Policies & Compliance

AI Med Spa Compliance Checklist

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1. Introduction and Purpose

This Med Spa Compliance Guide is designed to help med spa owners, medical directors, practitioners, and beauty professionals operate compliantly and effectively. It incorporates industry standards, regulatory expectations across jurisdictions, and practical operational guidance. Customize all [[merge fields]] with your specific details before use. Med spas straddle cosmetology and medical practice rules.

2. Key Requirements and Best Practices

Secure appropriate medical director or supervising physician oversight per state medical board rules.
Distinguish purely cosmetic services (board of cosmetology) from those requiring medical delegation or prescription.
Implement good-faith exams or consultations before certain procedures.
Use a detailed, modality-specific informed consent form and document the conversation, not just the signature.
Maintain higher standards for record retention, adverse event reporting, and advertising claims.
Ensure all practitioners operate within their licensed scope; never allow unlicensed medical acts.

3. Day-to-Day Compliance Checklist

Identify the medical director or supervising physician and confirm the delegation agreement is on file and current.

Map every service to the correct regulatory bucket: purely cosmetic, or medical requiring physician oversight.

Confirm good-faith exam and standing-order paperwork exists for every modality that requires it.

Run the same consultation, screening, and consent process for every laser, injectable, or microneedling client.

Log every procedure, product, and setting, plus any complication, the same day it happens.

Check marketing claims and before/after photos against FDA, FTC, and state medical-board advertising rules.

Update consent and intake forms every time a new service or device is added.

Keep medical and non-medical records separated where the state requires it.

Audit delegation protocols, equipment calibration logs, and staff credentials on a regular schedule.

Require documented competency training before anyone performs an advanced modality.

Have a healthcare attorney review CPOM ownership structure and fee-splitting exposure at least once a year.

Revisit this checklist whenever the medical board or FDA changes a relevant rule.

4. Tables and Checklists

Use simple tables (max 6 columns) for reference.

| Service Category | Typical Oversight | Consent Required | Record Retention | Notes |
|------------------|-------------------|------------------|------------------|-------|
| Cosmetic facials | Cosmetology license | Standard | Per board | No medical claim |
| Laser hair removal | Varies by state | Detailed | 3-7 years | MD or delegate often |
| Neurotoxin/filler | Medical director | Enhanced + risks | 7+ years | Prescription drug |
| Microneedling depth | Depends on depth | Specific | Per protocol | May cross categories |
| IV therapy | Medical | Full medical | Medical standards | Strict rules |

5. Resources

Primary oversight: State Medical Board + Board of Cosmetology (dual jurisdiction common)
FDA for devices and drugs; FTC for advertising
American Med Spa Association (AmSpa) guidelines and state law summaries
Malpractice carriers specializing in medical aesthetics
Legal counsel experienced in corporate practice of medicine (CPOM) doctrines

6. Disclaimer and Verification

This is a professional sample template for Med Spa Compliance Guide. It is not legal, tax, licensing, or professional (medical) advice. Requirements vary dramatically by state and change frequently. Verify every rule, supervision requirement, advertising restriction, and procedure classification with the relevant state medical board, board of cosmetology, and qualified healthcare/legal professionals before use. As of 2026-06.

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State medical-board scope-of-practice + HIPAA compliance checklist with supervision model.

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Criteria

01Scope-of-practice and medical-director/supervising-physician requirements by state
02Good-faith exam and delegation/standing-orders rules
03Injector licensure (RN/NP/PA) and supervision ratios
04HIPAA + medical-record retention
05Informed consent per treatment (Botox, fillers, lasers, IV)
06Adverse-event protocol and emergency meds
07Sharps/biohazard and infection control
08Product sourcing (FDA-approved, no gray-market)
09CLIA where labs apply
10Corporate practice of medicine (CPOM)/MSO structure.