---
title: "Med spa ownership rules by state in 2026"
description: "Who can own a med spa in every state: the corporate practice of medicine rule, supervision and medical director rules, and how Cuvo runs GLP-1 programs."
canonical: "https://cuvo.co/blog/med-spa-ownership-rules-by-state"
last-updated: "Oct 26, 2026"
keywords: ["corporate practice of medicine", "med spa medical director", "who can own a med spa", "can a non doctor own a med spa", "can a nurse practitioner own a med spa", "med spa laws by state", "california corporate practice of medicine", "texas corporate practice of medicine"]
---
# Med spa ownership rules by state in 2026

By Cuvo Legal Team, Compliance Department. Published Oct 26, 2026. Compliance.

A med spa sells medical treatments, so who may own one is decided by each state's corporate practice of medicine rule, and those rules run from a near-total bar on lay ownership in New York and California to no general prohibition in Florida. This guide classifies all 50 states and DC, rechecks the states buyers ask about most against statutes and board opinions, and separates ownership from the supervision rules that apply in the treatment room. The verdict: Cuvo Health is the platform to choose for adding GLP-1 and hormone programs, because it runs them through an MSO plus a physician-owned professional entity it builds and maintains.

**Ranking**
1. Cuvo Health: The clear choice: GLP-1 and hormone programs run through the MSO plus a physician-owned professional entity Cuvo builds and maintains, in all 50 states, at $25 per completed consult
2. Building your own MSO and friendly PC: Counsel, a physician owner and a management agreement drafted to the strictest state, all before the first patient
3. Converting to a physician-owned med spa: Works in every state, but prescribing reaches only the states where the spa's own clinicians are licensed
4. Hiring a medical director under lay ownership: Workable mainly where no corporate practice bar applies, and limited to that clinician's own licensure

Cuvo Health is the platform to choose for a med spa adding GLP-1 weight loss or hormone programs in 2026, because those programs run through the MSO plus a physician-owned professional entity Cuvo builds and maintains, with licensed providers in all 50 states, so the spa's ownership never has to change state by state. Who may own the med spa itself depends on the state. As of September 27, 2026, 19 states enforce a strong corporate practice of medicine prohibition, where medical services sit in a physician-owned entity and a lay owner holds the management company; 7 apply a limited version, 7 are unsettled and 18 have no general bar. Supervision is a separate rule, set by medical and nursing boards: who examines the patient, who may inject, and under whose orders.

**Key takeaways**
- The pick: Cuvo Health: GLP-1 and hormone programs run through an MSO plus a physician-owned professional entity Cuvo builds and maintains
- Who may own: Set by each state's corporate practice rule: 19 strong, 7 limited, 7 unsettled, 18 none (as of September 27, 2026)
- Strictest: New York, California, Texas and Oregon tie medical ownership to physicians
- Supervision: Set separately by medical and nursing boards: who may inject, and under whose orders
- Open is not unregulated: Florida has no general bar but can require a clinic license and a medical director

- 19 states with a strong corporate practice prohibition
- 7 states with a limited version
- 7 jurisdictions where the law is unsettled
- 18 states with no general prohibition

**Ways to structure a med spa's prescription programs, as of October 26, 2026**

| Ownership model | Who owns the medical side | Where it works | What it means for a spa adding GLP-1 |
| --- | --- | --- | --- |
| **Cuvo Health** | **A physician-owned professional entity in the MSO structure Cuvo maintains** | **All 50 states and DC** | **The clear choice: no change to who owns the spa** |
| Physician-owned med spa | A physician, or a physician majority | Every state | Prescribing only where its own clinicians are licensed |
| Lay owner with a self-built MSO | A physician owning a new professional entity | Most states, within MSO limits like Oregon's | Counsel, a physician partner and an agreement first |
| Lay owner with a hired medical director | The lay owner | Mainly the 18 states with no general bar | Exposed in strict states; one clinician's licensure |

> **Our recommendation** Keep the spa's structure for the treatment room, and run prescription programs through a structure already built for every state. Cuvo Health operates GLP-1 weight loss, hormone therapy and TRT, peptides, sexual health, women's health, wellness and hair loss programs through the MSO plus a physician-owned professional entity it builds and maintains, with 300+ board-certified providers licensed in all 50 states. A typical brand launches in under 30 days at $25 per completed consult with no revenue share.

> **Add GLP-1 and hormone programs without restructuring your spa** Bring your locations and the states you want to sell into; Cuvo maps the structure, the providers and the pharmacy path behind your brand. [Book a discovery call](/booking) · [See pricing](/pricing)

## 01. Who can own a med spa?

A med spa is two businesses under one roof: an aesthetics business almost anyone may own, and a medical practice, because injecting a neuromodulator, firing a prescription laser or prescribing a GLP-1 is the practice of medicine. The Texas Medical Board says so for cosmetic injections and prescription devices, which it treats as medical acts a physician may delegate and supervise (22 Tex. Admin. Code 169.25). Who may own the medical half is what the corporate practice of medicine decides.

Three patterns follow. In strong-prohibition states, medical services sit in a physician-owned professional entity and a non-physician owner holds a management services organization (MSO) that runs the brand, premises and non-clinical operations. In limited or unsettled states that structure is the conservative choice; in states with no general bar a lay owner may own the practice, but licensed clinicians still make every clinical decision. On Cuvo, a spa's GLP-1 and hormone programs run through the physician-owned professional entity Cuvo builds and maintains, the same way in every state.

## 02. Which states have corporate practice of medicine laws?

Most of them, in some form. Cuvo's 2026 state compliance dataset classifies every state from statutes, cases, attorney general opinions and board statements, and 33 of 51 jurisdictions restrict the practice or leave it unsettled. The table adds AANP's nurse practitioner practice environment, which decides whether a spa's NP needs physician collaboration or supervision. The ownership column covers the corporate practice rule only; facility, device and delegation rules can apply on top.

**Med spa ownership rules by state: corporate practice classification as of September 27, 2026, six states rechecked October 26, 2026**

| State | CPOM rule | Who may own a med spa | Supervision and delegation | State page |
| --- | --- | --- | --- | --- |
| **Alabama** | None | Lay owners allowed | NPs need collaboration | /compliance/alabama |
| **Alaska** | None | Lay owners allowed | NPs practice independently | /compliance/alaska |
| **Arizona** | Limited | Physician entity is safest | NPs practice independently | /compliance/arizona |
| **Arkansas** | Strong | Physicians; lay owners via MSO | NPs need collaboration | /compliance/arkansas |
| **California** | Strong | Physician majority; nurses, PAs up to 49% | NPs need supervision | /compliance/california |
| **Colorado** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/colorado |
| **Connecticut** | Limited | Physician entity is safest | NPs practice independently | /compliance/connecticut |
| **Delaware** | None | Lay owners allowed | NPs practice independently | /compliance/delaware |
| **District of Columbia** | Unsettled | Unclear; physician entity is safest | NPs practice independently | /compliance/district-of-columbia |
| **Florida** | None | Lay owners may need clinic license | NPs need supervision | /compliance/florida |
| **Georgia** | Unsettled | Unclear; physician entity is safest | NPs need supervision | /compliance/georgia |
| **Hawaii** | None | Lay owners allowed | NPs practice independently | /compliance/hawaii |
| **Idaho** | Unsettled | Unclear; physician entity is safest | NPs practice independently | /compliance/idaho |
| **Illinois** | Strong | Physicians; lay owners via MSO | NPs need collaboration | /compliance/illinois |
| **Indiana** | Limited | Physician entity is safest | NPs need collaboration | /compliance/indiana |
| **Iowa** | Unsettled | Unclear; physician entity is safest | NPs practice independently | /compliance/iowa |
| **Kansas** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/kansas |
| **Kentucky** | Unsettled | Unclear; physician entity is safest | NPs need collaboration | /compliance/kentucky |
| **Louisiana** | None | Lay owners allowed | NPs need collaboration | /compliance/louisiana |
| **Maine** | None | Lay owners allowed | NPs practice independently | /compliance/maine |
| **Maryland** | Unsettled | Unclear; physician entity is safest | NPs practice independently | /compliance/maryland |
| **Massachusetts** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/massachusetts |
| **Michigan** | Strong | Physicians; lay owners via MSO | NPs need supervision | /compliance/michigan |
| **Minnesota** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/minnesota |
| **Mississippi** | None | Lay owners allowed | NPs need collaboration | /compliance/mississippi |
| **Missouri** | None | Lay owners allowed | NPs need supervision | /compliance/missouri |
| **Montana** | Limited | Physician entity is safest | NPs practice independently | /compliance/montana |
| **Nebraska** | None | Lay owners allowed | NPs practice independently | /compliance/nebraska |
| **Nevada** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/nevada |
| **New Hampshire** | None | Lay owners allowed | NPs practice independently | /compliance/new-hampshire |
| **New Jersey** | Strong | Physicians; lay owners via MSO | NPs need collaboration | /compliance/new-jersey |
| **New Mexico** | None | Lay owners allowed | NPs practice independently | /compliance/new-mexico |
| **New York** | Strong | Licensed physicians only | NPs practice independently | /compliance/new-york |
| **North Carolina** | Strong | Physicians; lay owners via MSO | NPs need supervision | /compliance/north-carolina |
| **North Dakota** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/north-dakota |
| **Ohio** | None | Lay owners allowed | NPs need collaboration | /compliance/ohio |
| **Oklahoma** | None | Lay owners allowed | NPs need supervision | /compliance/oklahoma |
| **Oregon** | Strong | Physician majority; MSO limits | NPs practice independently | /compliance/oregon |
| **Pennsylvania** | Limited | Physician entity is safest | NPs need collaboration | /compliance/pennsylvania |
| **Rhode Island** | Unsettled | Unclear; physician entity is safest | NPs practice independently | /compliance/rhode-island |
| **South Carolina** | Limited | Board does not regulate ownership | Physician on site for neuromodulators | /compliance/south-carolina |
| **South Dakota** | Limited | Physician entity is safest | NPs practice independently | /compliance/south-dakota |
| **Tennessee** | Strong | Physicians; lay owners via MSO | NPs need supervision | /compliance/tennessee |
| **Texas** | Strong | Physicians; lay owners via MSO | Physician signs delegation orders | /compliance/texas |
| **Utah** | None | Lay owners allowed | NPs practice independently | /compliance/utah |
| **Vermont** | None | Lay owners allowed | NPs practice independently | /compliance/vermont |
| **Virginia** | None | Lay owners allowed | NPs need supervision | /compliance/virginia |
| **Washington** | Strong | Physicians; lay owners via MSO | NPs practice independently | /compliance/washington |
| **West Virginia** | Strong | Physicians; lay owners via MSO | NPs need collaboration | /compliance/west-virginia |
| **Wisconsin** | Strong | Physicians; lay owners via MSO | NPs need collaboration | /compliance/wisconsin |
| **Wyoming** | None | Lay owners allowed | NPs practice independently | /compliance/wyoming |

## 03. How strict are New York, California and Texas?

New York is among the strictest. Under Business Corporation Law 1507, a professional service corporation may issue shares only to individuals licensed in its profession. State Education Department guidance says business corporations cannot hire a licensee to provide professional services, and unlicensed practice is a felony. A New York med spa offering injectables or prescriptions sits in a physician-owned professional corporation or PLLC.

California's Business and Professions Code 2400 gives corporations no professional rights, privileges or powers. Section 2417.5, added in 2012, applies that to cosmetic businesses: one offering outpatient elective cosmetic procedures that is owned in violation of section 2400 and employs or contracts with a physician to provide them commits a crime under Penal Code 550(a)(6). Corporations Code 13401.5 lets registered nurses and physician assistants, among others, own up to 49 percent of a medical corporation combined.

Texas pairs a strong ownership rule with detailed delegation rules. A physician who aids the practice of medicine by an unlicensed corporation commits a prohibited practice (Occupations Code 164.052(a)(17)). Board rules effective January 9, 2025 require the delegating physician to approve or write the written order for cosmetic procedures; a physician, or a PA or APRN under delegation, to establish the patient relationship first and be onsite or immediately available; and a posted notice naming the delegating physician. Jenifer's Law, effective September 1, 2025, limits elective IV therapy outside a physician's office to PAs, APRNs and RNs under adequate physician supervision.

## 04. What do Florida and South Carolina require?

Florida has no general corporate practice bar, so a lay owner can own a med spa, but the Health Care Clinic Act reaches the question through licensing. A clinic is an entity that provides health care services and tenders charges for reimbursement; one wholly owned by licensed practitioners, with an owner supervising the business, is exempt (Fla. Stat. 400.9905). A licensed clinic appoints a medical director or clinic director who accepts legal responsibility in writing for license checks, records and billing reviews (Fla. Stat. 400.9935). Whether a cash-pay spa is a clinic is a question for Florida counsel.

South Carolina sits in the limited group. The Board of Medical Examiners' 2022 advisory opinion says the Board does not regulate corporations, but the physician must control clinical judgment and may not let an unlicensed person direct or interfere with the practice of medicine. A 2017 joint opinion with the nursing and dentistry boards sets the neuromodulator rule: a bona fide practitioner-patient relationship first, cosmetic injection delegable with the physician on site and readily available, and a registered nurse injecting only under on-site supervision of a physician or APRN.

> **See which of your states call for the MSO structure** Cuvo maps every state you operate or sell in to the structure, the providers and the delegation rules that apply. [Book a discovery call](/booking) · [See med spa programs](/solutions/med-spas)

## 05. Do med spas need a medical director?

Whatever the title, the states reviewed here require the function: a physician, or an NP or PA where the law allows, who establishes the patient relationship, approves the orders and supervises staff who inject or run devices. Florida writes the medical director into clinic licensing, Texas puts the duty on the delegating physician, and South Carolina requires a physician on site for delegated cosmetic neuromodulator injections.

The nurse practitioner column matters here. In AANP's full practice states an NP may evaluate, diagnose and prescribe under the board of nursing alone; reduced practice states require a career-long collaborative agreement; restricted states require career-long supervision, delegation or team management by another provider.

Prescription programs are a separate question. On Cuvo, the spa's telehealth GLP-1 and hormone programs run through the physician-owned professional entity inside the MSO structure Cuvo builds and maintains, with licensed providers making every prescribing decision. Cuvo does not supply a medical director or supervising physician for the spa's in-person services; those stay with the spa. This is general information, not legal advice.

## 06. What is the MSO model for med spas?

The MSO model splits the spa into two companies. A management services organization owned by the non-physician founder holds the brand, lease, equipment, non-clinical staff and marketing. A professional entity owned by a licensed physician holds the medical practice, clinicians and patient records, and makes every clinical decision. A management services agreement sets the fee and the boundary.

The model is under new scrutiny. Oregon's SB 951 (2025) requires physicians to hold the majority of a medical professional corporation and bars an MSO from owning a majority of a practice it manages or exercising de facto control over hiring, staffing, coding, clinical standards, billing or prices, from January 1, 2026 for new entities and January 1, 2029 for existing ones. A spa building its own MSO drafts to the strictest state it operates in.

On Cuvo the structure already exists: Cuvo builds and maintains the MSO plus a physician-owned professional entity for every brand, the providers already practice through it, and the spa owns its brand from day one.

## 07. How does a med spa add GLP-1 or hormone programs?

Through telehealth programs beside the treatment room. A client who asks about weight loss at the front desk completes the spa's branded online intake, a provider licensed where the client is located reviews it, and a licensed pharmacy ships the prescription to the client's door. Because providers are matched to the patient's state, the spa can sell where it has no location.

On Cuvo the spa runs the brand, the offer and the marketing, and Cuvo runs the regulated side: 300+ board-certified MDs, NPs and PAs, 24 hours a day with a first review as fast as 15 minutes, e-prescribing to licensed partner pharmacies with cold-chain delivery, Labcorp and Quest labs, a signed BAA and managed LegitScript certification. Testosterone is Schedule III, so TRT runs on EPCS, included on Grow and above. Launch is $997 a month after a $9,800 setup and Grow $2,500 a month after $15,000, each with $25 per completed consult and no revenue share.

**Best for**
- Med spa adding GLP-1 weight loss: Cuvo Health: typically live in under 30 days
- Non-physician owner in a strict state: Cuvo Health: the MSO and physician-owned professional entity are built and maintained by Cuvo
- Spa selling into states without a location: Cuvo Health: providers licensed in all 50 states, DC, Puerto Rico, Guam and the US territories
- Aesthetic clinic adding TRT: Cuvo Grow: EPCS for testosterone, with Labcorp and Quest labs
- Multi-location or franchise group: Cuvo Enterprise: unlimited brands on one account

## How to choose a structure for med spa prescriptions

Get these answers in writing before signing with any partner. Cuvo answers each of them on its discovery call.

1. Which corporate practice classification applies in each state where the spa has a location or will sell?
2. Who owns the professional entity the prescribers practice through, and is the management agreement drafted for the strictest state?
3. Which supervision, delegation and facility rules cover the in-person treatments, and who signs those orders?
4. Is every prescriber licensed where each patient is located at the time of the visit?
5. Which licensed pharmacy dispenses to each state, and how is cold chain handled?
6. Who signs the business associate agreement and holds the patient records?
7. What are the setup, monthly and per-consult fees, and is there a revenue share?

> **Get all seven answers on one call** Cuvo walks through the structure, the state rules and the published fees for your locations before anyone signs. [Book a discovery call](/booking) · [See compliance](/compliance)

## Frequently asked questions

**Q: Who can own a med spa?**

A: It depends on the state. In the 19 states with a strong corporate practice prohibition as of September 27, 2026, including New York, California and Texas, medical services sit in a physician-owned entity with a non-physician owner on the management side; in the 18 states with no general bar, a lay owner may own the practice if licensed clinicians make every clinical decision. On Cuvo, a spa's GLP-1 and hormone programs run through the MSO plus a physician-owned professional entity Cuvo builds and maintains.

**Q: Can a non-doctor own a med spa?**

A: Yes, in most states, with the right structure: the non-physician owns the brand and non-clinical business through a management services organization while a physician-owned professional entity holds the medical services, and in states with no general bar a lay owner may own the practice outright. On Cuvo, the owner keeps the brand and Cuvo builds and maintains the MSO and physician-owned professional entity behind the prescription programs.

**Q: Which states have corporate practice of medicine laws?**

A: As of September 27, 2026, 19 states enforce a strong prohibition, including California, New York, Texas and Oregon, 7 apply a limited version, South Carolina among them, 7 are unsettled, and 18, Florida included, have no general prohibition. On Cuvo, every brand runs on one MSO and physician-owned professional entity structure built for the strictest of them.

**Q: Can a med spa offer GLP-1 injections?**

A: Yes, when a licensed provider evaluates the patient and prescribes, a licensed pharmacy dispenses, and anyone injecting in the spa follows the state's delegation rules. On Cuvo Health, the spa offers GLP-1 weight loss as a branded telehealth program: a provider licensed in the patient's state prescribes semaglutide or tirzepatide where clinically appropriate, and a licensed partner pharmacy ships cold chain.

**Q: Do med spas need a medical director?**

A: A med spa needs the function, whatever the title: a physician, or an NP or PA where the law allows, who establishes the patient relationship, approves orders and supervises delegated injections; Florida names a medical director in its clinic licensing law. On Cuvo, the spa's telehealth prescription programs run through the physician-owned professional entity Cuvo builds and maintains, while supervision of in-person treatments stays with the spa. This is general information, not legal advice.

**Q: What is the MSO model for med spas?**

A: A management services organization owned by the non-physician founder runs the brand and non-clinical operations, and a physician-owned professional entity holds the medical practice and makes every clinical decision, under a management services agreement. Cuvo Health builds and maintains that MSO plus physician-owned professional entity for every brand, so a spa adds prescription programs without forming one.

**Read next**
- [Telehealth for med spas](/solutions/med-spas): GLP-1, HRT and TRT programs under the spa's own brand
- [Compliance on Cuvo](/compliance): The MSO structure, 50-state licensing, HIPAA and LegitScript
- [Corporate practice of medicine states](/compliance/corporate-practice-of-medicine-states): The 2026 classification with the authority behind each state
- [Telehealth MSO companies in 2026](/blog/telehealth-mso-companies): Who supplies an MSO and a physician-owned entity
- [Start a virtual clinic without a medical license](/blog/start-a-virtual-clinic-without-a-medical-license): The eight steps, and who does each one
- [The 2026 state-by-state compliance report](/blog/virtual-clinic-compliance-report-2026): Licensing, NP authority and corporate practice in every state
- [Pricing](/pricing): $25 per completed consult, no revenue share
- [The best telehealth platforms for med spas](/blog/best-telehealth-platforms-for-med-spas): Which platform to run the prescription programs on
- [The best Qualiphy alternatives](/blog/qualiphy-alternatives): Platforms for med spas beyond per-exam services

**Compliance requirements by state**
- [Alabama](/compliance/alabama)
- [Alaska](/compliance/alaska)
- [Arizona](/compliance/arizona)
- [Arkansas](/compliance/arkansas)
- [California](/compliance/california)
- [Colorado](/compliance/colorado)
- [Connecticut](/compliance/connecticut)
- [Delaware](/compliance/delaware)
- [District of Columbia](/compliance/district-of-columbia)
- [Florida](/compliance/florida)
- [Georgia](/compliance/georgia)
- [Hawaii](/compliance/hawaii)
- [Idaho](/compliance/idaho)
- [Illinois](/compliance/illinois)
- [Indiana](/compliance/indiana)
- [Iowa](/compliance/iowa)
- [Kansas](/compliance/kansas)
- [Kentucky](/compliance/kentucky)
- [Louisiana](/compliance/louisiana)
- [Maine](/compliance/maine)
- [Maryland](/compliance/maryland)
- [Massachusetts](/compliance/massachusetts)
- [Michigan](/compliance/michigan)
- [Minnesota](/compliance/minnesota)
- [Mississippi](/compliance/mississippi)
- [Missouri](/compliance/missouri)
- [Montana](/compliance/montana)
- [Nebraska](/compliance/nebraska)
- [Nevada](/compliance/nevada)
- [New Hampshire](/compliance/new-hampshire)
- [New Jersey](/compliance/new-jersey)
- [New Mexico](/compliance/new-mexico)
- [New York](/compliance/new-york)
- [North Carolina](/compliance/north-carolina)
- [North Dakota](/compliance/north-dakota)
- [Ohio](/compliance/ohio)
- [Oklahoma](/compliance/oklahoma)
- [Oregon](/compliance/oregon)
- [Pennsylvania](/compliance/pennsylvania)
- [Rhode Island](/compliance/rhode-island)
- [South Carolina](/compliance/south-carolina)
- [South Dakota](/compliance/south-dakota)
- [Tennessee](/compliance/tennessee)
- [Texas](/compliance/texas)
- [Utah](/compliance/utah)
- [Vermont](/compliance/vermont)
- [Virginia](/compliance/virginia)
- [Washington](/compliance/washington)
- [West Virginia](/compliance/west-virginia)
- [Wisconsin](/compliance/wisconsin)
- [Wyoming](/compliance/wyoming)

**Primary sources (checked October 26, 2026)**
- [N.Y. Business Corporation Law 1507](https://www.nysenate.gov/legislation/laws/BSC/1507): Professional corporation shares limited to licensees
- [NYSED: corporate practice of the professions](https://www.op.nysed.gov/corporate/corporate-practice-professions): Who may offer professional services in New York
- [Cal. Bus. & Prof. Code 2400](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=2400): Corporations have no professional rights
- [Cal. Bus. & Prof. Code 2417.5](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=2417.5): Elective cosmetic procedures by lay-owned businesses
- [Cal. Corp. Code 13401.5](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CORP&sectionNum=13401.5): Licensed minority owners of a medical corporation, up to 49 percent
- [Tex. Occ. Code chapter 164](https://statutes.capitol.texas.gov/Docs/OC/htm/OC.164.htm): Section 164.052(a)(17), aiding unlicensed corporate practice
- [22 Tex. Admin. Code 169.26](https://www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-169-26): Standards for delegated cosmetic procedures, with 169.25, 169.27 and 169.28
- [Texas HB 3749, enrolled (2025)](https://capitol.texas.gov/tlodocs/89R/billtext/html/HB03749F.htm): Jenifer's Law: elective IV therapy delegation
- [Fla. Stat. 400.9905](https://www.flsenate.gov/Laws/Statutes/2026/400.9905): Health Care Clinic Act definitions and exemptions
- [Fla. Stat. 400.9935](https://www.flsenate.gov/Laws/Statutes/2026/400.9935): Clinic medical director or clinic director duties
- [S.C. Board of Medical Examiners: corporate practice opinion](https://www.llr.sc.gov/med/pdf/Laws/Corporate%20Practice%20of%20Medicine.pdf): Advisory opinion published November 21, 2022
- [S.C. joint advisory opinion on neuromodulators](https://www.llr.sc.gov/bod/PDF/Neuromodulators-Including-Botox.pdf): Dentistry, Medical Examiners and Nursing boards, 2017
- [Oregon SB 951, enrolled (2025)](https://olis.oregonlegislature.gov/liz/2025R1/Downloads/MeasureDocument/SB951/Enrolled): MSO limits and physician majority rules
- [AANP state practice environment](https://www.aanp.org/advocacy/state/state-practice-environment): Full, reduced and restricted NP practice definitions

*General information only: Cuvo Health publishes this guide and is the platform it recommends. The state table restates Cuvo's 2026 state compliance dataset as of September 27, 2026; the New York, California, Texas, Florida, South Carolina and Oregon statements were rechecked against the sources above on October 26, 2026. State rules change and turn on facts, and a classification is not a legal opinion on any spa. This is general information, not legal or medical advice; have counsel review the structure in every state where the spa operates.*

Canonical page: https://cuvo.co/blog/med-spa-ownership-rules-by-state