Featured Articles
Nationwide: the FDA's GLP-1 telehealth crackdown and the prescriber-network gap
The FDA's warning letters on compounded GLP-1 marketing exposed how telehealth platforms and prescribing networks split responsibility. What med spas should check.
Key facts:
- The FDA issued 30 warning letters to telehealth companies over compounded GLP-1 marketing.
- One named company, MEDVi, was cited in a February 20, 2026 letter.
- Many platforms don't prescribe themselves. Affiliated medical groups do, which can create accountability gaps.
- Intake-form-only evaluations may not meet state prescribing standards.
What did the FDA flag?
The FDA issued 30 warning letters to telehealth companies marketing compounded GLP-1 drugs with claims it called false or misleading. In a February 20, 2026 letter to MEDVi, the FDA cited claims like "same active ingredient as Wegovy and Ozempic," which are misleading because compounded drugs are not FDA-approved. See the FDA warning letter.
What is the prescriber-network issue?
A March 2026 analysis found that many of these platforms don't actually prescribe. They rely on clinicians in affiliated medical groups to evaluate patients and write prescriptions. That split between the marketing platform and the prescribing group can leave gaps in who's accountable for patient evaluation, prescribing, and follow-up. Asynchronous, intake-form-only evaluations may not meet state requirements for prescribing injectables.
What it means for your med spa
If you work with any telehealth or prescribing partner, get clear on who owns each step. Vet partners for compliance with state prescribing laws and scope of practice, make sure evaluations meet your state's Good Faith Exam standard, and confirm your marketing matches how care is actually delivered.
FAQs
Are intake-form-only evaluations enough to prescribe GLP-1s?
Often not. Many states require a real evaluation that an intake form alone may not satisfy.
Why does the platform-versus-prescriber split matter?
It can blur accountability for evaluation, prescribing, and follow-up, which is exactly where enforcement looks.
Fresh Clinics helps med spa owners vet partners and meet Good Faith Exam standards. Learn more about Fresh Clinics membership.
Nationwide: Amazon's One Medical GLP-1 program and what it signals for med spas
Amazon launched a GLP-1 program through One Medical, bundling telehealth, prescribing, and pharmacy. Here's the signal for how med spas should structure GLP-1 care.
Key facts:
- On April 21, 2026, Amazon launched a GLP-1 Management Program through One Medical, nationwide.
- It bundles screening, provider consults, prescribing, follow-up, and pharmacy fulfillment.
- On-demand telehealth handles renewals only, not new prescriptions.
- This is a commercial launch, not a regulatory action.
What did Amazon launch?
On April 21, 2026, Amazon introduced a GLP-1 Management Program through its One Medical platform, available nationwide. It runs a single care pathway: pre-visit screening, a structured consultation with a licensed provider, prescribing, follow-up visits, and clinical monitoring. Prescriptions can be filled at the patient's pharmacy of choice. See Amazon's announcement.
Is this a regulation?
No. It's a commercial program, not a government action. But it matters because it sets a market benchmark for what doing GLP-1 properly looks like: provider-led evaluation, real follow-up, and documentation, with on-demand telehealth limited to renewals rather than new prescribing.
What it means for your med spa
If you offer GLP-1 services, this is the bar patients will start comparing you to. Build a care pathway with genuine assessment, prescribing by a licensed provider, follow-up, and monitoring. Align provider involvement with your state's requirements, and document how prescriptions are issued and filled, especially when a third-party or integrated pharmacy is involved.
FAQs
Can patients get a new GLP-1 prescription through Amazon's on-demand telehealth?
No. That channel handles renewals only. New prescriptions go through the structured consultation.
Does this change any law for med spas?
No. It's a commercial program, but it signals the standard of care patients will expect.
Fresh Clinics helps med spa owners build compliant, well-documented GLP-1 care pathways. Learn more about Fresh Clinics membership.
Nationwide: the CMS-FDA RAPID device pathway, and why it likely won't touch your med spa
CMS and the FDA launched the RAPID pathway to speed Medicare coverage for Breakthrough Devices. Here's why most aesthetic devices fall outside it.
Key facts:
- On April 23, 2026, CMS and the FDA announced the RAPID coverage pathway.
- It aligns FDA authorization timing with Medicare coverage review for certain Breakthrough Devices.
- It applies only to eligible Class II and Class III devices for serious or life-threatening conditions.
- Elective cosmetic and aesthetic devices are not in scope.
What is RAPID?
On April 23, 2026, CMS and the FDA announced the RAPID (Regulatory Alignment for Predictable and Immediate Device) pathway. It coordinates the timing of FDA market authorization with Medicare's National Coverage Determination review, so eligible devices reach Medicare coverage faster. See the CMS announcement and the FDA announcement.
Does it apply to aesthetic devices?
Almost certainly not. RAPID applies only to certain FDA-designated Breakthrough Devices, which are for life-threatening or irreversibly debilitating conditions. The agencies did not identify elective cosmetic devices or routine med spa procedures as eligible. Energy-based systems, body contouring, and lasers stay under their existing FDA authorization pathways, such as 510(k), and state oversight.
What it means for your med spa
This one is mostly a good-to-know, not an action item. Still, it's a useful prompt to review how each of your device-based technologies is FDA-classified and authorized, and to make sure your marketing reflects the actual cleared indications. More detail is coming through a Federal Register notice and public comment.
FAQs
Will RAPID speed up coverage for my laser or body-contouring device?
No. Those are elective aesthetic devices and fall outside the Breakthrough Devices Program and RAPID.
What devices does RAPID cover?
Certain FDA-designated Breakthrough Devices for serious or life-threatening conditions.
Fresh Clinics helps med spa owners keep device marketing aligned with FDA-cleared indications. Learn more about Fresh Clinics membership.
Latest Articles
Nationwide: 36 states have no med spa-specific rules, per the AMA
Key facts:
- In April 2026, the AMA reported that 36 states have no med spa-specific laws or regulations, citing a 2025 Dermatologic Surgery study.
- 44 states lacked patient-protection requirements specific to med spas.
- Only 12 states had any med spa-specific provisions.
- Roughly 70% of med spas operate without affiliation to a physician practice.
What did the AMA report?
On April 6, 2026, the American Medical Association highlighted a 2025 study in Dermatologic Surgery finding that 36 states have no identified laws or regulations specific to med spas, and 44 states lacked med spa-specific patient-protection requirements. Only 12 states had any med spa-specific provisions: Connecticut, Iowa, Illinois, Indiana, Massachusetts, New Mexico, Oklahoma, Rhode Island, Tennessee, Texas, Utah, and Wisconsin. See the AMA article.
If my state has no med spa rules, am I unregulated?
No, and this is the trap. In states without med spa-specific rules, oversight still comes through the general laws governing the practice of medicine, nursing, and facility operations. Regulators apply those. The AMA brief notes roughly 70% of med spas operate without affiliation to a physician practice, which is exactly the gap regulators are watching.
What it means for your med spa
Don't mistake no med spa statute for no rules. Check your supervision and delegation structure against your state's medical and nursing laws, confirm every clinical staff member is properly licensed for what they do, and keep documentation for patient evaluation, treatment planning, and consent. Enforcement sweeps are already happening, including a New York inspection of 223 med spas that cited 87 for violations.
FAQs
Which states have med spa-specific rules?
Per the study, twelve: Connecticut, Iowa, Illinois, Indiana, Massachusetts, New Mexico, Oklahoma, Rhode Island, Tennessee, Texas, Utah, and Wisconsin.
What governs med spas in the other states?
General laws on the practice of medicine, nursing, and facility operations.
Fresh Clinics helps med spa owners build a supervision structure that holds up under general medical and nursing law. Learn more about Fresh Clinics membership.
Nationwide: FDA removes 12 peptides from Category 2, but they're not cleared
Key facts:
- On April 22, 2026, the FDA removed 12 peptides from Category 2 of its 503A bulk drug substances list.
- The removal happened because nominators withdrew their nominations, not a new safety finding.
- Removal does not mean the peptides are eligible for compounding.
- Several go to Pharmacy Compounding Advisory Committee review, with meetings expected through February 2027.
What did the FDA do?
On April 22, 2026, the FDA removed 12 peptide substances from Category 2 of its 503A bulk drug substances list. The list includes BPC-157, LL-37 (Cathelicidin), Dihexa acetate, DSIP (Emideltide), Epitalon, injectable GHK-Cu, KPV, PEG-MGF, Melanotan II, MOTs-C, Semax, and TB-500. You can see the FDA 503A bulk drug substances list.
Does removal mean they're approved for compounding?
No, and this is the part that trips people up. The substances came off Category 2 because the parties who nominated them withdrew their nominations, not because the FDA decided they're safe to compound. Removal does not establish that they meet the criteria for compounding under section 503A. They remain under evaluation.
What happens next?
Several go to the Pharmacy Compounding Advisory Committee for review, with meetings expected through the end of February 2027. The committee gives non-binding recommendations, and the FDA acts after that. Existing 503A rules stay in effect. See the advisory committee meeting page.
What it means for your med spa
Don't read the headline as a green light. Verify each peptide's eligibility under section 503A before sourcing or using it, audit your compounding pharmacy partners, and keep prescriber documentation for patient-specific prescriptions. Watch the advisory committee outcomes through early 2027.
FAQs
Can I use these 12 peptides now?
Not on the basis of this change. Removal from Category 2 is not approval for compounding, and they remain under review.
Why were they removed?
The nominators voluntarily withdrew their nominations. It was not a new safety determination.
Fresh Clinics helps med spa owners stay on top of compounding eligibility and sourcing. Learn more about Fresh Clinics membership.
Nationwide: FDA's MoCRA cosmetic rules, what they mean if you sell skincare
Key facts:
- MoCRA (2022) expanded FDA authority over cosmetics: facility registration, product listing, adverse-event reporting, safety substantiation, and recall authority.
- On February 11, 2026, the FDA updated its Cosmetics Direct portal ahead of biennial registration renewal.
- Manufacturers and processors register facilities. A responsible person lists each marketed product.
- It's most relevant to med spas selling retail or private-label skincare.
What is MoCRA?
The Modernization of Cosmetics Regulation Act of 2022 gave the FDA broader authority over cosmetics. It added requirements for facility registration, product listing including ingredients, serious adverse-event reporting, safety substantiation, records access, and mandatory recall authority. On February 11, 2026, the FDA updated its Cosmetics Direct submissions portal to help facilities prepare for biennial registration renewal. See the FDA update and the MoCRA overview.
Does this apply to a med spa?
It depends on your relationship to the products you sell. If you only resell another company's finished, already-listed products, the manufacturer usually carries the registration and listing duties. If your practice's name is on the label, you market a private-label line, or you're involved in manufacturing, distribution, or listing, you may be a responsible person with obligations of your own. There are exemptions for some small businesses.
What it means for your med spa
Map your retail and private-label products to a responsible person. Keep supplier documentation showing who manufactures, labels, and lists each product, and set a clear path for routing adverse reactions and complaints to the right party.
FAQs
What is a responsible person under MoCRA?
The party responsible for listing a cosmetic product with the FDA, typically the manufacturer, packer, or distributor whose name is on the label.
Does selling retail skincare automatically trigger MoCRA registration?
Not necessarily. Reselling finished, already-listed products usually keeps the obligation with the manufacturer. Private-label or own-brand products are where duties can attach to you.
Fresh Clinics helps med spa owners keep their retail and product operations compliant. Learn more about Fresh Clinics membership.
Ohio: new IV therapy compliance standards for med spas
Key facts:
- On May 15, 2025, Ohio's Medical, Pharmacy, and Nursing Boards issued a joint statement on IV therapy in clinics and med spas.
- Only physicians, PAs, or APRNs with prescriptive authority can diagnose, prescribe IV medications, and oversee treatment.
- Standing orders for IV therapy are prohibited. Each treatment needs an individual evaluation.
- Only licensed professionals can prepare or administer IV medications.
What did Ohio's boards say?
On May 15, 2025, Ohio's Medical, Pharmacy, and Nursing Boards issued a joint statement aimed at IV therapy clinics and med spas, citing concern about improper diagnoses, drug preparation, and unlicensed administration. It sets out clearly who can do what.
Who can prescribe and administer IV therapy in Ohio?
Only a physician, PA, or APRN with prescriptive authority can diagnose a patient, prescribe IV medications, and oversee the treatment plan. Only licensed medical professionals can prepare or administer IV drugs. Aestheticians, medical assistants, and front desk staff cannot.
Are standing orders allowed?
No. Pre-set protocols that let IV therapy proceed without a real prescriber-patient relationship are prohibited. Each IV treatment requires an individual evaluation by a qualified prescriber, citing Ohio Administrative Code Rule 4729-3-12. Telehealth can establish that relationship, but it has to meet the same standard of care as an in-person visit, with documentation.
What it means for your med spa
If you run IV therapy in Ohio, drop any standing-order model and build a workflow where a qualified prescriber evaluates each patient. Confirm that only licensed staff prepare and administer. Enforcement risks include fines and license suspension.
FAQs
Can a med spa use standing orders for IV drips in Ohio?
No. Each treatment requires an individual evaluation by a qualified prescriber.
Can a telehealth visit establish the prescriber relationship?
Yes, if it meets the in-person standard of care and is documented.
Fresh Clinics helps med spa owners run compliant IV therapy with telehealth Good Faith Exams and medical oversight. Learn more about Fresh Clinics membership.
New Jersey: emergency APN practice flexibilities extended, for now
Key facts:
- On February 13, 2026, New Jersey's Governor extended the State of Emergency through April 2, 2026, keeping temporary APN supervision flexibilities in place.
- The extension delays, but does not cancel, the return to pre-emergency rules.
- Once it ends, APNs resume written joint protocols, documented physician collaboration, and controlled-substance protocols.
- It affects APN-led injectables, IV therapy, and device-based services.
What changed?
In January 2026, New Jersey signaled that pandemic-era practice flexibilities would expire within 30 days. Then, on February 13, 2026, Governor Sherrill signed an executive order extending the State of Emergency through April 2, 2026, which kept temporary modifications to APN collaboration and supervision requirements in place. See the Governor's announcement.
Is this new practice authority?
No. The extension only delays the return to pre-emergency rules. It does not grant anything new. When the emergency ends, APNs go back to maintaining written joint protocol agreements with collaborating physicians, documented collaboration, DEA registrations and controlled-substance protocols, and clear ownership and provider authority.
What it means for your med spa
Treat this as a deadline, not a reprieve. If your practice leaned on modified collaboration or remote supervision during the emergency, those arrangements may draw scrutiny once standard rules resume. Review and update your joint protocols, prescribing parameters, and physician collaboration before the emergency lapses.
FAQs
When do pre-emergency rules return?
After the State of Emergency ends, currently extended through April 2, 2026.
Does the extension expand what APNs can do?
No. It only postpones the return to standard supervision and collaboration requirements.
Fresh Clinics helps med spa owners get supervision agreements in order ahead of changes like this. Learn more about Fresh Clinics membership.
New Jersey: independent practice for APNs, but not for aesthetics
Key facts:
- On March 30, 2026, New Jersey's Governor signed S2996/A4052, giving qualifying APNs permanent independent practice authority.
- It applies to APNs in primary or behavioral health care with more than 5,000 practice hours.
- The law explicitly excludes elective aesthetic and cosmetic services.
- Aesthetic APNs still need a joint protocol with a collaborating physician.
What did New Jersey change?
On March 30, 2026, Governor Mikie Sherrill signed S2996/A4052, letting qualifying advanced practice nurses (APNs) practice without a joint protocol with a collaborating physician. To qualify, an APN must have more than 5,000 hours in an applicable population focus such as family practice, adult gerontology, pediatrics, women's health, or behavioral health. See the Governor's announcement and the official bill text.
Does this apply to aesthetic clinics?
No. The law explicitly states that qualifying independent APNs cannot provide elective aesthetic or cosmetic services. So an APN delivering injectables, IV therapy, or other cosmetic services in New Jersey still operates under the existing joint protocol rules, including prescribing standards, chart review, annual protocol review, and physician availability.
What it means for your med spa
If your New Jersey practice runs on APN-delivered aesthetic services, your supervision obligations have not changed. Keep your joint protocol agreements current, and don't assume the headline about independent practice applies to cosmetic work. The Board of Nursing is expected to issue implementing rules, so watch for those.
FAQs
Can an aesthetic nurse practitioner work independently in New Jersey now?
No. The independent practice authority excludes elective aesthetic and cosmetic services.
What do aesthetic APNs still need?
A joint protocol with a collaborating physician, with chart review, annual protocol review, and physician availability.
Fresh Clinics helps med spa owners keep their supervision structure sound as state rules shift. Learn more about Fresh Clinics membership.
Utah: physician indicted over non-FDA-approved peptides from China
Key facts:
- On April 1, 2026, a federal grand jury indicted a Utah osteopathic physician who owned a wellness clinic.
- He allegedly sold non-FDA-approved peptides imported from China to more than 200 patients between February 2024 and April 2025.
- Named substances include tirzepatide, semaglutide, BPC-157, TB-500, and NAD+.
- He faces eight counts involving misbranded drugs. The case was investigated by the FDA Office of Criminal Investigations.
What is the case?
On April 1, 2026, the U.S. Attorney's Office for the District of Utah announced a federal indictment of a licensed osteopathic physician who owned a wellness clinic in Utah. You can read the Department of Justice press release.
What is he alleged to have done?
Between about February 2024 and April 2025, the physician allegedly used an intermediary to obtain discounted, non-FDA-approved peptides from a supplier believed to be in China, then sold them to more than 200 patients. The peptides allegedly arrived in unlabeled vials, and he allegedly added labels that did not identify the manufacturer, packer, or distributor, which is what makes a drug misbranded under federal law. He is also alleged to have skipped comprehensive medical histories and provided syringes for self-injection without monitoring protocols. He faces eight counts.
What it means for your med spa
Imported or research-grade peptides are a live federal enforcement target, and holding a medical license is no shield. Verify the source, FDA status, and lawful pathway for every peptide or GLP-1 product before it reaches a patient. Make sure labels carry the required source information, and document patient evaluation, prescribing, and dispensing.
FAQs
What makes a drug misbranded?
Among other things, a label that fails to identify the manufacturer, packer, or distributor, or that is false or misleading.
Which peptides were named in the indictment?
Tirzepatide, semaglutide, BPC-157, TB-500, and NAD+, among others.
Fresh Clinics helps med spa owners build compliant sourcing and documentation into how they operate. Learn more about Fresh Clinics membership.
Texas: criminal charges in the Jenifer's Law med spa death case
Key facts:
- In April 2026, felony charges were filed against the former owner and former medical director of a Texas med spa over a 2023 IV therapy death.
- The case is the one behind Texas HB 3749 (Jenifer's Law), effective September 1, 2025.
- The Texas Medical Board found the medical director failed to supervise an unlicensed owner who made treatment decisions.
- In Texas, only physicians, PAs, or APRNs can prescribe or order elective IV therapy, and only physicians, PAs, APRNs, or RNs can administer it, under physician supervision.
What happened?
On April 29 and 30, 2026, prosecutors in Freestone County, Texas filed felony charges against the former owner and former medical director of a med spa in Wortham, Texas. The charges, which include murder, manslaughter, and criminally negligent homicide, stem from the July 2023 death of a patient after an IV infusion at the spa. The case is ongoing.
How does this connect to Jenifer's Law?
The patient's death prompted HB 3749, known as Jenifer's Law, which took effect September 1, 2025 and set delegation and supervision rules for elective IV therapy. You can read the enrolled bill text on the Texas Legislature site. The criminal case is separate from the law, but it's the event that drove it.
What did the Texas Medical Board find?
In August 2024, the Texas Medical Board disciplined the medical director for failing to properly supervise the owner, who was not licensed or qualified to make treatment decisions or administer prescription medications. The board found IV therapy with prescription drugs was given without proper safety protocols, emergency procedures, or adequate on-site licensed oversight. You can see the Texas Medical Board newsroom for its disciplinary actions.
What it means for your med spa
This is the clearest possible signal that supervision is not a paperwork formality. Under current Texas rules, only a physician, PA, or APRN can prescribe or order elective IV therapy, and only a physician, PA, APRN, or RN can administer it, always under physician supervision. An unlicensed owner cannot make treatment decisions. Document your delegation chain, emergency protocols, and supervising physician involvement.
FAQs
Who can order and administer elective IV therapy in Texas?
A physician, PA, or APRN can prescribe or order it. A physician, PA, APRN, or RN can administer it, under physician supervision.
Is this the same thing as HB 3749?
No. HB 3749 (Jenifer's Law) is the statute. This is a separate criminal prosecution arising from the same 2023 death.
Fresh Clinics helps med spa owners put real supervision and documentation in place, from telehealth Good Faith Exams to medical oversight. Learn more about Fresh Clinics membership.
Texas: what Jenifer's Law (HB 3749) means for med spas
Key facts:
- Texas HB 3749 (Jenifer's Law) took effect September 1, 2025.
- It regulates elective IV therapy provided outside a hospital or doctor's office.
- A physician, NP, or PA must evaluate the patient before an elective IV, which is a Good Faith Exam (GFE).
- Only a physician, NP, PA, or RN can start and administer the IV.
- It adds no new state requirements for injectables, laser, or other cosmetic procedures.
What is Jenifer's Law (HB 3749)?
HB 3749 is a Texas law named for Jenifer Cleveland, who died in 2023 after an IV infusion at a med spa in Wortham, Texas. Governor Greg Abbott signed it into law on June 20, 2025, and it took effect September 1, 2025. You can read the enrolled bill text on the Texas Legislature site.
The first draft was sweeping. It would have regulated cosmetic procedures across the board, required a physician to perform every initial exam, and mandated a physician on site. After industry input, the version that passed is far narrower and focuses on elective IV therapy.
What counts as elective IV therapy?
Elective IV therapy is the non-emergency administration of fluids, vitamins, or medications into the bloodstream for hydration, wellness, or temporary symptom relief, delivered outside a hospital or doctor's office. Think vitamin drips, hydration infusions, and mobile IV services. IV care given in a hospital or licensed clinic is regulated separately and isn't covered here.
Who can administer IV therapy in Texas now?
Before an elective IV is administered, a physician, nurse practitioner, or physician assistant must evaluate the patient, which in practice is a Good Faith Exam (GFE). Only a physician, NP, PA, or registered nurse can start and administer the IV. Medical assistants, licensed vocational nurses, paramedics, and unlicensed technicians can no longer perform that step. A physician can still delegate ordering and administration to qualified providers under adequate supervision.
Does Jenifer's Law affect injectables or laser treatments?
No. If your med spa offers injectables, laser, or other cosmetic treatments and not IV drips, HB 3749 adds no new state requirements to those services. The rumored on-site physician mandate did not make the final law. Existing Texas Medical Board rules still apply: a physician, PA, or NP must establish the patient relationship through a Good Faith Exam, which can be done via telehealth, before any aesthetic procedure, and at least one person trained in basic life support should be on site during procedures.
What should Texas med spas do about it?
If you offer IV therapy, check who starts your IVs and confirm every patient is evaluated first. If you don't, treat this as a prompt to confirm your GFE process, documentation, and supervision agreements are solid. Regulators are paying closer attention to the med spa industry, and the practices that stay ahead of it are the ones already running by the book.
FAQs
When did Jenifer's Law take effect?
September 1, 2025.
Does the law require a physician on site at all times?
No. It requires adequate physician supervision and delegation, not a full-time on-site physician. Existing Texas Medical Board rules govern supervision and emergency readiness.
Can a nurse practitioner or physician assistant perform the Good Faith Exam?
Yes. A physician, NP, or PA can evaluate the patient before an elective IV.
Who can legally start an elective IV in Texas?
A physician, NP, PA, or registered nurse. Medical assistants, LVNs, paramedics, and unlicensed technicians cannot.
Fresh Clinics helps med spa owners put this infrastructure in place, from telehealth Good Faith Exams to medical oversight and documentation. Learn more about Fresh Clinics membership.