Ownership rules
Non-physicians may own with physician medical director; MSO model permitted
Corporate Practice of Medicine
Lenient; no strict CPOM doctrine; non-physicians may own with physician oversight
The medical-director angle
Required; physician must oversee the medical spa and delegate procedures Ownership and the medical-director requirement are usually two sides of the same compliance coin.
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.