Medical spas in Tennessee

Physicians may inject and may serve as medical directors.⁶ A person is practising medicine if they treat or prescribe for a physical ailment or deformity, and since 2026 if they determine whether a treatment is clinically appropriate. The law excepts registered nurses and licensed practical nurses acting under a physician's supervision, control and responsibility, and physician assistants working in collaboration with a physician.⁶⁷

The Board of Medical Examiners' delegation policy covers nurses, medical assistants and other staff. A physician is responsible for the employee's acts. The policy lets a physician delegate only routine, technical tasks that the employee is trained for and that the physician customarily performs, only while the physician is on site or immediately available by phone or video, and not acts reserved to a licensed person.⁸

Physician assistants practise under jointly written protocols, or, once endorsed, under a collaborative agreement.⁹ Nurse practitioners need a Board of Nursing certificate and must file the name of a collaborating physician and a formulary before prescribing. The Board's physician rule for nurse practitioners, as posted on the official site, requires the physician to be available for consultation and to review a set share of charts.¹²¹³ We found no Board of Nursing statement on cosmetic injections by nurses.¹⁰

Dentists: the Attorney General found in 2014 that the definition of dentistry is broad enough for neurotoxins and fillers in the mouth and face for therapeutic or cosmetic purposes if the Board of Dentistry permits it by rule. We did not find a rule letting a general dentist inject for cosmetic reasons.¹⁴

A 2026 law, Public Chapter 755, bars delegating "aesthetic medications, including botulinum toxin, fillers, or chemical peels" to certified medical assistants. It names hospital ambulatory outpatient clinics. We found nothing applying it to a freestanding med spa.¹⁵

Ask who will inject you, what their licence is, and who the medical director is.

Tennessee's Board of Medical Examiners rule says a procedure within the practice of medicine that is done with a laser is the practice of medicine, and that anyone doing it must be under a licensed physician's supervision. The exceptions are in the electrolysis law.⁴ That law defines electrolysis as hair removal by electric current or by an FDA-approved laser process designated for permanent hair removal, so a licensed electrologist may do laser hair removal.¹⁶ We found no laser operator certificate, facility licence or registration. We found no separate rule for intense pulsed light.

The Board of Cosmetology and Barber Examiners' rule keeps estheticians to the non-living epidermis, bars skin removal that affects the living layers, and limits alpha-hydroxy acid products to 30 percent and a pH of 3.0 or above.¹⁷ The Attorney General found in 2012 that an unlicensed person providing aesthetic services in a medical spa is exempt from the cosmetology law only if the service is a medical practice, the person is licensed for it, and the person acts solely in that capacity.¹⁸

Since 2021, a licensed esthetician may do cosmetic microneedling if a physician supervises. The law does not say what supervision means.¹⁹

We found no Tennessee statute, rule or Board statement specific to IV hydration, vitamin drips or mobile IV businesses. Registered nurses give IV therapy as a delegated medical function, and licensed practical nurses may give it within the limits of the nursing rule, which sets training requirements for IV push.¹⁰¹¹ The Board of Medical Examiners says using agents such as EDTA or hydrogen peroxide beyond FDA-approved uses, without published support, may be a violation of the medical practice act.²⁰ A 2025 Department of Health order against a licensed practical nurse who co-owned a hydration centre cited that the centre was not registered as a medical spa.²⁸ Whether a mobile IV business must register is not settled by the text we read.

We found no Tennessee statement from the Board of Medical Examiners, Board of Pharmacy or Board of Nursing on semaglutide, tirzepatide or compounded weight-loss drugs. Compounded drugs must follow the national pharmacy compounding standards, and pharmacies must keep records of what they compounded and for whom.²¹

A prescriber is presumed in violation if they prescribe or dispense a drug, in person or online, unless the prescriber, or a licensed supervisee under protocol, first documented a history, a physical examination, a diagnosis and a plan. Prescribing based solely on answers to a set of questions is itself presumed a violation.⁴ Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

A "cosmetic medical service" is any service that uses a biologic or synthetic material, a chemical application, a mechanical device or a displaced energy form of any kind that alters or could damage living tissue, to improve appearance or achieve an enhanced aesthetic result.² That covers injectables, peels, microneedling, lasers and light devices.

The medical director must be a doctor of medicine or osteopathy with an active Tennessee licence and an active medical practice in Tennessee, not a telemedicine-only practice.⁴⁵ There is no limit on how many spas a director may oversee, but each address is registered separately.⁵ Registering means attesting that the director accepts responsibility for the cosmetic medical services at the spa. Operating without a current registration is unprofessional conduct by the medical director.⁴

A physician-owned practice is outside the registry unless it advertises as a medical spa or more than half their patients in the last twelve months received an elective cosmetic medical service.³⁴ The Board says registration does not replace a massage, salon or cosmetology licence, and that medical spa services must be done at the registered address, so pop-up parties and concierge services are not allowed.⁵

A business "doing business as or advertised as a medical spa" must show its medical director's name, and whether the director is board certified, on signs at the spa and in their media and advertising, including websites. If the director is not certified, the lack of certification must be shown. A director who is available remotely must say so in advertising.²⁴

Tennessee uses the term medical director in statute.²⁴ We found no text that bars a non-physician from owning a medical spa business. The registry law was written to reach any entity offering these services, not only physician-owned ones.⁴ A medical professional corporation or limited liability company may have only physicians, and certain other listed professionals, as owners, directors and officers. A non-physician employing entity may exercise only limited authority over diagnosis, treatment and referral decisions.⁴⁶

Tennessee licenses tattoo artists through the Department of Health. A tattoo artist must register, and studios are certified by the local health department.²² The law defines tattooing as placing designs or cosmetics under the skin with needles or instruments, and the Attorney General has held that microblading is tattooing and that an esthetician may not do it.²²²³ The tattoo law does not apply to a physician or a person under a physician's supervision, who must submit a supervising physician's notarized letter.²⁴ A rule says only a licensed physician may remove a tattoo.²⁴