Texas runs on delegation. Nearly every treatment on a med spa menu is a medical act performed by someone other than the physician who authorized it, and the document authorising it is the entire compliance story.
Texas also applies the corporate practice of medicine doctrine, which is the opposite of Florida. A structure that works in Florida frequently has no lawful clinical entity in Texas at all.
What Texas actually requires
- A medical director who is a licensed MD or DO. An NP or PA may deliver care under delegation but cannot hold the role.
- Written delegation. Verbal delegation is not recognized in Texas.
- The physician immediately available for consultation while procedures are performed.
- The physician’s name and Texas Medical Board license number posted in the treatment areas (22 TAC 169.26). Walk your rooms — if it is not on the wall, the arrangement is probably informal elsewhere too.
- Capacity under the supervising physician’s statutory cap where a PA or APRN holds a prescriptive authority agreement.
Who may do what in Texas
| License | What they may do |
|---|---|
| MD or DO | Independent; also the only license that may hold the director role |
| APRN | Under delegation and, for prescribing, a prescriptive authority agreement |
| Physician assistant | Under delegation and a prescriptive authority agreement to prescribe |
| Registered nurse | Only within the RN scope, under written delegation |
| Esthetician | Cannot inject — delegation never exceeds the receiving license |
One statute people get wrong: SB 378 was vetoed on June 2, 2025 and never became law, though competitor pages still present it as active 2026 rules. What did pass is the elective IV therapy law effective September 1, 2025.
What MDside provides in Texas
- A Texas-licensed MD or DO as medical director, with written delegation drafted against your actual menu.
- Confirmation that your supervising physician has capacity under the prescriptive authority cap before you build a staffing plan around them.
- Protocol maintenance as the menu changes, plus the posting your treatment rooms are required to carry.
- Licensed providers for evaluations and good faith exams.
- Pharmacy and lab relationships for weight management, hormone and aesthetic programs.
See everything that is included, or book a call and tell us which states you operate in.
Read the detail on Texas
Frequently asked questions
Can a nurse practitioner be a medical director in Texas?
No. Texas requires an MD or DO in that role. NPs and PAs may practice under delegation but cannot occupy the position.
Does the medical director have to be on site?
The standard is immediate availability for consultation, which is not the same as physical presence — but it does mean genuinely reachable while procedures are performed.
Did Texas ban med spa injectables in 2026?
No. SB 378 was vetoed on June 2, 2025 and never became law. Delegation rules and the 2025 elective IV therapy law are what actually govern.
General information about Texas practice structure and med spa regulation, not legal advice. Statutes, board rules and scope-of-practice requirements change. Confirm your obligations with healthcare counsel licensed in Texas.