Medical Director for Texas Med Spas
Three agencies, a physician ownership requirement, and delegation rules that changed in 2025. Here is what a Texas med spa has to have in place.
Three regulators, not one
Most Texas med spas answer to three separate agencies depending on their menu. The Texas Medical Board governs medical procedures and physician delegation. TDLR covers esthetic services, cosmetology establishments, and laser hair removal certification. DSHS handles areas including permanent makeup and tanning.
Operators routinely discover the third one late, usually after the first two are handled and a service is already being offered.
What has to be true
Physician-owned clinical entity
Texas prohibits non-physicians from owning the entity that provides medical services. A management company can hold business operations, but clinical authority stays with a physician-owned entity.
Written delegation
Every medical procedure needs standing delegation orders or patient-specific orders, covering the procedure, the device, and the provider performing it.
Correct facility licensing
Esthetic services need a TDLR establishment license. Laser hair removal needs its own facility certification. Your menu determines which apply.
What changed in 2025
Before January 2025 there was real ambiguity about where cosmetic service ended and the practice of medicine began, and many practices built structures inside that gap. TMB Rule 169.28 closed it, and HB 3749 tightened prescribing delegation to PAs and APRNs under physician supervision. Arrangements that were tolerated for years are now violations. If your practice was set up before that and has not been revisited, that is the more urgent conversation.
What we look at first
- Your full treatment menu, service by service
- Who performs each treatment and under what license
- How the entity is owned and who holds clinical authority
- Whether delegation exists in writing for everything you offer
Texas requirement
In Texas, only a physician licensed by the Texas Medical Board, an MD or DO, may serve as a medical director. A nurse practitioner or physician assistant cannot hold the role, though either may perform delegated services under physician supervision.
The medical director’s name and Texas Medical Board license number must be posted in all treatment areas.
Questions med spa owners ask us
Can a non-physician own a med spa in Texas?
Which agencies do we answer to?
Can our medical director work remotely?
We are already open. Where do we start?
Get a read on where you stand
Tell us your services, your city, and whether you are opening or already operating.
(210) 939-8373
Mon-Fri, 9am to 5pm
Tell us about your practice
Two minutes, and no obligation.
More from Texas Med Spa Directors
Who can own a med spa in Texas · Who we are and how we work · Talk to us about your practice · Delegation and standing orders
Ready to talk about your Texas practice?
Share your services and your timeline. We will follow up with the oversight structure that fits.
Talk With Our TeamJoin a Daily WebinarServing practices across Texas