Medical Director for Physician Assistants in Texas

PAs practice under physician supervision in Texas. In aesthetics, that means written delegation, a prescriptive authority agreement, and protocols that match your actual menu.

a medical device with a screen — photo by Sam Moghadam on Unsplash

Supervision has to be documented

A physician assistant in Texas practices under a supervising physician. Clinical training is broad, which suits PAs well to more complex aesthetic work, but the authority to perform it comes from the delegation rather than the license.

Prescribing follows the same pattern as it does for nurse practitioners. Ordering neurotoxins, fillers, or prescription weight management medications requires a prescriptive authority agreement with the supervising physician.

Where PAs typically operate

Advanced injectables

Neurotoxins, fillers, and biostimulators, including the more technically demanding placements, under written protocol.

Complex laser work

Fractional ablative resurfacing and vascular laser treatments, where broader clinical training matters, under the same delegation framework.

Medical weight management

GLP-1 and prescription weight programs, where prescriptive authority and monitoring protocols both have to be in place.

What supervision actually looks like

Texas does not treat supervision as a signature on a contract. The supervising physician remains responsible for care delivered under their delegation, which means protocols that cover your actual procedures, documented training on the specific devices, and genuine accessibility for consultation. A physician who has never worked in aesthetics is accepting exposure they cannot properly assess, and that is usually the relationship that fails first.

Clipboard, pencil, and pen on a wooden surface

What we confirm is in place

  • Written delegation covering every procedure you perform
  • A prescriptive authority agreement if you order prescription products
  • Protocols specific to each device platform
  • A supervising physician with real aesthetics experience

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.

Key takeaways

  • Texas permits entities jointly owned by physicians and physician assistants, but the Medical Board publishes limits on both equity and role.
  • No single PA may hold an interest equal to or greater than any individual physician owner, and PAs collectively stay in the minority.
  • PAs cannot be officers of a corporation, PA or PLLC, and cannot be a general partner or manage a partnership.
  • Jointly owned entities file an annual report, due 30 April each year.
  • Owning part of the practice does not change what a PA may perform or remove supervision.

Joint ownership is allowed, and it is bounded

Physician assistants in Texas are not shut out of ownership. They are constrained inside it, and the constraints are specific enough to design around if you read them before incorporating rather than after.

The Texas Medical Board records that House Bill 2098 (2011) allows entities to be jointly owned by physicians and physician assistants subject to certain limitations, including percent of ownership by physician assistants.

The limits the Board publishes are structural rather than cosmetic. The organizers must be physicians and a physician or physicians must control and manage the entity. On the equity side, A physician assistant or combination of physician assistants can have no more than a minority ownership interest, and The ownership interest of an individual physician assistant cannot not equal or exceed the ownership interest of any individual physician owner.

That second sentence is the one that surprises people. A minority overall is not sufficient on its own: no single PA may match or exceed any single physician owner. A cap table that satisfies the first test can still fail the second.

Roles, not just shares

Ownership percentage is only half of what the Board describes. The other half is what the PA may do inside the entity.

For corporations, professional associations and professional limited liability companies, the Board states that physician assistants cannot be officers. For partnerships, physician assistants cannot be a general partner nor can any physician assistants participate in the management of the partnership.

There is also a conduct limit that survives whatever the documents say: A physician assistant or combination of physician assistants cannot interfere with the practice of medicine by a physician owner or the supervision of physician assistants by a physician owner.

Read together, these rule out the arrangement many aesthetic practices actually run, where the PA is the operator in everything but name and the physician owner is a passive equity holder. The structure has to reflect where clinical control genuinely sits. How that interacts with a management company is covered under MSO and PC structure.

The annual filing date most jointly owned entities miss

Joint ownership is not a one-off registration. It carries a recurring obligation with a fixed date.

The Board states that There are annual reporting requirements for physician and physician assistant owners and that The annual reporting for jointly owned entities is April 30th of each year. It notes that reminders go out to entities that have previously reported, which is precisely why a first-year entity is the one most likely to miss it: there is nothing to remind you.

Put the date in the same calendar as your registration renewals and your protocol review, and treat a change in the ownership split during the year as a trigger to check the position rather than something to reconcile at filing.

Ownership does not settle delegation

A correct cap table authorizes nothing clinically. Those are separate questions answered by different rules.

The Medical Board treats nonsurgical medical cosmetic procedures as the practice of medicine, delegable to appropriately trained individuals, and requires that a physician, PA or APRN either be onsite during the procedure or be immediately available for emergency consultation in the event of an adverse outcome.

A PA who part-owns the entity still performs aesthetic procedures under delegation and supervision, and being an owner does not widen what they may do or remove the supervision requirement. Practices sometimes assume equity converts a PA into an independent operator. It does not. What the written arrangement has to establish is set out in the medical director agreement for a Texas med spa.

Questions PAs ask us

Can I own an aesthetic practice in Texas?
Not the entity providing medical services. That has to be physician-owned. A management company you own can handle business operations alongside a physician-owned clinical entity, drafted by a Texas healthcare attorney.
Does my supervising physician need aesthetics experience?
Nothing requires it, but it matters. They are approving your protocols and carrying responsibility for outcomes. Physicians without aesthetic experience frequently limit what they will authorize, or decline once they understand the exposure.
How many PAs can one physician supervise?
Texas sets limits on delegation, and the practical constraint is whether the physician can provide meaningful oversight for each. We factor a physician’s existing commitments into the match.
Can I supervise other staff?
Within what the delegation allows. Where the arrangement permits, a PA can hold protocol responsibility for RNs performing treatments in the practice.
When does a jointly owned entity have to file its annual report?
The Medical Board states the annual reporting date for jointly owned entities is 30 April each year. It also notes that reminders are sent to entities that have reported before, which is why a first-year entity is the one most at risk of missing it. Diarise it alongside your registration renewals rather than relying on a prompt.
Can a PA hold the largest single stake in the practice?
No. The Board’s published limits are that physician assistants collectively hold no more than a minority interest, and separately that an individual PA’s interest cannot equal or exceed that of any individual physician owner. A split that clears the first test can still fail the second, so check both against the cap table before incorporating.

This page is general information for Texas practice owners and is not legal advice. It is designed to support planning conversations, not to replace them. Rules change and local authority depends on the address; review your own arrangement with Texas healthcare counsel. Last reviewed August 2026.

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