California operates under the Corporate Practice of Medicine (CPOM) doctrine, one of the strictest in the country. A med spa performing medical procedures must be owned through a physician-controlled Professional Corporation (PC), not a standard LLC, with physicians holding at least 51 percent.
Source: Medical Board of California / B&P Code §2400 — https://www.mbc.ca.gov
Source: California Legislative Information (AB-890, SB 351) — https://leginfo.legislature.ca.gov
Every California med spa performing medical procedures must have a medical director who is an actively licensed MD or DO (or, as of January 2026, a qualifying 104 NP under AB-890). The role is substantive: writing protocols, deciding which procedures the facility offers, determining which staff are qualified, and actively supervising. The Medical Board enforces delegation and supervision standards and has expanded audits of med spas.
Source: Medical Board of California — https://www.mbc.ca.gov
| Provider | Injectables? | Good Faith Exam? |
|---|---|---|
| MD / DO | Yes, full authority | Yes |
| NP (104, AB-890) | Yes, independently within scope | Yes |
| NP (standard / 103) | Yes, under standardized procedures | Yes |
| Physician Assistant | Yes, under supervision | Yes |
| Registered Nurse (RN) | Yes, under a patient-specific order after a GFE | No |
| LVN | No — prohibited even with supervision | No |
| Esthetician / Medical Assistant | No | No |
Source: CA Board of Registered Nursing (B&P §2725; 16 CCR §1474) — https://www.rn.ca.gov
Source: Board of Vocational Nursing & Psychiatric Technicians — https://www.bvnpt.ca.gov
Before any injectable or prescription-classified treatment, an authorized prescriber (MD, DO, NP, or PA) must complete a Good Faith Exam (GFE) establishing a valid provider-patient relationship. As of 2026, California has moved firmly away from broad standing orders: the GFE must result in a documented, individualized Patient-Specific Order (PSO) for that patient and that treatment. A GFE alone is not enough without the PSO. Only then may an RN perform the procedure under that order. An RN cannot perform the GFE.
Telemedicine is central to modern med spa operations in California, both for the Good Faith Exam and for remote prescribing. It is permitted, but tightly governed by overlapping state and federal rules.
California permits the GFE by telemedicine, allowing a collaborating physician or NP to evaluate a patient remotely before an RN performs treatment. The standard of care is identical to in-person. Boards expect synchronous audio-video; California law excludes fax, standard email, and basic text chat. Asynchronous questionnaires cannot bypass a real-time encounter, and the exam must still produce a patient-specific order.