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Do I need a Medical Director to Inject Botox®?

doctors shaking hands

In this article, we will discuss all things “medical director”. What do they do? And who needs one? What’s included in the agreements between injectors and medical directors? How much do they cost? What’s the commitment is between both parties? And more!

Every RN and some NPs (depending on the state) needs a medical director, also often called a collaborating physician, in order to administer Botox® and other aesthetics services. So keep reading to know all-things medical directors!

What is a medical director?

A medical director is a “trained physician who provides supervision and oversight of the medical treatments provided the authority of a medical director’s license to ensure that patients are treated to the standard of care required”, described by Allergen the manufacturers of Botox®. Basically, they are the ones legally responsible for signing off on the policies and procedures for the practice (ex. Botox® standard orders, sliding scales, etc.) and overseeing the treatments performed.

It is important to note that the role of the medical director and requirements for practice vary significantly depending if you are an RN injector, NP or PA injector or MD injector. So note which terminology we are using closely. Not to mention it varies state by state as well.

RN injectors

Across the board in the United States an RN injector will need a medical director. This is because the scope of practice of an RN currently does not allow the practice of medicine. The practice of medicine means prescribing a treatment plan.

Also pretty much across the country, before any RN injector can treat a patient, a “good faith exam” (an aesthetic specific assessment which is not necessarily a full history and physical) must be completed by a physician or Advanced Practice Provider. This could be your medical director, or a different provider. However if it is an Advanced Practice Provider (NP/PA) that provider likely needs to have a Collaborative Agreement with your medical director. Confused yet?

Advanced Practice Providers injectors

Depending on your state, as a Nurse Practitioner or a Physician Assistant, a certain percentage of charts, or all charts, will be reviewed and signed by the medical director to attest that treatment and documentation is appropriate. Typically, there is a percentage of charts designated by your state for Advanced Practice Providers to have signed by the medical director.

All charts typically need to be signed by the medical director for RN injectors, as noted above. Overall, the medical director’s job is to ensure safety, appropriate documentation and top-quality care is given to the patients by practicing staff.

In certain states, Virginia for example, an independent practice Nurse Practitioner can be a medical director for a Med Spa. In order to understand more about your state, we recommend checking out AMSPA or a local attorney. We go way more in detail about this in our article, How to figure out your state’s laws.

doctor sitting in front of his desk

Why is one needed?

Well, if your state mandates you need a medical director, then you need one. Refer to Who Can Inject Botox? an interview with Suzanne Jagger, CRNA, APRN. We discuss how any medical doctor can practice aesthetics autonomously without restrictions. For NPs, depending on the state, they may be able to practice aesthetics autonomously (go through these posts to find tips on researching your state’s regulations and Haley Wood’s website and do not need a medical director.

The “gray area” for CRNAs and Midwives is even bigger and is highly state-dependent (see a theme here?) For RNs, a medical director/collaborating physician is always needed, as they are legally not “allowed” to practice autonomously. By law, RNs cannot practice medicine or prescribe treatment.

Depending on the state, RNs and certain APRNs, and PAs are not allowed to prescribe medications, create treatment plans, etc. They tend to receive orders from their affiliated provider and follow their orders. In aesthetics and other areas of medicine, we may see “standing orders” written to practice within. However, anything the nurse does could legally fall both on the RN and on the license of their medical director.

Many times, the medical director stays in-house whenever the business is open. Other times, they visit a few times a week/month, or are mostly remote. Each one is different, and understanding the needs of your business is vital. 

What else do medical directors provide?

If trained in aesthetics, they can be a resource for an injector who has questions regarding any services or procedures. Depending on the details of your contract, they could help assume business-related roles or anything else you agree upon. In some states, for example Florida, an aesthetics medical director is supposed to be a core physician meaning Plastics, Dermatology, etc.

What if my medical director is not trained in aesthetics?

Depending on your state, it may not be required for your medical director to be a core specialty physician. If this is the case for your state that will likely allow you to employee a medical director for a lower fee than if a core physician is mandatory. You as the provider are the expert in aesthetics, and it is acceptable for you to have a more in depth aesthetics knowledge than you medical director. As the person hands-on implementing these treatments and diving into all the clinical knowledge, this is common. However, it is prudent to obtain at minimum a basic working knowledge of aesthetics for your medical director.

Injectables EDU offers a Medical Director Course that offers your Medical Director a certificate to keep on file with your malpractice as well. Our course covers the Basic Botox Clinical and explains medical director liability and responsibility. And keep in mind this was created by Cassie Lane, NP, DNAP and it highlights the relatively low risk associated with being a medical director for aesthetics and Botox®.

Where do I find a medical director?

Finding a medical director is one of the top priorities for any nurse/APP that can’t practice independently. You may have a relationship already to a qualified medical director that’s been looking to dip their toe into the world of aesthetics and would agree to be a medical director. There are a few different ways to find one, and we have some resources listed below:

  1. Medical Director Companies (many options):
    1. National Medical Directors, the first and ONLY virtual medical directors specializing in aesthetics: https://nationalmedicaldirectors.com/
    2. Guardian Medical Direction: https://guardianmedicaldirection.com/
    3. https://collaboratingdocs.com/
    4. https://go.ibanurses.com/collab-network
    5. https://doctors4providers.com/
    6. https://nursepreneurs.com/medical-director/
  2. An Indeed post: you can simply just post on Indeed for an “Aesthetics Practice Medical Director”, and provide a pay range, hours, responsibilities, etc. Already have your legal documents ready for when you get a good match (see below!).

We will be following up with another blog post soon comparing these medical director staffing services. Keep your eye out!

What are my responsibilities as an aspiring aesthetics business owner?

There are a lot of different documents and moving parts for a medical director agreement, and Injectables EDU offers a Collaborative Agreement for the Advanced Practice Provider. This is available for Advanced Practice Providers in a state that does not require an MSO/MSA (or physician ownership), wanting to solidify a partnership with a medical director.

We recommend making a free mentoring call with Cassie to see if this might apply to you! This package is full of documents (such as the actual collaborative agreement/contract template, fee agreement, outlines the standing physician orders, and much more). Once purchased, this package will provide all the needed documents to create an efficient and organized collaborative agreement and fee agreement. There are lots of great additional resources included as well.

Once your contract is signed, depending on your medical director, they may be more or less hands-on in the treatment process. It is always your responsibility as the person in charge of the business to ensure that your state’s laws are being followed and all necessary parts of the agreement stay upheld. If there is a complaint against you to the medical or nursing board, you can have serious consequences. No one wants to lose their nursing license over a legal misunderstanding!

How much does a medical director cost?

Depending on the contract responsibilities and relationship to the medical director (a friend vs. through a company), the payment varies. Check out the post on “How Much Should a Collaborating Physician Be Paid?” for more answers!

face being injected

Bottom line…

In order to start an aesthetics business, you may need a medical director/collaborating physician. For the most part these terms can be used interchangeably. The process can seem daunting at first, but there are companies and document packages available that make it much easier. Keep doing your research and you’ll soon be on the road to starting your own beautiful business! Remember:

Ready to hone your skills and make money with Botox? Take a look at our available online & small group hands-on Botox training.

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Hi, I’m Cassie Lane!

CRNA, DNAP, Founder of Injectables EDU

I want to help build a community that builds strong providers and strong practices providing support and mentorship that makes the whole industry stronger.

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