Licensing planning guide

Maryland med spa
licensing guide.

Cosmetic delegation requires a qualified licensed healthcare provider.

Prepared by Prospyr · Sources checked September 15, 2026

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What to know in Maryland

Start with these state-specific findings, then use the checklist below to review the rest of your practice. The linked authorities explain the conditions and exceptions behind each point.

01

Delegation and assignment have defined recipients

The regulations allow delegation to a PA or assignment to another licensed healthcare provider whose licensing board has determined that the procedure is within scope. An unlicensed assistant or esthetics credential alone does not satisfy that described pathway.

Source: Maryland COMAR 10.32.09: Cosmetic medical procedures and devices
02

Written protocols and training are required

The chapter addresses physician qualifications, patient evaluation and treatment planning, supervision, written equipment/procedure protocols and theoretical and clinical training for non-physicians. Review the specific supervision provisions and any approved PA agreement.

Source: Maryland COMAR 10.32.09: Cosmetic medical procedures and devices

Your next steps

  1. Match every procedure and proposed performer to the licensing-board scope determination required by the regulation.
  2. Maintain the written protocols, equipment instructions and maintenance log, training records and emergency/follow-up procedures.

Questions to resolve before opening

  • Has the performer’s own licensing board authorized this cosmetic procedure within scope?
  • Which evaluation, treatment-plan and supervision provision applies to this delegation or assignment?

Bring your actual ownership chart, service menu, devices and staff credentials to the relevant board or healthcare counsel. The same answer may not apply to a different procedure or business model.

A practical licensing checklist

These planning steps complement the Maryland highlights. They are a workflow for investigation, not a claim that every listed permit applies to every practice.

01

Ownership & clinical control

Identify the owners of the clinical entity, who employs clinicians, who controls medical decisions and how management fees are paid. Ask healthcare counsel to confirm the entity and any professional-ownership or fee-splitting limits before signing agreements.

02

People & procedures

List the person who evaluates, prescribes, performs and supervises each treatment. Verify the actual professional license, restrictions, procedure training and required agreements. A course certificate alone does not establish a legal scope of practice.

03

Premises, devices & products

Check clinic or establishment licensing, local zoning and occupancy, device registration, drug purchasing and storage, and any laboratory or body-art services. Adding a procedure or location can change the applicable requirements.

04

Patient care & opening file

Document consent, assessment, treatment orders, emergency escalation, infection prevention and record access. Assign an owner to every unresolved question and keep the authority supporting the final decision.

Official sources & scope

A source-based planning guide for practice owners, not legal advice or a license approval. The state highlights cover the issues identified below; the workbook helps you resolve additional ownership, scope and facility questions with the relevant boards and qualified counsel. Requirements depend on your services, staff and business structure.

No attorney review is claimed. Report an update.

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