Medical Spa Compliance Checklist

At a Glance

• This checklist organizes the major compliance areas for a med spa.
• It is a planning tool, not a guarantee of compliance.
• Requirements vary by state, provider license, ownership, and services.
• Confirm each item with qualified professionals and official sources.

Licensure

• [ ] All providers hold active, appropriate licenses
• [ ] Licenses are verified with the issuing board
• [ ] License renewals are tracked
• [ ] CE requirements are met

Scope

• [ ] Each provider's scope of practice is confirmed for the treatments they perform
• [ ] Treatments are matched to provider credentials
• [ ] Training certificates do not substitute for scope confirmation

See Scope of Practice for Aesthetic Providers.

Ownership

• [ ] Ownership structure is reviewed for corporate-practice compliance
• [ ] Non-clinical ownership is confirmed as permitted (or restructured)
• [ ] Business entity is properly registered

See Corporate Practice of Medicine.

Oversight

• [ ] Medical director is engaged if required
• [ ] Medical director agreement is in place
• [ ] Oversight duties are defined and documented
• [ ] Medical director is licensed in the state

See Medical Director Coverage and What Does a Medical Director Do?.

Delegation

• [ ] Delegation is permitted under state rules
• [ ] Written protocols are in place for each delegated treatment
• [ ] Delegatees are qualified and competent
• [ ] Supervision levels are defined and followed

See Delegation.

Good Faith Exams

• [ ] Whether a Good Faith Exam is required is confirmed
• [ ] Who performs the exam is defined
• [ ] Exam timing and frequency are established
• [ ] Exam documentation is standardized

See What Is a Good Faith Exam?.

Protocols

• [ ] Treatment protocols for each service
• [ ] Emergency response protocols
• [ ] Adverse event protocols
• [ ] Protocol review schedule

Consent

• [ ] Informed consent forms for each treatment
• [ ] Consent is documented before treatment
• [ ] Consent forms are reviewed and updated
• [ ] Photo consent is obtained where applicable

Patient Records

• [ ] Treatment notes with product, lot, dose, and sites
• [ ] Before-and-after photos with consent
• [ ] Patient history and assessment
• [ ] Follow-up documentation
• [ ] Adverse event documentation
• [ ] Record retention policy

See What Should an Aesthetic EMR Include?. For documentation guidance, see Aesthetic Treatment Documentation Checklist, How to Document Botox and Dermal Filler Treatments, and Common Medical Spa Documentation Mistakes.

Privacy

• [ ] HIPAA policies in place
• [ ] Staff trained on privacy
• [ ] Secure storage of records
• [ ] Patient communication is secure
• [ ] Breach response plan

Medication Handling

• [ ] Products sourced from authorized suppliers
• [ ] Lot tracking for all injectables
• [ ] Storage requirements met (temperature, security)
• [ ] Inventory managed
• [ ] Recall protocol in place

Infection Control

• [ ] Sanitation standards met
• [ ] Sterilization procedures followed
• [ ] Single-use items disposed of properly
• [ ] Facility cleanliness maintained

Emergency Preparedness

• [ ] Emergency response protocol
• [ ] Emergency medications and equipment available
• [ ] Staff trained on emergency procedures
• [ ] Escalation path to medical director
• [ ] Hospital transfer plan

Training

• [ ] All providers trained for the treatments they perform
• [ ] Hands-on supervised experience documented
• [ ] Complication management training
• [ ] Ongoing continuing education

Insurance

• [ ] Malpractice insurance covers aesthetic treatments
• [ ] General business liability
• [ ] Workers' compensation
• [ ] Coverage is reviewed annually

Advertising

• [ ] Marketing is truthful and avoids guarantees
• [ ] Before-and-after photos comply with state rules
• [ ] Credentials are accurately represented
• [ ] Testimonials comply with state rules

See Aesthetic Advertising Compliance Basics.

Chart Review

• [ ] Medical director reviews charts periodically
• [ ] Review frequency is defined
• [ ] Findings are communicated and corrected
• [ ] Review is documented

Ongoing Review

• [ ] Compliance is reviewed at least annually
• [ ] Protocols are updated when services or rules change
• [ ] Staff training is refreshed
• [ ] Insurance is reviewed
• [ ] New state guidance is monitored

What Providers Should Verify

• This checklist is a planning tool, not a guarantee of compliance.
• Requirements vary by state, license, ownership, and services.
• Confirm each item with qualified professionals and official sources.
• Compliance is ongoing, not a one-time setup.

Frequently Asked Questions

Does completing this checklist make my practice compliant? No. This is a planning tool. Compliance depends on meeting the specific requirements that apply in your state and to your services.

How often should I review compliance? At least annually, and whenever services, staff, ownership, or rules change.

Where can I find state-specific requirements? Start with the State Requirements hub, then confirm with your state's licensing boards and qualified counsel.