Is there a difference between a physician who is the medical director of a spa and a physician who performs aesthetic medical procedures in a spa that is not physician-owned?

Yes. The “Medical Director” designation has come to mean different things to different people. Correctly used, it describes a physician who does not practice medicine, but rather one who is responsible for overseeing medical practice within a clinical environment. Thus, the function of a Medical Director is limited to administrative responsibilities, such as reviewing, advertising and marketing materials for regulatory compliance.

When a medical practice offers ancillary spa services or a physician-owned spa offers aesthetic medical procedures, a physician can properly refer to himself or herself as a “Medical Director.” The physician generally wears two hats in these organizations-one as a practicing physician and another as an administrator.

Only a physician-owned spa can legitimately have a Medical Director. Unfortunately, the medical spa industry often uses the term “Medical Director” to lead consumers to believe that a non-physician owned spa is employing a physician to perform medical services. A non-physician owned spa cannot provide aesthetic medical procedures to the public nor can it legally employ a licensed physician. Thus, use of the term “Medical Director” by a non physician-owned spa to mislead the public to believe they employ a doctor who performs aesthetic medical services would be a fraudulent business practice.

Physicians may operate a private physician’s office within a non-physician owned spa, however they must ensure that all advertising and marketing materials used by the spa properly disclose the physician’s relationship with the spa.

Many non-physician spa owners believe they can employ a physician to be their “Medical Director” and perform aesthetic medical procedures within their spa. This is incorrect. Any physician who accepts employment by a non-physician spa owner with the intent of performing aesthetic medical procedures as the spa’s medical director is subject to disciplinary action and increased liability.

Consumers should do a little homework before blindly accepting services from a spa advertising aesthetic medical procedures by a “Medical Director.”

(1)Medesthetics febr 2007 page 20)
Legal Issues by Scott Blair, JD. MIM .)

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