectations, and ongoing clinical oversight.

No Fixed Numerical Cap

North Carolina does not impose a fixed numerical limit on the number of NPs or PAs a physician may supervise for prescribing. Oversight expectations focus instead on whether supervision, accessibility, and quality review are reasonable and appropriate for the services provided.

Day-to-Day Delegation

Practical Tips That Survive Audits

Do not treat quality oversight as informal or undocumented. During reviews or investigations, regulators commonly ask to see written collaboration or supervision arrangements, recent chart or case reviews, and proof that physician oversight activities are occurring as described in clinic policies.

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

Injectables (e.g., Botox®, Fillers)

Injectable treatments are considered medical procedures in North Carolina and require physician oversight with appropriate delegation, supervision, and documentation.

Lasers, IPL, and Energy Devices

North Carolina does not operate a separate laser facility licensing program, but laser and energy-based procedures are still treated as medical services and must be performed under physician-approved protocols with documented training and supervision.

Microneedling, Peels, Threads, IV Therapy

Clinics should maintain procedure-specific checklists, informed consent forms, and training documentation aligned with physician delegation and oversight.

The Paperwork North Carolina Regulators Expect to See

Entity Documents

Clinical entity formation documents showing physician control of medical decision-making, along with any management or administrative agreements that separate business operations from clinical authority.

Licenses & Credentials

Active North Carolina medical director license, DEA registration if applicable, current APRN and PA licenses, RN licenses, and any training or credential records tied to aesthetic or device-based services offered.

Collaboration or Supervision Agreements

Written collaboration or supervision arrangements supporting NP and PA prescribing and clinical oversight, maintained for each applicable provider and consistent with actual practice.

Delegation Memos & Protocols

Written documentation outlining who may perform specific procedures, required training or prerequisites, competency checklists, and device or treatment parameters approved by the physician.

Laser Hair Removal File

Physician-approved protocols, staff training and competency documentation, device maintenance records, and treatment logs for laser or energy-based services, where applicable.

Marketing Approvals

Internal review records showing medical director awareness or approval of marketing content when claims reference medical services, supervision, or clinical care.

Common Pitfalls We See (and How to Avoid Them)

Assuming a nonphysician can act as a medical director.
Misunderstanding supervision by focusing on numbers instead of actual physician oversight.
Outdated collaboration documents and missing quality review records.
Treating laser or energy based procedures as nonmedical services.
Advertising that implies unlicensed or unsupervised medical practice.

FAQs

Can a nonphysician own my medspa?

Yes. A nonphysician may own or operate the business entity, but medical decisions, supervision, and clinical care must remain under physician authority in line with expectations of the North Carolina Medical Board.

How many APRNs or PAs can one physician support for prescribing?

North Carolina does not set a fixed numerical cap. Oversight focuses on whether physician supervision, accessibility, and quality review are appropriate for the services provided.

Do my prescribing or supervision agreements have to list every drug and device?

Agreements and policies should clearly reflect the scope of services and prescribing activity in practice. Keeping them aligned with actual operations helps avoid gaps during reviews.

Are estheticians allowed to perform microneedling or laser procedures?

Scope depends on the procedure and level of invasiveness. Many microneedling and laser services are treated as medical procedures and require physician oversight, protocols, and appropriate licensure.

What changed recently with North Carolina Medical Board rules?

Recent updates have emphasized documentation, supervision, and telemedicine standards through board guidance and enforcement activity.

Have North Carolina regulators increased attention on injectables and medspas?

Yes. Oversight has increasingly focused on who performs procedures, how supervision is structured, and whether marketing accurately reflects licensure and physician involvement.

Templates and Operational Playbooks (What to Implement This Week)

Collaboration and Supervision Template

A standard written framework outlining participating providers, scope of services, physician availability, consultation expectations, emergency coverage, and quality review activities.

Delegation & Scope Matrix

A simple table that maps each procedure to who may perform it, required training or prerequisites, and the level of physician involvement or availability.

Monthly QA Pack

Basic tools to document oversight, including a meeting agenda or summary and a chart or case review list with notes on findings and follow-up actions.

Aesthetic and Device Procedure File

Centralized documentation for injectables, lasers, and energy-based services, including physician-approved protocols, staff training records, competency sign-offs, and device maintenance logs.

Marketing Compliance Checklist

An internal review checklist to confirm that titles, credentials, service descriptions, and advertising language accurately reflect licensure, supervision, and who performs each service.

Building a Defensible Structure (the MSO + PC model)

Most North Carolina medspas that are not physician-owned use a two-entity structure to separate medical care from business operations:

A physician controlled clinical entity oversees medical decision making, employs or contracts clinicians, establishes clinical protocols, and maintains responsibility for patient care and medical records.
A separate management or administrative entity provides nonclinical services such as facilities, staffing support, marketing, and administrative operations, without directing or influencing medical judgment.

Guidance from professional organizations and board enforcement actions in North Carolina consistently emphasize that medical decisions must remain under physician authority. Clinics should ensure their contracts and day-to-day operations reflect this separation to reduce regulatory risk and avoid corporate practice concerns.

Implementation Plan (30/60/90 Days)

Days 1–30: Foundation & Paperwork

Inventory licenses (MD/DO, APRN/PA, RN, esthetician where applicable), collaboration or supervision agreements, and DEA registrations for controlled substances. Close all gaps first.
Consolidate protocols, consent forms, and medication or device logs. Align your scope matrix with North Carolina licensure rules and Medical Board guidance.
Review collaboration and supervision arrangements to confirm prescribing authority, physician availability, consultation processes, and quality oversight match actual practice. Document any updates clearly.

Days 31–60: QA in Action

Start routine QA meetings and chart or case reviews per your collaboration or supervision documents. Do not overpromise. Choose a cadence you will meet consistently.
Conduct a mock internal review focused on delegation, supervision, aesthetic procedures, and telemedicine documentation standards.
Refresh marketing. Scrub website copy and creative content so no one could infer unlicensed practice. Add clear physician oversight language where appropriate.

Days 61–90: Risk Hardening & Growth

Train injectors and device operators using competency checklists tied to your protocols. Log completion and maintain direct observation sign-offs where required.
Audit management agreements and governance documentation to demonstrate that physicians control medical decision-making.
Create a concise public compliance or patient safety statement linking to your medical director bio and outlining physician oversight practices.

How Medical Director Co. Supports North Carolina Medspas

Operating a compliant medspa in North Carolina requires more than designating a physician as medical director. Clinics must align physician oversight, delegation, documentation, and day-to-day operations with board expectations that continue to evolve. Medical Director Co. is built to support aesthetic practices that need licensed physician oversight along with practical compliance systems that work in real clinical settings.

What We Provide

Access to North Carolina Licensed Physicians
We connect medspas with North Carolina licensed MDs and DOs who understand aesthetic medicine and outpatient care. Physicians are matched based on experience with injectables, energy-based devices, and cosmetic procedures, so delegation and supervision are appropriate and well supported.

Collaboration and Supervision Support
Our team assists with written collaboration or supervision arrangements that reflect the scope of services, physician availability, consultation pathways, emergency coverage, and ongoing clinical review. We help ensure these documents stay current as services or staffing changes.

Ongoing Quality Oversight Support
We help clinics establish realistic quality oversight processes, including chart or case review workflows, documentation templates, and meeting records. These systems allow medical directors to participate remotely while maintaining clear, organized records if questions arise.

Aesthetic and Device-Based Guidance
For injectables, lasers, and energy-based services, we support protocol development, staff training documentation, competency tracking, and physician oversight structures that align with North Carolina expectations.

Practice Structure Alignment
Many North Carolina medspas use a clinical and management model that separates medical decision-making from business operations. We help review governance and management arrangements to ensure physicians retain control over clinical care while administrative teams handle nonclinical functions.

Regulatory Awareness
We monitor guidance and enforcement trends from the North Carolina Medical Board, Board of Nursing, and Board of Pharmacy and flag when updates to policies, protocols, or workflows may be appropriate.

Medical Director Co. supports North Carolina medspas with more than physician placement. We help clinics build sustainable oversight, documentation, and operational structures that reduce risk and support long-term growth.

Areas We Serve

We provide licensed medical directors and compliance support for clinics across North Carolina, including major metro areas.

North Carolina Resources
You Should 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.