Thinking of Becoming a Medi-Spa Medical Director? Proceed
with Caution!
Frequently, physicians agree to act as the medical director
for “medi-spas” without giving much thought to what responsibilities go along
with the position. Jumping into a medical -directorship without doing your due
diligence and making an informed decision can find you facing investigations
from state or federal regulatory boards of agencies.
If you are contemplating becoming a medi-spa medical director,
remember these facts:
-While, the administration of cosmetic substances and
performance of treatments with medical grade lasers may be delegated to medical
assistants or licensed nurses, a licensed physician, PA or APN MUST see a
patient prior to ordering/prescribing the administration or dispensing of a
cosmetic substance or the performance of a procedure.
-You are responsible for the supervision and training of
individuals providing care to patients. Unlicensed individuals are considered
medical assistants; the terms medical aesthetician and laser technician do not exist
in Nevada law. If a PA or APN is on staff, you should ideally be acting as
their supervising/collaborating physician.
-You may not practice outside the scope of your training or
experience or supervise others who are performing acts outside that scope. It
you do not have the proper experience and training, you may not be involved with
a medical –spa.
-Ensure that only drugs that you have approved are ordered
and are properly stored. Be aware of how drugs are ordered and how much is ordered.
A Nevada dispensing registration for the location is required if any drug is
dispensed.
-Purely aesthetic treatments must be provided by licensed aestheticians.
Be aware that the Nevada State Board of Cosmetology has specific requirements
for locations providing aesthetic treatments.
-All agreements to act as a medical director of a medical
spa should be in writing and should be reviewed by a health care attorney prior
to execution.
State licensing and regulatory boards have taken
disciplinary action against physicians for their involvement in medi-spas;
disciplinary action that can have far reaching consequences for you and your
practice.
If you are contemplating becoming involved with a medical
spa, we highly suggest talking with an attorney well versed in health care law.
Nutile Pitz & Associates has attorneys who are experience in the pitfalls
of medical spas and can assist you in making informed and careful decisions
about medical spa involvement.
