Medical Spa Laws and Requirements in Tennessee

While Tennessee law does not provide a single definition for a “medical spa,” it does establish clear rules for these licensed healthcare facilities. To support your clinic’s success, this guide breaks down the essential state requirements you need to know, from ownership restrictions to licensing.

How Medical Spa Laws Work in Tennessee

In Tennessee, a medical spa is legally defined as any business that provides cosmetic medical services. This distinction is critical, as it separates them from traditional day spas, which do not perform procedures that alter living tissue. Understanding these med spa regulations is the first step toward ensuring med spa compliance.

The state's medical spa laws in Tennessee exist primarily to protect patient safety. Because these facilities perform medical procedures, they are held to a higher standard than typical spas in Tennessee. This framework requires physician oversight to ensure all services are administered safely and correctly.

The Tennessee Board of Medical Examiners is the main governing body, requiring med spas to register annually. While the Board of Nursing's rules dictate the scope of practice for nurses on your staff, the Board of Medical Examiners oversees the facility's registration and the supervising physician. Meeting these medical spa requirements in Tennessee is essential for legal operation.

Medical Spa Requirements in Tennessee

To help you succeed, we will cover the core medical spa requirements in Tennessee, focusing on ownership, supervision, and registration. The state’s strict med spa laws by state standards, particularly the rules on who can own a med spa, limit ownership to licensed physicians. Furthermore, achieving med spa compliance requires a physician medical director who is responsible for both clinical oversight and the facility’s annual registration. Understanding these med spa regulations is fundamental to building a secure and successful practice.

Medical Spa Ownership & Business Structure Requirements in Tennessee

Tennessee's medical spa laws are shaped by the state's strict enforcement of the Corporate Practice of Medicine (CPOM) doctrine. This rule directly answers the question of who can own a med spa, limiting ownership to licensed physicians or specific physician-led partnerships. Consequently, non-physicians, including nurse practitioners and entrepreneurs, cannot directly own a medical practice in the state.

For non-physicians looking to enter the market, the Management Services Organization (MSO) model offers a path to achieving med spa compliance. This structure allows a non-physician to own a separate company that provides management services to the physician-owned clinic. Regardless of the business arrangement, all spas in Tennessee offering cosmetic medical services must appoint a medical director.

These med spa regulations require the medical director to be a licensed physician with an active practice in the state. The director must be actively involved in operations, assume responsibility for all cosmetic procedures, and handle the facility's annual registration. This oversight is a cornerstone of the medical spa requirements in Tennessee, ensuring patient safety and adherence to state law.

Facility, Licensing, and Compliance Requirements in Tennessee

To secure a medical spa license in Tennessee, your primary step is to register the facility with the Tennessee Board of Medical Examiners before opening. This registration must be managed by your medical director and renewed annually, forming a core part of the state's med spa regulations. Meeting these medical spa requirements in Tennessee is fundamental to achieving med spa compliance.

Operational rules also extend to advertising and administration. Tennessee has specific regulations for medical spa services, and your medical director is responsible for ensuring all promotions and signage meet state law. Additionally, the supervising physician must manage administrative tasks, including chart reviews and recordkeeping.

While the state’s medical spa laws in Tennessee do not explicitly detail rules for insurance, sanitation, or patient privacy, these areas are critical for safe operation. Adhering to federal standards like HIPAA and maintaining best practices for infection control are essential for protecting your patients and your practice. Our platform provides the tools to help you build and manage these comprehensive operational protocols.

Who Can Perform Medical Spa Procedures in Tennessee?

In Tennessee, procedures that alter living tissue are classified as cosmetic medical services, placing them under the practice of medicine. This includes common treatments like injectables, laser therapies, and microneedling, which are governed by strict med spa regulations. Understanding this distinction is fundamental to meeting the medical spa requirements in Tennessee and ensuring full med spa compliance.

When determining who can inject Botox in Tennessee, the state’s medical spa laws in Tennessee permit Nurse Practitioners (NPs) and Physician Assistants (PAs) to perform these services under physician supervision. Registered Nurses (RNs) have a different scope, with the rules allowing them to administer services like IV therapy, but they are generally restricted from performing injectables. Similarly, microneedling can be performed by both NPs and RNs, always under appropriate oversight.

All non-physician providers must operate under the supervision of a medical director, who is a licensed physician actively practicing in the state. This director is responsible for all delegated tasks, including those involving laser regulations in Tennessee, and must ensure the facility adheres to all med spa regulations. While specific state-mandated training rules are not detailed, your medical director is responsible for confirming provider competency and overseeing all clinical protocols to maintain med spa compliance.

Laser & Energy Device Regulations in Tennessee

Tennessee’s med spa regulations do not specifically define lasers, but they classify these devices under cosmetic medical services as any tool using a "displaced energy form" to alter tissue. This classification means that all energy-based treatments fall under the practice of medicine, requiring physician oversight to ensure med spa compliance. The medical director assumes full responsibility for services, a key component of the medical spa requirements in Tennessee.

Under the state's aesthetic laser laws, procedures like laser treatments can be delegated to nurse practitioners, physician assistants, and licensed estheticians, provided they operate under physician supervision. While the state does not outline specific laser technician requirements in Tennessee, your medical director is responsible for verifying the competency and training of any staff performing these procedures. Similarly, there are no explicit state rules for reporting adverse events, but the medical director must establish internal protocols to manage them professionally and protect patients.

Medical Spa Enforcement, Penalties & Risk Management in Tennessee

Violating Tennessee's medical spa laws can lead to serious consequences, including financial penalties and disciplinary action that could jeopardize your practice. Understanding the state's enforcement approach is critical for maintaining long-term med spa compliance and protecting your business. The Tennessee Board of Medical Examiners actively enforces its med spa regulations, and non-compliance can result in cease-and-desist orders, significant fines, and professional discipline against the medical director’s license.

To help you avoid these issues, here are some of the most common mistakes that put spas in Tennessee at risk:

• Improper delegation of medical tasks to unqualified staff
• False or misleading advertising that violates state rules
• Operating without proper physician ownership, a direct violation of the rules on who can open a med spa.
• Failing to register the facility annually with the Board of Medical Examiners.

Proactive risk management is the best defense. Here are some practical steps for how to stay compliant med spa Tennessee:

• Regular Compliance Audits: Periodically review your protocols against the latest medical spa requirements in Tennessee to identify and correct any gaps.
• Comprehensive Staff Training: Document training for all staff on their specific scope of practice, safety procedures, and the state’s med spa regulations.
• Detailed Documentation: Maintain clear records of patient consents, chart reviews, delegated tasks, and all other operational activities to demonstrate med spa compliance.

Stay Compliant with Portrait Care in Tennessee

Staying compliant in Tennessee requires a clear understanding of the state’s rules. The key takeaways are to adhere to physician-only ownership laws, appoint a qualified medical director for supervision and registration, verify all medical tasks are properly delegated, and implement strong risk management protocols. These steps are fundamental to building a secure and successful practice.

This content is for informational purposes only and is not a substitute for legal advice. We recommend consulting with a qualified healthcare attorney to confirm your practice meets all state requirements.

Our platform provides the tools and support to help you manage these requirements with confidence. You can learn more about opening a compliant med spa with our detailed guide. Schedule a demo today to see how Portrait can support your practice.