New Texas Medical Board Rules: What Med Spas & IV Clinics Need to Know
Starting January 9, 2025, the Texas Medical Board is rolling out important updates to its rules that will impact medical spas and IV hydration clinics. These changes aim to clarify supervision requirements, strengthen patient-provider relationships, and improve transparency about who is providing care.
Transparency for Patients: Rule §169.28
A key part of these updates ensures that patients know who is treating them and how to file complaints if needed. Under this rule:
Every treatment room and public area must display signs explaining how to file a complaint with the Texas Medical Board and listing the name and license number of the supervising doctor(s).
Anyone performing medical procedures under a doctor’s supervision (such as nurse practitioners or physician assistants) must wear a name tag with their name and credentials clearly visible.
Clearer Responsibilities for Delegating Physicians: Rule §169.26
Doctors who delegate medical tasks to PAs, APRNs, or other providers must follow new guidelines to ensure safety and proper training:
Training & Protocols – The doctor must confirm that the person performing the procedure is properly trained, understands risks, and knows when not to perform it. A signed protocol is required.
Physician Competence – The doctor must be trained in the procedure themselves and able to perform it according to standard care practices.
Pre-Procedure Patient Care
Before any procedure, a physician, PA, or APRN must:
Establish a patient-provider relationship, which can be done via telehealth or in person (for example, through a virtual good faith exam like Spakinect).
Ensure that at least one person trained in basic life support (CPR) is present in the facility.
New Supervision Rules: What’s Changing?
Under the updated Rule §169.26(d), providers must be more immediately available when delegating procedures. Here’s what’s different:
A physician, PA, or APRN must either be on-site during the procedure or be immediately available for emergency consultation.
If needed, the physician must see the patient for an emergency appointment.
Unlike before, PAs and APRNs can now handle emergency consultations, instead of just physicians, giving more flexibility in meeting supervision requirements.
Why This Matters for Med Spas
These updates provide clearer rules for medical delegation, making it easier for med spas to stay compliant while ensuring patients receive safe, well-supervised care. Texas med spas should take the time to review these changes and update their policies accordingly to avoid compliance issues.
