Why "Medspa Accreditation" Barely Exists — Yet

Most people assume "medical spa" comes with the same baseline oversight as any other medical setting: a licensed provider, a real exam, someone accountable if something goes wrong. It doesn't, automatically. There is no dedicated regulatory body that licenses medspas as medspas, no uniform national standard, and — until recently — no independent way for a patient to verify any of it before booking an appointment.

That gap isn't an accident. It's the predictable result of how the industry is actually structured, and it's worth understanding exactly where the oversight breaks down.

What's actually illegal — and how common it is anyway

Nearly everything performed at a medical spa legally counts as the practice of medicine. That means, in most states, a doctor — or in some states, a nurse practitioner — has to be involved before treatment happens. If you walk into a medspa, get Botox from an RN, and never see a physician, NP, or PA at any point, that's not a gray area. It's illegal. Laser hair removal from a technician with no physician involvement anywhere in the process is the same story.

What's supposed to happen is a Good Faith Exam: a licensed provider — doctor, NP, or PA — examines you, forms a treatment plan, and can then delegate the actual procedure to a nurse or aesthetician working under them. Skip that exam entirely, and the spa is operating outside the law, however professional the lobby looks. Outsourcing it to a telehealth call is legal in most states — but a five-minute call that doesn't meaningfully evaluate your skin isn't doing the job that exam is supposed to do, even when it technically satisfies the requirement.

The medical director loophole that keeps the lights on

Every medspa is required to have a medical director — the physician (or NP or PA in some states) whose license is on the line for every medical decision made in that building, and under whose name every device and every vial of Botox is purchased. In practice, plenty of medspa owners aren't doctors and don't want to pay a physician's salary, so they rent a license instead — sometimes for as little as $1,000 a month, with no actual clinical involvement expected.

One story makes the risk concrete: a nurse practitioner who'd served as a medical director for a nearby spa for about a year told us she never once worked there — she was simply listed. She had no idea what liability she'd taken on until she tried to open her own account to purchase Botox and discovered the spa was still using her license to order product, years after she'd stopped being paid to be their medical director. Nobody at that spa had found a replacement. They just kept using her name.

That's not a rare arrangement. It's a business model, and it means the "medical director" line on a website often tells you almost nothing about who's actually accountable for your care.

Who's even allowed to own a medspa

A separate question — who can own a medical spa — has its own, stricter set of rules. Most states have Corporate Practice of Medicine (CPOM) laws that require a medical practice to be owned by a licensed physician, specifically to prevent non-medical owners from influencing clinical decisions for profit. There is a legal workaround: a non-doctor can own a Management Services Organization (MSO), which contracts with a doctor through a Management Services Agreement to provide the medical side, with patient payments flowing to the doctor first and then to the MSO as a management fee.

Done properly, that structure is legal. Done the way it's frequently done — money flowing straight into the spa's account, with the "medical director" paid a flat fee out of it — it isn't. There's no reliable count of how many medspas nationally are structured illegally this way, but the financial incentive to skip the expensive, doctor-led structure is exactly why so many don't.

The arrests are real, and they're accelerating

This isn't a handful of cautionary tales — it's a growing docket, and the pace is picking up. Four people arrested in Texas in 2018 for practicing medicine without a license at a single medspa. Two more in California in 2019. In Texas, Jennifer Cleveland died after an illegal IV infusion in 2023; the unlicensed operator and her absentee medical director were both arrested and charged with murder. A Florida nurse practitioner is now years into a 75-year federal sentence for a telehealth prescribing scheme that harmed patients. In late 2025, a registered nurse was arrested in Arizona on five felony counts, including practicing medicine without a license. Rebecca Fadenelli, an esthetician who posed as a nurse, was arrested and recently sentenced to four years in prison. And in the Bronx, Luis Cabrera was arrested after a patient died from an NAD+ infusion he administered.

Each case follows a similar shape: someone without the license or oversight the law requires, and a patient with no way of knowing that before they booked. And this is just a sample, not a complete list — there are many more arrests happening across the country, and for every case that makes it to prosecution, more likely never surface publicly at all.

Why self-regulation keeps failing

Medical aesthetics is now a $24 billion-plus industry in the U.S., and that scale is exactly the problem. When there's that much money on the table, there's enormous financial incentive to cut corners — skip the real medical director, skip the real exam, source product from wherever's cheapest — and historically almost no cost for doing it. Self-regulation only works when the people cutting corners actually pay a price for it, and in an industry this large and this profitable, that price has simply never been high enough to change behavior at scale.

What real self-policing has existed has come almost entirely from the minority already operating at a high standard: physician-led practices with genuine medical oversight, holding themselves to strict internal standards not because anyone required it, but because they already practice medicine at that level. That's the uneven playing field in one sentence: the medspas already doing this right are absorbing real costs that their less scrupulous competitors are simply skipping, with no penalty for skipping them.

That's the vacuum an independent, verification-based certification is built to fill — not a voluntary code of conduct the worst actors can simply ignore, but a standard a patient can actually check before they book: is there a real medical director, was a real Good Faith Exam performed, is the ownership structure legal, is the product coming from a licensed source.

What to ask, until that's the default

Ask who owns the spa. Ask who the medical director is, and how often they're actually there. Ask who performed your Good Faith Exam and what their license is. Ask who's doing the procedure and what their license is. Right now, getting a straight answer to all four is the exception, not the rule.

MedSpa Board exists to make that verification automatic instead of something you have to do yourself. Find a certified medspa — or check whether your favorite one already is — at medspaboard.com.