Michigan — Med Spa Medical Director

Medical Director Requirements for a Med Spa in Michigan

Whether you need a medical director in Michigan, who can serve, how the role differs from ownership, and how to pay them without crossing fee-splitting lines — from Michigan board and statutory sources, reviewed by Faisal Darwiche, NP.

Michigan at a glance

NP practice authorityRestricted Practice
Medical director required?Yes — physician medical director
Who can serveLicensed physician (MD/DO)
Who performs the GFEPhysician, NP, or PA — never an RN
Can an RN own the business?Yes — via the compliant structure
CompensationFair-market-value — never a % of medical revenue

Last reviewed 2026-06-27 · Faisal Darwiche, NP. General guidance, not legal advice — confirm with your Michigan board and counsel.

Does Michigan require a medical director for a med spa?

In Michigan the safe, recognized setup puts a physician (MD/DO) at the top as medical director — the clinical entity has to be physician-owned, and cosmetic injectables are treated as the practice of medicine, so an actively involved physician medical director who writes the protocols and oversees delegation is the clean route, with the RN injecting under that delegation. One Michigan nuance worth knowing: because an NP can independently prescribe non-controlled drugs like neurotoxins and fillers, an NP can serve as the prescriber for the good-faith exam and treatment orders — but whether an NP alone can be the medical director and the delegating authority for an RN injector isn't settled under current Michigan law, so plan on a physician medical director and let a Michigan healthcare attorney confirm any NP-led arrangement before you rely on it. Either way, an RN needs a physician in the chain.

  • Physician (MD/DO) medical director — actively involved, writes protocols, oversees delegation (safe/clean route)
  • NP may serve as prescriber for the GFE/orders on non-controlled injectables (MCL 333.17211a)
  • NP-as-sole-medical-director / NP-delegating-to-RN is unsettled under current MI law — confirm with counsel (do not assert)

Sources: MCL 333.16215 (delegation by a licensee) + MCL 333.17211a (APRN non-controlled prescribing) · Michigan AG Opinion No. 6770 (1993) — CPOM: medical entity physician-owned · Verified 2026-06-26.

Medical director vs. owner — they're not the same thing

The medical director is clinically responsible for the practice; the owner holds the business. In Michigan they can be the same person or two different people. The common structure for non-physician owners separates the two: a management company (the business) contracts a physician-led clinical entity (the medicine). The medical director supplies the exams, orders, and protocols; the owner runs marketing, staffing, and facilities.

In Michigan you can absolutely own and run an aesthetics practice — it's structure, not a no. Michigan follows the corporate-practice-of-medicine doctrine and treats cosmetic injectables as the practice of medicine, so the entity that delivers the medicine has to be owned by licensed professionals — a physician-owned PC or PLLC — which means an RN can't directly own that clinical entity. The clean, recognized path: you own a management company (an MSO handling the business side — marketing, billing, staffing, facilities) that contracts with a physician-owned professional corporation through a fair-market-value management services agreement. You inject under delegation; the good faith exam and treatment orders come from your prescriber. Net: an RN absolutely can own and operate a med spa in Michigan with the right setup — just have the exact entity structure papered by a Michigan healthcare attorney.

  • RN owns an MSO / management LLC (business side only: marketing, billing, staffing, facilities, equipment)
  • MSO contracts a physician-owned clinical PC/PLLC via a FMV MSA (fee not a % of medical revenue)
  • Clinical entity owned by licensed professionals (MCL 450.1284 PC / 450.4904 PLLC); physician ownership is the safe route

Sources: Michigan Professional Corporations — MCL 450.1284 (each PC shareholder licensed in the service the PC renders) · Michigan AG Opinion No. 6770 (1993) — corporation may not provide medical care via employed/contracted physicians (CPOM) · Verified 2026-06-26.

How to pay a medical director in Michigan (without fee-splitting)

Compensate the medical director at fair-market-value for the clinical work they actually do — a flat retainer or hourly rate, documented. Paying them a percentage of treatment revenue is the classic fee-splitting trap. Keep the management fee (to the business entity) and the medical-director fee (for clinical oversight) as separate, defensible line items, and have a Michigan healthcare attorney paper both before you sign.

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Frequently asked

Does a med spa in Michigan need a medical director?

Yes. Michigan treats cosmetic injectables as the practice of medicine, so a physician medical director is the standard requirement — they perform or delegate the good faith exam, author the protocols, and stay genuinely involved. A nominal "paper" director is a compliance risk.

Who can be a medical director for a med spa in Michigan?

In Michigan the medical director is the licensed physician (MD/DO) who is clinically responsible for the practice — performing or delegating exams, signing standardized procedures, and being reachable. The role is clinical oversight, not a signature for hire; the involvement has to be real and documented.

How much does a medical director cost, and can it be a percentage of revenue?

Medical-director compensation in Michigan should be fair-market-value for the actual clinical work — a flat or hourly fee, not a percentage of medical revenue. Paying a cut of treatment revenue risks illegal fee-splitting. Structure the management fee and the medical-director fee separately, and have counsel paper both.

Can an RN own a Michigan med spa and just hire a medical director?

Yes — with the right structure. An RN owns the business side (typically an MSO), and the clinical entity is physician-led with a medical director who supplies the exams and orders. The RN injects under that delegation. Your attorney papers the exact entity for Michigan.

Keep going in Michigan

Good Faith Exam rules in Michigan
Who can perform it · telehealth
Open a Med Spa in Michigan
The full 90-day setup path
Michigan NP scope of practice
Source-cited scope deep-dive
All credential × state guides
The national hub

General guidance only. Not legal advice. State statutes change — verify with the Michigan Board of Nursing and a Michigan healthcare attorney before relying on this content.

Online training does not constitute hands-on clinical certification.

Reviewed 2026-06-27 by Faisal Darwiche, NP — 27 years, three practices opened. Read the master guide at /open-medspa.