Texas Medical Board Tightens Rules on Med Spa Delegation and Signage

The Texas Medical Board Rule 169.28, which takes effect January 9, 2025, explicitly classifies non-surgical cosmetic procedures like onabotulinumtoxinA and fillers as the practice of medicine, forcing Texas practices to document all clinical delegation in writing. Operationally, clinics must prominently display the delegating physician’s name, Texas medical license number, and an official complaint notice in all public areas and treatment rooms. Every staff member performing delegated acts must also wear a physical name tag showing their credentials. Under Texas Occupations Code Chapter 157, a physician is restricted from delegating prescriptive authority to more than seven advanced practice registered nurses or physician assistants at one time. These updates arrive alongside House Bill 3749, signed June 20, 2025, and effective September 1, 2025, following the June 2, 2025 veto of Senate Bill 378. With typical medical director compensation running $1,500 to $5,000 monthly, or $150 to $400 hourly, Texas practice owners must audit their delegation agreements, staff badges, and in-clinic signage immediately to ensure total alignment with these strict structural mandates.

Source: Med Spa Standards, https://www.medspastandards.com/texas-medical-director-compensation-tmb-delegation-rules-2026