Tennessee — Med Spa Medical Director
Whether you need a medical director in Tennessee, who can serve, how the role differs from ownership, and how to pay them without crossing fee-splitting lines — from Tennessee board and statutory sources, reviewed by Faisal Darwiche, NP.
Last reviewed 2026-06-27 · Faisal Darwiche, NP. General guidance, not legal advice — confirm with your Tennessee board and counsel.
In Tennessee the medical director has to be a physician — an MD or DO with an active Tennessee license and an active practice in the state. Because cosmetic injectables are the practice of medicine and Tennessee strictly enforces corporate-practice rules, the physician sits at the top of the clinical side: supplies the delegation and protocols, stands behind the Good Faith Exams and orders, and stays genuinely involved. For an RN this is the anchor — your physician fills two seats: prescriber for the orders, and medical director for the practice. Lock in that physician relationship and your model is sound; have a Tennessee healthcare attorney confirm the medical-director agreement.
Sources: Medical Director Co — Tennessee (the supervising/medical-director physician must be an MD or DO with an active TN license and in-state practice) · Portrait — Tennessee Medical Spa Laws (medical director must be a licensed physician with an active practice in the state) · Verified 2026-06-26.
The medical director is clinically responsible for the practice; the owner holds the business. In Tennessee 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 Tennessee you can absolutely own and build an aesthetics business as an RN — the answer is structure, not a flat no. Tennessee strictly enforces the corporate-practice-of-medicine doctrine, so the clinical entity that practices medicine has to be physician-owned (only licensed physicians — or physicians together with certain other listed professionals — may own an entity providing medical services). You own the business through a management company (an MSO you control: marketing, billing, staffing, facilities) that contracts the physician-owned clinical entity through a fair-market-value management services agreement, while the physician keeps genuine clinical control. Net: an RN can own and run it with the right setup — have a Tennessee healthcare attorney paper the MSO/PC separation so it's real, not just on paper.
Sources: Lengea Law — How to Open a Med Spa in Tennessee (TN strictly enforces CPOM; only licensed physicians may own an entity providing medical services) · Portrait — Tennessee Medical Spa Laws (MSO model; non-physician owns a management company that contracts the physician-owned clinic) · Verified 2026-06-26.
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 Tennessee healthcare attorney paper both before you sign.
The free 17-question assessment returns a Tennessee-specific plan: the right entity structure for your credential, the medical-director and good-faith-exam path, and your exact next action. 7 minutes, no card. Built by Faisal Darwiche, NP.
Yes. Tennessee 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.
In Tennessee 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.
Medical-director compensation in Tennessee 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.
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 Tennessee.