Medical Spa Regulations in California

A MediSpaCover State Guide — what practices need to know to operate compliantly in California
✓ Reviewed by legal counsel | Last reviewed: August 11, 2026

Who Can Own a Med Spa in California

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.

  • A standard LLC or non-medical corporation cannot own a med spa delivering medical services.
  • Non-physician investors participate through a Management Services Organization (MSO) under a written Management Services Agreement, but cannot control clinical decisions.
  • New for 2026: under AB-890, a qualifying "104" nurse practitioner may practice independently within scope. Whether a 104 NP can wholly own the medical PC is unsettled among attorneys and unresolved by the courts or Medical Board.
  • SB 351 (effective January 1, 2026) further tightened what an MSO may control.
  • Med spas offering medical procedures must be registered with the Medical Board of California.

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

Medical Director Requirements

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

Who Can Perform Services, and at What Level

ProviderInjectables?Good Faith Exam?
MD / DOYes, full authorityYes
NP (104, AB-890)Yes, independently within scopeYes
NP (standard / 103)Yes, under standardized proceduresYes
Physician AssistantYes, under supervisionYes
Registered Nurse (RN)Yes, under a patient-specific order after a GFENo
LVNNo — prohibited even with supervisionNo
Esthetician / Medical AssistantNoNo

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

Good Faith Exam and Delegation Authority

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.

  • The patient-specific order must identify the procedure, note contraindications, and reflect the supervising physician's oversight.
  • Broad or generic standing orders are no longer adequate in California; each medical treatment requires an individualized patient-specific order. This is one of the most commonly cited scope issues.

Telemedicine

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.

Telemedicine Good Faith Exams

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.

Remote Prescribing and Controlled Substances

  • Non-controlled medications: no federal in-person exam requirement, but the prescriber must meet the standard of care and follow California board rules.
  • Controlled substances (Schedule II-V): under DEA temporary telemedicine flexibilities extended through December 31, 2026, a DEA-registered prescriber may prescribe via synchronous audio-video without a prior in-person visit. Permanent rules are expected before that date, so this is subject to change.
  • California overlay: to prescr