Navigating medical spa compliance in 2025: A guide for aesthetic and wellness professionals

The aesthetic and wellness industries are currently experiencing unprecedented growth. The medical spa market, according to a report by Technavio, is anticipated to grow by $27B from last year to 2028, representing nearly a 20% growth. It’s a trend driven by disposable income, lifestyle changes, and the thriving medical tourism industry. However, alongside this remarkable growth trajectory comes increased regulatory scrutiny and, with the recent administration change, potentially new compliance challenges that can have a direct impact on your business.

Recent findings from a study undertaken by the American Society for Dermatologic Surgery Association (ASDSA) flagged some concerning trends in med spa supervision. In their 2024 study, ASDSA found that 73% of injectable treatments at med spas were performed by non-physicians and that a supervising physician was only present in 38.1% of establishments. The study also found that when complications arose, only 46% of facilities reported that they notified a medical director or supervising physician. 

Since the med spa industry operates within a complex regulatory environment that differs from state to state, it’s vital for med spa operators to be aware of these regulations and remains compliant to protect their reputation, patient health and business.

Understanding the regulatory framework

Compliance is essential to ensuring patient safety and business sustainability, so it’s key to understanding the most important areas that could impact a med spa’s business. The most important areas are:

1. Ownership structure: Different states have their own requirements for med spa ownership. Some mandate ownership must be by licensed medical professionals while others allow owners to be non-medical as long as their employees are qualified, licensed staff.

2. Supervision requirements. The ASDA’s findings emphasize the importance of having proper medical supervision within med spa facilities. They are currently working to enact the Medical Spa Safety Act which would prioritizes:

• Continuous physician oversight during medical procedures.
• Mandatory training requirements for medical directors.
• Clear public notifications when a physician is not on site.
• Comprehensive adverse event reporting systems.

Abiding by the proposed terms of the Medical Spa Safety Act would put med spas in a stronger position when it comes to creating a safe space for patients and building a trusted reputation in the market. While this act is not enforceable as yet, its guidelines are worth adhering to on principle.

3. Documentation and safety protocols. Documentation systems and safety protocols should be carefully maintained and established. The ASDA study found that up to 40% of spas didn’t have an after-hours emergency number for patients which is a critical gap in care and safety protocols. It’s important to reassure patients and provide them with documentation and visibility into support networks before, during and after treatment.

Building a compliant practice: An exercise in planning and prevention

It’s important to establish appropriate business structures to allow med spa operators to better monitor and manage compliance and regulatory requirements. When reporting, planning, and compliance roles and responsibilities are clearly defined, it’s more likely to catch omissions and be more prepared for any changes to regulations as the new administration moves into play.

There are two types of business model that could support a shift towards a highly compliant and agile organization. The first is the Managed Services Organization (MSO) model which allows for separation between clinical operations that are overseen by licensed professionals, administrative functions managed by business professionals, marketing and customer service, and facility management. Another model is the Professional Medical Corporation which fits well in states with strict oversight requirements as it ensures proper medical supervision, clear lines of authority, and compliance with state-specific ownership requirements.

Risk management: Investing in people and processes

When it comes to creating a robust compliance framework, it’s vital to go beyond just business structures and into training and supporting staff. Training and certification should be ongoing as you ensure all practitioners maintain their appropriate certifications. It’s important to document all training and certifications to know where people need to expand their knowledge and expertise.  

Treatment protocols should be standardized for all services with clear documentation and reporting systems. Additionally, operators need to put adverse event reporting structures in place and have easily accessible support systems for your patients. This aligns with enhancing patient safety measures that should include comprehensive informed consent procedures, clear emergency protocols and after-hours care.

Planning ahead: Managing compliance in a changing landscape

As the industry continues to grow rapidly, staying ahead of compliance requirements is going to get even more important – and challenging. Technology, regulations, patient demand and innovative procedures require that practices are as prepared as possible to protect their patients and business. With this in mind, there are several emerging compliance considerations worth paying attention to:

• Technology integration – electronic health records, patient communication platforms and documentation management systems may create a more cohesive reporting and more visible treatment landscape. For patients, this means more visibility into companies that abide by the rules and prioritize their wellbeing. 
• Marketing compliance – social media guidelines, advertising regulations and claims substantiation requirements are likely to change over the next four years. Be aware of how these changes will influence communication and patient engagement, as well as regulatory expectations.
• Quality assurance – consider undertaking regular internal audits and embedding continuous improvement protocols to ensure the med spa practice is ahead of the game when it comes to compliance and quality. 

Maintaining regulatory compliance while delivering exceptional patient care will put any med spa in a superb position in a highly competitive and demanding market. Those that demonstrate proper supervision, documentation and safety protocols are creating a sustainable, compliant practice that meets regulations and patient expectations. This is the formula for success in 2025 that will allow any stage of med spa to thrive in an increasingly regulated and challenging environment. 

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