A medical spa offers a hybrid of medical and cosmetic procedures. For those in the medical spa business, or those hoping to start one, there are a myriad of legal considerations, including the “corporate practice of medicine doctrine” (CPOM). In some states, pursuant to the CPOM doctrine, physicians must have financial ownership interest in a medical practice, in others, non-physicians cannot own a medical spa.
Thus, if a physician is servicing as a “medical director” on a contract basis, with no ownership interest in the medical spa, this could violate the corporate practice of medicine law.