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 Tennessee Board of Medical Examiners and other applicable state agencies, and consult qualified legal counsel before making decisions or taking action.
Executive Summary
- Only a Tennessee-licensed physician (MD or DO) can serve as a medical director or supervising physician for a medical spa. The medical director must hold an active Tennessee license and maintain an active medical practice in the state.
- Tennessee requires medical spa registration with the state. The medical director is responsible for cosmetic medical services and must ensure that the registration is renewed annually. Operating without a current registration can be considered unprofessional conduct and may trigger disciplinary action.
- Cosmetic procedures such as injectables, energy-based treatments, and microneedling are treated as medical acts. Physicians may delegate these services to qualified staff, but delegation must be documented and comply with state medical board standards and applicable collaborative or supervisory agreements.
- APRNs and PAs can prescribe medications only under written collaborative or supervisory agreements with a physician. These agreements define the scope, prescribe authority, and set expectations for oversight.
- Tennessee law also requires transparency around the medical director’s certification status. Medical spas must clearly display the supervising physician’s name and certification information in signage and advertising.
- Unlike some states that regulate cosmetic devices through separate licensing agencies, Tennessee places significant responsibility on the supervising physician through medical board oversight, written protocols, and medical spa registry requirements.
Tennessee Medical Director Requirements for Medspas
Tennessee regulates medical spas primarily through the Tennessee Board of Medical Examiners, the medical spa registry law, and supervision rules for physicians, APRNs, and PAs. Because cosmetic medical services are legally treated as medical practice, oversight, delegation, and registration requirements all flow through the supervising physician. Missing even one administrative obligation, such as annual medical spa registration or written collaborative agreements, can expose a practice to disciplinary action or liability.
This page organizes the moving parts: who can serve as a medical director or supervising physician; how collaboration works for nurse practitioners and physician assistants; what delegation actually requires under Tennessee law; and the operational structure most medspas use to stay compliant. Where applicable, references align with Tennessee statutes, board rules, and registry requirements.
The Tennessee Quick Compliance Checklist
Use this as your monthly audit. Assign each item to a specific role (medical director, APRN/PA lead, RN supervisor, clinic administrator).
The medical spa is registered with the Tennessee Board of Medical Examiners, and the supervising physician is listed on the registry. Registration is renewed annually, and the medical director attests responsibility for cosmetic medical services. Operating without an active registration may be considered unprofessional conduct.
Active Tennessee MD or DO license with an active medical practice in the state. The physician must be capable of supervising cosmetic medical services and maintaining accessibility for consultation, chart review, and patient safety oversight.
Collaborative Practice Agreements (APRNs) and Supervisory Agreements (PAs) are written, signed, and define prescribing authority, scope of services, consultation protocols, and chart review expectations. All delegated cosmetic procedures follow documented physician authorization.
Written protocols outline which provider types may perform specific treatments — physician, APRN, PA, RN, or support staff — based on Tennessee statutes and board guidance. Cosmetic services that alter living tissue are treated as medical acts requiring physician oversight.
Procedure-specific policies exist for injectables, energy-based devices, microneedling, IV therapies, and similar services. Protocols define complications management, emergency response procedures, and physician escalation pathways.
If supervision occurs remotely, telehealth standards are followed and the physician remains accessible for real-time consultation and documentation review. Supervision expectations are outlined in delegation or collaborative agreements.
Signage and advertising clearly identify the supervising physician, certification information, and provider credentials. Titles and credentials used in marketing accurately reflect licensure and scope.
Routine chart audits, adverse-event tracking, medication oversight, and periodic policy reviews are documented. Quality assurance processes reflect the physician’s responsibility for cosmetic medical services at the registered medical spa.
Recordkeeping & Access
Maintain collaborative agreements, supervision contracts, delegation policies, competency training logs, and incident reports. The supervising physician has access to patient records for review and oversight duties.
Change Management
When adding a new treatment modality, such as a new injectable or energy-based device, update protocols, delegation documents, staff training, and consent forms before offering the service.
The Legal Frame: Medical Spa Registration + Supervising Physician Requirements
Who Can Be a Medical Director or Supervising Physician in Tennessee?
A Tennessee-licensed MD or DO with an active license and active medical practice may serve as the supervising physician for a medical spa. The physician must be listed on the state’s medical spa registration and accept responsibility for cosmetic medical services provided at the practice.
In aesthetic settings, medical directors commonly include physicians trained in dermatology, plastic surgery, emergency medicine, or primary care who maintain appropriate training and supervision protocols for cosmetic procedures.
Why Nonphysician Medical Direction Is Not Permitted
Cosmetic medical services fall within the practice of medicine under Tennessee law. Procedures such as injectables, laser treatments, and microneedling may only be performed by physicians or delegated by physicians under written agreements that meet board standards. APRNs and PAs cannot operate independently and must maintain collaborative or supervisory agreements defining their scope and prescribing authority.
Because the supervising physician assumes responsibility for clinical services through the state registry and board rules, medical decision-making authority cannot be transferred to nonphysicians.
Collaboration & Delegation: NPs and PAs in a Tennessee Medspa
Prescriptive Authority
APRNs may prescribe medications only through a written Collaborative Practice Agreement (CPA) with a physician, and PAs may prescribe through a written Supervisory Agreement approved by the Tennessee Board of Medical Examiners. These agreements define the scope of prescribing authority, consultation procedures, and oversight expectations.
Controlled substances require appropriate DEA registration and compliance with board rules. APRNs and PAs cannot prescribe independently without physician collaboration or supervision in place.
Provider Limits
Tennessee statutes do not impose a fixed numerical cap on prescriptive delegation like some jurisdictions. Instead, the supervising physician must maintain appropriate oversight and ensure that collaboration and supervision remain safe, documented, and consistent with professional standards.
Day-to-Day Delegation
Cosmetic medical services, including injectables, energy-based procedures, and microneedling, are treated as medical acts. Physicians may perform these procedures or delegate them to qualified licensed professionals, but delegation must be written, documented, and supported by training and supervision protocols.
Practical Tips That Survive Audits
Maintain organized documentation of Collaborative Practice Agreements, Supervisory Agreements, chart review schedules, and training records. Regulators commonly ask to see proof that delegation is documented and that physician oversight is active rather than nominal.
Keep records showing how supervision occurs, including consultation notes, meeting documentation, and evidence that protocols are updated when new procedures are introduced.
Injectables & Device Procedures: What “Legal” Looks Like in Practice
Injectables (e.g., Botox®, Dermal Fillers)
Injectables are considered cosmetic medical services that alter living tissue and therefore fall under the practice of medicine. They require physician oversight and written delegation to appropriately licensed staff.
Lasers, IPL, and Energy-Based Devices
Energy-based treatments are included within the definition of cosmetic medical services when they alter or damage living tissue to improve appearance. The supervising physician must ensure protocols, training, and oversight align with board rules and medical spa registration requirements.
Microneedling, Chemical Peels, Threads, IV Therapy
Because these services may affect living tissue, medspas typically implement procedure-specific protocols, consent forms, emergency procedures, and escalation pathways approved by the supervising physician.
The Paperwork Tennessee Actually Expects to See
Medical Spa Registration Documents
Proof of active medical spa registration, including the supervising physician’s name, license number, and certification information submitted to the state registry.
Licenses & Credentials
Active physician license, APRN or PA licenses, nursing credentials where applicable, DEA registration for prescribers, and documentation showing the supervising physician maintains an active medical practice in Tennessee.
Collaborative and Supervisory Agreements
Written CPAs for APRNs and Supervisory Agreements for PAs that define prescribing authority, scope of delegated acts, consultation requirements, and chart review expectations.
Delegation Protocols & Training Records
Written protocols showing which provider types perform each cosmetic service, plus competency checklists, device settings guidelines, and training documentation signed by the supervising physician.
Marketing and Signage Documentation
Evidence that advertising and signage include accurate credential representation and supervising physician information, as required by medical spa registration rules.
Common Pitfalls We See (and How to Avoid Them)
- Assuming an RN or aesthetic provider can act as a medical director. Only a Tennessee-licensed MD or DO with an active medical practice may serve as supervising physician for a registered medical spa.
- Operating without a current medical spa registration. Registration must be renewed annually, and operating without it may be considered unprofessional conduct.
- Missing or outdated collaborative agreements. APRNs and PAs must maintain current written agreements defining their delegated authority.
- Delegating procedures without written protocols. Cosmetic medical services require documented physician authorization and oversight structures.
- Marketing language that misrepresents credentials or independence. Advertising must accurately reflect licensure and supervising physician involvement.
FAQs
Can a nonphysician own my medspa?
Ownership structures must comply with Tennessee medical practice laws. Clinical medical decision-making remains under physician authority, and many medspas use physician-led clinical entities with separate business management structures.
How many APRNs or PAs can one physician collaborate with?
Tennessee law focuses on safe supervision rather than a fixed numerical cap. Oversight responsibilities must remain reasonable and documented.
Do collaborative agreements need to define prescribing authority?
Yes. CPAs and Supervisory Agreements should outline scope, prescribing limits, consultation procedures, and chart review expectations.
Are estheticians allowed to perform injectables or medical device procedures?
Procedures that alter living tissue are considered cosmetic medical services and require physician performance or delegation to appropriately licensed medical professionals.
What documentation must be on file for inspections?
Medical spa registration records, physician credentials, collaborative agreements, delegation protocols, training logs, and marketing compliance materials are commonly reviewed.
Templates and Operational Playbooks (What to Implement This Week)
Use these frameworks to build internal SOPs that reflect what Tennessee regulators typically expect to see when reviewing cosmetic medical practices.
Collaborative Practice & Supervision Agreement Template
Because APRNs and PAs must operate under written agreements with a supervising or collaborating physician, your internal template should include:
Parties and practice locations; scope of delegated services; prescribing authority; consultation and referral processes; emergency procedures; documentation standards; and chart-review expectations. Agreements should clearly reflect the physician’s responsibility for cosmetic medical services performed at the registered medical spa.
Delegation & Scope Matrix
Create a written matrix outlining which licensed providers may perform specific treatments. Typical columns include:
- Procedure | Authorized Provider Type | Training Requirements | Delegated Authority | Physician Availability | Complication Management Protocol.
Tennessee law defines cosmetic medical services as treatments that alter or damage living tissue using biologic materials, chemicals, devices, or energy-based systems, so delegation protocols must reflect physician oversight.
Monthly Quality Assurance (QA) Pack
Maintain a recurring QA file that includes:
- Meeting agendas and minutes; chart review summaries; complication or adverse-event tracking; device maintenance documentation; and updated protocols approved by the supervising physician.
- Because the medical director attests responsibility for cosmetic medical services through the state registry, documentation demonstrating active oversight strengthens compliance readiness.
Cosmetic Medical Device & Treatment Binder
Instead of a device-specific licensing binder, Tennessee practices typically maintain a centralized clinical binder that includes:
- Delegation policies; training records; consent forms; treatment logs; and protocols for procedures like injectables, energy-based treatments, and microneedling.
- Microneedling devices, for example, are classified as cosmetic medical devices capable of altering living tissue, meaning they fall under medical spa oversight requirements.
Marketing Compliance Checklist
Review advertising regularly to confirm:
- Accurate provider titles; supervising physician identification; credential transparency; and claims that reflect clinical oversight. Medical spa registration rules require disclosure of supervising physician information in signage and advertising materials.
Building a Defensible Structure (Clinical Oversight + Business Operations)
Many Tennessee medical spas use a structure that separates clinical care from administrative management:
- A physician-led clinical entity controls medical records, treatment protocols, and delegation decisions;
- A separate management organization may handle operations such as staffing, scheduling, marketing, or billing support.
Tennessee law places responsibility for cosmetic medical services squarely on the supervising physician listed on the medical spa registry, so governance documents should clearly reflect physician authority over clinical matters.
Implementation Plan (30/60/90 Days)
Days 1–30: Foundation & Documentation
- Confirm active medical spa registration and supervising physician listing.
- Inventory all licenses, collaborative agreements, and supervision contracts.
- Consolidate clinical protocols, consent forms, and delegation matrices so they align with Tennessee Board of Medical Examiners rules.
Days 31–60: Oversight in Practice
- Begin routine QA meetings and chart reviews consistent with collaborative or supervisory agreements.
- Audit documentation workflows to ensure the supervising physician has access to records and consultation processes remain active.
Days 61–90: Risk Hardening & Growth
- Train staff using documented competency checklists tied to written protocols.
- Review marketing materials and signage for compliance with physician disclosure requirements.
- Establish a public-facing compliance statement outlining patient safety practices and medical director oversight.
How Medical Director Co. Supports Tennessee Medspas
Operating a compliant medical spa in Tennessee requires more than listing a physician on paperwork. State registry requirements, collaborative agreements, and delegation protocols all need ongoing maintenance. Medical Director Co. provides support tailored to Tennessee medical spa compliance.
Access to Qualified Tennessee Physicians
We connect clinics with Tennessee-licensed MDs and DOs who understand cosmetic medical services and the oversight expectations tied to the medical spa registry.
Collaborative Agreement & Supervision Support
Our team provides templates aligned with Tennessee requirements for APRN Collaborative Practice Agreements and PA Supervisory Agreements, including prescribing authority, consultation processes, and documentation expectations.
Ongoing Quality Assurance Systems
We help establish recurring chart reviews, documentation workflows, and protocol updates so supervising physicians can maintain clear oversight responsibilities.
Telehealth & Remote Supervision Integration
When appropriate, we assist clinics in structuring remote supervision workflows that remain compliant with Tennessee telehealth and collaboration standards.
Compliance Monitoring
As Tennessee medical spa rules evolve, we help update templates, protocols, and operational documents to reflect current board expectations.
Medical Director Co. provides Tennessee clinics with licensed physicians, compliance frameworks, and documentation systems designed to support safe and lawful growth.
Areas We Serve
We provide licensed medical directors and compliance support for clinics across Tennessee, including major metropolitan areas:
