Georgia does not license med spas, does not maintain a registry, and does not require a specialty for the medical director. What it does is cap your delegating physician. One physician may hold the combined equivalent of eight APRN nurse protocol agreements and physician assistant job descriptions at any one time. Your PAs count against the same ceiling as your nurse practitioners. That single number decides your Georgia growth plan, and it counts your physician assistants too.
The cap counts your physician assistants too
O.C.G.A. § 43-34-25(g) limits a delegating physician to the combined equivalent of eight APRN protocol agreements and PA job descriptions at once. The physician chooses the ratio between them.
This changed on July 1, 2024. Before HB 1046, the limit was four APRNs and four PAs, counted separately. Operators who planned around the old rule sometimes discover they have more room than they thought, and operators who read a stale summary sometimes think they have less. Both plan badly.
The statutory exceptions in subsection (g) are unchanged. They reach hospitals, health departments and similar settings. They do not reach a private aesthetic clinic.
| Your Georgia footprint | Advanced practice clinicians | Delegating physicians needed |
|---|---|---|
| One location, three injectors | 3 | 1 |
| Two locations, four each | 8 | 1, at the ceiling |
| Three locations, three each | 9 | 2 |
| Any mix of APRNs and PAs | count them together | ceiling is 8 combined |
The arithmetic is the point. Model it before you sign the next lease, because the ninth advanced practice clinician has nothing to practice under until you have a second delegating physician in place.
Distance is a second constraint, and telehealth does not escape it
A delegating physician must hold an active Georgia license, practice medicine in Georgia, and either have a principal place of practice in Georgia or be within 50 miles of the location where the protocol is being used. “Where the protocol is being used” means the physical location of the patient at the time services are rendered.
If your APRN is delivering care by telehealth, the delegating physician still has to satisfy all of it. The requirement does not bend for a remote model, and it does not bend for a business structure.
The protocol is the instrument, and it has a filing deadline
In Georgia a physician delegates medical acts to an APRN through a nurse protocol agreement. It is a written document, agreed and signed by both, and it is what authorizes the APRN to order drugs, devices and treatments.
Four things the agreement has to get right:
- A comparable specialty or field. The APRN and the delegating physician must be in a comparable specialty area. If your delegating physician practices emergency medicine and your APRN runs an aesthetics and weight management panel, a reviewer can reasonably ask how those align. There is no bright-line list, which is exactly why the pairing deserves thought rather than convenience, and why the difference between a director and a collaborating clinician is worth settling before you choose one.
- Filing within 30 days. Protocols must be submitted to the Board within 30 days of execution, meaning within 30 days of both signatures.
- An annual review, calendared. Both parties must keep a copy of the approved agreement and proof of every annual review, and produce them on request from the Georgia Composite Medical Board or the Georgia Board of Nursing.
- The prescribing limits stated plainly. Schedule I and II substances sit outside the ordinary protocol. HB 557 created a narrow authority at § 43-34-25(d.1) for hydrocodone, oxycodone and compounds in emergency situations, with its own conditions. Most med spa menus never touch it, and a protocol that quietly implies otherwise is a problem.
An incomplete protocol on file with the Board for more than three months is deemed invalid, and a new submission and fee are required. The three months run from the notification date, not from filing.
What drives the cost in Georgia
Nobody prices a Georgia directorship off a single number. What moves it:
- How many protocols the physician is carrying. A physician at six of eight has less room and more exposure than one at two.
- Whether PAs are in the mix. Separate documentation, a separate framework under Title 43, and a separate failure mode.
- The menu. Weight management and hormone therapy carry monitoring and lab intervals that aesthetics alone does not, and the good faith exam standard in Georgia applies before any of it.
- Geography. The 50-mile rule turns a multi-site plan into a recruiting problem.
- Whether the physician actually reviews. Annual review, chart involvement and protocol authorship are work. A fee that assumes a signature and nothing else is buying a signature and nothing else.
Fee structures in this market vary widely and are best understood as a market observation rather than a benchmark. What matters more is what the fee buys, and whether the person taking it has capacity under the cap.
Red flags on both sides of the table
From the operator’s side, be wary of a physician who: already holds protocols near the ceiling and will not say how many; cannot describe their principal place of practice relative to your locations; offers to sign without reading your service menu; or treats the annual review as a formality.
From the physician’s side, be wary of an operator who: wants the protocol signed before the menu is settled; asks for a protocol broader than the services actually delivered; resists calendaring the annual review; or proposes compensation that moves with clinic revenue. A share of revenue is the highest-risk formulation available and it is not necessary to get a directorship done.
What this means for you
Count your advanced practice clinicians, APRNs and PAs together, and check the number against eight before you do anything else. If you are at six or seven and planning a location, start recruiting a second delegating physician now, because the constraint arrives on the day the ninth clinician starts and not before. Map every site against the 50-mile rule using the patient’s location, not your corporate address. Then get the protocol written against the menu you actually deliver, file it inside 30 days, and put the annual review in the calendar with a named owner. See what medical direction in Georgia involves, or read the detail on the protocol cap.
Related reading
Frequently asked questions
How many nurse practitioners can one Georgia physician cover?
The combined equivalent of eight at any one time, counting APRN protocol agreements and physician assistant job descriptions together, subject to the statutory exceptions. Those exceptions cover hospitals, health departments and similar settings, and they do not cover private aesthetic clinics. The physician decides the ratio between APRNs and PAs.
Did the Georgia cap change recently?
Yes. HB 1046 took effect July 1, 2024 and replaced the previous limit of four APRNs and four PAs, counted separately, with a combined equivalent of eight. Anything published before that date, including older summaries still circulating, states a rule that no longer applies.
How far can a Georgia delegating physician be from the clinic?
The physician must practice medicine in Georgia and either have a principal place of practice in the state or be within 50 miles of where the protocol is being used. That location is the physical location of the patient when services are rendered, which matters for any telehealth arrangement.
Does Georgia require a medical spa license or registration?
No. Georgia has no med spa facility license and no state registry. That absence is why operators arriving from stricter states often assume Georgia is permissive, and why the protocol cap catches them at the second or third location rather than the first.
Can a nurse practitioner be the medical director in Georgia?
No. An APRN practices under a nurse protocol agreement signed by a delegating physician. They do not sign one for someone else. The delegating physician must be an MD or DO licensed in Georgia.
This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.