Medical Spa Requirements in Florida

Opening a medical spa in Florida sounds like a golden opportunity. But here’s the thing—if you don’t follow state rules, you could land in serious trouble fast. From how you hire staff to what treatments you offer, everything is regulated.

Florida has unique laws that separate medical spas from traditional day spas. That’s where most new owners slip up. Aesthetic services may seem harmless, but injectables, lasers, and even microneedling often fall under "medical" in the state’s eyes.

Why does regulation matter so much?
Because when medical procedures are involved—even if cosmetic—patient safety is the state’s top priority. Not to mention, getting caught non-compliant could cost you your business license or bring lawsuits.

So, whether you're planning to open your first med spa or just want to double-check you're doing things right, here’s what you need to know.

Business and Licensing Requirements for Florida Med Spas

You can’t just rent a storefront, slap on a “MediSpa” sign, and start injecting Botox. Florida law treats medical spas like medical clinics. That means you’ll need to follow the rules set by the Florida Department of Health and possibly register as a Health Care Clinic under the Health Care Clinic Act.

Here’s what you’ll need before your doors open:

• Entity Formation: Set up a legal entity (like an LLC or corporation) through the Florida Division of Corporations.
  
  
• Medical Director: You must have a licensed physician (MD or DO) on board to supervise or perform medical treatments.
  
  
• Clinic Licensing: If you're offering medical services and accepting payments directly, you may need to register with the Agency for Health Care Administration (AHCA).
  
  
• Tax IDs and Insurance: Get your EIN from the IRS and purchase both business liability and malpractice insurance.
  
  

Missing any of these? You could face fines—or worse—be forced to shut down.

Physical and Operational Requirements for Med Spas

Your spa needs to look good, but it also needs to follow safety codes. Florida’s Board of Medicine and Department of Health inspect and regulate medical facilities for hygiene, storage, and more.

These are some basics you need to cover:

• Sanitation: Every treatment room should be cleaned thoroughly after each session. Use single-use supplies where possible.
  
  
• Medical Equipment: Devices like IPLs or RF machines must be FDA-approved and maintained with service logs.
  
  
• Records Management: All patient charts must be stored securely and comply with HIPAA rules. You’ll need a policy for who can access them and when.
  
  

Think of it this way: if your spa were audited tomorrow, could you pass inspection without scrambling? If not, it’s time to tighten things up.

Who Can Perform What in a Florida Medical Spa?

This is where a lot of owners get confused. In Florida, the rules about who can inject, laser, or prescribe are crystal clear.

Only licensed professionals may perform medical procedures, and many require supervision.

Here’s a quick breakdown:

Procedure	Who Can Perform It	Supervision Needed?
Botox/Fillers	RN, ARNP, PA, MD, DO	Yes, under medical direction
Laser Treatments	PA, ARNP, Licensed Electrologist	Often yes
Microneedling (medical)	PA, ARNP, MD, DO	Yes
Facials/Massages	Licensed Aesthetician	No (if non-medical)

Hiring unlicensed staff to do medical work? That could cost you a malpractice lawsuit or worse.

So always ask: “Is this procedure medical in nature?” If yes, involve a physician.

Which Services Need Physician Oversight in Florida?

Some services blur the line between cosmetic and clinical. Florida classifies treatments like dermal fillers, laser resurfacing, and chemical peels above 30% strength as medical. That means these require a physician’s involvement.

These services need oversight or direct performance by a medical professional:

• Botox, Dysport, and fillers
  
  
• PDO threads
  
  
• Deep peels (TCA, Jessner’s over a certain %)
  
  
• Laser hair removal (depending on device)
  
  
• Skin tightening machines using energy modalities
  
  

Many physicians delegate these tasks, but delegation doesn’t mean hands-off. The physician is still responsible for what happens in their clinic, even if they’re not there.

Not sure if a procedure qualifies as medical? Ask your medical director or check the Florida Board of Medicine’s rules here.

Staying Compliant and Avoiding Legal Issues

You’ve got your licenses, a trained team, and state-approved equipment. Great. Now, let’s keep you out of legal hot water.

Here are the must-haves for ongoing compliance:

• Patient Consent Forms: For every procedure, written and signed—no exceptions.
  
  
• Before-and-After Photos: Protects you legally and helps with marketing.
  
  
• Malpractice Coverage: Even RNs and PAs need it. One mistake could bankrupt your spa.
  
  
• Routine Internal Audits: Check your charts, protocols, and supervision every quarter.
  
  

Pro tip? Always treat your spa like it’s under review. Because one unhappy patient or a random inspection could turn things upside down fast.

Final Thoughts on Florida Medical Spa Compliance

Running a medical spa in Florida can be rewarding, but it’s not a free-for-all. With state oversight growing tighter, staying compliant isn’t optional. It’s the difference between thriving and getting shut down.

Want to protect your spa? Keep these three points in mind:

• Always have the right licenses and medical oversight.
  
  
• Make sure staff only do what their license allows.
  
  
• Keep records clean, secure, and up-to-date.
  
  

When you treat your spa like a serious medical business, clients notice—and regulators respect it.