At the request of the American Med Spa Association, Harry Nelson provided an update on the subject of recent enforcement activity focused on medical spas by the Medical Board and Board of Barbering and Cosmetology. Numerous California medical spas have reported recent unannounced visits from both Medical Board and Barbering and Cosmetology Board investigators, with a focus on illegal ownership structures in violation of the corporate practice of medicine doctrine and a need for greater separation of medical and aesthetic personnel and operations. The enforcement climate highlights a greater need than ever for medi-spas to review their business structures, and have their operational structure, practices, and documentation in order. “It is much simpler,” Nelson writes, to “address compliance issues proactively before the government shows up than to do so in the aftermath of an investigation identifying deficiencies.”
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