Opening a medical aesthetics clinic? Every state has different rules for ownership, supervision, and licensing. Our comprehensive guide breaks down exactly what you need in all 50 states and DC.
The Corporate Practice of Medicine (CPOM) doctrine determines whether a non-physician can own a medical practice in your state.
17 States
These states strictly prohibit non-physicians from owning medical practices. You must use an MSO/PC (Management Services Organization / Professional Corporation) structure.
CA, NY, TX, IL, NJ, NC, TN, IN, PA, AR, MI, ND, WI, WV, OR, CO, MD
18 States
These states have some CPOM restrictions but offer more flexibility. Non-physician ownership may be possible under certain conditions or with specific entity structures.
Varies by state -- check individual state details below
16 States
These states do not enforce CPOM doctrine. Non-physicians can own and operate medical practices directly, though a medical director is still required for clinical oversight.
Direct ownership allowed -- still need medical director
Click any state below to see its specific requirements for opening a medical aesthetics clinic.
The Corporate Practice of Medicine doctrine is the single biggest factor determining how you structure your clinic.
CPOM is a legal doctrine adopted by many states that prohibits corporations or non-physicians from practicing medicine, employing physicians, or exercising control over medical decisions. The purpose is to prevent commercial interests from interfering with the physician-patient relationship.
What this means for you: If you are not a licensed physician and you want to open a medical aesthetics clinic in a CPOM state, you cannot simply form an LLC and start treating patients. You need a specific legal structure.
In strict CPOM states, non-physician entrepreneurs use a two-entity structure:
The MSO and PC enter into a Management Services Agreement (MSA) that defines their relationship. The MSO handles the business side while the PC handles the medical side. This structure keeps the non-physician legally separate from the practice of medicine.
California is the most common state people ask about. Here is the full step-by-step process for a non-physician opening a medical aesthetics clinic in California.
Before anything else, you need a licensed California physician (MD or DO) who will own the Professional Corporation and serve as medical director. This person must be actively involved in clinical oversight -- they cannot be a "rubber stamp."
ClinicFramework can place a qualified medical director in California through our network.
Your physician files Articles of Incorporation with the California Secretary of State as a Professional Corporation. The PC must be owned 100% by a licensed physician. File Form SI-550 (Statement of Information) within 90 days. Register with the Medical Board of California.
Cost: ~$100 filing fee + attorney fees ($2,000-$5,000 typical for setup).
You (the non-physician entrepreneur) form a standard California LLC or corporation. This is your business entity. You own it entirely. The MSO will provide all non-medical business services to the PC.
Most entrepreneurs choose an LLC for liability protection and tax flexibility.
This is the most critical document. The MSA defines the relationship between your MSO and the physician's PC. It should clearly outline: services provided by the MSO (space, equipment, billing, marketing, non-clinical staff), compensation structure (flat fee or fair-market-value calculation), term and termination clauses, and the physician's retained authority over all medical decisions.
Have a healthcare attorney draft this. A bad MSA is the #1 way clinics get in trouble.
The MSO typically signs the commercial lease and purchases/leases all equipment. The MSO then provides the space and equipment to the PC under the MSA. This keeps real estate and equipment costs on the business side.
California requires multiple licenses depending on services offered:
-- City/county business license (both MSO and PC)
-- DEA registration (if using controlled substances)
-- Laser registration with CA Dept. of Public Health (if laser services)
-- Medical waste generator permit
-- Fictitious business name statement (if operating under a DBA)
-- NPI number for the PC
Clinical staff (NPs, PAs, RNs) are hired by the PC and work under the physician's supervision. California NPs do NOT have full practice authority -- they require standardized procedures and physician supervision. Non-clinical staff (front desk, marketing, billing) are hired by the MSO.
California requires direct physician supervision for NPs performing aesthetic procedures.
The medical director must create written standardized procedures and treatment protocols for every service offered. Establish a compliance program including: patient consent forms, treatment documentation standards, adverse event reporting procedures, and regular chart audits. Obtain malpractice insurance for the PC and all providers.
With structures in place, you are ready to operate. The MSO manages the business. The PC provides the medical services. The medical director oversees all clinical operations. Maintain clear separation between business and medical decision-making at all times.
Budget 3-6 months from start to opening day. Total startup costs typically range from $150K-$500K depending on location and services.
Need help with any of these steps?
ClinicFramework provides medical director placement, MSA templates, compliance consulting, and startup guidance for California clinics.
Contact us
Common questions about opening a medical aesthetics clinic.
Templates, checklists, and guides to help you launch your clinic. Additional resources are added regularly.
Customizable Management Services Agreement template with key provisions for medical aesthetics clinics. Attorney review recommended.
Coming SoonPhysician supervision and collaborative practice agreement template. Covers supervision scope, chart review requirements, and liability.
Coming SoonPre-launch compliance checklist customized by state. Covers entity formation, licensing, insurance, protocols, and operational requirements.
Coming SoonPrintable PDF summarizing CPOM categories, NP practice authority, and ownership requirements for all 51 jurisdictions.
Coming SoonSpreadsheet template to estimate your clinic startup costs including buildout, equipment, legal, licensing, and operating capital.
Coming SoonTemplate job description and expectations document for recruiting a medical director for your aesthetics clinic.
Coming Soon