What Georgia actually requires of a med spa medical director.
National platforms routinely sign Georgia practices to physicians who do not practice in Georgia, listing the med spa itself as the physician’s address. Georgia requires the delegating physician’s principal place of practice — where they treat patients more than half the time — to be in this state, or within 50 miles of your clinic. A med spa the physician visits occasionally does not satisfy that, and the Board states plainly that a virtual address does not either. This page is the rules themselves, with the citation beside every claim so you can check it.
The short version
A Georgia med spa offering injectables, IV therapy, or most energy-based treatments is performing medical acts. Those acts require a physician who delegates them lawfully and who can show the delegation was real.
In practice that means five things: a physician whose specialty is comparable to the work being delegated, and who is trained in it; a nurse protocol agreement or PA job description filed with the Board within 30 days of execution; a good faith exam performed by a physician, NP, or PA — never by an RN alone; documented annual on-site observation and quarterly chart review; and the supervising physician's identity posted where the public can see it.
The Board said in May 2026 that it evaluates these arrangements on substance rather than form. In August 2026 it began unannounced inspections. The gap between what the agreement says and what the file shows is now the whole exposure.
Four things changed this year.
If your compliance file was assembled before this spring, each of these is a reason to reopen it.
The Board issued its IV Hydration and Therapy position statement
It set out who may evaluate a patient, what an RN may and may not do, what written policies a facility must keep on site, and a requirement to publicly identify the supervising physician. It also stated that the Board will look at the substance of an arrangement rather than its form, and named fee-based physician-matching services directly.
The delegation rules were amended
Chapter 360-32 changes took effect covering controlled-substance limits within nurse protocol agreements and the authority to pronounce death. If your protocol language predates this, it is describing a rule that no longer reads the way it did.
The laser chapter grew to cover energy devices
Rule 360-35-.01 now defines cosmetic laser services to include energy-based procedures using ultrasound, cryolipolysis, microwave, or radiofrequency devices. Practices that added RF microneedling or body contouring believing the laser rules did not reach them are working from an outdated read.
Unannounced inspections began
The Board's executive director confirmed that inspectors had already visited Georgia med spas and IV clinics without notice. Preparation that depends on advance warning is no longer preparation.
Eight requirements, eight citations.
These are the provisions a reviewer will ask about. Every source is listed in full at the foot of this page.
The specialty has to match the work
“No physician may enter into a nurse protocol agreement with an APRN whose specialty area or field is not comparable to the physician’s specialty area or field.” The Board applies this at the point of filing, and its own APRN guidance lists a specialty mismatch among the deficiencies that cannot be cured — the protocol is not returned for correction, it simply does not stand. This is the requirement that disqualifies a large share of the physicians currently signing med spa agreements.
Thirty days to file, three months to lapse
A nurse protocol agreement must be received by the Board within 30 days of the date it is executed. Amendments carry the same 30-day deadline. A protocol left incomplete on file for more than three months is deemed invalid. An act performed under an unfiled or lapsed agreement has no delegation standing behind it, whatever the signed contract in the drawer says.
Ten supervised, ten independent — per procedure
Before an APRN may perform a procedure that was not specifically mastered during their own education and training, the Board requires a procedure log: at least 10 procedures under the direct supervision of the delegating physician and at least 10 performed independently, signed by both the APRN and the physician and submitted to the Board. A separate form is filed for each procedure. Injectables and energy-based treatments are not part of a standard APRN curriculum, so in an aesthetic practice this reaches nearly every service line you offer.
The physician has to be trained in it too
For lasers this is explicit: a consulting physician “must be trained in laser modalities which should include the physics, safety, and surgical techniques involved in the use of lasers… the pre- and post-operative care involved in treatment, as well as the treatment of complications associated with laser devices.” No Georgia rule names a specific injectables course, but the same logic runs through the whole delegation framework — the physician remains responsible for every delegated act, and cannot meaningfully oversee a technique they have never performed. A director covering injectors and laser operators should hold documented training in both and be able to produce the certificates.
Annual on-site observation, quarterly record review
The physician must document and maintain a record of direct on-site observation of the APRN's practice at least once annually, and conduct medical record reviews quarterly to monitor the quality of care delivered. Note what is required: not the observation, but the record of it. Oversight that happened and was never documented looks identical, on inspection, to oversight that never happened.
What the agreement has to contain
Names, addresses, and license numbers; practice locations; the drugs, devices, and treatments authorized; a provision for immediate consultation; the applicable standard of care; conditions requiring physician evaluation; documentation requirements; prescription form specifications; and the schedule for periodic patient record review. A generic template that omits any of these is not a compliant agreement simply because it is signed.
Post the physician's name publicly
Licensees are directed to clearly provide to the public who the delegating or supervising physician is and how to contact that physician, posted so the public has unrestricted access. This is the requirement Georgia practices most often have not met — and it is also the easiest one for an inspector to check before ever walking through the door.
Who may do what in a Georgia med spa.
The single most common compliance failure is a practice where the right treatment is performed by the wrong license.
Scroll the table sideways to see every column →
Two services can look equally routine on a menu and sit on opposite sides of the line. Whether a treatment is ablative, whether it breaks the skin, and whether it uses a prescription agent all change who may perform it.
APP — nurse practitioner or physician assistant* · ALP — licensed assistant laser practitioner · SLP — licensed senior laser practitioner · LE — licensed esthetician
* An APP may only perform a delegated procedure under a nurse protocol agreement or job description filed with, and accepted by, the Board.
| Treatment | Who may perform it | Needs supervision? | Exam first? | Authority |
|---|---|---|---|---|
| Laser hair removal & IPL | ALP or SLP | Yes — on site or reachable live | No | Rules 360-35-.05 and .07. The facility still needs a consulting physician. |
| Photo rejuvenation, vascular & other non-ablative laser | ALP or SLP | Yes — on site or reachable live | Yes | Rule 360-35-.05 |
| Radiofrequency, ultrasound, cryolipolysis, microwave (no needles) | ALP or SLP | Yes — on site or reachable live | Yes | Rule 360-35-.01 — these became cosmetic laser services in 2026 |
| RF microneedling (Morpheus8, Sylfirm X and similar) | APP* only | Yes — delegating physician | Yes | Energy device under Ch. 360-35 and penetration of the skin, a delegated medical act — O.C.G.A. § 43-34-23 |
| Fractional CO2 and other ablative resurfacing | APP* only | Yes — delegating physician | Yes | Rule 360-35-.01 covers non-ablative services only — ablative work sits outside laser-practitioner scope entirely |
| Microneedling with PRP or PRF | APP* only | Yes — delegating physician | Yes | Blood draw, processing and reinjection are medical acts — O.C.G.A. § 43-34-23 |
| Medium-depth chemical peel | APP* only | Yes — delegating physician | Yes | Medical act — O.C.G.A. § 43-34-23. See the definition below. |
| Superficial chemical peel | LE | No | No | Cosmetology scope; not a delegated medical act |
| Prescription-strength skin lightening | APP* only | Yes — delegating physician | Yes | Requires a prescription drug order; an LE cannot dispense or apply one on their own authority |
Scroll the table sideways to see every column →
What supervision actually means here. Rule 360-35-.07(1)(d) requires the facility to have a senior laser practitioner or consulting physician “present at the facility or immediately available for consultation and supervision either personally or via telecommunications.” A supervisor on video satisfies that. What it does not mean is a name on a contract and nobody reachable — “immediately available” means able to respond while the patient is in the chair, and worth documenting per session.
The thing that does not soften is the exam. Rule 360-35-.05(1)(c) waives the pre-treatment examination only for laser hair removal and pulsed light. Every other laser and energy service needs one before the service, and that is the gap practices most often have.
What makes a peel “medium-depth.” Depth is measured by how far the agent injures the skin, not by brand. A superficial peel reaches the epidermis down to the papillary dermis — glycolic acid, salicylic acid, Jessner’s solution, or TCA at roughly 10–20%. A medium-depth peel reaches through the papillary dermis into the upper reticular dermis — typically TCA at 35% or above, or a combination such as Jessner’s plus TCA. A deep peel reaches the mid-reticular dermis and is phenol-based.
Several popular branded peels marketed to med spas are medium-depth by this measure, and at least one manufacturer states in its own materials that the product must be administered in a medical setting by a medical professional. The brochure does not change the depth, and the depth is what decides who may apply it.
The RN line is the one that catches practices. In its May 7, 2026 position statement the Board stated that an RN or LPN may not be the only licensed health care professional performing the history and physical or the assessment of whether a procedure is appropriate. A practice where the injector both evaluates the patient and administers the treatment, with the physician's involvement limited to a signature on a protocol, does not satisfy this — and that arrangement is extremely common.
Not every physician can be your medical director.
This is the requirement owners are least aware of, and the one most likely to invalidate an arrangement that reads perfectly well on paper.
Rule 360-32-.04(3): “No physician may enter into a nurse protocol agreement with an APRN whose specialty area or field is not comparable to the physician’s specialty area or field.”
The Board checks this when the protocol is filed. In its own published APRN guidance, a specialty mismatch sits among the deficiencies that cannot be cured — it is not a correction request, it is a protocol that never takes effect. Every treatment performed under it was performed without delegation behind it.
What “comparable” means for an aesthetic practice
The rule publishes no list of approved specialties. Comparability is read against the work actually being delegated, and for a med spa that reading is not subtle: if your APP is performing procedures, your physician needs to come from a specialty that performs procedures.
Dermatology, plastic surgery, facial plastic surgery, and emergency medicine all practice procedurally and manage the complications that follow aesthetic treatment — vascular occlusion, burns, infection, anaphylaxis, airway. Those are defensible matches for injectables and energy-based devices.
A family medicine or general internal medicine physician whose own practice contains no procedural component is a far harder case to make, and most internal medicine subspecialties are no better fit. This is not a judgment about the quality of those physicians. It is that the rule measures comparability against the delegated act, and a practice built around chronic disease management is not comparable to injecting filler into the glabella or firing an ablative laser.
The defect hides well: a willing, well-regarded primary care physician signs a protocol for a service line they have never performed and could not manage a complication from, and nothing surfaces it until someone reads the file. By then the question is not whether the protocol was filed, but whether it was ever valid.
Georgia is unusually workable here — if you use the rule correctly.
Chapter 360-35 is one of the more permissive laser frameworks in the country for non-physician operators, and one of the easiest to misread.
The definition now reaches well past lasers
Rule 360-35-.01 defines cosmetic laser services to include non-ablative elective cosmetic light-based skin care, photo rejuvenation, and hair removal using lasers or pulsed light devices — and also energy-based medical procedures using an ultrasound, cryolipolysis, microwave, or radiofrequency device that does not remove or burn the living skin surface but may damage underlying tissue if misused. Radiofrequency microneedling and most body contouring now sit inside this chapter.
An esthetician can operate, as an Assistant Laser Practitioner
Rule 360-35-.05 provides that an assistant laser practitioner practices under the supervision of a physician licensed by the Board or a licensed senior laser practitioner, and that patients must be examined by a consulting physician, physician assistant, or advanced practice nurse before treatment.
The exception is the whole business model. The same rule states that on-site supervision and the pre-treatment examination are not required for laser hair removal and pulsed light treatments. That one sentence is why a Georgia practice can run a hair removal service line with a credentialed esthetician and a consulting physician who is not standing in the room — and why the same practice cannot extend that staffing to photo rejuvenation, RF, or body contouring without the exam.
The failure mode is predictable: a practice builds a lawful hair removal operation, adds a second device, and keeps the staffing model that only ever applied to the first one.
What the Board is looking for is evidence, not paperwork.
In its May 7, 2026 position statement the Georgia Composite Medical Board said it would evaluate supervisory arrangements based on substance rather than form, and identified fee-based physician-matching services by name. The distinction it is drawing is between a physician who is engaged and a physician whose involvement is a signature.
That distinction is not decided by the agreement. It is decided by what exists in the file on the day someone asks:
Is the nurse protocol agreement filed, accepted, and current — or was it signed and never sent? Is there a dated record of the annual on-site observation? Are there quarterly chart reviews, with findings? Is the physician's specialty comparable to the procedures being delegated, and can they produce training certificates for each modality they oversee? Is the physician's name posted where a patient can find it? When something went wrong, is there a variance entry and a resolution?
An arrangement that can answer those questions looks like oversight regardless of how it is structured. One that cannot is exposed regardless of how carefully the contract was drafted.
Georgia medical director FAQ.
Does a med spa in Georgia need a medical director?
If the med spa offers medical treatments — injectables, IV therapy, most laser and energy-based procedures — then yes. Those are medical acts. Under O.C.G.A. § 43-34-23 a physician may delegate a medical act only to a qualified licensed person, and the physician remains responsible for the delegated act. A practice offering medical treatments without a physician standing behind them has no lawful basis for the delegation.
Laser hair removal needs a medical director. This is the one owners most often assume is exempt, because Rule 360-35-.05 removes the on-site supervision and pre-treatment exam requirements for hair removal and pulsed light. Those two exemptions are not an exemption from having a physician. Rule 360-35-.07 still requires a non-physician facility to hold a consulting physician agreement, file that physician’s credentials, keep them available for emergencies, and post their name where patients can see it.
Can a registered nurse perform the good faith exam in Georgia?
No. In its May 7, 2026 IV Hydration and Therapy position statement, the Board stated that an RN or LPN may not be the only licensed health care professional performing the history and physical or the assessment of whether a procedure is appropriate for the patient. That evaluation must come from a physician, nurse practitioner, or physician assistant.
An RN may administer IV hydration, nutrient therapies, and medications only when there is a valid individualized order prescribed by a physician, NP, or PA. The order must be individualized to the patient — a standing protocol alone is not a substitute for it.
How long does a Georgia nurse protocol agreement take to file?
Rule 360-32-.03 requires that the agreement be received by the Board within 30 days of the date it is executed, and the same 30-day deadline applies to amendments. A protocol that remains incomplete on file for more than three months is deemed invalid.
Ask for proof of acceptance, not proof of mailing. An agreement that was sent but never accepted leaves every act performed under it without delegation behind it.
What oversight does Georgia actually require from a supervising physician?
Rule 360-32-.05 requires the physician to document and maintain a record of direct on-site observation of the APRN's practice at least once annually, and to conduct medical record reviews quarterly to monitor the quality of care delivered.
The word doing the work is document. These are evidentiary obligations. A physician who genuinely oversees a practice but keeps no record of having done so is, on inspection, indistinguishable from one who did nothing.
Does Georgia require a med spa to publicly post who its supervising physician is?
Yes. The May 7, 2026 position statement directs licensees to clearly provide to the public who the delegating or supervising physician is and how to contact that physician, and states the information should be posted so the public has unrestricted access to it.
This is the requirement Georgia practices have most often not met, and the cheapest one to fix. It is also the only one an inspector can verify from your website before ever visiting.
Can an esthetician operate a laser in Georgia?
Yes, as a licensed Assistant Laser Practitioner under Chapter 360-35. Rule 360-35-.05 provides that the assistant laser practitioner works under the supervision of a Board-licensed physician or a licensed senior laser practitioner, and that patients must be examined by a consulting physician, physician assistant, or advanced practice nurse before treatment.
The exception is significant: on-site supervision and the pre-treatment examination are not required for laser hair removal and pulsed light treatments. Georgia is, for this reason, one of the more workable states in the country for a non-physician laser staffing model — within that boundary.
The exam is the citation waiting to happen. For every laser or energy service other than hair removal and pulsed light, Rule 360-35-.05 requires the patient to be examined before the service by a consulting physician, or by a PA or APRN who holds a cosmetic laser practitioner licence. Practices routinely run a patient through a package of treatments on the strength of one exam taken at intake, or no documented exam at all. The rule ties the exam to the service, not to the client relationship. Supervision is the looser of the two requirements: Rule 360-35-.07(1)(d) lets the senior laser practitioner or consulting physician be present at the facility or immediately available, including by telecommunications. The exam is the one with no remote option.
If a clinic has a senior laser practitioner, does laser hair removal still need a supervising physician?
Yes — at the facility level. Rule 360-35-.05 lets an assistant laser practitioner work under the supervision of either a Board-licensed physician or a licensed senior laser practitioner, so an SLP can supply the day-to-day supervision of the ALP.
But Rule 360-35-.07 sets a separate requirement on the facility itself. A non-physician facility must have a consulting physician agreement in place, file that physician’s credentials, keep the physician available for emergency consultation, and post the physician’s information along with current supervisor details where the public can see it.
So the SLP answers the supervision question for the practitioner. The consulting physician requirement attaches to the premises and does not go away. Having an SLP on staff changes who watches the ALP; it does not remove the need for a medical director.
Do Georgia's laser rules cover radiofrequency and body contouring devices?
They do. Rule 360-35-.01 defines cosmetic laser services to include energy-based medical procedures using ultrasound, cryolipolysis, microwave, or radiofrequency devices that do not remove or burn the living skin surface but may damage underlying tissue if misused. A practice that added RF microneedling or body contouring on the understanding that the laser chapter did not apply should re-examine that assumption.
Who may actually perform them depends on whether the skin is broken. A purely external energy treatment — RF skin tightening, ultrasound, cryolipolysis, microwave — is now a cosmetic laser service, so an ALP or SLP may perform it. Two conditions come with that: the patient must be examined before the service, and a senior laser practitioner or consulting physician must be present at the facility or immediately available, including by telecommunications, under Rule 360-35-.07(1)(d).
RF microneedling is a different question. It is an energy device under Chapter 360-35 and it penetrates the skin, which is a medical act that must be delegated under O.C.G.A. § 43-34-23. That places it with an APRN or PA working under a filed protocol, or with a physician — not with an esthetician holding a laser practitioner licence. The same reasoning applies to microneedling with PRP or PRF, where the blood draw and reinjection are independently medical.
What specialties can be a medical director for a med spa in Georgia?
Rule 360-32-.04(3) prohibits a physician from entering a nurse protocol agreement with an APRN whose specialty area or field is not comparable to the physician’s own. There is no published list of approved specialties — comparability is measured against the procedures actually being delegated.
In practice, for an aesthetic practice, that means the physician should come from a specialty that performs procedures and manages procedural complications: dermatology, plastic surgery, facial plastic surgery, or emergency medicine. A family medicine or general internal medicine physician with no procedural component to their own practice is difficult to reconcile with the rule, as are most internal medicine subspecialties. A specialty mismatch appears in the Board’s APRN guidance as a deficiency that cannot be cured.
Does the supervising physician need to be trained in injectables and lasers?
For lasers, yes, explicitly. Rule 360-35-.06(c) requires a consulting physician to be trained in laser modalities — physics, safety, surgical technique, indications, pre- and post-operative care, and the treatment of complications.
For injectables, no Georgia rule names a specific course. The requirement is structural rather than itemized: the physician remains responsible for every delegated act under O.C.G.A. § 43-34-23, and the specialty-comparability rule assumes a physician who actually performs this category of work. A director overseeing injectors and laser operators should hold documented training in both modalities and be able to produce the certificates on request.
What is the APRN procedure log, and when is it required?
It is a Board form required when an APRN seeks approval to perform a procedure that was not specifically mastered during their education and training. It documents at least 10 procedures performed under the direct supervision of the delegating physician and at least 10 performed independently. Both the APRN and the physician sign it, and it is submitted to the Board.
A separate form is filed for each procedure. Because injectables and energy-based treatments are not part of standard APRN curricula, this generally applies to most of what an aesthetic practice offers — and it is frequently missed entirely.
What is a “ghost” medical director?
A physician who signs the agreement and provides little or no genuine clinical oversight. The arrangement usually looks fine on paper — that is the point of it.
In its May 7, 2026 position statement the Board said it would evaluate these arrangements based on substance rather than form, and named fee-based physician-matching services directly. The practical test is what the file shows: whether chart reviews, the annual on-site observation, and the filed delegation documents exist and are current.
There is a structural version of the same problem that national platforms have not solved. Georgia requires the delegating physician’s principal place of practice — defined by the Board as the location from which they treat patients more than 50% of the time — to be in Georgia, or within 50 miles of where the protocol is used. The Board states that virtual addresses, P.O. boxes and hourly or daily flex rental space do not qualify. A physician whose real practice is in another state does not acquire a Georgia principal place of practice by having your med spa listed as their address.
The Board has already named fee-based physician-matching services in a published position statement, and its 2026 inspections found, among other things, a lack of physician oversight and medical exams being skipped before treatment.
Is the Georgia Composite Medical Board inspecting med spas?
Yes. In August 2026 it was reported that the Board's executive director confirmed inspectors had already begun conducting unannounced visits to Georgia med spas and IV clinics.
An unannounced inspection means the documentation that exists at that moment is the documentation that counts. There is no window to assemble a binder after the fact.
What should I ask a prospective medical director in Georgia?
Five questions, and the answers should be immediate. What is your specialty, and which of these procedures do you perform yourself? What documented training do you hold in injectables and in lasers? How often will you be physically on site, and is that frequency written into the agreement? Who files the nurse protocol agreement, and will I receive proof of Board acceptance? Where is your principal place of practice, and is it within 50 miles of my clinic?
That last question matters most. The Board requires the delegating physician’s principal place of practice — where they treat patients more than half the time — to be in Georgia, or within 50 miles of where the protocol is used. Virtual addresses, P.O. boxes and flex rental space do not qualify.
Check everything above.
Every claim on this page traces to one of these. If a rule changes and this page has not, the rule governs.
- Ga. Comp. R. & Regs. Chapter 360-32 — Nurse Protocol Agreements. rules.sos.ga.gov/gac/360-32
- Ga. Comp. R. & Regs. Chapter 360-35 — Lasers. rules.sos.ga.gov/gac/360-35
- Georgia Composite Medical Board, IV Hydration / Therapy Position Statement, May 7, 2026. medicalboard.georgia.gov
- Georgia Composite Medical Board, APRN Procedure Log (10 supervised / 10 independent, one form per procedure). medicalboard.georgia.gov
- Georgia Composite Medical Board, APRN Protocol Registration — principal-place-of-practice and 50-mile requirements. medicalboard.georgia.gov
- Georgia Composite Medical Board, APRN Information Summary — lists specialty mismatch among deficiencies that cannot be cured. medicalboard.georgia.gov
- Georgia Composite Medical Board — rule and law updates. medicalboard.georgia.gov
- O.C.G.A. § 43-34-23 (delegation of medical acts), § 43-34-25 (nurse protocol agreements), § 43-34-103 (physician assistants).