Most searches for a med spa medical director are really searches for a signature. Someone to satisfy the state requirement, collect a monthly fee, and stay out of the way. That arrangement is common, it is cheap, and it is the one that fails when something goes wrong.
Empire faculty who own their own practices describe the relationship differently, and the difference is worth understanding before you sign anything.
What a Med Spa Medical Director Actually Does
Asked to define a med spa at all, Michelle Langston APRN put the medical director first — ahead of the menu, the devices and the premises.
“A med spa to me is an office that has a well-trained leader, a great medical director — whether it’s a nurse practitioner or a physician — that’s actively involved in that clinic,” she said.
Note what that sentence does not say. It does not specify a credential as the qualifying factor, because in many states either can serve depending on scope. What it specifies is involvement.
The functions a working medical director actually performs:
- Sets and signs off the protocols for every procedure on the menu — not only the complicated ones
- Defines what may be delegated, to whom, and under what supervision
- Is reachable during treating hours, and available to see a patient
- Reviews adverse events and changes the protocol when one occurs
- Owns the emergency plan, including what is stocked and who can use it
The Test: Is Your Medical Director Actively Involved?
The clearest illustration of what “actively involved” means in practice is an operational one. Langston plans her own treating schedule around her medical director’s availability.
“I don’t do full facial balancing if I’m going to hop on a plane to teach students the next day,” she said. “I will ask him: I’m going to be out of town on Friday, I’m flying out Thursday night, I’m doing a couple of lips today — do you mind, when I follow up, if there’s something going on, can I send him to your office? If he’s working out of town, then I need to really think about — am I going to reschedule them? And I do.”
Read that again as a standard. She reschedules paying patients when neither she nor her medical director can cover the follow-up window. That is what the relationship is for, and it is the opposite of a signature on a form.
If you cannot imagine having that conversation with your medical director, you do not have one in any meaningful sense.
What to Ask When You Are Looking for a Medical Director
Questions that separate a working relationship from a paper one:
- What are your treating hours, and are you reachable during mine? Overlap matters more than proximity.
- Will you see a patient of mine if one develops a complication? Get the answer before you need it.
- Who covers when you are away? A named person, not a general assurance.
- Will you review and sign the protocol for every procedure I offer? Including the ones you do not personally perform.
- How do you want adverse events reported to you, and how quickly?
- What is your own malpractice position on supervising this practice?
Medical Director Requirements Vary by State
Tatiana Sarmiento, who practices in Florida, treats the board as the first call rather than the last.
“Every state is different, and I always inform my nurses that if you are going to implement something new into your practice, please check with your board of licenses first — if that is part of your scope of practice,” she said. She is direct about the grey areas: in Florida, whether an RN may inject is, in her words, more of a grey area, and her standard advice is to remove the ambiguity by advancing the credential rather than arguing about the boundary.
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What varies by state, and what you therefore cannot take from an article:
- Whether a physician is required, or an NP may direct
- Whether the medical director must be on-site, and how often
- How many practices one director may cover
- Who may perform the good faith exam
- Corporate practice of medicine rules governing who may own the entity at all
Empire covers this layer directly in Aesthetic Practice Legal & Licensing. The board is still the authority for your state.
Why the Regulatory Steps Exist
Dr. Chris Croley, Empire’s Chief Medical Officer, raises the consequence most owners never price in — usually in the context of a supplier promising that something is fine.
“We get solicitation from companies to say, here, you can buy this product, it’s legal,” he said. “The reality is the steps are in place for a reason. There are very strict regulatory requirements, and if there’s a bad outcome there could be civil complaints from the patient where they sue you. There could be criminal complaints or criminal charges.”
A medical director arrangement that exists only on paper is exactly what gets examined first when that happens.
Beyond the Medical Director: the Backup Network You Also Need
A medical director is not the whole of your safety architecture. Melissa Pulcini-Buttine PA argues for a wider set of relationships built before they are needed.
“Network — and if you’re not comfortable in the beginning, I would make friends of my colleagues and have a person to back you up as needed,” she said. “If someone calls me with a complication, I’m there to help them. Make friends. You can make an ophthalmic surgeon friend if you’re doing” work near the eye.
She also names the practical reason the hospital is not the plan: “The ER does not have Hylenex.” Sending a vascular occlusion to an emergency department that does not stock hyaluronidase produces, in her words, a very different workup and a very different outcome. Your network is the plan.
Langston keeps stock deliberately and tells her neighbours so: she carries a dozen vials because she runs trainings, and she has told nearby practices that they can call on her.
How to Find a Medical Director for a Med Spa: Where to Start
- Call your state board first and establish what your state actually requires — credential, on-site frequency, and how many sites one director may cover.
- Look for someone who already practices near you, because overlap in treating hours is the functional requirement.
- Ask the six questions above before discussing fee.
- Put coverage in writing — who sees your patient, at which address, in what timeframe.
- Build the wider network in parallel. A colleague who will take your call, and an oculoplastic or ophthalmic contact if you inject near the eye.
- Agree how protocols get reviewed and how often.
The medical director question is one of the decisions that is hardest to unwind later, which is why it belongs in the plan rather than in the paperwork. Empire covers the business architecture around it in Blueprint for Success and the 3-Day Business Bootcamp.
Medical direction is separate from ownership — who can own a medical spa covers the second question, and how to open a med spa covers the sequence.
The Question Patients Cannot Ask
Langston’s observation about patients applies here too. A patient cannot assess whether your medical director is real. They cannot see the protocol binder, the coverage arrangement or the emergency stock.
Which means the practice that has built it properly gets no credit for it unless it says so — on the website, in the injector bios, and in the consultation.
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