Texas — Med Spa Medical Director
Whether you need a medical director in Texas, who can serve, how the role differs from ownership, and how to pay them without crossing fee-splitting lines — from Texas 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 Texas board and counsel.
In Texas, NP practice authority is Restricted Practice. Most aesthetic practices in Texas run with a physician serving as medical director — performing or delegating the good faith exam and owning clinical responsibility — but the precise requirement turns on your credential and entity structure.
We publish a confident, sourced answer for a state only once it's primary-source verified. For Texasthis specific rule isn't locked in our validated record yet — confirm the current wording with the Texas Board of Nursing and a Texas healthcare attorney before you rely on it.
The medical director is clinically responsible for the practice; the owner holds the business. In Texas 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 Texas an RN can own and operate an aesthetics business — the answer is structure, not a flat no. Texas follows the corporate-practice-of-medicine doctrine and treats cosmetic injectables as the practice of medicine, so an RN can't directly own the entity that practices medicine. The recognized path: she owns an MSO (a management LLC she controls — the business side: marketing, billing, staffing, facilities) that contracts with a physician-owned clinical entity (PA/PLLC), which supplies the medical direction, delegation, and orders. (A PA may instead hold a minority stake in the physician-owned entity — below any physician owner's share.) She injects under that delegation; the Good Faith Exam and treatment orders come from an NP/MD medical director or a per-patient telehealth-GFE service. Net: an RN absolutely can own and run it with the right setup — but the exact entity structure has to be papered by a Texas healthcare attorney (whether an NP may directly own a nursing-scoped entity is a genuine gray area; the MSO route is the safe one).
Sources: Texas Occupations Code §§151.002, 155.001, 164.052 (practice of medicine + CPOM) · Texas Business Organizations Code §§301.004, 301.012 (authorized owners of a professional medical entity; PA minority interest) · Texas Medical Board — 22 TAC §§169.25–169.29 (nonsurgical cosmetic procedures = practice of medicine; delegation), eff. Jan 2025 · MSO model — ByrdAdatto, "Who Can Own a Med Spa: Unpacking MSOs" + CPOM Field Guide · Verified 2026-06-20.
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 Texas healthcare attorney paper both before you sign.
The free 17-question assessment returns a Texas-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.
In Texas, NP practice authority is classified as Restricted Practice. Whether a separate medical director is required depends on your structure and credential. Confirm the current rule with the Texas board and a healthcare attorney before you open.
In Texas 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 Texas 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 Texas.