Collaboration vs. Delegation in Medical Aesthetics: What every Med Spa Needs to Know

Collaboration typically refers to a legal working relationship between two or more independently licensed healthcare providers—most often Physicians, Nurse Practitioners (NPs), or Physician Assistants (PAs).

In today’s rapidly evolving medical aesthetics industry, it’s common to hear terms like collaboration and delegation used interchangeably. But they’re not the same — and misunderstanding this distinction can expose your med spa to serious legal and licensing risks.

At AestheticComplianceExperts.com, we regularly audit clinics and the most frequent compliance failure by far is this exact misunderstanding.

What Is 

Collaboration?

Collaboration is a formal relationship between two or more independently licensed providers, such as a physician and an NP (Nurse Practitioner) or PA (Physician Assistant). It is built on mutual clinical responsibility — not supervision.

Key Features:

• Involves licensed providers only

• Requires a collaborative agreement (e.g., PAA for NP, supervisory agreement for PA)

• Each provider retains independent clinical authority within their scope

• No hierarchical oversight — rather, structured care alignment

Texas Examples:

• NPs must have a Prescriptive Authority Agreement (PAA) under §169.5 when working with physicians  .

• PAs require a Supervisory Agreement according to §169.5(b) .

Even though they’re working together, this isn’t delegation — it’s collaboration.

What Is 

Delegation?

Delegation occurs when a licensed provider authorizes non-degreed or non-independent staff (like RNs, MAs, estheticians, or laser technicians) to perform clinical tasks under defined protocols.

Key Features:

• Applies to non-licensed or non-independent staff

• Requires written protocols and standing delegation orders

• Mandates appropriate supervision — direct or general, depending on procedure

• The delegating provider is legally accountable

Updated Texas Rules:

• Delegation now falls under Chapter 169 Subchapter E, §§169.25–169.28, replacing the repealed §193.17  .

• Highlights include:

  
  

  • §169.25: Defines non-surgical cosmetic procedures as medical acts;

  • §169.26: Sets training and written protocol requirements;

  • §169.27: Details physician’s responsibility for orders and oversight;

  • §169.28: Mandates staff ID posting and signage  .

  
  

Bottom line: If a task isn’t performed by a licensed provider or done under a collaborative agreement, it requires strict delegation oversight under these rules.

Why This Matters — Big Time

Confusing collaboration and delegation can lead to:

• Licensing board violations

• Practicing outside legal scope, even unintentionally

• Loss of insurance or civil liabilities

• Severe penalties for non-compliance

And remember: “My medical director said it’s okay” is not a legal defense to offset documented rules.

How to Get It Right

Here’s the compliance checklist every med spa needs:

1. Define each team member’s role clearly

   
   

   • Licensed providers = collaboration

   • Support staff = delegation

   
   

2. Use the correct documentation

   
   

   • PPA & Supervisory Agreements for collaboration

   • Written protocols / Standing Delegation Orders + training logs for delegation

   
   

3. Stay current on Texas law

   
   

   • Delegation rules now live at §169.25–169.28 — confirm your clinic aligns  .

   
   

4. Organize your compliance binder

   
   

   • Keep agreements, protocols, training records, and logs in one place — ready for review.

   
   

Final Takeaway

In medical aesthetics, ignoring the difference between collaboration and delegation puts everything on the line — your license, reputation, and livelihood.

• Collaboration = shared, independent practice with a licensed peer

• Delegation = oversight and accountability for non-providers

At AestheticComplianceExperts.com, we specialize in helping clinics set up legal collaboration agreements and clean delegation systems so you can provide results — without risking compliance.

Resources & Links

• Texas Chapter 169, Subchapter E — Delegation rules (§§169.25–169.28)

• Texas Medical Board website — rule updates & guidance 

• Texas Board of Nursing — APRN delegation policies 

Need Help?

Aesthetic Compliance Experts specializes in:

• Develop state-specific Credentialing & Compliance Manuals

• Create customized Standard Operating Procedure (SOP) manuals

• Conduct virtual and on-site clinic compliance audits

Contact us today to protect your license, your business, and your peace of mind.