Texas does not bar non-physician ownership the way California does. A non-physician can own the business through a Management Services Organization (MSO) structure, but a supervising physician (medical director) is mandatory, and aesthetic procedures are legally the practice of medicine.
Source: Texas Medical Board — tmb.state.tx.us
Source: Texas Occupations Code Ch. 164 — statutes.capitol.texas.gov
Under Texas law, aesthetic procedures (injectables, lasers, GLP-1 prescribing, hormone therapy) are the practice of medicine. Only a licensed physician can perform or delegate these acts, and the physician remains fully responsible for the outcome; delegation does not transfer liability. In January 2025 the TMB consolidated its delegation framework under 22 TAC Chapter 169.
Source: Texas Medical Board — 22 TAC Chapter 169 — tmb.state.tx.us
| Provider | Injectables? | Good Faith Exam / order? |
|---|---|---|
| MD / DO | Yes, full authority | Yes (delegating authority) |
| NP (APRN) | Yes, under physician supervision | Yes, can perform GFE/order |
| Physician Assistant | Yes, under supervision (22 TAC §185.14) | Yes, can perform GFE/order |
| Registered Nurse (RN) | Yes, under written delegation after a GFE | No |
| LVN | Limited; generally not injectables | No |
| Esthetician / Medical Assistant | No | No |
Source: Texas Board of Nursing (Nursing Practice Act, Ch. 301) — bon.texas.gov
In Texas the good faith exam must be performed by a provider who can diagnose and order treatment, a physician, NP, or PA, never the RN. Under 22 TAC §169.26, the written delegation protocol must specify the required qualifications of the person performing the delegated act.
Texas allows telehealth prescribing of GLP-1 medications when a proper patient-provider relationship is established, a clinically appropriate assessment is conducted, and prescribing follows TMB telemedicine standards (22 TAC §174.6). Prescribing via a brief online questionnaire without a proper evaluation is a TMB violation.
Source: Texas Medical Board — Telemedicine (Occupations Code Ch. 111; 22 TAC §174) — tmb.state.tx.us
Source: DEA / HHS Telemedicine Flexibilities — dea.gov
Mobile med spa services are permitted in Texas only when the full medical framework, physician delegation, a valid order, and proper supervision, 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.
Source: Texas Medical Board — tmb.state.tx.us
Prescription and compounded products (including compounded GLP-1) must be prescribed by an authorized prescriber after a good-faith exam and sourced through appropriately licensed pharmacies. Texas med spas should verify their compounding pharmacy's current FDA compliance status. See the National Regulatory News & Headlines page for current developments.
Med spa liability spans the entire treatment menu. These link to primary and news sources so you can read the facts directly:
Texas enforcement context: the Texas Medical Board is one of the most active med spa enforcement bodies in the country. The most requested items when a complication becomes a claim are the written delegation protocol, the good-faith-exam record, and documentation of who ordered and who administered each service.
Source: Texas Medical Board — Look Up a License / Disciplinary Actions — profile.tmb.state.tx.us
Wellness Medical Protection Group, LLC is a licensed producer in Texas (License #_____) and places specialized med spa and integrative wellness insurance for Texas practices, including mobile and off-site work and the high-risk procedures many standard carriers decline.
Check your eligibility for practice coverage or request a consultation.
Check Eligibility Request a ConsultationDisclaimer: This is not an offer to purchase insurance. This page is intended to provide general information and should not be relied upon as a substitute for evaluating compliance with applicable legal requirements or unique risks and insurance needs of a particular healthcare provider. Texas scope-of-practice, ownership, telemedicine, mobile-service, and medical-director rules are complex and may change over time. Wellness Medical Protection Group, LLC does not guarantee accuracy or completeness of the information provided on this page. Providers should confirm current applicable requirements with the Texas Medical Board, the DEA, and relevant licensing boards, and consult a Texas healthcare attorney before structuring or operating a practice. Last reviewed: August 11, 2026.