Georgia med spa MSO-PC: who may inject, laser rules, and who owns the practice

Direct answer

Georgia is Moderate on the CPOM 50-state guide. Share limits, Board discipline, and the diligence default are on Georgia CPOM. For the general aesthetics build, start at the med spa MSO-PC hub. After papers, run CPOM compliance. Adding virtual consults? Read the Georgia telehealth MSO-PC guide. General information only, not legal advice. Foundry is not a law firm.

Who may do what in a Georgia med spa

The Georgia Composite Medical Board licenses cosmetic laser practitioners under Article 9 and Rule Chapter 360-35. Assistant laser practitioners work under a physician or a senior laser practitioner. Senior laser practitioners are PAs or nurses who hold the cosmetic laser practitioner license and practice under consulting-physician protocols. An esthetics license does not add Botox, filler, or cosmetic laser authority.

O.C.G.A. § 43-34-248 is the consulting-physician statute for facilities that provide cosmetic laser services other than hair removal. The consulting physician must be trained in laser modalities, establish and file protocols, examine each patient before those services (or delegate that exam as the section allows), and remain available for emergency consultation. The facility must post who the consulting physician is and, when that physician is off site, who is supervising.

PAs, nurses, and the medical director question

A physician assistant injects under a Board-approved job description. An APRN injects under a nurse protocol filed with the Board under O.C.G.A. § 43-34-25. An RN needs an individualized order after a proper history and physical; a standing order alone is not the Board's described path. O.C.G.A. § 43-34-25(n) and Board Rule 360-32-.04(5) restrict a physician from being an employee of an APRN the physician delegates to. Board guidance in 2026 has read that restriction broadly for APRN-owned practices. A medical director title on a lay-owned LLC is not ownership. Read physician PC owner before you hire for the role.

Who owns the Georgia practice

Treatment revenue belongs to the clinical entity. Retail skincare that is not a professional service can sit in the MSO. A Delaware LLC can own the MSO. It cannot hold shares in a Georgia professional corporation organized for medicine. If any patient is in Utah, Utah requires a domestic professional entity. See Utah CPOM. To file the two companies, use MSO-PC formation.

Setup steps for a Georgia med spa

1. List every treatment. Mark injections, laser hair removal, and other cosmetic laser services separately.
2. Match a Georgia-licensed physician to own the professional entity through friendly PC owner matching ($3,000/mo).
3. Form the Georgia professional corporation (or the structure counsel chooses) and the MSO, and sign a fair-market-value MSA. See MSO-PC formation ($15,000). Typical formation is 1 to 3 days after the menu, the states, and the physician match are scoped. Payer enrollment runs on the payer's clock.
4. Write the laser and injection file: consulting-physician agreement where § 43-34-248 requires it, Board-filed protocols, cosmetic laser practitioner licenses, and injector credentials. Keep esthetics services inside Chapter 43-10.
5. Route all treatment payments to the clinical entity and pay the MSO its fixed fee. Then run CPOM compliance.

Pricing

Georgia med spa MSO-PC FAQ

Who can inject Botox in a Georgia med spa?

The Georgia Composite Medical Board treats neurotoxin and filler injections as the practice of medicine. A physician may perform them. A PA may inject under a Board-approved job description. An APRN may inject under a nurse protocol filed under O.C.G.A. § 43-34-25. An RN needs an individualized physician order after a history and physical by a physician, NP, or PA; standing orders alone are not enough. The Board FAQ says physicians may not delegate neurotoxin or filler injections to medical assistants, and that doing so is unprofessional conduct under Ga. Comp. R. & Regs. 360-3-.02. Confirm a specific injector plan with Georgia counsel.

Can an esthetician run a laser in a Georgia med spa?

Cosmetic laser services in Georgia are regulated under O.C.G.A. Title 43, Chapter 34, Article 9 and Board Rule Chapter 360-35. A person who provides cosmetic laser services needs a cosmetic laser practitioner license from the Georgia Composite Medical Board, unless they are a physician. An esthetician license alone does not authorize laser work. Hair removal with lasers or pulsed light has lighter supervision rules than other cosmetic laser services. Other cosmetic laser services need a consulting-physician agreement under O.C.G.A. § 43-34-248.

Does Georgia require a consulting physician for laser hair removal?

O.C.G.A. § 43-34-248 requires a consulting-physician agreement for facilities that provide cosmetic laser services other than hair removal using lasers or pulsed light devices. Board Rule 360-35-.05 says on-site supervision and a prior examination are not required for laser hair removal and pulsed light treatments. For other cosmetic laser services, the consulting physician must be trained in laser modalities, file protocols with the Board, examine the patient before treatment (or delegate that exam as the statute allows), and be available for emergency consultation.

Can a lay founder own a Georgia med spa?

Georgia repealed its standalone corporate-practice statute in 1982, so there is no California-style ban. A professional corporation organized for medicine may still issue shares only to a person licensed and actively practicing that profession under O.C.G.A. § 14-7-5. Many founders use an ordinary LLC for the brand with a physician under contract, or an MSO supporting a physician-owned PC. Clinical judgment stays with the licensed clinicians. Georgia is Moderate on the CPOM guide. That label is not permission for a lay LLC to hold a professional corporation's shares.

How much does Foundry charge for a Georgia med spa MSO-PC?

MSO-PC formation is $15,000 one-time. A Georgia-licensed friendly PC owner is $3,000/mo.

Related reading

Written and last reviewed 2026-11-05 by Matthew Milford, Founder. Sources: Georgia Composite Medical Board; O.C.G.A. §§ 14-7-4, 14-7-5, 43-34-25, 43-34-248; Ga. Comp. R. & Regs. Chapter 360-35 and 360-3-.02. Foundry PC is not a law firm. General information only, not legal advice.