Texas Med Spa Laws: What Applies to Your Practice
A practical guide to clinical authority, ownership, patient evaluations, licensing, and documented physician supervision. Reviewed October 2026.
Start with your services and clinical team
Requirements depend on the treatments offered, the people providing them, and the setting. A business name or facility license does not determine an individual’s authority to perform medical care.
Review each service, device, provider credential, patient evaluation process, and delegation arrangement. Business ownership and clinical scope are separate questions that need their own review.
Three agencies, depending on your menu
Texas Medical Board
Medical practice, physician delegation, and supervision. Medical cosmetic procedures require appropriate clinical authority and qualified personnel.
TDLR
Esthetics, cosmetology establishments, and laser hair removal. Confirm the applicable practitioner and facility requirements for each service.
DSHS
Public health programs including permanent makeup and tanning. Other requirements may apply according to the treatment, device, and setting.
Ownership and clinical control
Texas restricts the corporate practice of medicine, but a blanket statement that no non-physician can hold any ownership interest is inaccurate. Limited physician–PA joint ownership is permitted under specific statutory conditions, with physician control and management.
A management services organization may support business operations. The clinical entity, ownership interests, management fees, and division of authority need individualized review by Texas healthcare counsel. A two-entity arrangement is not automatic proof of compliance.
Core issues to review
- A lawful entity and ownership structure
- Appropriate provider credentials and documented competency
- Patient evaluation, treatment orders, and applicable delegation
- Active supervision, consultation, and emergency escalation
- Facility requirements for the services offered
Active supervision and accountability
The delegating physician remains responsible for delegated medical acts. A signed medical director agreement alone does not establish adequate clinical involvement.
For covered delegated services, TMB’s notice provisions include the delegating physician’s name and license number in public areas and treatment rooms, the physician’s name in advertising, and staff identification with credentials. Review the applicable rule and setting-specific requirements.
Frequently asked
Does every med spa need a medical director?
Medical services require the applicable clinical authority, delegation, and supervision. A title or contract alone is insufficient. Esthetic services within a practitioner’s licensed scope at an appropriately licensed establishment do not require physician delegation simply because the business calls itself a med spa.
What changed in 2025?
TMB reorganized its rules and clarified delegation, supervision, and notice requirements in 2025. Separately, HB 3749 took effect September 1, 2025 and governs elective IV therapy as defined in that law, with specified setting exclusions. It is not a general GLP-1 prescribing law. Review the actual rule, service, and practice setting.
What are the penalties?
Consequences depend on the conduct, professional license, applicable law, and agency involved. They can include licensing discipline and other enforcement. Consult current agency guidance and qualified counsel about a specific situation; this page does not predict an investigation’s outcome.
Do these rules apply to a mobile or telehealth practice?
Clinical and licensing obligations still apply. Telemedicine and mobile care can have additional or setting-specific requirements, so they should not be treated as identical to office care. Review patient evaluations, orders, supervision, record access, and emergency arrangements for each delivery model.
More from Texas Med Spa Directors
Who can own a med spa in Texas · What a medical director costs · Talk to us about your practice · Does a med spa need a medical director?
Primary references: TMB joint ownership · TMB 2025 rule overview · HB 3749.
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