Can a Physician Assistant (PA) Open a Med Spa? [State by State Guide]

Can a Physician Assistant (PA) Open a Med Spa?

Yes, PAs can open med spas in a lot of states, but the details matter. Your ability to own or co-own depends on your state’s CPOM laws, your business setup, and getting the right doctor involved.

States like Colorado and Minnesota let PAs own med spas. You still need a medical director, but you can hold equity, make business calls, and run operations.

In strict CPOM states, you can’t own the clinical side, but you can run an MSO (that’s a Management Services Organization). Here’s how it works:

• A doctor-owned business runs the medical side.
• Your LLC handles the business side: marketing, billing, staffing, and equipment.
• You get paid from management fees.

This way, you stay legal and still manage the business.

Some PAs co-own med spas with physicians. You split equity and decisions, with the doctor overseeing clinical parts and the PA handling daily ops. Always have detailed operating agreements about roles, profit share, and exit plans.

No matter the setup, doctors must control protocols, clinical care standards, and supervision. You run the business; they lead the medicine.

Learn if PAs are allowed to open a med spa in your state and if so, what the requirements for physician oversight are.

Understanding the PA's Role in Aesthetics

PAs are licensed medical professionals. You diagnose, treat, and handle patient care under a doctor’s supervision. In aesthetics, you’ll perform procedures like Botox injections, dermal fillers, laser treatments, and chemical peels.

Your training in anatomy, pharmacology, and patient assessment sets you up for success in med spa treatments. You know how to check for contraindications and deal with complications. In med spas, patient safety and clinical judgment matter just as much as your injection skills.

Most states see PAs as qualified injectors. To work in aesthetics, you’ll need:

• Your PA license
• Special training in cosmetic treatments (injection techniques, laser safety, aesthetic assessment)
• Probably a few extra certifications, like from the American Academy of Aesthetic Medicine

In med spas, you often work with nurses, nurse practitioners, and physicians. You’ll do patient consults, treatments, and follow-up. If you’re the owner, you’ll also decide on daily operations, marketing, and business growth.

State Where PAs Can Open a Med Spa

If you're a Physician Assistant looking to own 100% of a med spa, you usually need to target states that don't strictly enforce the Corporate Practice of Medicine (CPOM) doctrine. This legal doctrine generally stops non-physicians or standard corporations from employing doctors to provide medical services, but several states have relaxed these rules or don't apply them at all. In these specific jurisdictions, you can legally hold all the equity in the business entity and manage operations.

It's vital that you distinguish between owning the business and your clinical scope of practice. Even if you own the LLC outright, you must still adhere to state medical board regulations regarding supervision, chart review, and delegation agreements when you perform medical treatments like administering botulinum toxin or using class IV lasers. You typically need a collaborating physician to oversee clinical protocols even if they don't own shares in the company.

Here are states without strict CPOM laws that generally allow PAs to own a med spa:

• Arizona: You'll find Arizona is one of the most friendly states because it doesn't recognize the Common Law Corporate Practice of Medicine doctrine. This allows you to form a standard entity and own the practice entirely. You simply need to ensure you maintain the appropriate supervision agreement for your clinical services and prescriptive authority.
• Utah: This state made significant changes to its laws recently. Utah allows PAs with sufficient experience (typically 10,000 practice hours) to practice without a supervising physician. This autonomy lets you own the business and handle clinical decision-making independently without the usual administrative burdens.
• Florida: Florida allows non-physicians to own medical practices because it technically doesn't have a CPOM prohibition. You can own 100% of the med spa, but you must appoint a licensed physician as the Medical Director to oversee all medical procedures and ensure compliance with the standard of care.
• Alaska: You won't face a prohibition on the Corporate Practice of Medicine here. This allows PAs to incorporate and own the medical business assets. You still need to follow regulations concerning collaboration for prescribing controlled substances or performing invasive procedures.
• Wyoming: This state typically permits corporate ownership of medical practices. You can set up your business structure as the sole owner. Just ensure you hire a physician or establish a collaborative agreement to satisfy the medical board's requirements for oversight.

States Where PAs Can Partially Own a Med Spa

You can often hold a minority interest in a med spa if the business structure and state laws permit joint ownership between physicians and allied health professionals. Most of these arrangements require you to form a Professional Corporation (PC) or a Professional Limited Liability Company (PLLC) where a licensed physician maintains the majority share and clinical oversight. This setup ensures the business complies with the Corporate Practice of Medicine (CPOM) doctrine while allowing PAs to build equity.

It's crucial to check local statutes because the specific ratio of ownership varies by location. For example, California explicitly caps PA ownership at 49% and requires a physician to hold the controlling 51% stake. In Texas, a PA can own a minority interest, but a physician must strictly own the majority and maintain responsibility for medical protocols.

The following states generally allow Physician Assistants to hold partial ownership or co-own a professional entity with a supervising physician:

• California
• Connecticut
• Hawaii
• Illinois
• Kentucky
• Maryland
• Massachusetts
• Michigan
• Minnesota
• Nevada
• New Jersey
• North Carolina
• Oregon
• Pennsylvania
• Tennessee
• Texas
• Virginia
• Washington
• Wisconsin

States Where PAs Cannot Open a Med Spa

You'll hit regulatory walls in several states that strictly enforce the Corporate Practice of Medicine (CPOM) doctrine. This legal framework determines who can own a medical entity, and in strict jurisdictions, it blocks anyone without an MD or DO license from holding equity in a clinical practice. Even if you're the one administering neuromodulators and performing laser skin resurfacing, the law dictates that a physician must own 100% of the medical corporation.

You can't even hold a minority share or split ownership with a partnering doctor in these locations. While you're free to own a Management Services Organization (MSO) that handles the software, payroll, and marketing, the actual business entity providing patient care must belong entirely to a physician.

Current regulations generally prohibit PA ownership of the medical entity in these states:

• Georgia: The state enforces strict rules that limit medical practice ownership specifically to licensed physicians.
• Indiana: State code mandates that a medical practice must maintain physician ownership and total control.
• Kansas: The Healing Arts Act restricts the ownership of any business providing medical services solely to licensed physicians.
• Louisiana: Regulations prevent anyone other than a physician from owning shares or holding interest in a medical corporation.
• New York: State law creates a hard barrier where PAs cannot own shares in a Professional Limited Liability Company (PLLC) or Professional Corporation (PC) designated for medicine.
• Ohio: The State Medical Board explicitly prohibits PAs from owning a medical practice or employing their supervising physician.
• South Carolina: Medical boards here maintain that a licensed physician must wholly own the clinic providing medical care to patients.

Key Legal Considerations and Scope of Practice

Med spas count as medical businesses, not salons, so you have to follow medical practice laws. These rules control who can own a med spa, who can do certain procedures, and what kind of doctor supervision is necessary. Rules vary a lot by state.

Your state’s medical board defines your scope of practice. Some states let PAs do aesthetics with general physician oversight. Others require direct supervision for some treatments. A few states say only doctors can own practices.

The Corporate Practice of Medicine (CPOM) doctrine sets the rules about med spa ownership. CPOM laws block non-doctors from making medical decisions or running clinical care. In strict CPOM places like Pennsylvania and Texas, only doctors can own practices. Other states let PAs own or co-own med spas if there’s a doctor in charge.

• Look up your state’s requirements.
• Check with your medical board.
• Review licensing laws.
• Talk to a healthcare attorney.

If you don’t follow the rules, you could face fines, lose your license, or have to close.

Good Faith Exam (GFE) rules are important too. Many states need a medical professional (doctor, PA, or NP) to check each patient before treatments. If you’re allowed to do GFEs, that’s another way you help your med spa stay compliant.

Collaboration with a Medical Director

In most states, PAs work under a physician’s supervision. That doctor is your medical director. They're responsible for all medical care in your med spa.

Your medical director will:

• Set treatment protocols
• Review charts
• Oversee quality
• Be available for questions

They don’t need to be there every day, just reachable when needed. Sometimes, this is a part-time or consulting job, with the doctor checking in and giving advice for tough cases.

Finding the right medical director is huge. You’ll want someone who gets aesthetics, trusts your clinical skills, and avoids micromanaging. Look for board certification, experience in cosmetic procedures, and knowledge of your state’s supervision requirements.

Your agreement with your medical director should cover:

• Responsibilities
• How supervision works
• Pay
• How often they review your work

Clear agreements help you avoid confusion and keep everything legal.

Portrait’s medical director matching service finds vetted, licensed doctors who fit your state, scope, and goals. Portrait does the searching, so you can work on building your business.

Opening and Running a Med Spa as a PA

So, can a PA open a med spa? For sure, if you dig into your state’s laws, set up the right business structure, and bring in the right doctor for oversight. PAs have the medical chops, patient care skills, and ambition to succeed in aesthetics. With good prep and solid backing, you can build a compliant and profitable med spa that matches your goals.

Portrait gives you the all-in-one platform, services, and cost savings you need to launch and grow. From step-by-step launch help to ongoing compliance, Portrait keeps things simple so you can focus on delivering great patient care.

Book an intro call today to see how Portrait can help you open, operate, and grow your med spa.