Medical Spa Regulations in Tennessee

A MediSpaCover State Guide — what practices need to know to operate compliantly in Tennessee
✓ Reviewed by legal counsel | Last reviewed: August 16, 2026

Who Can Own a Med Spa in Tennessee

Tennessee is a restricted-practice state: the medical director must be a physician with an active Tennessee practice, and non-physicians typically participate through a Management Services Organization (MSO) model. NPs, PAs, and RNs operate under written protocols with a supervising physician, they do not own the clinical entity outright.

  • The medical director must be a physician actively practicing in Tennessee.
  • Non-physician involvement (including NP-, PA-, or RN-led business ownership) is structured through an MSO with a written protocol and supervising physician.
  • NPs and PAs require a written protocol/supervision arrangement; Tennessee does not grant NP full practice authority.

Source: Tennessee Board of Medical Examiners — tn.gov/health

Source: Tennessee Board of Nursing — tn.gov/health

Medical Director Requirements

A Tennessee med spa needs a physician medical director with an active Tennessee practice who sets protocols, supervises delegated care, and stands behind the medical services. Injectables, lasers, and IV therapy are the practice of medicine requiring genuine physician oversight, not a nominal arrangement.

Source: Tennessee Board of Medical Examiners — tn.gov/health

Who Can Perform Services, and at What Level

ProviderInjectables?Notes
MD / DOYes, full authorityDelegating authority; clinical control
NPYes, under a collaborative/protocol agreementPhysician collaboration required; cannot own clinical entity
Physician AssistantYes, under supervisionSupervising physician required
Registered Nurse (RN)Yes, under delegation after a GFECannot perform GFE or prescribe
LPN / LVNLimited; generally not injectablesRestricted scope
Esthetician / non-licensedNoNon-medical services only

Source: Tennessee Board of Nursing — tn.gov/health

Good Faith Exam and Delegation Authority

A good faith exam by a physician, NP, or PA must precede treatment and establish the order under which an RN administers. The RN cannot perform the GFE or prescribe. Written protocols with the supervising physician define each delegated service.

Telemedicine

  • Tennessee permits telehealth consistent with the standard of care; the GFE may be conducted via compliant synchronous telehealth where appropriate.
  • Controlled-substance prescribing follows the federal DEA telemedicine flexibilities (extended through December 31, 2026, subject to permanent rulemaking) plus Tennessee licensing and the Controlled Substance Monitoring Database (CSMD); the stricter rule governs.

Source: Tennessee Telehealth (Board of Medical Examiners) — tn.gov/health

Source: Tennessee CSMD — tn.gov/health

Mobile and Off-Site Services

Mobile med spa services are permitted in Tennessee only when the full medical framework, the required physician or prescriber oversight, a valid order, and proper handling, is met at the off-site location. The mobile setting does not lower the standard.

  • The oversight and delegation structure applies to mobile work, not just the fixed clinic.
  • A good faith exam and valid order are required before any injectable or prescription treatment off-site; group or event settings require an individualized exam and order for each attendee.
  • Sterility, sharps handling, medication storage and cold chain, emergency readiness (including anaphylaxis), and proper disposal must be maintained off-site to clinical standards.
  • Controlled substances transported or administered off-site must follow DEA storage and recordkeeping rules.

Because mobile and event-based aesthetics draw regulatory attention and the compliance burden travels with the provider, practices should confirm their coverage explicitly extends to off-site and mobile work.

Lab Draws, Prescribing, and Performing the Service

  • Prescribing (including GLP-1): an authorized prescriber may prescribe after a GFE.
  • Administering: RNs may administer injectables and infusions under a valid order after the GFE; LPNs are generally restricted from injectables.
  • Lab draws: phlebotomy by qualified personnel; interpretation and