What states require a collaborating physician for NP medspa?

Here's the breakdown by category. State classifications are sourced from the AANP State Practice Environment (Updated: 05/2026).

REDUCED PRACTICE STATES (12) — Collaborative agreement with a physician required for full prescribing authority. Most NP-owned medspas use the MSO/PC structure.

Alabama, Arkansas, Illinois, Indiana, Louisiana, Michigan, Mississippi, Missouri, New Jersey, Ohio, Pennsylvania, Wisconsin.

RESTRICTED PRACTICE STATES (10) — Physician supervision required. The MSO/PC structure is the standard NP-aesthetic ownership path.

California, Florida, Georgia, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, Virginia (conditional — 5-year experience pathway exists).

FULL PRACTICE STATES (27 + DC) — No career-long collaborative agreement required. NPs may own and operate solo (some have brief post-licensure transition periods of 1,000–3,600 hours, after which independent practice is granted).

Alaska, Arizona, Colorado, Connecticut (post 2,000 hours), Delaware, Hawaii, Idaho, Iowa, Kansas, Kentucky (4-year for Schedule II only), Maine, Maryland (post 18 months), Massachusetts, Minnesota (post 2,080 hours), Montana, Nebraska (post 2,000 hours), Nevada, New Hampshire, New Mexico, New York (post 3,600 hours), North Dakota, Oregon, Rhode Island, South Dakota, Utah (post 2-year for controlled substances), Vermont (post 24 months), Washington, West Virginia, Wyoming, plus the District of Columbia.

A few specific points worth knowing:

California is the most restrictive due to a strict Corporate Practice of Medicine doctrine. AB890 (2020) created a Category 103 pathway to independent practice for NPs with 3+ years of experience plus mentorship — but most NP-owned aesthetic practices in CA still operate under the MSO/PC structure.

Florida passed an autonomous-practice statute in 2020 for primary care, but it explicitly excluded aesthetic services. Florida is still treated as Restricted Practice for medspa purposes.

Virginia has a 5-year experience pathway to autonomous practice. NPs with 5+ years of full-time clinical experience may apply.

Texas, New York, Illinois, and California all enforce strict CPOM doctrines. The MSO/PC structure is essential in these states and state-specific counsel review is non-negotiable.

For each state, the structural and market detail lives at /open-medspa-in-[state]. The source-cited scope-of-practice deep-dive lives at /scope-of-practice/[state].