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New Med Spa Compliance Checklist

The paperwork a new med spa should have in place before the first patient, in one checklist. Record the date each item was done, who owns it and where it's kept, so the answer is ready the first time a board, inspector or insurer asks.

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New Med Spa Compliance Checklist

MedSpaBinder

Clinic

Opening date

Completed by

Rules differ by state. Confirm ownership, supervision and delegation rules with a healthcare attorney in your state.

Item
Done (Y / N)
Date
Owner
Where kept
Structure and supervision
Ownership structure checked against state law
Medical director agreement signed and dated
Supervision or collaboration protocol for each NP / PA
Delegation for each RN and injector, by treatment
Standing orders signed by the medical director
Good faith exam process: who does it, when, how recorded
Licences and staff
Every provider's licence verified, copy on file
BLS cards on file for clinical staff, with expiry dates
Treatment training and competency recorded per injector
Malpractice insurance covering each provider and service
OSHA
Bloodborne pathogens exposure control plan
Bloodborne pathogens training, with dates
Hepatitis B vaccine offered; declinations signed
Sharps containers and disposal arranged
Hazard communication: chemical list and safety data sheets
Medications and equipment
Product accounts opened direct with manufacturers
Medication fridge with min / max thermometer and log
Inventory log with lot numbers for every injectable
Emergency kit and protocols (hyaluronidase if using HA filler)
Records
Consent forms for every treatment
Chart template with product, lot, units and sites
Incident and complaint logs
Privacy policies (check whether HIPAA applies)
Reviewed by (initials)

Reviewed by: ______________________ Date: ____________ Next review: ____________

Why do this before opening

Most of what a board, inspector or insurer asks a med spa for is set up once: the medical director agreement, supervision and delegation documents, standing orders, licences, the OSHA plan and the logs. Each is far easier to put in place before the first patient than to rebuild after a complaint.

The rules for who can own a med spa, who can do which treatment and how they're supervised are set by each state's medical, nursing and pharmacy boards, and they differ a lot. Use this list to make sure nothing is missed, and confirm the state-specific items with a healthcare attorney.

What the checklist covers

  • Structure and supervision: ownership, the medical director agreement, protocols for NPs and PAs, delegation for nurses, standing orders and the good faith exam.
  • Licences and staff: verified licences, BLS cards, training and competency, and insurance.
  • OSHA: the bloodborne pathogens exposure control plan, training, hepatitis B vaccination, sharps and hazard communication.
  • Medications and equipment: where products come from, how they're stored and logged, and emergency readiness.
  • Records: consent, charting, incidents, complaints and privacy.

How to use it

  • Work through it before opening, writing where the evidence for each item is kept.
  • Give each item an owner, so it's clear who keeps it current.
  • Review the list at least yearly, and whenever the medical director, a provider or a service changes.

Questions

Who can own a med spa?

It depends on the state. Some states restrict ownership of medical practices to physicians under the corporate practice of medicine doctrine, and others allow lay ownership with a medical director. Check with a healthcare attorney in your state before you sign a lease.

What changes when the medical director changes?

Standing orders, protocols and delegation are usually signed by the medical director, so they need to be redone and signed by the new one before treatments continue. Keep the old documents on file with their end dates.

Sources

General guidance, not legal or medical advice. Requirements vary by state; follow your medical director and product labels.