Two Common Approaches
Medical Director Agreement
You own the med spa but contract with a licensed physician who maintains complete control over:
- All medical services and protocols
- Clinical decision-making
- Patient care standards
You handle business operations. They handle medical decisions.
MSO Structure
You own a Management Services Organization (MSO) that provides business support to a separate physician-owned Professional Corporation (PC). The structure works like this:
- Your MSO handles marketing, billing, and facilities
- The PC (owned by a physician) handles all medical services
The Critical Requirement: Physician Independence
The key to CPOM compliance is proving the physician has genuine clinical independence. They must be able to:
- Refuse to perform procedures they deem unsafe or inappropriate
- Modify protocols based on clinical judgment
- Make medical decisions without your interference
Medical boards actively audit these arrangements. If your structure looks compliant on paper but you're actually controlling medical decisions, you're violating CPOM. This can result in:
- License revocation
- Business closure
- Significant fines
Learn more in our complete Med Spa Compliance Guide, including how to set up compliant structures and avoid CPOM violations.
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