Disclaimer: This content is provided for educational and informational purposes only and should not be interpreted as legal advice, medical advice, or official regulatory guidance. Washington medical director duties, delegation rules, prescribing regulations, and telehealth standards may change over time. Always verify current requirements directly with the Washington State Department of Health, the Washington Medical Commission, the Washington Nursing Care Quality Assurance Commission, the Washington Pharmacy Quality Assurance Commission, and consult qualified healthcare legal counsel before making operational or compliance decisions.
Executive Summary
- The medical director must be a Washington-licensed physician, MD or DO, who retains authority over medical decision-making. Business owners may manage administrative and operational functions through management arrangements, but they may not control diagnosis, treatment, prescribing, or clinical supervision under Washington Corporate Practice of Medicine principles and RCW 18.71.
- Physicians may delegate medical services and support prescribing by physician assistants through written practice agreements. Advanced registered nurse practitioners practice independently within their licensed scope. Practice agreements and internal policies should clearly define authorized services, provider availability, consultation and referral expectations, emergency coverage, and ongoing quality review. These documents should be revised when staffing, services, or treatment modalities change.
- Washington compliance is shaped by statutory requirements, administrative rules, and professional standards of care. Regulatory review commonly focuses on supervision structures, documentation integrity, controlled substance prescribing, telehealth compliance, and whether daily workflows align with written agreements and internal policies. Clinics should periodically assess their structure and procedures against current Department of Health and commission guidance.
- Injectables, laser procedures, and other energy-based treatments are considered the practice of medicine in Washington when they involve medical assessment or treatment. Practices are expected to maintain provider-approved protocols, documented training and competency validation, supervision frameworks where required, and appropriate device and treatment records tied to licensed provider oversight.
- Although Washington does not have a standalone aesthetics statute specific to medspas, regulatory scrutiny has increased regarding who performs cosmetic procedures, how supervision and practice agreements are structured, and whether marketing accurately reflects provider licensure and involvement. Clear delegation policies, consistent documentation, and transparent advertising remain central risk management tools.
Washington compliance is shaped by four intersecting authorities:
- Washington Medical Commission: Physician licensure, scope of practice, delegation, supervision, and enforcement under RCW 18.71 and the Uniform Disciplinary Act.
- Washington Nursing Care Quality Assurance Commission: ARNP scope of practice and independent prescribing authority under RCW 18.79.
- Washington Pharmacy Quality Assurance Commission: Regulation of dispensing, compounding, pharmacy operations, and controlled substance compliance.
- Corporate Practice of Medicine principles: Restrictions on nonlicensed control of clinical judgment, ensuring that diagnosis, treatment, and prescribing remain under licensed provider authority.
If you are launching or expanding an outpatient practice in Washington, whether a medspa, telehealth service, behavioral health clinic, weight management program, or IV wellness practice, this guide explains how the key regulatory components align and identifies the core documentation Washington regulators expect clinics to maintain.
Quick Compliance Checklist
Use this monthly and assign each item to a responsible person such as the medical director, ARNP or PA lead, RN lead, or clinic manager.
Clinical decision-making remains under licensed provider authority consistent with RCW 18.71 and the Uniform Disciplinary Act. Any MSO or management agreement clearly separates administrative services from diagnosis, treatment, prescribing, and supervision. Nonclinical owners do not direct medical judgment.
The medical director holds an active Washington MD or DO license. ARNPs, PAs, and RNs maintain current Washington licensure within scope. PAs have a current written practice agreement. DEA registration is active when controlled substances are prescribed. PMP registration and use requirements are met.
Written delegation documents define scope of services, training requirements, competency validation, and supervision structure. Policies are updated when services or staffing change.
ARNPs prescribe under full practice authority within scope. PAs prescribe pursuant to a written practice agreement. Internal policies outline medication categories, consultation pathways, and quality review expectations.
Maintain chart or case review documentation, PA supervision records, incident logs, and PMP query documentation. Oversight activity is documented consistently and aligns with written policies.
Maintain provider-approved protocols, documented training, competency sign-offs, supervision structure where required, and device maintenance logs.
Advertising complies with RCW 19.86. Titles and claims accurately reflect licensure, scope of practice, and supervision structure.
The Legal Frame: CPOM + Who Can Be a “Medical Director”
What Is CPOM in Washington?
Washington regulates the practice of medicine under RCW 18.71 and the Uniform Disciplinary Act, RCW 18.130. While Washington does not codify CPOM as a single statute, the Corporate Practice of Medicine doctrine is recognized through case law and enforcement. Licensed providers must retain authority over medical judgment, supervision, and prescribing.
Clinical decisions, delegation of medical services, and medical record oversight must remain under licensed provider control. Business entities may provide administrative services such as marketing, staffing, leasing, and billing, but they may not direct or interfere with medical decision-making. The Washington Medical Commission evaluates compliance based on whether medical care is controlled by properly licensed professionals.
Who Can Be a Medical Director?
A medical director in Washington is typically a physician licensed under RCW 18.71 or RCW 18.57 and in active, good standing status. Specialty is less important than the provider’s competence to oversee the services offered, supervise delegated acts under applicable Washington statutes, and fulfill quality oversight responsibilities.
Regulators expect documented involvement in clinical policies, delegation arrangements, and quality assurance activities that reflect actual provider oversight.
Delegation & Prescriptive Authority (APRNs/PAs): The Documents that Matter
Washington governs delegation and prescriptive authority through RCW 18.71, RCW 18.71A, RCW 18.79, the Uniform Disciplinary Act, and applicable Washington Administrative Code rules enforced by the Department of Health and professional commissions.
- Delegation of medical acts: Physicians in Washington may delegate medical services to ARNPs and PAs when the tasks fall within the individual’s licensure, education, and training. Written policies should clearly describe which procedures or services may be performed, required competency and training standards, supervision expectations for PAs, and the physician’s ongoing responsibility for patient care where applicable.
- Prescriptive authority and practice agreements: ARNPs in Washington have full practice authority and may prescribe within their scope of licensure. PAs may prescribe medications pursuant to a written practice agreement with a supervising physician that complies with Washington law. Practice agreements should specify the scope of prescriptive authority, categories of medications authorized, consultation and referral processes, physician availability, and any quality review or oversight mechanisms such as periodic chart review. Agreements must reflect actual clinical practice and remain current as services or staffing evolve.
Practical Tips That Survive Audits
- Avoid setting oversight requirements that are unrealistic to maintain. Choose a chart review cadence and meeting schedule that can be followed consistently, and keep written proof of those activities. Summaries of reviewed cases, dated attendance records, and documented follow-up actions demonstrate that supervision is active and not merely theoretical.
- Keep a centralized oversight tracker. Maintain an updated record of PA supervising physicians, any applicable ARNP relationships, effective dates of agreements, scope of delegated services, and revisions over time. When services expand or staffing changes occur, update practice agreements and protocols immediately so internal documentation mirrors how care is actually delivered.
- Document competency, not just credentials. Providers performing injections, operating devices, or delivering delegated services should have signed skills validations tied to specific protocols. Maintain training records, proof of supervised evaluations when required, and renewal tracking to support ongoing qualification under Washington standards of care.
Program-Specific Spotlight
Medspas (Injectables, Energy Devices, Skin Procedures)
- Injectables, including onabotulinumtoxinA, Botox®, and dermal fillers, are considered the practice of medicine in Washington when they involve medical assessment and treatment. Delegation frameworks and written clinical protocols should address patient evaluation standards, dosing parameters, product and lot tracking, management of complications such as anaphylaxis or vascular occlusion, and clear escalation procedures to the supervising physician when necessary. Oversight expectations are grounded in RCW 18.71 and enforced by the Washington Medical Commission.
- Laser and other energy-based procedures are not regulated through a separate medspa facility license in Washington, but they are treated as medical services when they affect living tissue. Clinics should maintain provider-approved protocols, documented training and competency validation, defined supervision structures where required, and equipment service logs. Acquisition and clinical use of devices should be supported by written policies that reflect licensed provider oversight.
- Regulatory climate: Washington regulators continue to examine who is performing aesthetic services, how supervision or practice agreements are structured, and whether public-facing materials accurately represent licensure and scope. Even without an aesthetics-specific statute, enforcement actions often focus on improper delegation, insufficient documentation, and marketing that suggests unsupervised or independent medical authority where it does not legally exist.
Telehealth (Virtual Primary Care, Psychiatry, Weight Management)
- Supervision and delegation in remote settings: In Washington, physicians may supervise PAs providing telehealth services so long as supervision structures, communication pathways, and quality oversight are active and documented. ARNPs practice independently within their scope, including in telehealth settings. Written practice agreements for PAs and internal clinical policies should address telehealth workflows, provider availability, consultation procedures, and how medical records are accessed for chart or case review. Oversight must comply with RCW 18.71, RCW 18.71A, RCW 18.79, and applicable Department of Health rules.
- Prescribing via telemedicine: Telehealth prescribing in Washington must meet the same standard of care as in-person treatment and comply with state and federal requirements, including controlled substance regulations when applicable. Clinical documentation should confirm patient identity, informed consent, clinical evaluation, and treatment planning. Electronic prescribing must comply with Washington and federal law, and prescribing practices should align with applicable practice agreements and internal policies, particularly for psychiatric services and weight management programs.
Psychiatry & Behavioral Health
Collaboration and supervision in psychiatry and behavioral health settings must follow Washington scope of practice statutes, including RCW 18.71, RCW 18.79, and RCW 18.71A, along with applicable standards of care enforced by the Washington Medical Commission and Department of Health. Physicians supervise PAs pursuant to written practice agreements, while ARNPs practice independently within their licensed scope.
Clinics should implement safeguards for controlled substances, including active DEA registration, Washington Prescription Monitoring Program checks, crisis escalation protocols, and documented case or chart reviews as part of their quality assurance process.
Weight Loss & Wellness (GLP-1s, Phentermine, IV Therapy)
Written clinical policies in Washington should clearly define which medications and treatment categories are permitted or excluded, including GLP-1 agents and controlled substances such as phentermine, consistent with RCW 18.71, RCW 18.79, and Washington Pharmacy Quality Assurance Commission requirements. Protocols should address baseline medical evaluations, ongoing monitoring schedules, and adverse event response procedures.
For IV therapy services, clinics should maintain medication inventory logs, provider-approved treatment protocols, and documented staff training, along with emergency response procedures that include anaphylaxis management and escalation pathways.
The Paperwork Washington Regulators Actually Ask to See
When a complaint, payer audit, or commission investigation occurs, Washington regulators expect documentation that supports how your clinic operates in practice. Records should be current, internally consistent, and readily available for production.
- Entity & Governance: Organizational documents should demonstrate that clinical authority is exercised by licensed providers. Management or administrative service agreements must clearly outline that business entities do not control diagnosis, treatment decisions, prescribing, or supervision. Governance records should reflect compliance with Washington Corporate Practice of Medicine principles.
- Licenses & Registrations: Maintain proof of active Washington licensure for the medical director and all clinical staff, including MDs, DOs, ARNPs, PAs, and RNs as applicable. DEA registrations must be valid where controlled substances are prescribed. Any required Washington registrations connected to pharmacy, telehealth, or specialty services should also be documented.
- Practice Agreements: Written practice agreements for PAs must accurately describe scope of duties, prescriptive authority, physician availability, and consultation expectations. Internal documentation should support ARNP independent prescribing within the Washington scope of practice and reflect actual clinical workflows.
- Delegation & Scope Matrix: Keep a written reference identifying which provider types are authorized to perform specific services. Include required training benchmarks, competency validation processes, and review timelines. This document should match how services are delivered day to day.
- Protocols & Consents: Procedure-specific clinical guidelines and patient consent forms should be maintained for injectables, device-based treatments, IV therapy, and related services. Protocols should address evaluation criteria, dosing standards where applicable, risk disclosure, and emergency response steps.
- Device & Procedure Records, if applicable: Retain documentation showing that staff operating lasers or energy-based equipment have completed training and competency validation. Maintenance logs and service records should demonstrate that devices are properly maintained and used under approved protocols.
- Quality Oversight Records: Maintain evidence of chart reviews, case discussions, quality meetings, incident tracking, and corrective actions. Documentation should show ongoing provider involvement in monitoring patient care and compliance.
- Marketing Review Documentation: Keep internal review records confirming that advertising materials, provider titles, and service descriptions accurately represent licensure, scope of practice, and supervision structure in accordance with Washington law.
Washington Telehealth Documentation Standards
- Confirm and record patient identity, informed consent, clinical evaluation findings, and treatment decisions in accordance with Washington law, including RCW 18.71, RCW 18.79, and applicable Department of Health telehealth regulations. Documentation should support that a valid provider-patient relationship has been established.
- Prescribing through telehealth must meet the same professional standard of care as in-person services and comply with Washington and federal controlled substance requirements when applicable, including Prescription Monitoring Program obligations.
- Medical records must be securely stored, readily accessible for supervising physician review where required, and available for production in the event of a Washington Medical Commission inquiry, Department of Health investigation, or payer audit.
Delegation in Telehealth
- Written practice agreements for PAs in Washington should expressly address telehealth services, including remote prescribing authority, supervision expectations, and communication pathways. Although ARNPs practice independently, internal clinical policies should clarify consultation procedures and oversight structures for virtual care delivery.
- Defined escalation procedures must be in place for urgent or high-risk situations, including psychiatric emergencies and medication-related complications, with clear documentation of referral or physician involvement when required.
- Supervising physicians for PAs must have reliable remote access to patient records to facilitate chart review, quality monitoring, and ongoing clinical oversight consistent with Washington standards.
Telehealth Weight Loss Prescribing
- GLP-1 medications: In Washington, GLP-1 agents may be prescribed through telehealth once a valid provider-patient relationship has been established and appropriately documented under state law and the applicable standard of care.
- Phentermine: As a Schedule IV controlled substance, phentermine may be prescribed via telehealth when clinically justified, but it presents increased regulatory scrutiny. Documentation should reflect the Washington Prescription Monitoring Program review, medical necessity, and a defined follow-up plan consistent with controlled substance rules.
- Best practice: Before initiating controlled substances for weight management, a real-time audiovisual evaluation or in-person visit is strongly recommended, along with structured monitoring, reassessment intervals, and clear documentation of ongoing risk evaluation.
Avoid These Common Washington Mistakes
- Treating the medical director role as nominal. If the physician is not actively involved in developing clinical protocols, overseeing delegated services, and participating in quality review, the structure may raise concerns under Washington law. Business or management entities must not direct diagnosis, treatment decisions, or prescribing authority.
- Failing to revise practice agreements. Adding new services, introducing devices, or modifying provider responsibilities without updating written PA practice agreements or internal clinical policies creates inconsistencies between documentation and real-world operations, which may draw attention during a commission review.
- Weak quality oversight documentation. When chart reviews, case conferences, or supervisory activities are sporadic or poorly recorded, regulators may question whether oversight is substantive. Monitoring processes should be organized, repeatable, and consistently documented.
- Downplaying the medical nature of aesthetic services. Injectables, laser treatments, and energy-based procedures are considered the practice of medicine in Washington when they involve diagnosis or treatment. They require provider-approved protocols, appropriate training, and documented oversight.
- Overstating provider involvement in marketing. Public materials that suggest greater physician supervision than actually exists or imply independent medical authority beyond a provider’s legal scope may create regulatory exposure. Advertising should accurately reflect licensure, scope of practice, and supervision structure.
Step-by-Step: Building a Defensible Washington Setup (30/60/90 Plan)
Days 1–30: Foundation
- Evaluate the practice structure: Confirm that clinical authority is exercised by a properly licensed Washington provider. Review management or administrative service agreements to ensure nonclinical parties do not influence diagnosis, treatment decisions, prescribing, or supervision, consistent with Washington Corporate Practice of Medicine principles.
- Confirm licenses and registrations: Conduct a credential audit of all clinical personnel, including Washington MD or DO licensure, ARNP, PA, and RN licenses, and DEA registrations when controlled substances are prescribed. Verify that each credential supports the services currently offered and address any discrepancies before expanding operations.
- Establish core clinical documentation: Prepare or revise written delegation policies, PA practice agreements, and procedure-specific clinical protocols. These materials should outline communication channels, escalation processes, emergency response coverage, and quality monitoring expectations, and they must reflect how care is actually delivered in everyday operations.
Days 31–60: QA in Motion
- Set the oversight cadence: Conduct your initial quality review meeting, determine a manageable chart or case audit volume, and record observations along with any corrective measures. Reliability and documentation matter more than reviewing a high number of charts.
- Run an internal compliance check: Complete a structured self-audit against Washington requirements for delegation, PA practice agreements, and quality oversight under RCW 18.71, RCW 18.71A, RCW 18.79, and related Department of Health rules. If aesthetic or device-based services are offered, specifically review training records, competency documentation, and protocol alignment. Resolve deficiencies before scaling services.
- Review public-facing communications: Audit your website, marketing materials, and patient forms to ensure provider titles, credentials, and service descriptions accurately reflect Washington licensure and supervision structures. Consider including a short disclosure explaining provider oversight and patient safety standards to support transparency.
Days 61–90: Harden & Scale
- Confirm competency records: Verify that injectors and device operators have completed documented skills assessments, including supervised evaluations where applicable and dated competency sign-offs. Maintain organized training files and renewal tracking to support continued qualification under Washington standards of care.
- Improve audit readiness: Ensure supervising physicians for PAs have dependable remote access to patient records to conduct oversight and quality review. Documentation should be structured, current, and easily retrievable in the event of a Washington Medical Commission inquiry, Department of Health investigation, or payer audit.
- Control service expansion: Before introducing new procedures or equipment, complete required provider training, update clinical protocols, revise PA practice agreements if responsibilities change, and confirm that marketing language accurately reflects provider licensure and scope under Washington law.
FAQs
Can a nonphysician own a clinic in Washington?
Yes. A nonphysician may own or invest in the business entity, but they may not control medical judgment or the practice of medicine. Diagnosis, treatment decisions, prescribing, and clinical supervision must remain under licensed provider authority consistent with Washington Corporate Practice of Medicine principles. Many clinics use management service agreements to separate administrative functions from clinical control.
Who is eligible to serve as a medical director in Washington?
A medical director is typically a Washington-licensed MD or DO in active, good-standing status. The physician’s specialty is less important than their competence to oversee the services offered, establish delegation frameworks, supervise PAs where required, and participate in ongoing quality assurance activities.
What written agreements are required for ARNP or PA prescribing in Washington?
ARNPs have full practice authority and may prescribe within their licensed scope without a collaborative physician agreement. PAs must practice under a written practice agreement with a supervising physician that defines scope, prescriptive authority, consultation expectations, and oversight responsibilities. These documents should reflect actual clinical operations and remain current.
Do aesthetic services such as laser procedures require separate paperwork?
Washington does not issue a standalone medspa facility license specific to laser services, but aesthetic and energy-based treatments are considered the practice of medicine when they involve diagnosis or treatment. Clinics should maintain provider-approved protocols, documented training, competency validation, and oversight records that can be produced during a review or audit.
Have Washington regulators increased scrutiny of injectables and medspas?
Yes. Regulatory attention has focused on scope of practice compliance, supervision or practice agreement structures, and whether marketing accurately represents licensure and provider involvement. Clinics that maintain clear delegation policies, thorough documentation, and consistent quality oversight are generally better positioned during regulatory review.
How Medical Director Co. Fits into Washington Compliance
Medical Director Co. supports clinics in developing structured, practical compliance systems that align with Washington regulatory expectations and the realities of outpatient care.
- Washington-licensed physicians: Access to Washington MDs and DOs with experience in medspas, telehealth, behavioral health, and weight management services who understand delegation rules, PA practice agreements, and documentation standards under Washington law.
- Practice agreement and supervision support: Assistance drafting and maintaining PA practice agreements and internal prescribing and oversight policies that reflect scope of practice, provider availability, and day-to-day clinical workflows.
- Sustainable quality oversight: Practical tools for chart review, case audit documentation, meeting records, and oversight tracking that are manageable to maintain and defensible if reviewed by the Washington Medical Commission or Department of Health.
- Aesthetic and procedural compliance: Guidance on clinical protocol development, competency validation, training documentation, and oversight structures for injectables, laser treatments, and other energy-based services.
- Practice structure alignment: Review of management and governance arrangements to help ensure medical decision-making remains under licensed provider authority consistent with Washington Corporate Practice of Medicine principles.
- Regulatory monitoring: Ongoing awareness of updates from the Washington Medical Commission, Nursing Care Quality Assurance Commission, and Pharmacy Quality Assurance Commission, with recommendations on when internal policy or workflow changes may be appropriate.
Areas We Serve
We provide licensed medical directors and compliance support for clinics throughout Washington, including major metropolitan areas:
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.
