On this page
- What a medical director actually does
- Who can be a medical director
- Do you need one
- What is a good faith exam, and why it drives everything else
- What a medical director costs
- Where to find one
- How to vet one
- How to pay one without creating a problem
- The arrangement that will not survive scrutiny
- Four ways to get clinical cover, compared
- The other way to answer the question
- Glossary
How to find a medical director for a med spa
Most med spa owners find a medical director through their own network, a local dermatology or emergency medicine practice, or a supervision company that places physicians remotely. Reported retainers run from about $500 to $10,000 a month depending on how involved the physician is. The harder part is not finding one. It is finding one who will actually do the work.
What a medical director actually does
The title is misleading. A medical director is not a figurehead who signs a form once a year. In most states the physician is the legal owner of the clinical care your business delivers, and the paperwork has to show that.
The duties that come up consistently across state rules and supervision agreements:
- Writing and approving treatment protocols. Dosing, contraindications, patient selection, what to do when something goes wrong.
- The good faith exam. A patient has to be evaluated and a physician relationship established before a delegated treatment happens. Texas rules, for example, require that “the physician relationship has to exist before the delegated act” and that the record shows it, according to Pabau’s 2026 summary of the Texas rules.
- Patient-specific orders. The instruction that authorises a specific treatment for a specific patient.
- Delegation and supervision. Confirming that each nurse, PA or esthetician is trained for each act delegated to them, and that the act is inside their licence.
- Chart audits on a set schedule, not when a regulator asks.
- Emergency planning, and being reachable when something goes wrong.
- Carrying malpractice cover that extends to the directorial role, which is not automatic.
Two acronyms you will meet immediately: GFE, the good faith exam, and PSO, the patient-specific order. Vendors use them constantly and rarely define them.
Who can be a medical director
In most states, an MD or DO with an active, unrestricted licence in the state where the patient is treated. That is the short answer, and it is the answer for the large majority of med spas.
The longer answer has three exceptions worth knowing, because each one saves or costs real money.
Nurse practitioners. In states that grant full practice authority, a nurse practitioner can lead a practice under their own licence and, in some of those states, hold the director role. In the rest, an NP still needs a collaborating or supervising physician, so hiring one does not remove the physician from the equation. This is one of the most state-dependent questions in the whole subject and it is worth a call to your board rather than a forum answer.
Physician assistants. A PA practises under physician supervision almost everywhere, so a PA generally cannot be the medical director in the sense the state means. Texas allows PAs and APRNs into certain oversight roles under written protocols, which is not the same as replacing the delegating physician.
Chiropractors, dentists, podiatrists. A chiropractor cannot serve as the medical director of a med spa offering injectables or prescription therapies. The licence does not extend to those acts, so it cannot authorise someone else to perform them. The same logic applies to any licence limited to a specific body region or modality.
Estheticians and non-clinical owners. You cannot be your own medical director, and in states applying the corporate practice of medicine doctrine you generally cannot employ the physician either. That is the whole reason the two-entity structure exists: a physician-owned professional entity that holds the clinical side, and a management company you own that handles everything else.
One rule cuts across all of it. Whoever holds the role must be able to perform, or lawfully delegate, every act your business delivers. A director whose licence does not reach your treatment menu is not a director for those treatments, whatever the contract says.
Do you need one?
Almost certainly, if you are offering anything that counts as the practice of medicine in your state, which typically includes injectables, most lasers, and prescription weight management.
Beyond that, the honest answer is that it depends on your state and we are not going to pretend otherwise. Med spa regulation is genuinely inconsistent across the US, and it is set by different bodies in different states. Texas alone involves three: the Texas Medical Board, the Board of Nursing, and the Department of Licensing and Regulation.
What varies most:
- Who may own the clinical entity. In states that apply the corporate practice of medicine doctrine, a non-physician cannot employ a physician to practise medicine, which usually pushes owners into a two-entity structure: a physician-owned professional entity plus a management company that handles everything non-clinical.
- How close the supervision has to be. California’s medical board expects the supervising physician to be immediately reachable even when off site, per ABAC Training’s 2026 guide. Other states are looser about presence and stricter about documentation.
- Whether a mid-level can hold the role. In a small number of states, nurse practitioners with full practice authority can lead a practice under their own licence.
None of that is legal advice, and the rules move. Texas moved its delegation rules from 22 TAC 193.17 to Chapter 169 in January 2025, and added a requirement that the physician’s name and licence number be posted in every treatment room. Check your own state board directly, and get a healthcare attorney in your state to look at your structure before you sign anything.
What about an IV hydration or weight loss business?
Same question, same answer, with one difference that catches people out. IV hydration and medical weight loss both involve prescription products, so the prescriber question arrives on day one rather than later.
Owners looking for a medical director for an IV hydration business usually search for exactly that, and find the same supervision companies that serve med spas. They are the same service. What changes is the protocol set: IV formulations, contraindications and the standing orders for who may cannulate. If you are adding weight management, add the prescribing pathway for GLP-1 therapy, which is a separate conversation with a separate risk profile.
An RN can typically own an IV hydration business in states without physician-ownership restrictions, but almost nowhere can they write the order that authorises the infusion. That order is the thing you are buying.
What is a good faith exam, and why it drives everything else
A good faith exam is the evaluation that establishes a clinician-patient relationship and authorises treatment. Someone qualified assesses the patient, reviews their history, confirms the treatment is appropriate for them, and documents it. It has to happen before the treatment, not alongside it and not afterwards.
Almost every compliance failure in this industry traces back to this one document. The injector was trained, the product was genuine, the protocol was sound, and there was no valid exam on file authorising that patient to receive that treatment on that day.
Who can perform it depends on the state. Commonly a physician, and in many states a nurse practitioner or physician assistant operating within their scope and under the relevant agreement. The person performing the exam is establishing the clinical relationship, so it cannot be delegated to someone whose licence does not permit it, and it is not a form the front desk fills in.
Can it be done by telehealth? In many states, yes, and an industry of remote good faith exam providers has grown up around exactly that. It is one of the more common reasons a med spa engages a supervision company rather than a local physician. Whether a remote exam satisfies your state is a question for your board, and the answer has been moving.
What it has to contain. At minimum: identity and date, relevant medical history and medications, allergies and contraindications, the assessment, the specific treatment authorised, and the signature and credentials of whoever performed it. Templates circulate widely. Treat a downloaded template as a starting structure that your own medical director adapts and signs off, never as a compliance document in itself.
How it connects to the rest. The good faith exam authorises the patient. The patient-specific order authorises the treatment for that patient. The standing order or protocol tells the injector how to perform it. Delegation confirms the injector is permitted to. Miss any one of the four and the chain breaks, and it is the chain, not the individual document, that a board examines.
For an IV hydration business the same requirement applies before an infusion, with a different history to take: hydration status, renal considerations, the specific formulation. Weight management adds another layer again, because a prescription is involved.
What a medical director costs
Two numbers get quoted in this market and they describe completely different things. Owners compare them against each other and come away confused, so it is worth separating them before looking at any figure.
A fractional medical director is a physician who supervises your business alongside their own practice. You pay a monthly retainer. This is what almost every med spa actually buys.
An employed medical director is a job. ZipRecruiter’s posting data puts the US average for a med spa medical director role at $232,369 a year, $111.72 an hour, with a median of $235,200 and a 75th percentile of $284,500. That is a real number, and it is irrelevant to a single-location spa. A $799 a month supervision service and a $232,000 a year hire are not competing offers.
Everything below is the fractional market.
By how involved the physician is
| Level | Reported monthly cost | What it buys |
|---|---|---|
| Nominal or on-call | $500 to $1,500 | Protocols signed, reachable by phone, occasional remote chart review |
| Engaged part-time | $2,000 to $5,000 | Regular chart review, site visits every month or two, protocol maintenance |
| Hands-on | $5,000 to $10,000+ | Regular on-site presence, performs good faith exams and procedures |
Sources: Pabau and Consentz both report those three bands. MedSpa Standards sets the same tiers slightly higher, at $1,500 to $3,000, $3,000 to $6,000 and $6,000 to $10,000+, and puts the national band at $1,500 to $8,000+ a month or $200 to $500 an hour. Consentz quotes an hourly alternative of $150 to $300.
By state
| State | Reported range |
|---|---|
| California | $4,000 to $8,000+ |
| New York | $4,000 to $8,000 |
| Texas | $3,000 to $6,000 |
| Georgia | $2,500 to $6,000 |
| Florida | $2,000 to $5,000 |
| Arizona | $2,000 to $5,000 |
Source: MedSpa Standards, 2026. California and New York run highest, which tracks both physician wages and how closely those boards supervise.
By your size
ABAC Training reports $1,000 to $1,250 a month for a single-injector spa, rising past $3,500 once you have three or more providers. At the fixed-price end, Medical Director Co. advertises $799 a month including a collaborative practice agreement and malpractice cover.
Price scales with your provider count, not your revenue. So the cost per treatment falls as you grow, and it hurts most in year one when you can least afford it.
The arithmetic nobody puts on their pricing page
Take the cheap tier and divide it by the hourly rate the same market quotes. At $200 to $300 an hour, a $500 to $1,500 monthly retainer buys somewhere between two and eight hours of physician time a month. A $799 service buys about four.
Now look at the duty list again: protocol authorship, chart audits, good faith exam oversight, delegation confirmation for every provider and every act, emergency availability. Four hours a month does not cover that for a busy spa, and the physician knows it.
This is the whole reason the cheap tier exists and the whole reason it is risky. The American Med Spa Association is blunt about where the line sits: a med spa cannot pay “for the use of the physician’s license, which is prohibited in every state”. If the retainer only makes sense as a payment for a signature, that is what it is.
Where to find one
Six channels, and the sensible approach is to work several at once rather than in sequence.
- Your own network. The highest hit rate and the most durable arrangements. A physician who already knows you is more likely to actually take the calls.
- Local practices. Dermatology, plastic surgery, emergency medicine and family medicine. Emergency physicians are often available and comfortable with protocol-driven work.
- Supervision and staffing companies. They will place someone quickly. Quality of oversight varies enormously and the cheapest tier is usually the thinnest.
- Management services organisations. Common in states with physician-ownership restrictions, because the MSO structure is the answer to that problem anyway.
- Telehealth supervision services, where your state permits remote oversight and remote good faith exams.
- Industry bodies. AmSpa and your state medical society, which are also where you will hear which arrangements are being challenged.
How to vet one
Five screens, in the order that saves the most time:
- Licence. Active and unrestricted in your state. Verify it on the state board site yourself rather than taking a copy of a certificate.
- Disciplinary history. Public, and worth ten minutes.
- Insurance. Professional liability that explicitly covers directorial duties, confirmed in writing by the carrier, not asserted in an email.
- Relevant experience. Aesthetic, dermatologic or emergency medicine background beats a general licence.
- Real availability, not paper availability. Ask directly how many other businesses they oversee, how often they will review charts, and what their response time is when someone has a vascular occlusion at 6pm on a Friday. The answer to that last question tells you most of what you need.
Seven questions to ask before you sign
- How many other businesses do you currently oversee, and where are they?
- How often will you review charts, and will you sign and date each review?
- Will you come on site, and how often?
- Who performs the good faith exams, you or someone you delegate to, and how?
- What is your response time for an emergency, a same-day complication, and a routine question?
- Does your malpractice policy name this directorial role, and can I see the confirmation from your carrier?
- Which of the treatments on my menu are you not comfortable authorising?
The last question is the one that separates a real director from a signature. A physician who answers “all of them, no problem” without looking at your menu has not read it.
How to pay one without creating a problem
Pay a flat retainer or an hourly rate, set at fair market value for the physician’s time. Do not pay a percentage of revenue and do not pay per treatment.
The American Med Spa Association’s guidance on the amount is fair market value, which it concedes is “simple but unhelpful”, and it declines to publish ranges at all. What it is specific about is structure: compensation must not create an incentive tied to referrals or volume, and a med spa cannot pay “for the use of the physician’s license, which is prohibited in every state”.
That rules out more than the obvious. Out: a percentage of revenue or collections, a per-treatment or per-encounter fee, a bonus indexed to patient numbers, and a retainer that steps up at patient-count thresholds. In: a flat monthly retainer, a documented hourly rate with contemporaneous time logs, or a base retainer plus hourly for defined extra work such as new protocols or incident reviews.
One step that costs nothing and is worth doing before the first payment. Write a short memo recording the duties, the estimated monthly hours, the comparable rates you found, and how you arrived at the number. If the arrangement is ever questioned, a dated valuation memo is worth more than the contract language.
The contract itself should set out scope of oversight, a delegation grid naming each procedure and the licence class permitted to perform it, the chart review and site visit cadence, named emergency response windows, malpractice and indemnification terms, and how either side exits with enough notice to arrange cover.
One more thing regulators now look at, which is not in the contract at all. Oversight is judged on documentation: dated chart review logs, signed protocols, site visit records, per-patient authorisation evidence. A perfect agreement with an empty file is not a defence.
The arrangement that will not survive scrutiny
There is a version of this that is widely sold and increasingly risky. A physician signs the protocols, appears on the paperwork, oversees a dozen businesses they have never visited, and is paid a few hundred dollars a month to be a name.
The tells are consistent. A director who will not commit to a chart review schedule. One who is licensed in a different state and plans to supervise remotely where the state does not clearly allow it. One who signs protocols they have not read. One who cannot tell you how many other sites they cover.
Medical boards in New York, Florida, Georgia, California and Texas have all been active on this. The exposure sits with the business, not only the physician, and it tends to surface at the worst possible moment, which is after an adverse event.
If the arrangement you are being offered costs less than the physician’s time is worth, you are not buying supervision. You are buying a document.
What happens if you do not have one
Consequences vary by state and by what went wrong, and anyone quoting you a single national penalty figure is guessing. What is consistent is where the exposure lands.
The business faces the unlicensed-practice-of-medicine question, which is the serious one, because it is not cured by fixing the paperwork afterwards. The physician faces board action over the supervision itself. The injector faces their own board over scope. Insurance is the quiet problem: a professional liability policy generally responds to care delivered within a lawful structure, and a carrier that decides the structure was not lawful may decline the claim, which is usually when an owner discovers the arrangement was thin.
The practical trigger is almost never a routine inspection. It is a patient complaint, an adverse event, or a disgruntled former employee, and by then the file either supports you or it does not.
Four ways to get clinical cover, compared
Owners tend to compare medical director quotes against each other without noticing there are four different structures on the table, only two of which are really the same product.
| Fractional medical director | Employed medical director | MSO with a physician-owned entity | Independent physician group provides the service | |
|---|---|---|---|---|
| Typical cost | $1,500 to $6,000 a month | $120,000 to $250,000 a year | Setup and legal, plus the physician’s compensation | Per-treatment platform fee |
| What you get | Oversight of care your staff delivers | The same, with a physician on staff | A compliant ownership structure, not a service | The clinical service itself, delivered by their clinicians |
| Who treats the patient | Your staff | Your staff | Your staff | Their licensed clinicians |
| Who is the prescriber | The director | The director | The physician entity | The independent group |
| State coverage | Wherever that physician is licensed | Same | Wherever the entity is licensed | Wherever the group is licensed |
| Set-up time | Weeks | Months | Months, plus counsel | Days |
| Best when | You deliver treatments in your own building | You are large enough to justify a salary | You need to solve ownership in a CPOM state | You want to offer a service you cannot deliver yourself |
The last column is a different answer to the question rather than a cheaper version of the first three. It does not help with the botox you inject on site. It does help if the reason you are hunting for a medical director is that you want to add a prescription service you have no way of delivering.
The other way to answer the question
Everything above assumes you are building the clinical service yourself and need a physician to own it.
There is a different structure, and it is worth understanding before you spend six months and several thousand dollars a month solving the problem the hard way. In it, you do not hire the prescriber at all. The clinical service sits with an independent, physician-led medical group whose licensed clinicians evaluate the client and prescribe where appropriate. You offer the program under your own brand, set your own retail price, and stay entirely outside the practice of medicine.
That is how Spa Healthcare works. The prescribing group is Beluga Health, an independent Florida professional corporation. The partner sells the program to their client; Local Healthcare provides the platform and collects payment as the partner’s billing agent; the clinician is independent. Prescription treatments are provided only where an independent, licensed clinician determines they are clinically appropriate after reviewing a client’s health history, and not everyone qualifies. Availability varies by state.
It does not remove your obligations for the treatments you already deliver in your own building. If you inject, you still need supervision for that. What it does is stop the list of services you can offer from being limited by which physician you can afford to retain this year.
On price, we publish the only fee we charge: $50 per treatment, per month. Medication and fulfilment are billed at cost and quoted to you directly, because pharmacy product pricing varies by product, strength and pharmacy, and any figure published here would be wrong for most readers. Any figures shown are illustrative, not a promise of income. What a partner earns depends on the retail price it sets, its patient volume and retention. The partnership agreement is the controlling document.
Beluga’s clinicians are licensed across all fifty states, so the programs are not limited to the handful of states a single retained physician happens to hold a licence in. That is the practical difference for a multi-location operator, or for anyone whose clients move.
Glossary
The vocabulary is used loosely by vendors and precisely by regulators, which is a bad combination when you are comparing quotes.
Good faith exam (GFE). The evaluation establishing a clinician-patient relationship and authorising treatment, performed before the treatment.
Patient-specific order (PSO). The instruction authorising a named treatment for a named patient, following the good faith exam.
Standing order. A written instruction covering a defined treatment for a defined category of patient, so a qualified staff member can act without a fresh order each time. It does not replace the patient-specific authorisation where the state requires one.
Protocol. The clinical document setting out how a treatment is performed: dosing, technique, patient selection, contraindications, and what to do when something goes wrong.
Delegation. The physician’s act of authorising a specific person to perform a specific act, having confirmed they are trained and licensed for it. Delegation is per person and per act, not blanket.
Delegating physician. Texas terminology for the role most states call the medical director or supervising physician.
Collaborative practice agreement. The written agreement between a physician and a nurse practitioner or physician assistant setting out the scope of what the mid-level may do. Required in states without full practice authority.
Corporate practice of medicine (CPOM). The doctrine, applied in many states, that a non-physician may not employ a physician to practise medicine or own a medical practice.
Management services organisation (MSO). The non-clinical company that provides premises, staff, marketing, billing and administration to a physician-owned clinical entity. The standard answer to CPOM.
Fair market value (FMV). The compensation standard for a medical director. It means the market rate for the physician’s time and duties, arrived at and documented independently of what the business earns.
Fee splitting. Paying a clinician a share of revenue or a per-patient amount. Prohibited in most states and the reason medical director pay is a flat retainer or an hourly rate.