What a med spa really is
Short answer: to start a med spa you need an ownership structure your state allows, a medical director or supervising physician, licensed injectors working within their scope, the right facility registrations, malpractice cover and a launch plan. Neurotoxins, fillers and most laser treatments are the practice of medicine, so the rules for medical practices apply. AmSpa
The industry is large and growing. The American Med Spa Association counted 10,488 US med spas in 2023, up from 8,899 in 2022, with average annual revenue of about $1.4 million. Most are single locations, and 73% of patients are repeat clients. AmSpa
Who can own a med spa
Many states bar non-physicians from owning a medical practice or employing physicians, under the corporate practice of medicine doctrine. In those states, nurse practitioners and physician assistants are often only allowed as minority co-owners with physicians, and aestheticians generally cannot co-own the medical business. AmSpa
The usual workaround is a management services organization. A non-physician owns the MSO, which runs the business side under a management agreement, while a physician-owned professional entity provides the care, and the MSO must not interfere with medical judgment. In California, for example, a physician must own at least 51% when partnering with non-physicians. AmSpa and ByrdAdatto In more permissive states anyone can form the entity, though a clinic license or board registration may still apply. Check the med spa section of your state guide.
Who can inject neurotoxins and fillers
Injecting is the practice of medicine, so only licensed providers acting within their scope may do it, and the rules vary by state. In many states nurse practitioners, PAs and registered nurses may inject with training and physician supervision. AmSpa Two examples show how far apart states are:
- Illinois: RNs, LPNs and medical assistants may inject only after a physician has examined the patient and issued a treatment order, with physician supervision. AmSpa
- Alabama: in September 2025 the medical board said only a physician, or a PA or NP with an approved protocol, may give cosmetic neurotoxin injections, which rules out RN injectors. AmSpa
Medical director, good faith exams and lasers
States decide whether a non-physician owner can contract a medical director, whether a physician or other qualified provider must examine every new patient before treatment, whether a supervisor must be on site and who may operate lasers. AmSpa tracks each of these as a separate state-by-state question and warns that the rules change often. AmSpa Get the answers for your state in writing from a healthcare attorney before you sign a lease.
How to start a med spa, step by step
- Confirm the ownership structure. Direct ownership, physician partnership or MSO, based on your state’s rules.
- Engage a medical director and agree supervision, protocols, chart review and good faith exam arrangements in writing.
- Form the entities and get your EIN, NPIs and any state clinic license or board registration.
- Hire licensed injectors and aestheticians and confirm each person’s scope for every service.
- Choose equipment and suppliers, including product sourcing direct from manufacturers or authorized distributors.
- Insure the practice with malpractice cover that names every treatment you offer.
- Set up booking, consent forms, photography consent and memberships before opening.
- Launch marketing four to eight weeks ahead with a founding client list and opening events.
Services to open with
Most new med spas start with services that need little equipment and bring clients back: neurotoxins, fillers, skin treatments and facials, then add lasers, body treatments or medical weight loss once the client base is there. Repeat visits are the economics of the business, so memberships and rebooking matter from day one.
Marketing a new med spa
- Meta allows ads for fillers, injectables, peels, microneedling and laser treatments, and cosmetic before and after images, only when targeted to people 18 and over, and bans ads that make people feel bad about how they look. Meta
- Instagram content filmed in your rooms, with your injectors, does more than stock imagery.
- Reviews decide local choices, and FTC rules ban fake reviews and incentives that depend on positive reviews. FTC
See how we market med spas on our med spa marketing page, or plan your opening with us.
