Every Texas medspa that offers Botox, fillers, IV therapy, or prescription lasers needs a delegating physician with an active Texas MD or DO license. That physician signs the written orders for each procedure, and their name and license number must be posted in your treatment rooms. NPs and PAs can prescribe only under a prescriptive authority agreement, and one physician can hold up to seven. Below are the Texas medical director requirements for medspas in 2026 and the documents to keep on file for an audit.
Disclaimer: This guide is educational and isn’t legal advice. Confirm current rules with the Texas Medical Board and your own healthcare attorney before acting on them.
Key Takeaways
- Only a Texas-licensed MD or DO can delegate medical procedures in a medspa, and an RN, NP, or PA can’t fill that role. (Jump to Section)
- Chapter 169 requires written orders, a good faith exam before treatment, BLS-trained staff on site, and the physician’s name and license number posted in public areas. (Jump to Section)
- NPs and PAs need a written PAA to prescribe, and the physician must register each delegation with the Texas Medical Board. (Jump to Section)
- Jenifer’s Law limits IV administration to physicians, PAs, APRNs, and RNs, while SB 378 never became law, so delegation rules for injectables haven’t changed. (Jump to Section)
Who Can Serve as a Medspa Medical Director in Texas
Only a physician with an active, unrestricted Texas MD or DO license can delegate medical procedures in a Texas medspa. Texas law never uses the title “medical director,” so in practice your medical director is the delegating physician named in your written orders. Board certification in dermatology or plastic surgery isn’t required, but the physician must be trained in every procedure they delegate.
An RN, NP, or PA can lead your clinical team, but none can hold this role. An out-of-state physician also needs a Texas license first.
How Texas Medspas Split Ownership Between a PLLC and an MSO
Texas follows the corporate practice of medicine doctrine, which bars non-physicians from owning or controlling a medical practice. That’s why most non-physician-owned medspas run on two entities connected by a written management services agreement. The split only protects you if daily decisions actually follow it.
| Entity | Owned By | Controls |
|---|---|---|
| Professional entity (PLLC or PA) | Texas-licensed physician | Protocols, clinical hiring, patient records, and treatment decisions |
| Management services organization (MSO) | Anyone, including nurses and investors | Lease, equipment, marketing, payroll, scheduling, and billing support |
When that line blurs, the physician faces TMB penalties ranging from fines to license revocation. Non-physician owners can face criminal exposure for practicing medicine without a license.
Which Texas Medspa Rules Apply in 2026
The Texas Legislature holds regular sessions only in odd-numbered years, so no new medspa laws were passed in 2026, and the next session opens in January 2027. The rules you follow this year come from the TMB’s rule overhaul and the bills from the last session. Many checklists still cite the old versions, so here’s what’s current.
| Rule or Bill | Status in 2026 | What It Means for Your Medspa |
|---|---|---|
| 22 TAC Chapter 169 (replaced §193.17) | In effect since January 9, 2025 | Delegation rules moved to 22 TAC §§169.25 to 169.28. Update any protocol citing §193.17. |
| HB 3749 (“Jenifer’s Law”) In effect sinc | e September 1, 2025 Elective IV th | erapy outside a physician’s office or licensed facility needs a physician, PA, or APRN order. |
| SB 378 (“Botox Party Bill”) Not law (vetoe | d June 2, 2025) Never took eff | ect. Delegation under Occupations Code Chapter 157 is unchanged. |
What 22 TAC Chapter 169 Requires From Your Delegating Physician
Chapter 169 treats nonsurgical medical cosmetic procedures, including injections and prescription devices, as the practice of medicine. A physician must delegate and supervise each one. The new rules run about half the length of old §193.17, but the written-order and posted-notice duties got sharper.
Written orders (§169.27): The physician writes or approves every order, including screening criteria and treatment guidelines.
Good faith exam: An MD, DO, PA, or APRN examines each patient before treatment.
Emergency readiness: Someone with BLS training is on site, and a physician, PA, or APRN is reachable for emergencies.
Posted notice (§169.28): The physician’s name, Texas license number, and a TMB complaint notice appear in public areas and treatment rooms.
Staff identification: Anyone performing a delegated act wears a badge with their name and credentials.
Need a Delegating Physician?
Texas MDs and DOs who know aesthetics.
Prescriptive Authority Agreements and the Seven-FTE Cap
NPs and PAs in a Texas medspa can prescribe only under a written prescriptive authority agreement (PAA) with a delegating physician. One physician can hold PAAs with up to seven APRNs and PAs combined, or their full-time equivalent, unless a facility-based or medically underserved exception applies. The cap limits prescriptive delegation only, so it doesn’t restrict how many RNs or aestheticians the physician oversees.
Under Texas Occupations Code §157.0512, every PAA lists the parties and their license numbers, practice locations, drugs and devices authorized or excluded, consultation and emergency plans, and a QA plan with chart review and periodic meetings. The physician must also register the delegation with the TMB. Pick a chart review number and meeting schedule you’ll actually keep, then log every one.
Who Can Perform Each Medspa Service in Texas
One Texas medspa can answer to the TMB and the Texas Department of Licensing and Regulation (TDLR) at once. Facials and standard skincare stay under TDLR. Once a service becomes a medical procedure, physician delegation rules apply.
| Service | Regulator | Who Can Perform It |
|---|---|---|
| Neurotoxins and dermal fillers | TMB | Trained delegates under written orders. A cosmetology license alone never authorizes injections. |
| Elective IV therapy | TMB (HB 3749) | Administered only by a physician, PA, APRN, or RN. |
| Laser hair removal | TDLR Certified tech | nicians at a certified facility with a consulting physician. |
| IPL, RF microneedling, and other lasers | TMB | Delegates trained on that device, under written orders. |
| Chemical peels and microneedling | TDLR or TMB | Cosmetic-strength work stays with estheticians. Deeper or prescription-strength work needs delegation. |
Texas Medical Director Requirements for Medspas: Compliance Checklist
Investigators ask for documents, so keep these within reach. Assign each row to one named person. Review it monthly and every time you add a service.
| Item | Keep on File | Owner |
|---|---|---|
| Entity structure | PLLC documents and an MSA showing physician clinical control | Owner and counsel |
| Licenses | All clinical licenses plus TDLR laser certificates | Clinic manager |
| PAAs | Signed PAAs, TMB registration, and a current FTE count | Medical director |
| Written orders | Procedure-specific orders citing Chapter 169 | Medical director |
| QA proof | Chart reviews and minutes matching each PAA | Lead NP or PA |
| Posted notices | Physician license notice, TMB complaint notice, and badges | Clinic manager |
| Emergency readiness | BLS cards, emergency meds, and complication protocols | Lead clinician |
| Marketing | Medical director sign-off and accurate staff titles | Owner |
| New services | Updated orders, consents, and training logs before launch | Medical director |
How Medical Director Co. Supports Texas Medspas
Medical Director Co. is a nurse-owned company headquartered at 14114 N Dallas Parkway in Dallas, and Texas is our home market. We match medspas with Texas-licensed MDs and DOs who understand aesthetics, generally within 24 hours. Every agreement goes through attorney review before it reaches your practice.
In-house legal review: Bolton Harris, J.D., a Texas Bar member since 2016 and former Dallas County prosecutor, reviews our attorney-reviewed medical director agreements and PAAs.
Texas-ready paperwork: PAA templates, written orders, and QA logs built for Texas law.
Clear pricing: Plans start at $799 per month, with no setup fees and no long-term contract.
Statewide coverage: We place collaborating physicians across Texas, including Dallas, Houston, Austin, San Antonio, Fort Worth, El Paso, and Arlington.
Our team answers the phone until 11 p.m. every night at (214) 227-9886.
Frequently Asked Questions
Can a nurse practitioner be the medical director of a Texas medspa?
Texas requires the delegating physician for medical procedures to be an MD or DO with an active Texas license. An NP can manage clinical operations, perform good faith exams, and prescribe under a PAA. The medspa still needs a delegating physician behind every medical service it offers.
Can a non-physician own a medspa in Texas?
A non-physician can own the business side through an MSO, but not the medical practice. The clinical entity must be physician-owned and keep control of protocols, records, and treatment decisions. Your management services agreement should spell out that split in writing.
Does a Texas medspa medical director have to be on site?
Texas doesn’t require the delegating physician to be physically present for most delegated procedures. Supervision must still meet the adequacy standard in 22 TAC §169.26. A physician, PA, or APRN must be reachable for emergencies, and someone with BLS training must be on site.
Can estheticians do Botox in Texas?
An esthetics or cosmetology license never authorizes injections on its own. SB 378 would have tightened this, but the governor vetoed it, so physician delegation under Chapter 157 still governs. Before delegating injections to anyone without a nursing license, confirm the plan with your medical director, malpractice carrier, and healthcare attorney.
How fast can a Texas medspa get a medical director?
Medical Director Co. generally matches Texas medspas with a licensed physician within 24 hours. Plans start at $799 per month with no setup fees or long-term contract. Our in-house attorney reviews every agreement before you sign.
Getting Your Texas Medspa Audit-Ready
The Texas medical director requirements for medspas come down to one qualified physician, current paperwork, and proof that oversight actually happens. Pull your written orders this week and check whether any still cite §193.17. If they do, or if your QA logs don’t match your PAAs, start there.
Matched in 24 Hours
Texas-licensed physicians, attorney-reviewed agreements, no setup fees.
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.
