Appropriate Credentialing and Supervision of Medical Clinics and Spas
October 24, 2022
Nashville, TN — TMA has compiled resources on reporting of improper supervision of medical clinics or spas to the Tennessee Department of Health. The department has authority for various licensing Health Related Boards whose responsibilities are to protect the public interest.
Concerns over instances when a physician has not provided proper oversight of an advanced practice registered nurse-owned or physician assistant-owned practice were raised at TMA’s House of Delegates meeting in May via Resolution No. 16-22.
TMA members may report peers who they believe are not properly supervising medical clinics or spas. They may access the complaint form produced by the Tennessee Department of Health here.
To remain anonymous, the complaint form must be downloaded and emailed to oiv.complaints@tn.gov or mailed to the following address:
TN Department of Health
Office of Investigations
665 Mainstream Drive, Second Floor
Nashville, TN 37243
Questions may be directed to the department at 615-741-8485 or toll free at 800-852-2187.
The Tennessee General Assembly passed the Tennessee Patient Safety Cosmetic Procedures Act in 2014. The law’s intent was to protect patients from injuries resulting from poorly-performed cosmetic medical services.
These procedures are defined as any service that uses a biologic or synthetic material, a chemical application, a mechanical device, or a displaced energy form of any kind that alters or damages, or is capable of altering or damaging, living tissue to improve the patient’s appearance or achieve an enhanced aesthetic result.
In 2015 and 2016, the Tennessee General Assembly amended this law to provide clarification and reduce unintentional burdens placed on physician practices. Depending on the type of entity and the number of patients receiving cosmetic medical services, an entity may require a medical director or supervising physician to enroll in an online registry with the payment of a fee to the state.
A medical director or supervising physician is defined as a physician who meets three requirements:
- Holds an active Tennessee MD or DO license
- Has an active medical practice physically located in Tennessee
- Is responsible for the provision of or supervises the provision of cosmetic medical services
For further information and background, TMA members may access the law guide topic, Med Spas - Medical Director Requirement and Registry.
Additionally, TMA’s legal department has produced a Supervising Physician Toolkit to help members stay in compliance with regulations governing their role as a physician collaborating with an advanced practice registered nurse (APRN) or physician assistant (PA). Contact TMA's Becky Morrissey at becky.morrissey@tnmed.org with any questions.