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By Board Vice Chair Vickie Pyevich, M.D.
With the growing interest in medical aesthetic services across Iowa as well as concerns this board has received regarding MedSpas that are not properly supervised, it’s critical for physicians serving as medical directors—or considering that role—to stay up to date on regulatory requirements.
In Iowa, medical spas are regulated under the Iowa Administrative Code (IAC) Chapter 481--655.6, which governs medical aesthetic services. Below is a concise guide to these rules governing medical spas, along with compliance reminders and best practices. This is not a comprehensive list of rules; supervising physicians should consult an attorney to ensure they are meeting all requirements of the law.
Medical Spas Supervised By Physicians Are Subject to Specific Rules
Medical Director Requirements for Physicians
A physician may be a medical director, so long as the physician holds an active, unrestricted Iowa medical license. Non-physicians may own med spas, but all services must be under physician supervision or the supervision of another licensed healthcare provider working within their scope of practice.
The physician must be located within 60 miles of the location where the medical aesthetic services are performed. This ensures timely oversight, accessibility for emergencies, and compliance with Iowa law.
The medical director must:
- Ensure proper training, competency, informed consent, and safety protocols are in place;
- Assume responsibility for oversight, delegation, patient safety, quality of care, and adherence to state rules; and
- Be clearly identified in all advertising, signage, and websites related to the medical spa. Physicians must ensure that advertising activities do not include false, misleading, or deceptive representations.
A “medical spa” (per Iowa rule 481 IAC 655.6) is any entity that is advertised, established, or maintained to provide medical aesthetic services, such as injectables (e.g., Botox, fillers), laser treatments, micro-needling, non-superficial exfoliation, and other procedures that alter living tissue beyond superficial epidermal layers.
“Non-superficial” means the procedure must be capable of modifying or damaging living tissue below superficial epidermal cells.
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Delegation and Supervision
The performance of medical aesthetic services is considered the practice of medicine; delegation is only permitted when the service is delegated by the medical director to qualified non-physician personnel. A medical director shall not delegate medical aesthetic services to non-physician persons who are not appropriately licensed or certified in Iowa. The Iowa Board of Medicine requires written verification of the education and training of all non-physician persons performing delegated medical aesthetic services.
Delegated services must:
- Be within the medical director’s scope of competence and judgment to supervise.
- Be “routine and technical” in nature (i.e., not requiring physician-level judgment at every step).
- Be performed under appropriate supervision with adequate oversight, training, and protocols in place. Ask yourself: would I allow this individual to perform the service on my family member?
- Ensure that all qualified licensed or certified non-physician persons receive direct, in-person, on-site supervision from the medical director or other qualified licensed physician for at least four hours each week, and that the regular supervision is documented.
- Provide on-site review of medical aesthetic services performed by qualified licensed or certified non-physician persons each week and review at least 10% of patient charts for medical aesthetic services performed by qualified licensed or certified non-physician persons.
The Iowa Board of Medicine takes medical spa compliance very seriously. The board is committed to ensuring medical spas meet the highest standards of safety and compliance.
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Here are some reminders on things we commonly hear about but are easy to remedy:
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Self-reporting: Report any outside discipline to the board within 30 days. This includes discipline from other states, malpractice suits, fines, or charges from law enforcement, including DUIs. Failure to report may lead to additional discipline by the board.
- Self-reports can be made via email to Charles Hill, executive director, at charles.hill@dia.iowa.gov; or
- Mailed to the Iowa Board of Medicine, 6200 Park Ave., Ste. 100, Des Moines, IA 50321.
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Death certificates: Don’t refuse to help with death certificates, and ensure they are signed within 72 hours.
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Prescribing: Know the guidelines around self-prescribing and treating close family members, note the documentation requirements, and know which prescriptions qualify as a controlled substance (testosterone is one).
Guest blog by Katie Kuehner, D.O.
As a practicing physician, I never imagined that my professional life could be upended by a single phone call. On July 22, 2025, everything changed when I received a terrifying call from someone claiming to be Investigator Jason Hayes, badge number BR7474786 and Chief Investigator #3, from the Iowa Board of Medicine. He informed me that drugs and narcotics had been seized at the Texas-Mexico border, directly linked to my name, my medical license, my NPI, and multiple bank accounts across states. The accusations were grave: five counts of federal drug trafficking under 21 U.S.C. § 841(a) and four counts of federal money laundering, all involving interstate and international borders. He declared my license suspended effective immediately, with an active FBI arrest warrant issued and all my bank accounts frozen. I knew I was innocent—likely framed or a victim of identity fraud—but the panic was overwhelming. My heart and thoughts raced. As a doctor, my license is everything; without it, I can't treat patients, support my family, or pursue the career I've built over years. The fear of arrest, extradition to Texas, and total ruin was paralyzing.
Read the entire blog.
Administrative Rules in the Iowa Administrative Code governing the Iowa Board of Medicine have moved to Chapters 650 through 663 of Section 481 (Department of Inspections, Appeals, and Licensing).
An important part of the investigative process for the board is asking a peer to review the case and determine if standard of care was met. A written report is required. Compensation is available for the time and expertise involved in these peer review reports. If you would be interested in serving as a peer reviewer, please email Laura Berardi, executive officer for the Iowa Board of Medicine.
Royce Woodroffe, M.D., joined the Iowa Board of Medicine as a physician member in August 2025. He has been appointed to a three-year term. Dr. Woodroffe is a neurological and spinal surgeon, serving the central Iowa area. He maintains his ties to Iowa City, where he still lives after graduating from the University of Iowa.
If you have an interest in serving on the Board of Medicine, please submit an application through the new IAppoint website.
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