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.
Source: Tennessee Board of Medical Examiners — tn.gov/health
Source: Tennessee Board of Nursing — tn.gov/health
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
| Provider | Injectables? | Notes |
|---|---|---|
| MD / DO | Yes, full authority | Delegating authority; clinical control |
| NP | Yes, under a collaborative/protocol agreement | Physician collaboration required; cannot own clinical entity |
| Physician Assistant | Yes, under supervision | Supervising physician required |
| Registered Nurse (RN) | Yes, under delegation after a GFE | Cannot perform GFE or prescribe |
| LPN / LVN | Limited; generally not injectables | Restricted scope |
| Esthetician / non-licensed | No | Non-medical services only |
Source: Tennessee Board of Nursing — tn.gov/health
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.
Source: Tennessee Telehealth (Board of Medical Examiners) — tn.gov/health
Source: Tennessee CSMD — tn.gov/health
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.
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.