An April 6, 2026, American Medical Association article, citing a Dermatologic Surgery study, reports that 36 states lack clear rules governing Med Spa ownership, licensure, and supervision, resulting in inconsistent oversight and patient protection standards.
Study Examines State Laws on Med Spa Ownership, Licensure, and Supervision
On April 6, 2026, the American Medical Association reported that 36 states lack clearly defined regulatory oversight specific to Med Spas, based on a 2025 study published in Dermatologic Surgery. The analysis examined state laws governing ownership, licensure, and supervision of Med Spa services. The findings are relevant to Med Spa operators because they reflect differences in how states define compliance obligations and enforce patient protection standards.
State-Level Review Shows Limited Med Spa Licensing and Oversight
A 2025 study published in Dermatologic Surgery identified significant gaps in how states regulate Med Spa operations, particularly in areas of ownership, licensure, and clinical oversight. The American Medical Association article reported that 36 states had no identified laws or regulations specific to Med Spas, and 44 states lacked patient-protection requirements specific to those businesses.
The 2025 analysis found that only 12 states—Connecticut, Iowa, Illinois, Indiana, Massachusetts, New Mexico, Oklahoma, Rhode Island, Tennessee, Texas, Utah, and Wisconsin—had any Med-Spa-specific regulatory provisions.
As reported in the American Medical Association article, licensing requirements were limited. All states except two lacked identifiable licensing standards specific to Med Spas as a distinct category. Massachusetts required clinic licensure in certain ownership structures, while Tennessee required state registration.
Separate findings cited by the American Medical Association highlight the wide variation in Med Spa ownership and supervision structures. In its 2025 issue brief, Scope of Practice: Physician-Led Care in Medical Spas, the American Medical Association reported that approximately 70% of Med Spas operate without affiliation to a physician practice, and only 37% were physician-owned in 2022.
The American Society for Dermatologic Surgery Association outlines standards for physician supervision, patient evaluation, training, and documentation through its model “Medical Spa Safety Act,” updated in March 2025. The model legislation states that lack of regulation has enabled cosmetic medical procedures to be performed by inadequately trained or supervised individuals and proposes requirements for on-site physician supervision, treatment planning, informed consent, and adverse event reporting.
These findings are relevant to Med Spa operators because they show that compliance requirements related to supervision, delegation, and clinical responsibility are often defined at the state level rather than through consistent national standards.
Source Attribution
According to the April 6, 2026, American Medical Association article, the findings are based on a 2025 study published in Dermatologic Surgery that examined state laws related to Med Spa ownership, licensure, supervision, and patient protections.
Compliance Context: State Laws Define Med Spa Oversight and Enforcement
In the 36 states identified as lacking Med-Spa-specific regulatory oversight, state law determines how Med Spa services are regulated, including supervision, delegation, prescribing, and scope of practice. In those jurisdictions, oversight is applied through existing laws governing the practice of medicine, nursing, and facility operations.
Inspection activity in New York demonstrates how agencies apply those requirements in practice. A January 8, 2026, press release from the New York Department of State described a coordinated, multi-agency operation involving inspections of 223 Med Spas, with 87 cited for violations such as unlicensed practice and lack of supervision. The agency indicated that inspections would continue as part of ongoing enforcement efforts.
In Connecticut, enforcement activity related to GLP-1 services developed over multiple stages. Public statements issued on April 9, 2026, by state and federal officials followed earlier actions, including a May 21, 2025, warning to clinics and Med Spas and cease-and-desist letters sent in December 2025 to businesses advertising compounded GLP-1 drugs. The activity focused on how weight-loss medications were marketed, sourced, and prescribed in Med Spa and clinic settings.
Across these examples, enforcement actions are tied to how services are performed under existing state requirements, including physician oversight, delegation to non-physician providers, prescribing practices, and credential verification. The procedures involved—such as injectable treatments and medication-based services—align with categories identified in the Dermatologic Surgery study and related American Medical Association materials as requiring physician supervision, training, and defined oversight under state law.
Practical Implications for Med Spa Operators
Based on the AMA-cited findings on supervision, licensure, and scope of practice, key compliance considerations include:
- Verify that supervision structures align with state law, including physician involvement, delegation protocols, and scope-of-practice requirements governing Med Spa services.
- Confirm that all clinical staff are properly licensed and credentialed, particularly when non-physician personnel perform injectable or device-based procedures.
- Ensure prescribing practices comply with applicable regulations, especially for medication-based services such as GLP-1 treatments, including sourcing, dosing, and provider authorization.
- Maintain documentation supporting patient evaluation, treatment planning, and informed consent, consistent with the requirements of medical and nursing practice laws.
- Review how services are marketed and represented, including claims related to medical treatments, to ensure alignment with state and federal advertising and consumer protection standards.
What to Watch Next in Med Spa Oversight
Ongoing inspections, enforcement actions, and legislative proposals continue to shape how states apply existing laws to Med Spa services, particularly in areas such as supervision, prescribing, and scope of practice.
About Spakinect
Spakinect provides compliance infrastructure and telehealth-supported supervision solutions for medical aesthetic practices. For additional information, see our website.
Image Attribution: “Courtroom at the Cherokee County Courthouse in North Carolina, United States” by Harrison Keely, via Wikimedia Commons, licensed under CC BY 4.0
