MedSpa & Aesthetics
CPOM applies when medical services are offered. Physician PC required in most states.
Medical spas and aesthetic practices are among the most common use cases for friendly PC owner services. When a medspa or aesthetics practice offers services that require a medical license — injectables, laser treatments, PRP, hormone therapy, weight loss medications — those services must be delivered through a physician-owned entity in CPOM states.
Key CPOM Considerations
- All injectables (Botox, fillers, Kybella) require physician oversight in most states
- Laser treatments are medical devices under most state laws requiring physician entity
- PRP, IV therapy, and hormone optimization are medical services requiring proper structure
- Non-physician providers (NPs, PAs) can provide services but must be supervised by a physician
- The medspa business entity (MSO) can be separately owned; the medical services entity (PC) must be physician-owned
- California SB 351 (effective Jan 1, 2026) has significant implications for medspa operators in California
MedSpa & Aesthetics — CPOM & Compliance Guide
The Medspa Compliance Problem
The medspa industry grew rapidly over the past decade, and compliance structures often lagged behind business growth. Many medspas are operated by non-physician entrepreneurs with a physician "on call" — but without proper physician ownership of the medical entity. State medical boards have been increasing enforcement, and this structure is legally insufficient in most CPOM states.
What Services Require a Physician PC
Any service that requires a physician's order, a medical license to perform, or constitutes the practice of medicine requires the delivering entity to be physician-owned in CPOM states. This includes: botulinum toxin (Botox, Dysport) injections, dermal fillers, platelet-rich plasma (PRP) treatments, laser and light-based procedures, IV therapy, hormone therapy and optimization, weight loss prescription medications, and any other service classified as medical under state law.
The Correct Structure for MedSpas
The standard structure for a CPOM-compliant medspa is the MSO-PC framework. The medspa's business operations (marketing, staffing, equipment, real estate) are managed by the MSO, which can be owned by the non-physician entrepreneur. The medical services entity is the PC, which must be physician-owned. The MSO provides services to the PC under a Management Services Agreement. The PC owns the medical side of the business and contracts with or employs the clinical providers.
California MedSpas and SB 351
California medspas face the most demanding compliance environment. California's Medical Board actively audits medspa operations, and SB 351 (effective January 1, 2026) tightened the rules on management agreements. California medspa operators must ensure their MSA does not give the MSO operational control over physician decisions — including physician hiring, firing, and clinical protocol approval.
Multi-Location MedSpas
Multi-location medspa operators face additional complexity. Each location may require its own state-specific physician PC if the locations are in different CPOM states. A single national PC is often insufficient for a medspa chain operating across multiple strict-enforcement states. Structure should be reviewed by state for each location.
Key States for MedSpa & Aesthetics Operators
These are the states with the highest CPOM enforcement relevance for medspa & aesthetics businesses:
Disclaimer: This page provides general educational information and does not constitute legal advice. CPOM rules vary by state and evolve over time. Consult a qualified healthcare attorney for advice specific to your situation.
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