Med spas
How a med spa can add a peptide program
A med spa already works under medical rules, and those rules decide how it can offer peptides. Ownership and medical director requirements vary by state; California's Medical Board says a lay-owned spa that simply hires a medical director is a prohibited structure. Peptides compounded under section 503A are made for an identified patient on a prescription; FDA says clinics that want office stock can obtain it from 503B outsourcing facilities. A telehealth program through a licensed practice keeps the peptide line separate from what your staff do on site.
The structure
Who does what in a peptide program
Three separate parties, so that every medical decision is made by someone licensed to make it. Whether a given program is lawful also depends on state rules, which is why each structure goes through healthcare counsel before launch.
Your business
Brings the audience, refers clients to the medical practice, and handles everything that is not medical. How your business is paid, and whether the program can carry your brand, are set by healthcare counsel for each state; in California, for example, a non-physician business may not offer or advertise medical services.
A licensed medical practice
A clinician licensed in, or registered with, each patient's state evaluates every patient and decides whether to prescribe. Every medical question goes to the clinician.
A licensed pharmacy
Fills each prescription for the individual patient and ships it to them. Your business never buys, holds or resells medication.
Your part
What you do
- Introduce the program to clients and refer them to the medical practice, in the way your counsel approves for your state
- Keep your own medical director for the procedures your staff perform on site
- Keep the telehealth peptide line separate from in-clinic services
- Use claims and drug names exactly as the prescription and label allow
Not your part
What you never do
- Assume your medical director covers the telehealth program, or the reverse
- Keep compounded peptides as office stock from a 503A pharmacy
- List a compounded drug under an approved brand name
- Call your pharmacy or a compounded drug "FDA approved"
The rules
The rules that matter for med spas
State law varies. These are sourced examples, not a survey of every state.
Who may own a med spa depends on the state
California's Medical Board says a business that offers medical procedures and hires a physician as its "medical director" without physician ownership is a prohibited structure. In Texas, the American Med Spa Association says non-physician entities generally may not employ physicians to practice medicine. Florida may require a clinic that is not wholly owned by licensed practitioners to be licensed and to appoint a medical or clinic director who accepts legal responsibility in writing. Since September 1, 2025, Texas law also limits who may order and administer elective IV therapy outside a physician's office.
Patient prescriptions vs office stock
Under federal law, a 503A pharmacy compounds only for an identified patient on a prescription. FDA says clinics that want office stock, medication kept on the shelf without a prescription for a named patient, can obtain it from 503B outsourcing facilities, which may not make a given peptide. A telehealth program ships each prescription to the patient, so it runs on patient prescriptions.
Every business type
Rules that apply to every peptide program
The prescriber must be licensed where the patient is
A clinician who treats a patient by telehealth generally must be licensed in the patient's state. Some states, such as Florida, let out-of-state clinicians register instead. Texas treats an out-of-state clinician's care of a Texas patient as practicing medicine in Texas, and California requires documented patient consent before care by telehealth.
Claims need evidence, and prices must be complete
The FTC requires competent and reliable scientific evidence for health claims. It has acted against a physician-run clinic over unsupported disease claims, and in 2025 against a telehealth weight-loss company whose advertised prices left out the drug, the labs and the provider visits.
Never borrow a brand name or call a pharmacy "FDA approved"
FDA has warned a med spa for listing a compounded drug under an approved brand name, and an IV clinic for describing its source as an "FDA-approved pharmacy." Compounded drugs are not FDA approved, and pharmacies are licensed by states, not approved by FDA.
How compounding pharmacies work, and what they can make, is on what a 503A compounding pharmacy is. The full launch structure is in the guide to starting a peptide program, and medical direction is covered on do you need a medical director.
Planning a peptide program for your med spa?
Tell us what you do on site and where your clients live. We answer in one business day, and every structure goes through healthcare counsel before launch.
Frequently asked
Med spas: questions
Can a med spa offer peptides?
Often, if the structure fits your state's rules. Who may own the med spa and who must supervise varies by state; California, for example, prohibits a lay-owned spa that simply hires a medical director. A telehealth peptide program run through a licensed medical practice keeps the prescribing with that practice and separate from the procedures your staff perform on site.
Can a med spa keep compounded peptides in stock?
Not from a 503A pharmacy, which compounds only for identified patients on a prescription. FDA says office stock can be obtained from 503B outsourcing facilities. A telehealth program avoids the question because each prescription ships to the patient.
What has FDA warned med spas about?
Among other things, listing a compounded drug under an approved brand name, which FDA cited in a September 2025 warning letter to a med spa, and describing a pharmacy as "FDA approved," which it cited to an IV clinic in June 2026.
Does our medical director cover a telehealth peptide program?
The telehealth practice supplies its own clinicians and medical direction for its program. Your medical director remains responsible for the services your staff perform on site, under your state's rules.
Nothing on this page is legal advice. State law varies and changes; this page was last checked against its sources on 18 October 2026. ConduitMD provides software and management services to an independent medical practice and its partners; it does not prescribe, compound or dispense.