Florida’s aesthetics industry is growing, and more owners want to understand who can serve as a medical director in the state before they open or expand a clinic. This question affects supervision, delegation, protocols, and legal risk.
Many new operators assume an NP or PA can fill the medical director role, but Florida law states that only a Florida-licensed MD or DO can be a medical director for a medical spa. This rule shapes how med spas structure their teams, delegate tasks, and make clinical decisions.
Understanding who can serve as a medical director in Florida is essential for legally opening a medspa and building a safe, scalable operation. This guide explains the state’s expectations, how delegation works, and why physician leadership is central to compliance, patient safety, and long-term growth.
Understanding Who Can Be a Medical Director in Florida
Florida statutes make the medical director’s role clear. If a practice performs medical procedures, the medical director must be a physician. This means a Florida-licensed MD or DO is required for injectables, laser treatments, weight loss medications, IV therapy, and similar services. Non-physicians cannot direct medical care because Florida law assigns medical responsibility, clinical judgment, and supervision authority exclusively to licensed physicians.
This rule often surprises new owners, but it protects both patients and providers. It also ensures that someone with full medical training makes final decisions when complications arise. This is why knowing who can be a medical director in Florida is central to safe staffing and planning.
Why Only Physicians Can Serve as Medical Directors
Medical direction in Florida is tied to the practice of medicine. The state assigns final authority for diagnosis, treatment planning, supervision, and corrective action to physicians. These responsibilities involve decisions that cannot be delegated to another type of provider. As a result, the medical director must hold an active medical license and be able to manage all clinical outcomes.
Here are the core responsibilities that must remain with the physician medical director:
- Final judgment on medical decisions
- Oversight of all delegated medical procedures
- Supervision of injectables, lasers, and prescriptive activity
- Review of charts and escalation needs
- Approval of protocols and treatment menus
These duties require a trained medical decision-maker who can respond in real time when clinical questions or complications arise.
Delegation Rules and Scope Expectations in Florida
After learning who can serve as a medical director in Florida, the next question is usually: what can be delegated and what must stay with the physician. Florida’s delegation rules are detailed, and they outline how clinics must manage tasks, training, and supervision. These rules form a significant part of Florida medical director compliance requirements.
What Physicians May Delegate in a Med Spa
A physician can delegate tasks, but only if they are within the doctor’s scope, safe to delegate, and assigned to someone licensed and trained to perform them. Delegation is helpful, but it has limits. The physician remains responsible for the outcome of every delegated act.
Physicians may delegate certain tasks when protocols and training are in place:
- Injectables and fillers
- Laser and light-based procedures when operators meet state requirements
- Medication administration under a written protocol
- Follow-up visits and selected assessments
- Documentation and charting support
These delegated tasks must follow written protocols that the physician reviews and updates in response to service changes, staff changes, or new devices.
What Cannot Be Delegated in Florida
Some responsibilities cannot be transferred to any non-physician. These duties involve independent medical judgment and must remain under the medical director’s supervision at all times.
Florida protects both patients and practitioners by keeping certain tasks in the physician’s hands:
- Making or confirming a medical diagnosis
- Directing treatment plans
- Managing complications that require medical judgment
- Overseeing prescriptive authority
- Final review of medical records
These expectations form the backbone of medical director requirements in Florida and guide the organization of all clinical services.
What This Means for Med Spa Owners in Florida
Understanding who can be a medical director in Florida helps owners design a safe and efficient clinic. It also avoids the challenges that appear when a clinic relies on the wrong type of oversight. Many new practices assume that an NP or RN can act as the medical director, but this creates compliance risks that can affect insurance, advertising, training, and workflow.
Why Med Spas Need a Physician Medical Director
Injectables, device-based treatments, and IV services are considered medical acts in Florida. These procedures require a supervising physician who sets protocols, defines supervision levels, and responds to clinical needs. When owners understand these rules early, they can legally open a medspa and avoid costly corrections later.
A physician medical director supports the clinic by overseeing the core elements of medical care, namely:
- Protocol design and safety oversight
- Delegation and supervision standards
- Provider training and competency reviews
- Chart review and quality assurance
- Emergency and complication management
These responsibilities ensure the medical system is reliable, consistent, and ready for growth.
Why Strong Medical Direction Supports Growth
Clear supervision helps prevent compliance issues and supports long-term expansion. Clinics with strong medical leadership can add services more confidently, train staff more effectively, and avoid regulatory problems that slow growth. This creates a stable base for expanding to new locations or offering advanced treatments.
Florida’s Key Compliance Expectations
Florida’s rules focus on written documentation, training, supervision, and accurate representation of provider roles. Owners who understand who can be a medical director in Florida are better positioned to meet these expectations from day one.
Common oversight requirements include:
- Written delegation and supervision protocols
- Clear prescriptive and chart review processes
- Device oversight and operator training
- Accurate use of provider titles in marketing
- Emergency and follow-up standards
These expectations help owners stay aligned with Florida medical director compliance rules.
How Medical Director Co. Supports Florida Med Spas
Once owners understand who can be a medical director in Florida, the next step is finding a qualified physician who understands aesthetic oversight. Medical Director Co. streamlines and standardizes this process by matching med spas with Florida-licensed physicians who understand supervision, delegation, and safety requirements.
Our structure is designed to make compliance simple:
- Pricing starts at $799 per month to keep physician oversight accessible.
- No placement fees, which reduces upfront costs for new clinics.
- No MSO premiums, making compliance easier for non-physician owners.
- Complimentary MSO agreements that support safe and legal operating structures.
- No switching fees, so your clinic can adapt as it grows.
- 24-hour nationwide placement for clinics that need fast onboarding.
These advantages help owners move forward without delays or unnecessary costs.
Find a Florida Medical Director with Medical Director Co.
We place licensed medical directors and build compliance frameworks for med spas across the state.
Areas we serve include:
Summary of Key Points
- Only Florida-licensed MDs and DOs can be medical directors for medical aesthetics.
- Delegation rules limit what can be assigned to NPs, PAs, and RNs.
- Med spas must follow medical director requirements in Florida to offer injectables, lasers, and device-based treatments.
- Physicians must oversee protocols, chart reviews, training, and corrective action.
- Strong medical direction supports safety, growth, and long-term profitability.
Final Thoughts
Understanding who can be a medical director in Florida is essential for building a safe and compliant med spa. A qualified physician creates structure, reduces risk, and supports growth in a complex regulatory environment.
Medical Director Co. helps clinics find the right oversight to operate confidently and scale with stability.
FAQs
- Who is legally allowed to be a medical director in Florida?
Only Florida-licensed MDs and DOs may serve in this role. They hold the clinical authority required for medical supervision and delegation. - Why do med spas need a physician medical director?
Services such as injectables, lasers, and IV therapy are medical procedures that require supervision under Florida law. - Can a non-physician own a med spa in Florida?
Yes. But they must follow the rules for opening a medspa legally by hiring a physician to oversee all medical services. - What happens if a clinic uses an NP or PA as a medical director?
It may result in board complaints, insurance denials, or regulatory action because only a physician can fulfill the medical director role. - How can Medical Director Co. help with compliance?
Medical Director Co. matches clinics with licensed physicians who provide compliant oversight, clear protocols, and support tailored to aesthetic practices.

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.