Does the Corporate Practice of Medicine Doctrine Apply to Medical Spas in Florida?

Short answer: Florida has no such doctrine, but other rules apply.

Welcome to today’s mini vlog on “Are Medical Spas Subject to the Corporate Practice of Medicine Doctrine in Florida?” Medical spas, which blend aesthetic services with medical treatments, have become increasingly popular, but the regulations surrounding their operation can be complex. Florida does not have a corporate practice of medicine doctrine that bars non-physicians from owning a medical practice or medical spa. Instead, the Health Care Clinic Act requires an entity that provides health care services and tenders charges for reimbursement to hold a clinic license from the Agency for Health Care Administration unless an exemption applies. A practice wholly owned by licensed health care practitioners is generally exempt. A licensed clinic must have a medical director or clinic director who accepts legal responsibility for its compliance (ss. 400.9905, 400.991 and 400.9935, Fla. Stat., as of October 2026). Whoever owns the business, medical decisions belong to the licensed professionals.

Injectables and laser treatments are medical procedures. Non-physicians perform them only within their own license and under the supervision the law requires (ss. 458.303 and 458.348, Fla. Stat.). While non-physicians may have a stake in the business side of the spa, they cannot interfere with or control any medical decisions. A physician must ultimately be responsible for all medical procedures and treatment plans offered in the spa. An attorney can help clarify ownership structures and how these supervision rules apply to your spa.

For medical spa owners, the structural questions are licensing and supervision rather than ownership. Some owners use a management services organization (MSO), which lets non-physicians run the business operations while licensed professionals make all medical decisions. Everyone who performs medical services must be properly licensed, and the spa must follow the rules on patient care and record-keeping. An attorney focused on healthcare law can help you set up a structure that fits these rules.

Because the rules turn on clinic licensing, scope of practice and supervision rather than ownership, legal review is worth doing before you open or buy a medical spa. An attorney can help you check whether the spa needs a clinic license or qualifies for an exemption, and how physician supervision should be documented, so medical decisions stay with licensed professionals while non-physicians manage the business side. Legal review can help a med spa’s structure follow these rules.

Related reading

• Starting an Aesthetic Practice in Florida: Legal Considerations
• Ensuring Your Medical Spa Meets Florida’s Safety and Sanitation Standards
• Best Practices for Informed Consent in Medical Spa Procedures
• Medical Spa Supervision: Determining the Roles of Physicians, Nurses, and Estheticians
• Overview of Medical Board Regulations for Medical Spas

Practice area: Med Spa Attorney in Florida: Buying and Selling a Med Spa