In most states, the identity of your medical director is a private commercial arrangement. In Tennessee, it is published on a state website with their license number next to it.
Since January 1, 2016, Tennessee has required medical spas to appear on an online registry maintained by the Board of Medical Examiners under Tenn. Code Ann. § 63-6-105. Anyone — a competitor, a plaintiff’s attorney, a journalist, an unhappy client — can look up your clinic and see who signed for it.
That single design choice changes the economics of a Tennessee directorship, and most operators do not think about it until something goes wrong.
What the registry contains
The statute directs the Board of Medical Examiners, in consultation with the Board of Osteopathic Examination, to establish and maintain an online registry for medical spas. At a minimum it lists:
- The name and physical address of the medical spa
- The name of the medical director or supervising physician
- That physician’s medical license number
- Whether they are an MD or a DO
The Board is authorized to set an annual fee for listed spas. Registration is renewed, not filed once and forgotten.
The definition catches you by advertising
This is where operators trip. Tennessee’s medical spa definition, at Tenn. Code Ann. § 63-1-153, reaches a practice that advertises or holds itself out as a medical spa, as well as one primarily engaged in elective cosmetic medical services.
Read that as a marketing rule as much as a clinical one. A wellness studio that adds neurotoxin on Fridays and starts using the words “med spa” on Instagram has arguably brought itself inside the definition through its own copy. The service menu is one trigger; the language on your website is another.
If you are not sure which side of the line you are on, the cheap move is to review the words before you review the menu.
Why a public registry changes the calculus
A directorship that exists only on paper is a bad idea everywhere. In Tennessee it is a bad idea that is indexed.
- Discovery starts with a search, not a subpoena. Connecting a physician to a clinic takes seconds, so the “I barely knew that clinic” defense never gets off the ground.
- Physicians can be audited by pattern. A single name appearing across an implausible number of listings is visible to anyone who looks, including the Board.
- Stale listings are their own problem. If your medical director resigned in March and the registry still names them in October, you have a public record asserting supervision that was not happening.
- Competitors read it. So do recruiters, and so do the attorneys advertising against your category.
Who may do what in Tennessee
Only a Tennessee-licensed MD or DO may serve as medical director or supervising physician. Tennessee does not require any particular specialty for the role — a family medicine, internal medicine or emergency physician may serve, and any vendor pricing a directorship on the premise that only a dermatologist or plastic surgeon will do is selling you a story.
Cosmetic medical procedures — injectables, energy-based treatments, microneedling — are medical acts. A physician may delegate them to appropriately licensed personnel, but delegation must be documented and must fit the receiving license, the applicable supervisory or collaborative arrangement, and Board standards. Delegation never expands scope; it only authorizes within it.
The annual renewal, and the physician who left
| Event | What has to happen | What usually happens |
|---|---|---|
| Opening a new location | Registry entry before operating | Filed late, after the launch party |
| Medical director resigns | Replace and update the listing | Listing left unchanged for months |
| Annual renewal | Renew and confirm accuracy | Auto-renewed with stale details |
| Rebrand to “med spa” | Definition may now apply | Nobody re-checks the definition |
| Adding cosmetic services | Protocols and delegation updated | Menu changes, paperwork does not |
The gap between column two and column three is the entire Tennessee compliance problem.
How Tennessee compares
Tennessee’s registry is unusual. Georgia has no facility registry at all but caps a physician at four APRN protocol agreements. Florida licenses clinics through AHCA rather than publishing a directory. Texas requires the physician’s name and license number to be posted in the treatment room rather than online — the same instinct, different venue.
Four states, four different answers. There is no national med spa compliance standard, and any product sold as one is a template with a state name pasted on top.
How MDside handles Tennessee
We place Tennessee-licensed MDs and DOs who will actually appear on the registry with their license number, keep the listing accurate as locations and directors change, write delegation and protocols against your real menu, and review your marketing copy against the statutory definition before it goes live.
Related reading
Frequently asked questions
Do all Tennessee med spas have to register?
Medical spas within the statutory definition are required to appear on the Board of Medical Examiners registry. The definition reaches practices that advertise or hold themselves out as a medical spa as well as those primarily providing elective cosmetic medical services.
Is the Tennessee med spa registry public?
Yes. It is an online registry, and it lists the medical director’s name and license number alongside the clinic.
Can a nurse practitioner be a Tennessee medical director?
No. The medical director or supervising physician role requires a Tennessee-licensed MD or DO. APRNs and PAs deliver care under the applicable supervisory arrangement.
Does the medical director need to be a dermatologist?
No. Tennessee does not mandate a specialty for the role.
What happens if our medical director leaves?
You need a replacement and an accurate registry entry. A listing that still names a departed physician is a public assertion of supervision that is not occurring, and it is visible to anyone who searches.
General information about Tennessee medical spa registration and supervision, not legal advice. Statutes, board rules and registry requirements change. Confirm your obligations with healthcare counsel licensed in Tennessee.