Med spa · Washington

Washington med spa MSO-PC: injectables, lasers, and who owns the clinic

Washington treats injectables and prescription lasers as medicine, sets written-protocol and supervision rules for delegation, and keeps ownership of the medical side with licensees. See how to staff it.

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Direct answer

A Washington med spa that offers neuromodulators, filler, or prescription laser, light, radiofrequency, or plasma treatments is practicing medicine under WAC 246-919-606 and WAC 246-919-605. A physician must examine the patient and authorize treatment, then may delegate injectables to a trained PA, RN, or LPN and laser work to a properly trained licensed professional under a written office protocol. Washington is a Moderate corporate practice of medicine state, so the clinical work usually sits in a physician-owned professional service corporation or PLLC, and the founder owns an MSO that runs the brand, lease, booking, and retail under a fixed fee. Foundry forms that MSO-PC for $15,000 one-time and matches a Washington-licensed friendly PC owner for $3,000/mo.

The full Washington statute list sits on Washington CPOM, and the CPOM 50-state guide shows how Washington compares with other states. For other states, start at the med spa MSO-PC hub. General information only, not legal advice. Foundry is not a law firm.

What sits in the PC and what sits in the MSO

Work	Physician-owned PC	MSO owned by the founder
Neuromodulators, filler, other cosmetic injections	Yes. Authorized by a physician after an exam	No
Laser, IPL, radiofrequency, and plasma treatments with prescription devices	Yes, under WAC 246-919-605	May own and lease the equipment to the PC at fair market value
Written office protocols and the quality assurance program	Yes	No
Patient charts and consent forms	Yes	Hosts the EHR as a vendor under a business associate agreement
Brand, website, booking, front desk, retail skincare	No	Yes
Lease, buildout, non-clinical payroll, bookkeeping	No	Yes, billed to the PC at a fixed or cost-plus fee

Estheticians are licensed separately by the Department of Licensing and may not inject. Nurse practitioners practice under their own license, so the delegation rule below covers physicians delegating to PAs, RNs, and LPNs.

Injectables: delegation under WAC 246-919-606

The physician is trained in the procedure, keeps a training record, and examines, diagnoses, and gets informed consent before authorizing treatment.
Delegates are PAs, RNs, or LPNs trained in technique, cutaneous medicine, complications, and infection control.
A written office protocol names the responsible physician, patient selection criteria, and complication care.
Each patient signs a consent form naming the delegate and their license, and each delegate wears a name tag.
For products FDA-approved for that use, the physician is reachable by phone and able to respond within 30 minutes.
For products used off-label or not FDA-approved, the physician is on site for the whole procedure.
A physician may sponsor up to three PAs for these procedures, and delegates may not re-delegate.

Lasers and energy devices: WAC 246-919-605

Prescription laser, light, radiofrequency, and plasma devices applied to the skin are the practice of medicine in Washington. The physician must be trained on each device, examine the patient before authorizing treatment, and run a quality assurance program. Delegation to a properly trained licensed professional whose scope covers the device requires:

A written office protocol naming the devices, settings, and patient selection criteria.
The delegating physician on the immediate premises during each patient's initial treatment.
For brief absences, a local back-up physician who agrees in writing, is reachable by phone, and can see the patient within 60 minutes.
No use on the globe of the eye and no independent medical judgment by the delegate.

The 60-minute rule shapes staffing: a laser room needs a physician nearby, and an absent physician cannot be an ongoing arrangement. Map each device on your menu before you hire.

Fees and the money flow

Keep clinical card payments in the PC's account, have the MSO invoice the PC for defined services at a fixed or cost-plus fee, and price it at fair market value. Review referral and rebate terms against chapter 19.68 RCW and run the MSA red-flag audit on CPOM compliance before you sign. Adding virtual consults? Read the Washington telehealth MSO-PC guide.

Setup steps for a Washington med spa

List every treatment on the menu and mark which ones are medicine: injectables and prescription energy devices.
Match a Washington-licensed physician to own the PC ($3,000/mo) and supervise under the protocols.
Form the professional service corporation or PLLC and the MSO, and sign an FMV management services agreement. See MSO-PC formation ($15,000).
Write the injectable and laser protocols, the consent forms, and the quality assurance program.
Lease equipment and space from the MSO to the PC at fixed fair-market-value rates.
Route clinical payments to the PC's bank account and keep retail sales in the MSO.

Pricing

MSO-PC formation

$15,000

One-time. The MSO and the Washington physician-owned PC, scoped to your menu and locations.

Friendly PC owner

$3,000/mo

A Washington-licensed physician who owns your PC.

Washington med spa MSO-PC FAQ

Can a non-physician own a med spa in Washington?

Not the medical side. Injectables and prescription laser treatments are the practice of medicine under WAC 246-919-605 and 246-919-606, and Washington is a Moderate CPOM state. The founder owns the MSO, and a Washington-licensed physician owns the PC.

Who can inject Botox in a Washington med spa?

Physicians, and trained PAs, RNs, and LPNs under physician delegation with a written protocol under WAC 246-919-606. Nurse practitioners work under their own license. Estheticians may not inject.

Does the physician have to be on site in a Washington med spa?

It depends on the procedure. For FDA-approved injectables used as approved, the physician must be reachable by phone and able to respond within 30 minutes. For off-label products, the physician must be on site. For delegated laser work, the physician is on the premises for each patient's initial treatment.

Who can run lasers in a Washington med spa?

A properly trained licensed professional whose scope covers the device, under a physician's written protocol and quality assurance program, per WAC 246-919-605.

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

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

Opening a Washington med spa?

Book a free 20-minute call with your menu and locations and states. We will scope the PC, the MSO, and the physician owner.