Medical Director
The rent-a-doc era is over.
For twenty years, a med spa could satisfy the supervision requirement with a physician’s signature and nothing else. In 2026, that arrangement is what gets your clinic closed. We do the other thing: a physician who actually approves your protocols, reviews your charts, credentials your staff, and picks up the phone.
Seven questions. No email required. Answer them honestly.
2026 enforcement
2 in 5
New York med spas were cited for violations in the state’s 2026 enforcement sweep. Georgia’s medical board has moved against matchmaker supervisor platforms outright. California, Texas, and Florida are all enforcing a genuine-oversight standard.
“Real, not nominal.” — the phrase regulators are using
The oversight audit
Seven questions a regulator would ask you.
These are the checks that come up in enforcement actions. Tick the ones you can honestly answer yes to. Nobody is watching — the point is for you to know before someone else finds out.
Work through the seven checks above. Each one maps to something a state board has cited a med spa for.
This audit is general information, not legal advice. Requirements vary by state and change. What it will tell you is whether your arrangement looks like the ones being enforced against — and that is usually enough to know whether you have a problem.
The job
What a medical director is actually obligated to do.
Not “be available in an emergency.” Not “be on the paperwork.” These are the specific, documentable acts that state boards look for.
Approve and sign protocols
Every treatment protocol and standing order, signed by the physician before a single patient receives that treatment. Injectables, lasers, peels, IV therapy — each one.
Review charts, on a schedule
Documented, recurring chart review. Not occasional. Not “when something looks off.” A cadence you can produce a log for.
Credential the clinical staff
Every RN, NP, PA, and aesthetician performing a delegated procedure is credentialed by the physician, and the delegation is in writing.
Confirm scope of practice
Every procedure performed by a non-physician has to sit inside that person’s license. A laser manufacturer’s certificate is not a license.
Be reachable
Available for clinical questions while the clinic is open. A physician nobody can reach during business hours is not supervising anyone.
Review complaints and adverse events
Patient complaints and adverse outcomes go to the physician, get reviewed, and get documented. That log is the first thing a board asks for.
The distinction that matters
Nominal supervision is not supervision.
Every state that has moved on med spas in the last eighteen months has drawn the same line. It isn’t about whether you have a medical director. It’s about whether the one you have is doing anything.
Nominal — what is being enforced against
- A signature on a contract and nothing after it
- Protocols written by a device rep, or by nobody
- No chart review, or no record that any happened
- Unreachable during operating hours
- Paid a percentage of revenue or per treatment
- Has never seen the clinic, the staff, or a chart
- Licensed in a different state than the clinic
Real — what EliteUSMD provides
- Protocols reviewed and signed by the physician before go-live
- Documented chart review on a set cadence, with a log you can produce
- Staff credentialed and delegation put in writing, by procedure and license type
- Reachable for clinical questions during operating hours
- Flat monthly fee at fair market value — never a cut of revenue
- Standing monthly meeting with your clinical team
- Licensed in your state. Always. No exceptions, no workarounds
How your director is paid
If you pay a percentage, you have a bigger problem than supervision.
Paying a medical director a share of revenue, or a fee per treatment, is fee-splitting. Depending on your state and what’s being prescribed, it can implicate anti-kickback and corporate-practice rules — which is a different and much worse category of exposure than a documentation gap.
This is one of the most common structural mistakes in the industry, and it is usually made by owners who thought they were being generous.
Do not do this
Compensation that moves with volume ties a physician’s clinical judgment to your revenue. That’s the thing regulators are looking for.
Do this
The physician gets paid the same whether you did forty treatments or four hundred. Which is the entire point — it’s what makes their sign-off worth something.
Who qualifies
Not everyone with a license can be your medical director.
This trips up more clinics than any other single question, usually after they’ve already hired someone.
License type
Can serve as medical director?
The detail that catches people out
Physician (MD or DO)
yes
Must hold an active, unrestricted license in the state where your clinic operates. An excellent physician licensed one state over cannot serve. Most states do not require an aesthetics specialty — emergency medicine, family medicine, and internal medicine all qualify.
Nurse Practitioner
Depends entirely on the state
In full-practice-authority states, an NP may own and clinically direct a practice. In restricted states — including California, New York, and Texas — an NP cannot serve as medical director, no matter how experienced.
Physician Assistant
No
A PA practices under physician supervision by definition. Someone who requires supervision cannot be the supervisor.
RN, LPN, aesthetician
No
No certification, no device training, and no manufacturer credential changes this. Calling a non-physician “medical director” does not transfer medical authority to them — but it may increase your exposure.
Rules vary by state and change. Tell us where your clinic is and we will tell you what applies there.
How EliteUSMD works
We are not a matchmaking service.
EliteUSMD is a physician-owned medical group. The physician who oversees your clinic contracts with us, is credentialed by us, and is held to a standard by us. We are not a directory that hands you a name and disappears.
1
We look at what you actually do
Which treatments, which staff, which licenses, which state. That determines what supervision is required — not the other way around.
15 minutes
2
You're matched with a physician licensed in your state
Credentialed, in good standing, and experienced with the service lines you offer. We verify licensure before placement and monitor it continuously after.
EliteUSMD
3
Protocols and the written agreement
We prepare the protocols and the delegation agreement — every procedure listed specifically, matched to the staff license type authorized to perform it, with chart-review cadence and termination terms in writing. Your physician reviews and signs.
EliteUSMD
4
Oversight starts, and keeps going
Chart review on schedule. A standing monthly meeting with your clinical team. Reachable for clinical questions. Good Faith Exams running through the program from day one, so every patient is cleared against the protocols your physician approved.
Ongoing
Typical time from signing to live: three to four weeks.
What you actually get
When a board opens a file, they ask for documents.
Not for a description of your oversight. For the paperwork. Everything below exists from the day you go live, and stays current — so if you’re ever asked, the answer is a folder, not an explanation.
Signed treatment protocols and standing orders
Every service line you offer, reviewed and signed by your physician before the first patient. Updated when you add a treatment.
A written delegation agreement
Every treatment protocol and standing order, signed by the physician before a single patient receives that treatment. Injectables, lasers, peels, IV therapy — each one.
A chart review log
Dated, recurring, and producible on request. This is usually the first thing asked for and the first thing missing.
Staff credentialing records
Every treatment protocol and standing order, signed by the physician before a single patient receives that treatment. Injectables, lasers, peels, IV therapy — each one.
Good Faith Exam records
Ongoing license monitoring
Your physician’s licensure is verified before placement and monitored continuously after. A lapsed license discovered by a regulator is a very different day than one we caught first.
Month to month. No long-term contract. No placement fee.
Questions
What clinics ask us.
Does my medical director have to be on site?
It depends on the state and the procedure. Most states do not mandate a fixed on-site frequency but do require the physician to be genuinely available — reachable during operating hours, reviewing charts on a documented schedule, and involved in the clinical operation. Some states have more defined expectations around physician presence for specific procedures. Tell us your state and your service lines and we will tell you what applies.
Can I keep the medical director I already have?
Sometimes. If they are licensed in your state, in good standing, and willing to do the actual work — approve protocols, review charts, credential staff, be reachable — then the arrangement may be sound and just needs to be documented properly. Run the audit above. If you scored well, your problem may be paperwork rather than structure. If you didn’t, we should talk.
What happens if a patient complains, or a board opens a file?
You will be asked to produce documents: the signed protocols, the delegation agreement, the chart review log, the credentialing records, and the Good Faith Exam for the patient in question. If those exist and are current, you are in a defensible position. If they don’t, the absence is the finding. Everything in our program is built so those documents exist before anyone asks.
Do I have to use your Good Faith Exam?
Yes. Clinics in the program run their exams through our process. This isn’t an upsell — it’s the only way the physician can approve your protocols and stand behind the clearances being issued under them. A medical director who doesn’t know how patients are being cleared isn’t supervising anything.
Does your physician oversee controlled substances?
No. Physicians in our network oversee non-controlled substances only. If your service lines require controlled-substance oversight, we will tell you that up front rather than after you have signed.
Who carries malpractice insurance?
The clinic maintains malpractice coverage for its staff and for the medical director’s supervisory role. We will tell you what the coverage needs to include during onboarding.
Is any of this legal advice?
No. EliteUSMD is not a law firm and does not provide legal services. Everything on this page is general information about how supervision requirements commonly work. It is not a substitute for advice from an attorney licensed in your state, and you should get that advice. What we provide is the physician oversight itself — the protocols, the chart review, the credentialing, the documentation.
Find out where you stand before someone else does.
Fifteen minutes. Tell us your state and your treatments, and we will tell you what supervision your clinic actually needs — and whether what you have now would hold up.
Month to month. No long-term contract. No placement fee.