Ghost Medical Directors Have Been Put on Notice

Ghost Medical Directors Have Been Put on Notice

By Kate Dee, MD — Founder, Glow Medispa | Author, Med Spa Mayhem

I have been writing and talking about ghost medical directors for years. In Med Spa Mayhem I called them out by name — the revolving-door MDs and NPs who rent out their licenses to non-medical spa owners for a thousand dollars a month and never set foot in the building. I warned that someone was going to die. Someone did. Her name was Jenifer Cleveland, she was 47 years old, she was a mother of four, and she walked into a med spa in Wortham, Texas on July 10, 2023 for an IV vitamin drip. She never walked out.

On April 28, 2026, the spa’s unlicensed owner, Amber Johnson, turned herself in to authorities in Freestone County and was charged with felony murder, manslaughter, criminally negligent homicide, multiple counts of delivery of a dangerous drug, practicing medicine without a license, and tampering with physical evidence. The next day, the spa’s “medical director” — a Frisco anesthesiologist named Michael Patrick Gallagher, MD — walked into the same jail. He was booked on a 25-count warrant, including a count of murder.

Read that again, slowly. A doctor who, by all accounts, was barely present at the spa he was supposedly overseeing is now facing a murder charge for what happened there. The outcome of the criminal cases is not yet known. But for every doctor or nurse practitioner out there right now collecting a quiet little check to be a name on a piece of paper at a med spa they don’t actually run: this is your wake-up call. Your license is on the line. Your freedom may be too.

How we got here: the rise of the ghost medical director

To understand why a Texas grand jury is now charging a doctor with murder over an IV bag, you have to understand how the medical aesthetics industry actually works — not how it markets itself.

Practicing medicine and owning a medical practice are two different things in the law. In fact, Doctors are the only license allowed to practice medicine. Separately, in the vast majority of states, only a physician can own a medical practice. That is the foundation of what are called Corporate Practice of Medicine (CPOM) laws, and they exist for a specific reason: to keep non-medical business interests from making medical decisions. Injecting Botox, hanging an IV, running a laser — those are medical procedures. They require a doctor (or in some states a nurse practitioner) to assess the patient, set a treatment plan, and take responsibility when something goes wrong.

So how did the country end up with tens of thousands of med spas owned by aestheticians, RNs, MBAs, dentists, real-estate flippers, and frankly anyone with a Square reader and a Groupon account? They hire a doctor. On paper. The doctor is the “medical director,” and the doctor’s license is what allows the business to buy Botox, order lasers, hang IV bags, and call itself a “medical” spa. In the cleanest version of this arrangement, the doctor is present, performs good faith exams, writes the protocols, supervises mid-level providers, and signs off on every patient. That doctor is doing their job.

In the version that has metastasized across this industry, the doctor is a ghost. The medical director shows up for the grand opening, maybe makes a cameo for a photo on the website, and otherwise lives 100, 200, sometimes a thousand miles away. The owner buys the drugs on the doctor’s license. The owner — or an aesthetician, or a brand-new injector who finished a weekend course — sees the patients and performs the procedures. The doctor receives a check, often somewhere between $400 and a few thousand dollars a month, and signs whatever paperwork is put in front of them. There are companies that exist solely to broker these arrangements. There are databases of physicians willing to rent out their license for down to $400 a month, no oversight required. There are services that offer a low-cost “good faith exam” by video conference performed by a nurse practitioner the patient will never meet again.

It is a paperwork fiction. And it is the unfortunate business model of the modern American med spa.

Why doctors agree to it

I get asked this all the time, usually with a kind of horrified curiosity: why on earth would a real doctor do this?

Some of them are simply uninformed. They genuinely do not understand what they are signing. I once interviewed a nurse practitioner who had served as the medical director of a competing spa for a year and could not tell me a single thing she had done there — because she had never been there. When I explained that the spa was practicing medicine illegally under her license, and that she carried full legal liability for every procedure performed there, she was stunned. She really didn’t understand the liability she had taken on. Worse: years after she quit, the spa was still ordering Botox under her name. They had simply never bothered to find a replacement. The revolving door keeps swinging around in circles, and the previous sucker is left holding the bag.

Some are perfectly aware and decide the money is worth the risk. A retiring doctor, a hospitalist with student loans, an anesthesiologist between jobs — they look at $1,000 to $5,000 a month for “doing nothing” and they convince themselves the spa owner is competent and that nothing bad will happen on their watch. They never see the patients. They never write the protocols. They never inspect the storage of medications. They are, in any honest accounting, renting their license to a non-medical business owner who is using it to practice medicine.

And some are doctors who, for one reason or another, are unemployable in any setting where someone might actually pay attention to them.

What happens when nobody is actually watching

Here is what a real medical director is supposed to do: write the protocols, train the staff, perform or supervise good faith exams, oversee the storage and handling of drugs, supervise mid-level providers, review complications, and be available — in person or close enough to be in person — when something goes wrong. That is the job.

Here is what happens when nobody is actually doing that job. A non-physician owner orders prescription IV solutions she has no training to administer. There are no protocols, because nobody wrote any. There is no good faith exam, because nobody qualified to perform one is on site. The staff is not trained to recognize a complication, because the medical director never trained them. When the patient collapses, there is no doctor in the room or anywhere nearby.

This is not a hypothetical. This is exactly what happened in Wortham, Texas.

How Jenifer Cleveland died

Jenifer Cleveland was 47, a mother of four, and worked at radio station KNES Texas 99.1 in Fairfield, Texas, selling advertising. She had been doing some social media marketing for a med spa called “The Luxe Medspa by Amber Johnson” in nearby Wortham. On its Facebook page, the spa told customers: “I (Amber Johnson) am behind this Medspa. I am a Certified Practitioner with all current licenses with a Medical Director, Dr Gallagher MD from Dallas, Texas.” Amber Johnson did not, in fact, have a medical license. Dr. Gallagher was an anesthesiologist with a primary practice in Frisco, more than 100 miles away.

On the morning of July 10, 2023, Jenifer went in for what was advertised as an IV vitamin infusion. According to court documents and reporting from KWTX and the American Med Spa Association, Johnson administered roughly a liter of an “IV cocktail” that included a vitamin B complex — ascorbic acid, cyanocobalamin — and total parenteral nutrition (TPN) electrolytes. TPN is not a “wellness” product. It is a prescription-only solution that contains potassium chloride, the same drug used in lethal injections. Run it too fast, run it into the wrong patient, run it without monitoring, and you can stop a heart in minutes.

Jenifer’s infusion began at 11:04 a.m. At 11:31 a.m. — twenty-seven minutes later — she lost consciousness, collapsed, and had no pulse. EMS performed CPR all the way to the hospital. She was pronounced dead after suffering cardiac arrest. Her final autopsy listed the cause of death as “sudden cardiac death of uncertain etiology,” noting that the role of the IV therapy “cannot be definitely ruled-in or ruled-out as contributory.” The grand jury, evidently, has reached its own conclusion.

And where was the medical director on the morning of July 10, 2023? According to the Texas Medical Board’s suspension order, Dr. Gallagher had been physically present at Luxe Med Spa exactly three times in its short history: for the grand opening in May, once more in June, and on the day Jenifer died. He was, the Board concluded, “more than 100 miles away” at the time the IV was being administered, with “no medically licensed personnel physically present.” The spa, the Board found, had no protocols for IV therapy. Johnson was ordering the prescription IV solutions — including the TPN — using Dr. Gallagher’s credentials.

It is also worth knowing who Dr. Gallagher was before he became the medical director of a med spa in a small town he did not live in. According to a 2023 deposition reported by KWTX, in late 2021 the head administrator of Gallagher’s former employer, Texas Healthcare Partners Group, ordered him to “self-report an alcohol abuse problem” after a complaint that he had been impaired while performing anesthesia. Gallagher entered an outpatient rehabilitation program through the Texas Physicians Health Program. His employer terminated his privileges that October. Less than two years later, he was the only physician of record at a med spa where an unlicensed owner was pushing prescription electrolytes into someone’s arm.

The fallout

On October 17, 2023, the Texas Medical Board temporarily suspended Dr. Gallagher’s medical license, finding that his continued practice posed “a continuing threat to the public welfare.” The spa’s website came down. Its Yelp page survived for a while with a single, perfect one-star review from Jenifer’s cousin: “I don’t advise anyone to use your services unless they want to end up dead like my cousin.”

Then the legislature got involved. In June 2025, Texas Governor Greg Abbott signed House Bill 3749 — colloquially “Jenifer’s Law” — into effect. As of September 1, 2025, elective IV therapy provided outside of a hospital or licensed health facility must be ordered or prescribed by a physician, physician assistant, or advanced practice registered nurse acting under valid prescriptive authority and adequate physician supervision. Delegation of the actual administration is limited to physicians, PAs, APRNs, or RNs. There is now a real legal definition of what adequate supervision looks like, and there is real scrutiny of the medical director relationship itself. The era of the figurehead MD signing a piece of paper in Frisco while a non-licensed owner runs IVs in Wortham is, at least in Texas, formally over.

And then, in late April 2026 — nearly three years after Jenifer’s death — the criminal charges came down.

Murder charges

Amber Johnson surrendered first, on April 28, 2026, on charges of felony murder, manslaughter, criminally negligent homicide, nine counts of delivery of a dangerous drug, practicing medicine without a license, and tampering with or fabricating physical evidence. Twenty-four hours later, Michael Patrick Gallagher walked into the Freestone County Jail on a 25-count warrant: felony murder, manslaughter, criminally negligent homicide, nine counts of delivery of a dangerous drug, and thirteen counts of practicing medicine in violation of statute. Both posted bond at $96,500 and were released.

Both are presumed innocent. The cases are working their way through the Freestone County criminal courts, and we do not yet know how a jury will weigh the gap between an absent medical director and a woman who died on his “watch.” We also do not know what plea deals, dismissals, or convictions may follow. The legal outcome is genuinely uncertain.

But here is what is not uncertain. A licensed Texas physician is currently out on bond on a murder charge for what happened at a medical spa he visited three times. The medical-director-on-paper model just produced its first criminal charge of murder against the doctor. That precedent now exists. Prosecutors in other states have been watching.

If you are a ghost medical director right now, read this twice

Every week I hear from physicians and nurse practitioners who have, in some form, the same conversation:

“I don’t really know what they’re doing in that spa, but they pay me a few thousand a month and the owner seems nice.”

“I signed up to be the medical director, but I haven’t been by in months.”

“They told me I didn’t have to do anything — just lend my name.”

If any of those sentences sounds familiar, I want you to understand what they actually translate to in the new world we are now living in: you are personally on the hook for every patient who walks through that door. Every Botox vial purchased on your license. Or fake Botox purchased off of Alibaba. Every prescription electrolyte mix hung on a stand. Every “good faith exam” that was not done, or was done by someone who legally could not do it. Every adverse event, every infection, every cardiac arrest. The medical board can suspend or revoke your license over it. Plaintiffs’ attorneys can take your house over it. And as Dr. Gallagher’s case now demonstrates, prosecutors can put your freedom on the table over it.

“I didn’t know what they were doing” is not a defense. It is, in fact, the core of the accusation. The whole point of being a medical director is that you are supposed to know. If you don’t know, you have failed at the only job you were paid to do.

So here is my unsolicited advice, from one physician to another. Today, this week, before you go back to billing one more anesthesia case in Frisco or one more shift in the ER:

Pull up every medical director agreement you have signed. Read it. Then go look at the spa’s website and ask yourself, honestly, whether what they are advertising matches what you are actually supervising. Walk in unannounced — not for a photo, an actual walk-through. Ask who is performing good faith exams and on what authority. Ask to see the IV protocols, the emergency protocols, the drug storage, the patient records. Ask whether your license is being used to order anything you have not personally approved. Find out whether your name is still on a Botox account at a place you stopped working with two years ago. (You would be amazed.) If the answers are uncomfortable, get a lawyer who knows medical spa law — not your cousin who does real estate — and unwind the relationship the right way, in writing, with revocation of your name on every account. Then go look in the mirror and ask yourself whether the monthly check was ever worth it.

If you are a patient, the questions I have been asking you to ask for years have not changed: Who owns this spa? Who is the medical director, and when are they actually working here? Who is performing my good faith exam, and what is their license? Who is doing the treatment, and what is their license? If anyone hedges, hesitates, or names a doctor whose face nobody at the front desk recognizes, walk out. Just walk out.

A final word

Jenifer Cleveland died on a Monday morning in July, twenty-seven minutes into what someone told her was a “wellness” treatment. She left four children behind. Her death has now produced a state law, a license suspension, two arrests, and a murder charge against the absent doctor whose name was on the door.

If you are a physician or nurse practitioner with your name on the door of a med spa you do not actually run, you have been put on notice. The free money was never free. It was a loan, and the interest is now coming due.

— Kate Dee, MD

Sources & further reading

Michael Patrick Gallagher facing murder and manslaughter charges in death of Jenifer Cleveland (KWTX, April 30, 2026) — https://www.kwtx.com/2026/04/30/michael-patrick-gallagher-facing-murder-manslaughter-charges-death-jenifer-cleveland/

Amber Johnson facing multiple charges in Freestone County, including murder, manslaughter (KWTX, April 29, 2026) — https://www.kwtx.com/2026/04/29/amber-johnson-facing-multiple-charges-freestone-county-including-murder-manslaughter/

Ex-Medical Director of Wortham med spa surrenders to authorities on 25-count warrant (KCEN-TV) — https://www.kcentv.com/article/news/local/ex-medical-director-wortham-med-spa-surrenders-authorities-warrant/500-7352392b-f372-4451-9d2d-fc003de407e2

Texas Med Spa Medical Director, Owner Charged in 2023 IV Therapy Death (American Med Spa Association, May 1, 2026) — https://www.americanmedspa.org/news/texas-med-spa-medical-director-owner-charged-in-2023-iv-therapy-death/

Deposition reveals doctor in Luxe Med Spa case was terminated by previous employer, ordered to self-report ‘alcohol abuse problem’ (KWTX, October 20, 2023) — https://www.kwtx.com/2023/10/20/deposition-medical-negligence-lawsuit-reveals-doctor-luxe-med-spa-case-was-terminated-by-previous-employer-ordered-self-report-alcohol-abuse-problem/

Woman’s Death After IV Therapy Leads to License Suspension for Frisco Anesthesiologist (D Magazine) — https://www.dmagazine.com/healthcare-business/2023/10/womans-death-after-iv-therapy-leads-to-license-suspension-for-frisco-anesthesiologist/

Jenifer’s Law headed to Gov. Abbott’s desk — will increase regulations for medical spas (KWTX, May 29, 2025) — https://www.kwtx.com/2025/05/29/jenifers-law-headed-gov-abbotts-desk-will-increase-regulations-medical-spas-wake-central-texas-womans-death/

Texas Governor Signs Bill into Law Increasing Regulations on Medical Spas (Holland & Knight, June 2025) — https://www.hklaw.com/en/insights/publications/2025/06/texas-governor-signs-bill-into-law-increasing-regulations