Colorado · Moderate

Do You Need a Medical Director for a Med Spa in Colorado?

Whether Colorado requires a medical director — and what that director is actually on the hook for — shapes your staffing, your liability, and your startup budget. Here's the Colorado picture.

By Evan at Inside MedSpa

Medical director requirement

Required for facilities offering injectable procedures; physician oversight mandatory

Corporate Practice of Medicine

Lenient; no strict CPOM enforcement; non-physicians may own with physician medical director This is the doctrine that decides whether a non-physician can own or control the practice, and it usually travels hand-in-hand with the medical-director question.

Who can supervise or delegate

NP/PA may inject under physician collaboration; independent practice for injectables is not clearly permitted

How the exam ties in

Required; in-person or telehealth allowed under certain conditions

What to verify in Colorado

Establish written physician delegation agreement and confirm medical director availability; clarify telehealth GFE policy with the Colorado Medical Board before implementing.

Primary source: Colorado Medical Board; Colorado Board of Nursing

General business information for Colorado medical-spa owners, current as of 2026 — not legal advice. State boards update rules often; confirm specifics with the Colorado board (and your own counsel) before you act.

See the full Colorado regulation profile →

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