Start with the procedure and the professional
The Texas Medical Board classifies nonsurgical medical cosmetic procedures as medical practice. Its current FAQ points to Rule 169, Subchapter E. Appropriate physician delegation and qualified personnel are central; a training certificate alone does not establish authority to perform every procedure.
TMB: medical spa procedures · Current TMB rules
Ownership and clinical control
Review ownership, employment, management fees and clinical decision-making with Texas healthcare counsel. Do not assume a director agreement resolves an impermissible entity arrangement. Exceptions and permitted structures require individual analysis.
TMB September 2024 bulletin: corporate practice of medicine
Nursing roles and competence
Assess nursing scope for each clinician and procedure. Education, licensed role, population focus, individual competence and the clinical setting matter. APRNs and RNs are not interchangeable, and informal training does not replace the education required for a different license or role.
BON nursing practice FAQ · BON APRN FAQ
Cosmetology, devices and laser services
TDLR distinguishes cosmetology services from medical treatment. A cosmetology or esthetician license does not itself authorize medical procedures. Laser hair removal has separate regulatory requirements; review the exact service, facility and operator requirements before offering it.
TDLR: medical spas · Laser hair removal rules
Patient assessment and remote care
Review patient evaluation, prescribing, documentation, consent and follow-up requirements for the proposed care. A remote arrangement must be assessed under applicable telemedicine and professional rules; this website does not declare remote care appropriate for every patient or service.
TMB rules and practice requirements
Advertising and referral arrangements
Have counsel review professional titles, treatment claims, referral compensation and any fee-sharing arrangement before advertising. Do not promise guaranteed outcomes or imply regulator endorsement.
Regulatory reading: February 2025
In its February 2025 bulletin, the Medical Board emphasized that delegated care still requires active physician involvement. This is historical regulator guidance, not a company announcement or a new 2026 rule.
Read the original TMB bulletin
Sources checked October 20, 2026. This overview is general information; consult the current official text and counsel for your arrangement.