Can a Physician Assistant Open a Med Spa? [All 50 States Inside]

Ever dreamed of owning your own med spa but weren't sure if it was even possible as a physician assistant (PA)? You're not alone!

The field of medical aesthetics is booming, and PAs are perfectly positioned to use their skills in this exciting field. But the big question remains: Can a PA open a med spa?

The answer, like many things in law, is...it depends.

So buckle up, because we're diving deep into the world of med spa ownership for PAs. We'll explore the different ownership structures available, state-by-state regulations, and how you can overcome hurdles to turn your dream med spa into a reality.

Can a PA open a med spa?

Before we get into that answer, please note that the information provided in this article is for general informational purposes only and does not constitute legal advice. It is recommended to consult with your respective state boards, a licensed attorney, or your malpractice carrier to ensure that you are practicing within the letter of the law and adhering to all regulatory requirements. The regulations regarding aesthetic treatments and medical spas can vary from state to state and may change over time.

For physician assistants (PAs) interested in opening a med spa, the answer depends on the specific regulations of your state.

Let's jump into the ownership possibilities for PAs and explore what’s possible.

Here’s how a PA can own a med spa:

• Independent ownership (Limited): In a small number of states, ownership of medical practices isn't restricted to physicians. Here, PAs could potentially own a med spa outright. But these states often have stricter supervision requirements for the services offered.

• Co-ownership with a physician: A more common scenario involves PAs partnering with a licensed physician. The physician typically holds a majority ownership stake and acts as the medical director, ensuring compliance with state regulations.
  
  This collaboration allows PAs to leverage their expertise while adhering to legal guidelines.

• Minority ownership: Even in states with physician ownership mandates, PAs might be able to hold a minority interest in a med spa. This provides some level of ownership and potential profit sharing, but the final say lies with the majority owner (usually the physician).

• Management services organization (MSO) structure: An MSO is a business entity that manages the non-medical aspects of a medical practice. PAs could work with an MSO that connects them with a physician who acts as the medical director.
  
  This structure allows PAs significant business control while maintaining legal compliance.

What are management services organizations (MSOs)?

Management services organizations (MSOs) are specialized administrative and management companies that provide staffing, administrative, and management services to medical practices like med spas.

MSO arrangements are especially helpful whenever a non-physician wants to be involved in the ownership of a med spa, as they can connect you with services of qualified professionals (medical directors, nurse injectors, etc.) to the medical practice.

State-by-state regulations: States where a PA can open a med spa

Arizona

Physician assistants (PAs) can open a med spa in Arizona, but with a key requirement: A licensed physician must act as the medical director, overseeing the practice and ensuring compliance with state regulations. This can be done via the services of a medical services organization (MSO).

Florida

PAs can open a med spa in Florida. However, Florida law restricts profit-sharing based on the service performed by the supervising physician.

This means PAs cannot receive a higher share of profits solely based on procedures they perform themselves.

Hawaii

PAs can open a med spa in Hawaii, however PAs must practice along with a licensed physician that can be hired through a medical services organization (MSO).

All laser and light procedures, dermal fillers, Botox, collagen injections, and microneedling are considered medical treatments in Hawaii. PAs will likely need to demonstrate additional training or certifications specific to the procedures they perform within the med spa setting, even with physician supervision. 

Iowa

PAs can open a med spa in Iowa, provided that they hire the services of a medical director. Specific procedures like laser treatments and electrolysis may require additional training or certifications for PAs, even with physician supervision. 

Maine

PAs can open a med spa in Maine with a collaborative practice agreement. This involves a licensed physician employed as a medical director, which can be managed via a medical services organization (MSO).

Massachusetts

Under Massachusetts law, non-physicians can also operate a med spa practice as long as they apply for a clinic license from the state’s Department of Public Health.

If the med spa is not owned by a physician, it's recommended to structure it as a professional services organization (PSO) or a Professional Limited Liability Company (PLLC). This legal structure helps ensure compliance with state regulations.

Michigan

PAs can open a med spa in Michigan. However, it's recommended to structure it as a Professional Services Organization (PSO) or a Professional Limited Liability Company (PLLC) to ensure compliance with state regulations.

Mississippi

In Mississippi law, PAs can open a medspa. The PA is also not restricted as far as requirements go for performing procedures as long as it’s with oversight from a medical director.

New Hampshire

PAs can open a med spa in New Hampshire, provided that a licensed physician is involved for specific procedures like laser treatments. This can be through a medical services organization (MSO).

PAs can perform Botox and fillers according to a practice agreement with a physician.

North Carolina

PAs are considered licensed individuals who can co-own med spas in North Carolina and can perform procedures within their scope of practice, as defined by the state.

However, they must consult with a medical director that can be obtained via a medical services organization (MSO).

Oklahoma

PAs can open a med spa in Oklahoma. A licensed physician must be employed by the med spa for oversight of certain medical services, which include injections, laser treatments, and other procedures.

South Carolina

PAs can open med spas in South Carolina. There are no strict ownership restrictions, but the medical board requires proper training and documentation for all non-licensed personnel performing delegated tasks.

Plus, a licensed physician is only allowed to supervise up to PAs or other non-physicians in the practice.

Utah

PAs can open a med spa in Utah. While any doctor can perform cosmetic injections without additional training, all procedures are considered medical treatments by the state.

This means PAs can perform procedures within their scope of practice, but with oversight from a medical director. This can be done via a medical services organization (MSO).

Wyoming

PAs can open a med spa in Wyoming. The state allows ownership by both licensed professionals and non-physicians.

State-by-state regulations: States where a PA cannot open a med spa

Need help launching your med spa? Try Moxie.

Moxie empowers aspiring medspa owners across the country to launch faster, manage their operations, and achieve real success.

We help you go from idea to launch and ease the burden of legal work and paperwork, so you can focus on what you do best — providing exceptional care to your clients.

Here's how Moxie can help your med spa thrive:

• Find a medical director without hassle: Moxie can pair you with the right and qualified med spa medical director for your practice through our extensive network of professionals.

• Simplify compliance: Moxie provides pre-made consent forms and protocols crafted by industry-leading lawyers and MDs, saving you thousands on legal fees. (That's up to $10,000+ back in your pocket!)

• Marketing done for you: Moxie manages everything from website creation (under your brand) to targeted advertising that drives new clients through your doors.

• Hands-on, expert coaching: Our dedicated coaches meet with you regularly to support your growth, give you hands-on help, and guide you through the process of growing your medspa.

Book a Free Strategy Session Today and See How We Can Help.