A Michigan nurse practitioner can prescribe nonscheduled drugs in the NP’s own name, but cannot fill the physician’s role in a med spa. Under MCL 333.17211a, controlled substances are prescribed only as a delegated act of a physician. Laser supervision, medical exfoliation supervision, and delegation of medical acts to your staff also run to a physician. As of October 2026, that has not changed.
No section cited in this post uses the title “medical director.” The question that matters is which functions the law assigns to a physician. In Michigan there are four.
An NP is a registered nurse with a specialty certification
The Public Health Code defines an advanced practice registered nurse as a registered professional nurse who has been granted a specialty certification under section 17210 in nurse midwifery, nurse practitioner, or clinical nurse specializt (MCL 333.17201(1)(a)).
The scope definition the NP works under is the “practice of nursing”: the application of specialized knowledge and skill to the care, treatment, counsel, and health teaching of individuals (MCL 333.17201(1)(c)). The “practice of medicine” is defined separately as the diagnosis, treatment, prevention, cure, or relieving of a human disease, ailment, defect, complaint, or other physical or mental condition (MCL 333.17001(1)(j)).
That gap between the two definitions is the whole issue. Michigan has added specific powers to the nurse practitioner by statute. It has not rewritten the nurse practitioner’s scope.
What the 2017 law gave nurse practitioners
2016 PA 499, effective April 9, 2017, added four things:
- Nonscheduled prescribing. An APRN may prescribe a nonscheduled prescription drug (MCL 333.17211a(1)(a)). No delegation language attaches to it.
- Prescriber status. The definition of “prescriber” includes an advanced practice registered nurse, subject to section 17211a (MCL 333.17708(2)).
- Starter doses. An APRN may order, receive, and dispense complimentary starter dose drugs without delegation from a physician. Controlled substance starter doses remain a delegated act (MCL 333.17212(2) and (3)).
- Rounds. An APRN may make calls or go on rounds in ambulatory care clinics and other settings without restrictions on the time or frequency of visits by a physician (MCL 333.17214).
For a weight-loss or aesthetics clinic, the first item is the commercially important one. Semaglutide, tirzepatide and botulinum toxin are not scheduled drugs. An NP’s prescription for them does not need a physician’s name on it under section 17211a.
Controlled substances stay with the physician
An APRN may prescribe a controlled substance in schedules 2 to 5 only “as a delegated act of a physician” (MCL 333.17211a(1)(b)). When that happens, both the nurse’s name and the physician’s name must be used, recorded, or otherwise indicated with the prescription, and so must both of their DEA registrations (MCL 333.17211a(2)).
The Board of Medicine’s rule sets out the paperwork. Under Mich. Admin. Code R 338.2411, the delegating physician must establish a written authorization containing:
- The name, license number, and signature of the delegating physician.
- The name, license number, and signature of the nurse practitioner.
- The limitations or exceptions to the delegation.
- The effective date.
The physician must review and update the authorization annually and note the review date on it, keep it at the physician’s primary place of practice, and give the nurse practitioner a signed copy.
Testosterone is a Schedule III controlled substance under 21 C.F.R. § 1308.13(f), and Michigan’s Board of Pharmacy adopts the federal schedules by reference, with listed exceptions, in Mich. Admin. Code R 338.3111. Phentermine is Schedule 4 under MCL 333.7218. If your menu includes hormone therapy, an NP-only clinic cannot write it without a delegating physician and a current written authorization.
Three med spa functions a nurse practitioner cannot perform
Supervising the laser. A laser procedure for dermatological purposes must be performed under the supervision of a licensed physician (MCL 333.16276(1)). A certified nurse practitioner is exempt when the NP personally performs the procedure in a health care facility (MCL 333.16276(3)(c)). The exemption covers the NP’s own hands. It does not make the NP the supervisor of your laser technician.
Supervising medical exfoliation. Dermaplaning or microdermabrasion below the stratum corneum must be performed under physician supervision, and only a licensed physician is exempt (MCL 333.16276a, effective April 2, 2025). The NP is a supervised individual under that section.
Delegating medical acts. A licensee may delegate acts, tasks, or functions that “fall within the scope of practice of the licensee’s profession” (MCL 333.16215(1)). The NP’s profession is nursing. A registered nurse’s scope includes the direction and supervision of less skilled personnel in delegated nursing activities (MCL 333.17201(1)(e)). It does not include handing a medical act, such as a filler injection, to an RN, a medical assistant or an esthetician. That delegation has to come from a physician.
Task by task
| Function | NP alone | Physician required | Authority |
|---|---|---|---|
| Prescribe a nonscheduled drug (GLP-1, neurotoxin) | Yes | No | MCL 333.17211a(1)(a) |
| Prescribe Schedule 2 to 5 (testosterone, phentermine) | No | Yes, delegation plus written authorization | MCL 333.17211a(1)(b); R 338.2411 |
| Dispense starter doses, nonscheduled | Yes | No | MCL 333.17212(2) |
| Personally operate a laser in a health care facility | Yes | No | MCL 333.16276(3)(c) |
| Supervise another person’s laser treatment | No | Yes | MCL 333.16276(1) |
| Supervise medical exfoliation | No | Yes | MCL 333.16276a |
| Delegate medical acts to RNs or unlicensed staff | No | Yes | MCL 333.16215(1) |
The contested part: diagnosing and treating with no physician at all
You will hear two readings, and you should know both.
The first: Michigan has no statute that requires a collaborative agreement by that name, section 17211a gives nonscheduled prescribing without conditions, and so an NP may run a cash-pay injectables or weight-loss practice alone.
The second: prescribing follows a diagnosis and a treatment decision, those are the practice of medicine under section 17001, the only scope the Code gives an NP is the practice of nursing, and so the medical parts of the visit need physician delegation under section 16215.
The Code does not resolve this in a sentence. MDside works to the second reading. Our Michigan structures put a physician behind every medical act, with written delegation to each nurse practitioner, because a structure built on the first reading has no statute to point to when a complaint arrives. See how the two roles compare on nurse practitioner vs. physician medical directors.
Two bills would change this, and neither has passed
House Bill 4399 and Senate Bill 268 were both introduced on April 29, 2025. Each would amend sections 17201, 17210, 17211a and 17212 and add a new section 17210a on the scope of practice of nurse practitioners.
As of October 1, 2026, the Legislature’s bill history shows HB 4399 reported from the House Health Policy Committee with a substitute (H-1) and referred to the Committee on Rules on November 5, 2025. SB 268 shows no action after referral to the Senate Committee on Regulatory Affairs. Neither is law. Do not build a clinic on a pending bill.
What this means for you
If you are a nurse practitioner opening a Michigan clinic, you still need a Michigan-licensed physician for controlled substances, laser and exfoliation supervision, and any procedure your staff perform by delegation. If you are an owner hiring an NP as “medical director,” check each service on your menu against the table above and find the rows that say physician. Put the R 338.2411 authorization and the delegation documents in place before the first patient, and calendar the annual review. Ownership of the professional entity is a separate question, covered on medical director services in Michigan. For how we vet the physicians and NPs we place, see how we credential providers, and for non-controlled programs see weight management.
Frequently asked questions
Can a nurse practitioner practice independently in Michigan?
Partly. Under MCL 333.17211a, a Michigan APRN may prescribe nonscheduled prescription drugs without a physician’s delegation. Controlled substances in schedules 2 to 5 may be prescribed only as a delegated act of a physician. The Code defines an NP’s scope as the practice of nursing, so whether an NP may diagnose and treat with no physician involvement is contested.
Can a nurse practitioner prescribe testosterone in Michigan?
Only by physician delegation. Testosterone is a Schedule III controlled substance. MCL 333.17211a(1)(b) allows an APRN to prescribe schedules 2 to 5 as a delegated act of a physician, with both names and both DEA registrations indicated. Rule R 338.2411 requires a signed written authorization that the physician reviews every year.
Can a nurse practitioner supervise laser hair removal in Michigan?
No. MCL 333.16276(1) requires laser procedures for dermatological purposes to be performed under the supervision of a licensed physician. A certified nurse practitioner is exempt only for procedures the NP personally performs in a health care facility. Technicians, nurses and estheticians operating the laser need a supervising physician.
Did Michigan pass full practice authority for nurse practitioners?
No, as of October 1, 2026. House Bill 4399 and Senate Bill 268, both introduced April 29, 2025, would add a nurse practitioner scope section to the Public Health Code. HB 4399 was referred to the House Committee on Rules on November 5, 2025. Neither bill has been enacted.
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This is general information, not legal advice. Rules vary by state and change. Confirm your own facts with counsel.