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Medical Director Agreement Checklist for Med Spas

"Medical Director" is one of the most searched terms in aesthetics, and for good reason. Your medical director relationship shapes who can own the practice, who can treat, and what happens when something goes wrong. Use this checklist before you sign, and at every annual review.

1. Ownership Comes First

In California, a business that offers medical procedures must be owned by physicians: physicians must own at least 51% of a professional medical corporation. Registered nurses, NPs, PAs and certain other licensed professionals may own the rest, up to 49% combined, and they can't outnumber the physician shareholders. A physician can serve as medical director for a practice they don't own, but that arrangement requires additional attorney-drafted contracts, which are outside the scope of this checklist. A nurse can't hire a "sponsoring physician" to supervise a nurse-owned practice. Other states have their own ownership rules, so check yours before signing anything.

2. Real Supervision, Not Paper Supervision

The Medical Board of California warns consumers about a "paper-only supervisor." Aesthetic practice uses general supervision: the physician doesn't have to be on site but must be immediately available by telecommunications or other electronic means. Your agreement should name:

  • How the medical director is reached during treatment hours, and the backup when they aren't.
  • Expected response times.
  • Scheduled chart reviews and on-site visits, and how each is documented.

3. Written Protocols Signed by the Right People

In California, RNs perform medical functions under standardized procedures. Your agreement should say who drafts, signs, dates and periodically reviews them. See our upcoming post on the 11 elements California requires.

4. Good Faith Exam Responsibilities

The Medical Board's guidance says an appropriate prior exam is required before prescription drugs or devices are used, and that exam may not be delegated to an RN. Your agreement should name who performs the GFE, how often it's repeated, and where it's documented.

5. Competency and Training Records

Name who verifies each nurse's training before they perform a delegated procedure, how competency is re-checked, and where the records are kept.

6. Emergencies and Complications

Spell out what happens when a complication occurs, such as a vascular occlusion or an allergic reaction:

  • When to call the medical director.
  • What's in the emergency kit.
  • When to transfer the patient.
  • How the event is documented.

7. Products and Sourcing

State who approves the product list, which suppliers are used, and that no "research use only" or unapproved products will be stocked.

8. Records, Termination and Transition

Cover who keeps patient records, what happens to the standardized procedures if the agreement ends, and how patients are protected during a transition.

Have Your Attorney Review It

This checklist helps you prepare questions; it doesn't replace legal advice. A healthcare attorney in your state should review any medical director agreement.

Want this built for your practice? Our Policies and Procedures Manuals include medical director, GFE and emergency sections written for your state and treatment menu. See the Manuals
Want CE on this topic? Guidelines for a Compliant Practice: Pillars of Success (3 contact hours) covers medical director qualifications and compliant practice structure. California BRN Provider #18009. Take the Course at AestheticNursingCEs.com

Educational information only, not legal advice. Requirements vary by state; confirm with your state board.

Sources

Compliance Readiness Checklist and Tabbed Policy Binder on a Practice Desk
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