Medical Spa Laws in California
California enforces the corporate practice of medicine doctrine strictly, requiring physician ownership or a compliant MSO structure for medical spas. A licensed physician must supervise all injections and treatments, and patients must receive an in-person good-faith exam before any procedure. The regulatory environment is among the most restrictive in the nation; non-physician ownership is generally prohibited unless structured through a physician-owned MSO.
- Who can inject
- MD/DO, NP, PA, RN under physician supervision; scope varies by provider type
- Medical director requirement
- Required; physician must supervise all injections and oversee facility protocols
- Good-faith exam
- Required; in-person exam by physician before treatment (telehealth may be limited)
- Corporate Practice of Medicine
- Strict; physician ownership or MSO model required; corporate practice of medicine doctrine applies
- Recent regulatory activity
- Ongoing board guidance on scope of practice for NPs and PAs in aesthetic medicine; verify current regulations.
Do this in California
Consult with California legal counsel on corporate structure (physician-owned entity or compliant MSO) and confirm your supervising physician's scope of practice with the Medical Board.
California medical spa FAQs
Can a non-physician own a medical spa in California?
Generally no, due to California's strict corporate practice of medicine doctrine. Ownership must be physician-controlled, either directly or through a compliant MSO structure; consult counsel on permissible arrangements.
What is the role of the medical director in a California medical spa?
The medical director (a licensed physician) must supervise all injections, oversee treatment protocols, maintain patient records, and ensure compliance with state regulations. The extent of on-site presence should be documented.
Are telehealth exams allowed before Botox or filler injections?
In-person exams are generally required for initial treatment; telehealth may be limited or prohibited for aesthetic injections—verify with the California Medical Board for current guidance on your specific treatment.
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