Medical director requirement
Required; physician must supervise all injectable procedures.
Corporate Practice of Medicine
Strict; physician ownership or MSO structure required. 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 not permitted for injectables.
How the exam ties in
Required; in-person exam mandatory before treatment.
What to verify in New York
Verify physician supervision structure and ensure all staff delegation complies with NY Department of Health regulations.
Primary source: NY Department of Health; NY Medical Board
General business information for New York medical-spa owners, current as of 2026 — not legal advice. State boards update rules often; confirm specifics with the New York board (and your own counsel) before you act.