This patient safety guide is co-authored by VIO Franchise Group and SafeLink Consulting.
Before you book. Before you consent. Before anyone picks up a needle, laser, or device. The questions that protect you as a medspa patient and what the answers should look like.
The medical spa industry has grown into a $17 billion market with more than 11,000 locations across the United States and consumer demand has never been higher. But growth in the industry has outpaced growth in patient protections. Before your next appointment, there are things you have every right to know. |
Medical spas sit at the intersection of beauty and medicine. That intersection can be remarkable where science-backed treatments, delivered by skilled practitioners, create real, meaningful results. It can also be a place where the appearance of medical care exists without its substance. Knowing the difference is not just about getting better results. It is about your safety.
We write this not to discourage you from seeking aesthetic treatment. We write it because patients deserve to be informed partners in their own care. And right now, across the industry, not enough of them are.
WHAT THE RESEARCH SHOWS
The Numbers Every Med Spa Patient Should See
Two peer-reviewed studies published in Dermatologic Surgery by the American Society for Dermatologic Surgery (2024, 2025) surveyed medical spas nationally. Their findings are the clearest picture available of what patients are actually walking into.
73% |
78.6% |
50 - 81% |
39% |
| Of injectable procedures performed by nonphysicians | Of medical directors not board-certified in dermatology or plastics | Of physicians not onsite when invasive procedures were performed | Of spas notify a physician when a patient has a complication |
None of these numbers mean that your treatment will go wrong. What they mean is that the system around you - the oversight, the accountability, the emergency response may not be what you assume it to be. That is worth knowing before you consent.
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The New York Investigation, December 2025: A joint New York City Council and State investigation inspected 223 medical spas statewide. Of the 15 examined closely in the five boroughs, every single one was performing procedures outside the bounds of state law. Reported patient harms included burns, infections, sepsis, and hospitalization. |
What You Are Entitled to Know and Ask
Who is performing your procedure?
You have the right to know the name, credentials, and license type of every person who will touch you. A nurse practitioner, registered nurse, physician assistant, and physician each have different training and different legal authorities. An esthetician is not licensed to perform medical procedures. Ask specifically: what is your license, and are you authorized to perform this procedure in this state?
Who is the medical director and are they real?
Each state requires clinical oversight of a med spa by a licensed and credentialed clinician. Research shows that in many facilities, this physician exists primarily on paper - listed on the website but not engaged in daily oversight, not reviewing protocols, and often unreachable when something goes wrong. Ask: Is the medical director available today? What is the process for reaching them if I have a complication after I leave?
What product or device is being used on you?
You have the right to know the brand name and manufacturer of any injectable. If a practice cannot or will not tell you what product they are using, or if pricing seems unusually low, that is a significant warning sign. The FDA has issued safety warnings about counterfeit botulinum toxin products that have caused hospitalizations in the United States.
What happens if something goes wrong?
Before any procedure, you should know: who do you call if you experience a reaction after hours? Fewer than 40% of medspas had an after-hours number available for patients. A practice that cannot answer this question clearly does not have an adequate complication response protocol.
What are you signing?
Informed consent is not a liability waiver. It should clearly describe the procedure, the risks, the alternatives, and who is performing it. Be especially careful about photography consent: if a practice asks to use your before-and-after photos for marketing, that requires a specific, separate HIPAA-compliant authorization. Your photos are protected health information,
THE RED FLAGS
Signs That Should Give You Pause
X |
Staff cannot tell you the name or credentials of the person who will perform your procedure |
X |
The practice website shows no information on clinical oversight by a licensed and credentialed clinician |
X |
Pricing on injectables is significantly below market rate - under $8–10 per unit for neurotoxin |
X |
No one reviews your medical history or asks about allergies before treatment |
X |
The practice cannot provide a complication contact number or after-hours protocol |
X |
You are pressured into same-day booking decisions or discouraged from asking questions |
X |
The consent form is vague, rushed, or presented as a formality rather than a protection |
THE GREEN LIGHTS
What Good Care Actually Looks Like
| ✓ | Staff clearly identify themselves by name, credential, and scope of practice |
| ✓ | A medical director is named, actively involved, and reachable - not just listed on a website |
| ✓ | Products are named specifically, from licensed US distributors, at realistic market pricing |
| ✓ | A thorough intake process reviews your health history before any treatment begin |
| ✓ | Informed consent is reviewed with you, not simply handed over to sign |
| ✓ | You are given a clear after-hours contact and complication response procedure before you leave |
| ✓ | Photography consent for marketing is separate from and additional to clinical consent |
YOUR PRIVACY
Your Health Information Is Protected - Even at a MedSpa
Medical spas providing healthcare services and transmitting health information electronically are covered entities under HIPAA. Your intake forms, treatment records, and before-and-after photographs are all protected health information. You have the right to access your records, to request corrections, and to know how your information is being used.
If a med spa uses your photos on Instagram or in ads without your specific, written, HIPAA-compliant authorization, that is a potential violation regardless of how common the practice has become in the industry.
|
You would not have surgery without knowing who your surgeon is and what credentials they hold. The same standard applies to your medspa provider. The aesthetic setting of a med spa does not change the medical reality of what is being done to your body. - David Carter, Senior Director of Compliance - VIO Franchise Group |
THE BOTTOM LINE
You Deserve Care That Can Prove It Is Safe - Not Just Believe It
The vast majority of medspa practitioners are skilled, caring professionals who take their obligations seriously. The structural gaps documented in the research are not the result of malice. They are the result of an industry that grew faster than the operational infrastructure around it.
The practices that have built genuine compliance infrastructure - documented supervision, trained staff, verified products, clear complication protocols - are the ones that answer your questions without hesitation, because they have nothing to hide and everything to stand behind.
Questions about spa safety? Want a better understanding of med spa safety regulations?
SafeLink and VIO work with medspa operators to build the compliance infrastructure that makes these questions easy to answer.
VIO Franchise Group | info@viomedspa.com
SafeLink Consulting Inc. | info@safelinkconsulting.com
SOURCES & REFERENCES
1. Almukhtar RM et al. Supervision Unveiled: Navigating the Supervision Landscape in Medical Spas. Dermatol Surg. 2024;50(10):954–957.
2. Second national medspa supervision study. Dermatol Surg. 2025. (ASDS) [full citation on file].
3. NYC Council. Joint Investigation into Growing Industry of Medical Spas. council.nyc.gov. Dec. 11, 2025.
4. FDA Safety Communication. Adverse Events with Counterfeit Botulinum Toxin Products. fda.gov.
5. Rossi AM et al. Nonphysician practice of cosmetic dermatology. Dermatol Surg. 2019;45:588–597.
6. Wang JV et al. Experiences with medical spas and associated complications. Dermatol Surg. 2020;46:1543–1548.
Ready to build a compliance program that works?
SafeLink Consulting provides site assessments, written program development, staff training, and ongoing managed compliance for med spas across the country. Discover more about Medical Spa Compliance.
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