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; physician must oversee the medical spa and delegate procedures

Corporate Practice of Medicine

Lenient; no strict CPOM doctrine; non-physicians may own with physician oversight 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 not clearly permitted

How the exam ties in

Required; in-person exam by physician or qualified provider before treatment

What to verify in Colorado

Retain a Colorado-licensed physician as medical director with clear written delegation protocols for all injectors, and verify current telehealth GFE rules with the Colorado Medical Board.

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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