Medical director requirement

Required; physician must be present or immediately available for all injectable procedures

Corporate Practice of Medicine

Strict; Corporate Practice of Medicine doctrine enforced; physician ownership or MSO with tight physician control 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 cannot inject; physician collaboration required but does not permit independent injectable authority

How the exam ties in

Required; in-person exam mandatory before treatment

What to verify in Pennsylvania

Ensure a licensed MD or DO owns or controls the medical spa and is present for all injectable procedures; verify CPOM compliance with Pennsylvania Medical Board counsel.

Primary source: Pennsylvania Medical Board

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

See the full Pennsylvania regulation profile →