✨ Aesthetic / Medical Spa · Texas
Texas: what a medical director of a aesthetic / medical spa must do
Whether Texas requires a physician medical director for a aesthetic / medical spa, the qualifications you need, and the duties the rule assigns.
Qualifications
Active, unrestricted Texas MD/DO license in good standing with the Texas Medical Board; must maintain documentation of hands-on training in each delegated cosmetic procedure.
Duties the rule assigns
- establish the patient relationship and maintain records
- sign written orders identifying the delegating physician and screening criteria
- confirm/document training for each delegated act
- remain available for emergency consultation (on-site presence not required unless the physician chooses that supervision mode)
- ensure the facility posts the delegating physician's name and TMB license number, plus a complaint-notice, in public areas and treatment rooms
Notes
Texas Medical Board rule (22 TAC §§169.25-169.28, effective Jan. 9, 2025, replacing former §193.17) does NOT use the term 'medical director' — it requires a named 'delegating physician' whose identity/license must be posted at the facility. Functionally similar to a medical-director designation (a specific physician is legally answerable and must be publicly identified) but the terminology and legal theory (delegation of a medical act, not facility licensure) differ — flagged for attorney review before equating the two.
Delegated services in this practice type
Business ownership and clinical authority are separate questions in this practice type. What the state says about the staff who deliver the services.
Registered Nurses
RNs (general licensure, not an APRN) are not subject to physician supervision in Texas — 22 Tex. Admin. Code § 217.11 imposes a 'directed, supervised' scope only on LVNs, by contrast with RNs' unsupervised practice. Nonsurgical medical-cosmetic procedures (Botox, fillers, energy-device treatments) are separately classified as the practice of medicine requiring physician delegation (22 Tex. Admin. Code §§ 169.25–.29, eff. Jan. 9, 2025) regardless of RN licensure.
For medical-aesthetics (med-spa) businesses performing nonsurgical medical-cosmetic procedures, 22 Tex. Admin. Code §§ 169.25–.29 (eff. Jan. 9, 2025, replacing former § 193.17) classifies those procedures as the practice of medicine requiring physician delegation, on-site signage naming the delegating physician, and staff ID badges — the RN may not own the clinical entity performing them; the common workaround (secondary-sourced, law-firm guidance) is an MSO structure where the RN owns the business/management side and a physician-owned PLLC holds the clinical entity. Separately, H.B. 3749 ('Jenifer's Law,' 89th Leg., eff. Sept. 1, 2025) newly restricts who may administer elective IV therapy to physicians, PAs, APRNs, and RNs, with prescribing/ordering still requiring physician delegation to PAs/APRNs — directly relevant to RN-staffed IV-hydration/med-spa businesses.
Estheticians
Licensed estheticians (Tex. Occ. Code Ch. 1602; 16 Tex. Admin. Code Ch. 83) practice independently within TDLR's defined scope — light/superficial exfoliation, facial treatments, non-laser hair removal, eyelash extensions. No physician involvement required. Lasers/IPL, botulinum toxin/filler injections, and chemical peels reaching live tissue are excluded from that license entirely and separately regulated by the Texas Medical Board as medical procedures (22 Tex. Admin. Code Ch. 169, incl. §§ 169.25-.26).
Mirrors the RN med-spa-ownership pattern elsewhere in this dataset: business ownership and clinical-procedure authority are separate questions.
Every agreement Texas names · Aesthetic / Medical Spa in other states