AI Is Transforming Healthcare—But Are Your Privacy Policies Keeping Up?

By: Carlos Arce, Attorney

Artificial intelligence is quickly becoming a standard part of healthcare operations. From ambient AI documentation tools that generate clinical notes to voice-assisted transcription platforms and automated workflow solutions, healthcare organizations are increasingly adopting technologies designed to improve efficiency and allow providers to spend more time focused on patient care.

As these tools become integrated into everyday practice, organizations should ensure their policies and compliance documentation evolve alongside the technology. AI implementation is not simply an IT decision—it also requires a thoughtful review of privacy practices, patient communications, vendor relationships, and internal governance.

Key Policies to Review

Healthcare practices adopting AI technologies should evaluate whether the following documents adequately address their use:

Notice of Privacy Practices (NPP): Consider whether the notice accurately describes how patient information may be collected, processed, stored, or disclosed through AI-assisted technologies.

Patient Consent and Intake Forms: Depending on the AI platform being used and applicable federal and state law, practices should determine whether patients should receive additional disclosures or have the opportunity to consent to—or decline—the use of AI-assisted recording or documentation during their visit.

Internal Privacy and Security Policies: Policies should address how AI tools are selected, monitored, and used by staff, including appropriate safeguards for protected health information (PHI).

Workforce Training: Employees should understand when AI tools may be used, what information may be entered into those systems, and the organization’s expectations for protecting patient privacy.

Vendor Management: Practices should verify that AI vendors handling PHI execute appropriate Business Associate Agreements (BAAs) where required and maintain HIPAA-compliant security and privacy practices.

Compliance Considerations

The use of AI may implicate several regulatory frameworks depending on the technology and the jurisdiction in which a practice operates. Organizations should evaluate their compliance obligations under HIPAA, the HITECH Act, the 21st Century Cures Act, applicable state privacy laws such as the Florida Information Protection Act (FIPA), state recording consent laws, and any applicable professional licensing requirements.

In addition to regulatory compliance, practices should establish internal procedures for evaluating new AI technologies before deployment. This includes understanding how patient data is processed, where it is stored, who has access to it, and whether the vendor’s security practices align with the organization’s compliance requirements.

Building an AI Governance Strategy

Rather than treating AI implementation as a one-time technology upgrade, healthcare organizations should incorporate AI into their ongoing compliance and risk management programs. Periodic reviews of privacy policies, consent documents, vendor agreements, and employee training materials can help ensure that organizational policies continue to reflect evolving technologies and regulatory expectations.

As AI continues to reshape healthcare delivery, practices that proactively update their policies and governance frameworks will be better positioned to integrate innovation while maintaining patient trust and supporting regulatory compliance.

Fractional Clinical Oversight vs. Legal Compliance: Why Healthcare Practices Need Both

By: Carlos Arce, Attorney

Healthcare providers across the country, including IV hydration clinics, med spas, wellness practices, and other cash-based healthcare businesses, have increasingly faced audits and investigations by state regulatory agencies regarding alleged Corporate Practice of Medicine (“CPOM”) violations and inadequate medical director oversight. One trend has become increasingly apparent.

Many of these businesses were established with the assistance of fractional medical director or supervising physician platforms. These organizations provide a valuable service by connecting practices with qualified physicians, assisting with clinical oversight, and helping providers navigate the operational aspects of launching a healthcare business. There is undoubtedly a place for these services in today’s rapidly growing healthcare industry. The problem arises when these platforms begin providing legal guidance regarding corporate structuring and regulatory compliance.

Too often, businesses are told they are “fully compliant” simply because template documents were provided or a basic management structure was recommended. However, when a state regulatory agency requests documentation demonstrating the separation between the clinical entity and the management company, the independence of medical decision-making, the authority exercised by the medical director, or the operational safeguards required under applicable state law, the necessary legal framework simply is not there. At that point, defending the practice becomes exponentially more difficult.

Regulatory compliance is not determined by whether a set of documents exists. It is determined by whether the structure, governance, operational practices, contractual relationships, and day-to-day conduct of the business comply with the specific laws and regulations of the applicable state. Every state approaches these issues differently, and many require far more than standardized agreement terms or generalized guidance.

Unfortunately, many healthcare practices operate under the belief that they are protected or compliant because they relied upon a supervising platform’s recommendations, only to discover during an audit that the legal analysis supporting those recommendations was either incomplete or nonexistent. The result is unnecessary regulatory exposure, significant legal expense, and avoidable disruption to the business.

This is not intended as criticism of fractional supervising platforms. On the contrary, they provide an important and increasingly necessary service within the healthcare ecosystem. The issue is one of professional boundaries.

Clinical oversight should remain the responsibility of physicians and clinical experts. Corporate structuring, CPOM analysis, governance documents, management services agreements, ownership structures, and state regulatory compliance should remain the responsibility of attorneys who focus their practices in healthcare law. When each professional stays within their respective area of expertise, the healthcare provider receives the benefit of both strong clinical oversight and a legally defensible business structure.

Healthcare regulation continues to become more sophisticated, and state agencies are devoting greater resources to examining ownership structures, management arrangements, and physician oversight. Providers deserve a compliance strategy that is built not only to help them launch their business, but also to withstand regulatory scrutiny years later. The goal should never be to simply “look compliant.” The goal should be to actually be compliant and to have the documentation, governance, and legal analysis necessary to prove it when regulators come knocking.

Georgia and Tennessee Signal the Next Phase of State Stem Cell Therapy Laws

PRP facial injection treatment

By: Victoria Perniola

Regenerative medicine adoption is moving quickly, and state legislatures are beginning to expressly support it.  Some states have focused on patient disclosures, research oversight, or access to investigational therapies. Others are beginning to create more specific frameworks for how certain stem cell or regenerative medicine therapies may be offered in clinical practice when those therapies have not been approved by the U.S. Food and Drug Administration (FDA).

Florida’s CS/CS/SB 1768, passed in 2025 and created Florida Statutes §§ 458.3245 and 459.0127, is an important reference point. These laws have established a legal pathway for certain non-FDA approved stem cell therapies in Florida, but only within a limited structure. It applies to licensed medical doctors (MDs) and osteopathic physicians (DOs), and the stem cell therapy must relate to orthopedics, wound care, or pain management.  The Florida Law is a “green light” with limits, but only as it relates to state laws.  The issues are still what they are at the federal level, grey.  

In May 2026, Georgia and Tennessee enacted new stem cell therapy legislation. Georgia HB 1275 was signed into law on May 11, 2026.  Tennessee HB 2246 was signed into law on May 19, 2026.  Georgia’s law expands on the Florida Law by allowing a physician assistant (PA) or nurse practitioner (NP) to perform qualifying human stem cell therapy following a lawful designation from a physician.  Florida needs to follow suit and likely will.  Even more bold, the Georgia Law does not expressly limit the therapy to orthopedics, wound care, or pain management. Tennessee expanded into a broader framework allowing stem cell therapy or regenerative medicine therapy within a physician’s scope of practice, presumably (but not expressly) incorporating midlevel application within the scope of their licenses and proper physician supervision that’s typical of mid level involvement.  

For regenerative medicine practices, med spas, wellness businesses, orthopedic practices, pain management clinics, product suppliers, and investors, the legal question is not simply whether a state has passed a stem cell law. The more important questions are: (1) what does the law say re who can provide the therapy and for what conditions, (2) what products qualify, (3) what procedures (e.g., informed consent) have to be followed, and (4) how does the new laws square with what else might be happening in each such state.   

To be clear, the new state laws aren’t creating anything other than an HOV lane within defined limits.  But that doesn’t mean that coloring outside those lines will expose clinicians to discipline.  Many such states are applying a variety of regen products (e.g., PRP, exosomes, Wharton’s Jelly, Cell Factors) that didn’t make their way into any state law.   Many non specified clinicians (e.g., dentists, chiropractors, podiatrists and mid level) are involved in each such state.  And many are administering these products for more conditions than what the new laws green light.   Assessing risks will require these business and clinicians to understand the laws, and also the regulatory environment.  

Florida’s SB 1768 as a Recent Reference Point

Florida’s SB 1768 is provides a recent and relevant comparison point for providers and businesses evaluating the newly enacted Georgia and Tennessee laws. The comparison shows how one state (Florida)  has structured a narrower pathway for certain non-FDA approved stem cell therapies, while Georgia and Tennessee appear to be moving toward broader frameworks in their respective states.

The Florida Law, one of the first states leading the charge, is ironically the most narrow in terms of what can be done and who can do it.   Qualifying therapies must be performed by an MD or DO licensed in Florida, and must relate only to orthopedics, wound care, or pain management. The statute also includes operational requirements tied to product sourcing, facility registration and accreditation, post-thaw viability reporting, advertising disclosures, informed consent, and physician discipline.

That structure gives Florida providers a framework to evaluate, but it also leaves out the many clinicians already active in the space as well as many therapies that are common in the regenerative medicine space. Practices focused on longevity, inflammation, recovery, aesthetics, sexual wellness, functional medicine, or broader regenerative health may not fit squarely within the narrow Florida Law.  Which is why looking at this law and the others is just a starting point for compliance.  Serious businesses in the space also have to know what’s being done at the regulatory level, not just what a law (that anyone can read) says.  

Florida gets that and has formed a Stem Cell Therapy Workgroup to study implementation issues, including how accrediting and certifying bodies should be evaluated, how the Florida Department of Health should assess additional entities with expertise in stem cell therapy, and what standards may be needed for consistent oversight.  It makes sense that the Workgroup conversation will open the door to expanding the law to meet the current treatment reality in the state.  

With that framework in mind, Georgia and Tennessee are useful comparisons because each state appears to respond to a different limitation in the Florida model. Georgia correctly addresses big miss in the Florida Law, that Florida’s current framework does not allow NPs or PAs to perform qualifying stem cell therapy.  Tennessee is also asking the right question when it addresses whether the law should extend beyond stem cell therapy into a broader regenerative medicine therapy framework.  Florida may have gotten the ball rolling, but both Georgia and Tennessee caught it and are running with it.  

Georgia’s Law Expands Who May Perform Stem Cell Therapy

The Georgia Law expressly allows an NP or PA to perform human stem cell therapy following a lawful designation from a physician.  The Georgia Law requires the therapy to be used for treatment or procedures within the scope of practice of the physician, NP, or PA, and the patient to be properly advised in writing.  In this way, the Georgia Law is more aligned with what’s actually happening in regen practices.  

Even with this broader language, practices should be careful not to treat the Georgia statute as a simple delegation pathway. The statute refers to a “lawful designation” from a physician, which means practices will need to evaluate how that designation should be documented, what level of physician involvement is required, and whether the therapy falls within the scope of practice of the NP or PA performing the service.

The statute may create room for a more flexible clinical structure, but it also raises important compliance questions. Before offering services under this framework, practices should review provider roles, written protocols, supervision or collaboration requirements, patient selection criteria, informed consent, adverse event response, and medical record documentation.  And like the Florida Law, Georgia regen practices need to understand what’s actually happening in the state and how regulators are responding (if at all).  

Georgia Is Not Limited to Orthopedics, Wound Care, or Pain Management

Georgia’s law is also different from Florida’s current framework because it does not expressly limit human stem cell therapy to orthopedic conditions, wound care, or pain management.  This is where reality meets regulation, which is rare with new regulations.  This structure gives Georgia’s law a broader practical reach than the Florida Law.  Instead of asking only whether the therapy falls within orthopedics, wound care, or pain management, the Georgia analysis turns on whether the therapy falls within the applicable provider’s scope of practice and whether the statute’s other requirements are met.

This is especially relevant for regenerative medicine businesses, nearly all of which operate well beyond orthopedics, pain management, and wound care. All of that makes the Georgia Law far more compatible with the fast growing longevity sector, where therapies are meshed together for outcomes.  

Georgia providers still need to review the product, the intended use, the claims being made, the route of administration, the patient population, the provider’s license, the supplier documentation, and the federal regulatory status of the product. Compared to Florida’s narrower law, Georgia’s law gives certain practices more flexibility.

Tennessee Broadens the Conversation to Regenerative Medicine Therapy

The Tennessee Law is important, but for a different reason. The version of the Tennessee bill as originally introduced looked more similar to Florida’s enacted framework. It focused on stem cell therapy and limited the therapy to orthopedics, wound care, and pain management.  However, that is not the version Tennessee enacted. Before passage, the bill was amended to broaden the statutory framework. As enacted, the Tennessee Law authorizes a physician to perform stem cell therapy or regenerative medicine therapy not approved by the FDA, so long as the therapy is used for a treatment or procedure within the physician’s scope of practice.  That said, the Tennessee Law does create a gap in failing to specifically include NPs and PAs, as Georgia did.  

The regenerative medicine market is not limited to one product category. Practices and suppliers may be dealing with cellular products, tissue-based products, Wharton’s jelly-related products, exosome-based products, or other biologic-adjacent offerings. Tennessee’s enacted framework appears to account for a broader product universe by creating requirements tied to product documentation, certificates of analysis, sterility reports, manufacturer information, advertising notices, informed consent, adverse event reporting, and clinical outcomes registries.

For businesses watching this space, Tennessee may be an early example of a state moving beyond traditional “stem cell therapy” language and into a broader regenerative medicine framework.

What These Laws Mean for Regenerative Medicine Practices

Many regenerative medicine businesses utilize many prescribing and treating professionals to administer many regen therapies for a whole host of matters.  And that gap needs to get filled over time at state level regulation.  We expect that to happen over time.  Even then, regen business have to continue to look at the entire regulatory enforcement landscape and differentiate between “what the law says” from what’s happening in their state.  

State Law is Only Part of the Analysis

While most of the regulatory activity is happening at the state level, businesses and clinicians still be mindful of the federal framework.  From a federal perspective, the analysis depends on the product itself and how it is being used. Providers and businesses should consider the product’s source, how it is processed, whether it is being used for a homologous purpose, whether it is autologous or allogeneic, the route of administration, and the claims being made. They should also consider whether the product fits within the 361 HCT/P framework, i.e., human cells, tissues, and cellular and tissue-based products. In general, the 361 HCT/P framework refers to certain products regulated under Section 361 of the Public Health Service Act and 21 C.F.R. Part 1271. If a product does not fit within that framework, it may be regulated as a drug or biologic requiring additional FDA authorization.  Though state based laws are flowing, the federal framework is still relevant and important.  

Final Thoughts

State regulators are driving the bus in terms of creating clearer pathways for regen.  More work need sot happen here.  And a central unifying body to hold those conversations would help big time.  That said, one this is clear:  regen is here to stay.  And no one seems to want to put that genie back int he bottle.  

Telehealth Rules for Medical Spas in Florida: Complete Compliance Guide for 2026

Telehealth has become an important tool for Florida medical spas offering virtual consultations, follow-ups, and aesthetic healthcare services. This guide explains telehealth rules for medical spas in Florida, covering compliance requirements, provider responsibilities, HIPAA standards, documentation practices, and legal considerations to help med spa businesses operate safely and successfully.

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The Regulatory Middle Ground: Navigating Non-Pharmacy Supply Chains in Clinical Practice

Pharmacist scanning medication in pharmacy

By: Caitlin A. Kopppenhaver, Attorney

The traditional landscape of clinical procurement often centers on two familiar pillars: the 503A compounding pharmacy and the 503B outsourcing facility. Because these entities are commonly associated with patient-specific compounded preparations and certain compounded sterile product models, many providers operate under the assumption that these are the only legal avenues for acquiring sterile products. However, as the wellness industry evolves toward specialized peptides and complex biologics, a significant knowledge gap has emerged regarding the roles of manufacturers, wholesale distributors, and third-party logistics providers (3PLs).

This gap becomes particularly evident when a workflow involves the receipt of lyophilized products intended for provider-controlled reconstitution and immediate administration. In these scenarios, the entity shipping the product may not be a pharmacy at all, and the workflow may still be supportable if the required regulatory elements are satisfied. The confusion often stems from a lack of familiarity with how title transfer and licensure operate outside of the pharmacy model. Unlike a pharmacy, which dispenses or compounds within a pharmacy framework, a manufacturer or distributor may sell or transfer product within a drug-supply-chain framework, and a 3PL generally facilitates the movement of that product without ever taking legal ownership.

The critical distinction for any clinical practice lies in the classification of the product being supplied and the nature of the final preparation step. When a lyophilized vial arrives from a 3PL or distributor, the responsibility for the final preparation may shift to the clinician or clinical practice, depending on the product, labeling, and ordering pathway. This process raises important questions about the boundary between compounding and reconstitution consistent with manufacturer labeling or instructions. While federal and state regulations may provide a pathway for certain non-pharmacy supply-chain models, the specific legal mechanics that allow a non-pharmacy to participate in such a workflow remain a nuance of supply-chain law that is frequently overlooked.

For practices utilizing these models, the challenge is ensuring that the administrative handling on-site does not inadvertently cross the line into unlicensed compounding. Understanding the interplay between federal distribution standards and the local practice of medicine is essential. Without a clear grasp of how a 3PL differs from a traditional pharmacy in the eyes of the law, a practice may find itself operating within a sophisticated supply chain without fully understanding the regulatory guardrails that make it possible. Identifying these structural differences is the first step in mastering the complexities of modern medical procurement.

LinkedIn Callout:

A lot of clinicians are familiar with two procurement pathways: 503A compounding pharmacies and 503B outsourcing facilities.

But those are not the only entities that may appear in a lawful medical supply chain.

Depending on the product and the structure, a clinical practice may also encounter manufacturers, wholesale distributors, private-label suppliers, and third-party logistics providers. These entities do not all serve the same legal function, and they should not be analyzed as if they are pharmacies.

This is where a lot of confusion comes up.

For example, if a product is supplied in lyophilized form and requires provider-controlled reconstitution before administration, the legal question is not simply: “Did this come from a pharmacy?”

The better questions are:

Who manufactured the product?

Is the product itself lawfully marketable for the intended use?

Who sold it?

Who took title?

Who shipped it?

How is it labeled?

Is the supplier properly licensed or registered?

What exactly is the provider doing on-site?

Is the provider reconstituting consistent with labeling/instructions, or doing something that starts to look like compounding, repackaging, dispensing, or manufacturing?

That analysis is highly fact-specific.

Some non-pharmacy supply-chain models may be supportable. Others may create significant regulatory exposure, especially where the product, labeling, title transfer, licensure, or on-site handling is not clearly understood.

The takeaway is not that every non-pharmacy model works, but rather that “not a pharmacy” does not automatically mean “not lawful”,  and it also does not automatically mean the model is safe. The legal analysis follows the actual flow of the product, not just the label placed on the supplier.

FDA’s Purolea Warning Letter: A Paradigm Shift for AI in Regulated Manufacturing

Pharmacists analyzing tablet with digital pharmacy system

 By: Caitlin A. Koppenhaver, Attorney with Florida Healthcare Law Firm and Chief Industry Advisor to APA 

Purolea Cosmetics Lab – 722591 – 04/02/2026 | FDA

When AI Makes Compliance Look Better Than It Is: FDA’s Purolea Warning Letter Is a Wake-Up Call for cGMP Operations

FDA’s April 2, 2026 warning letter to Purolea Cosmetics Lab should get the attention of every manufacturer, quality leader, and compliance consultant working in regulated production. The letter is notable not just because FDA identified serious cGMP deficiencies, but because the Agency expressly addressed the company’s use of artificial intelligence in creating specifications, procedures, and master production or control records that were supposed to support FDA compliance. FDA’s message was clear: using AI to generate compliance documents does not relieve a firm of the obligation to ensure those documents are accurate, complete, and actually compliant with cGMP requirements.

That is the part of this warning letter that deserves broader industry attention. The problem was not simply that the company used AI. The problem was that the firm appeared to treat AI-generated materials as though they were a substitute for a functioning quality system. FDA stated that if AI is used as an aid in document creation, the output must be reviewed to ensure it is accurate and actually compliant with cGMP, and FDA tied that failure to 21 CFR 211.22(c). The Agency also documented what it described as overreliance on AI during manufacturing operations.

FDA then gave the kind of example that will likely be repeated in compliance discussions for some time. According to the letter, investigators found that the firm had not conducted process validation before distributing drug products, as required under 21 CFR 211.100. When that was raised during the inspection, the company reportedly responded that it did not know validation was required because the AI agent it used had not identified that requirement. FDA did not treat that as an excuse, but rather as evidence of a deficient system.

In a cGMP environment, the standard is not whether documents look sophisticated, organized, or professionally written. The standard is whether the firm’s methods, controls, procedures, and oversight actually operate in a way that satisfies Parts 210 and 211. In the same warning letter, FDA cited the company for failing to perform appropriate microbiological testing on finished product batches, failing to adequately test components for identity and conformity with specifications, failing to validate the reliability of supplier test analyses at appropriate intervals, and failing to ensure adequate quality unit oversight over manufacturing operations. The AI discussion appeared in the middle of those larger operational oversights, which is exactly the point: polished language cannot compensate for missing controls.

This is where some companies get into trouble. They assume that a set of procedures, batch templates, specifications, and quality forms that read well must also be compliant. But cGMP compliance is not a document aesthetics exercise. It is an operational discipline. A procedure is not protective just because it sounds credible. It has to reflect the actual process, assign responsibility correctly, require the right controls, and be followed in practice. A master record is not meaningful if it was copied, generated, or assembled without site-specific review. A quality system is not real if the quality unit is not exercising actual oversight over release, investigations, deviations, supplier qualification, validation, and change control. FDA’s own Quality Systems Approach guidance makes the same point in broader form: quality systems and risk management approaches can help manufacturers meet cGMP requirements, but they do not replace the underlying requirements in Parts 210 and 211.

The warning letter also reinforces why working with experienced compliance partners is so vital. FDA recommended that, before the firm pursues resolution of its compliance status, it should engage a qualified consultant under 21 CFR 211.34 to assist with meeting cGMP requirements, perform a comprehensive six-system audit, and evaluate the completion and effectiveness of corrective and preventive actions. That recommendation is important because it reflects FDA’s expectation that remediation must be substantive, not cosmetic. The right compliance partner is not there to hand over documents that sound sophisticated. The right partner helps ensure the procedures are legally and operationally sound, mapped to the actual manufacturing process, integrated into the firm’s quality system, and capable of standing up during inspection.

That is especially important now, when AI tools are becoming easier to use and easier to overtrust. AI can help organize information, accelerate drafting, and support internal workflows. But in a regulated manufacturing environment, those benefits only matter if they are paired with competent human review, independent quality unit oversight, and site-specific implementation. Otherwise, the technology can create a dangerous illusion of compliance: documents that look complete, systems that appear mature, and records that seem polished, while the underlying controls are incomplete, misunderstood, or absent. FDA’s Purolea letter is a reminder that the Agency inspects how a system functions, not how well it reads.

The real lesson here is simple. Compliance has to be operative. It has to live in the training, the batch review process, the validation program, the raw material controls, the microbiological safeguards, the quality unit’s decisions, and the data that support release. If AI is used anywhere in that process, it must remain a tool, not the decision-maker. And if outside consultants are involved, their role should be to help build a system that works in practice, not just one that looks impressive in a binder.

The same point extends beyond cGMP and beyond AI. Across healthcare compliance more broadly, a policy, consent form, SOP, training module, audit framework, or marketing review process is not protective simply because it sounds polished, sophisticated, or legally informed. In regulated settings, the real question is whether the measure is accurate, operationalized and aligned with the actual legal and regulatory requirements that apply to the business. FDA’s criticism in the Purolea letter reinforces that appearance is not the standard, operational compliance is.

Healthcare M&A Trends in 2026: A Shift in Focus Toward Dermatology

rejuvenating facial treatment

By: Carlos Arce

As we move through the first quarter of 2026, the healthcare acquisition landscape is showing a clear divergence across specialties. While deal activity remains active overall, not all sectors are participating equally. In fact, we are seeing a notable pause in certain areas—alongside strong momentum in others.

Headwinds in Primary Care and Pediatrics

Primary care and pediatric practices are currently facing increased scrutiny from both buyers and lenders. The primary driver behind this hesitation is reimbursement uncertainty.

Ongoing payer cuts and evolving reimbursement methodologies—particularly those tied to government programs—have introduced a level of unpredictability that investors are not comfortable underwriting at this time. In Florida specifically, the Agency for Healthcare Administration (AHCA) is still working through payment-related issues, further contributing to market hesitation.

As a result:

  • Valuation multiples in these sectors have softened 
  • Many deals are being delayed or paused entirely 
  • Buyers are taking a “wait-and-see” approach until reimbursement stabilizes 

This doesn’t mean these businesses lack long-term value—but in the current environment, uncertainty is suppressing transaction activity.

Dermatology Emerges as a Standout Performer

On the other end of the spectrum, dermatology has become one of the most attractive sectors in healthcare M&A.

We are seeing strong demand from private equity-backed groups actively pursuing acquisitions in:

  • Traditional insurance-based dermatology practices 
  • Hybrid models that include med spa or aesthetic components 

What makes dermatology particularly compelling right now:

  • Favorable reimbursement dynamics compared to primary care 
  • Strong cash-pay components (especially in aesthetic services) 
  • High margins and scalable service lines 
  • Operational flexibility across different business models 

Interestingly, size is not the primary driver of value in this space at the moment. Both small and mid-sized practices are commanding strong interest and, in many cases, higher valuation multiples than we’ve seen historically.

Why Some Practices Command Premium Valuations

Across all specialties—but especially in dermatology—there is a consistent theme among practices achieving the best outcomes in a sale:

Preparation and operational discipline matter.

Buyers are paying a premium for businesses that demonstrate:

  • A strong culture of compliance 
  • Clean, well-organized financials 
  • Accurate and defensible profit and loss statements 
  • Consistent and transparent tax reporting 

When these elements are in place, the transaction process becomes significantly smoother. More importantly, it reduces perceived risk for buyers—which directly translates into higher and more achievable purchase prices.

Deal Structures: Roll-Ups vs. Strategic Acquisitions

We are also seeing a mix of transaction structures in today’s market:

  1. Roll-Up Strategies: Private equity-backed platforms are continuing to aggregate practices, particularly in dermatology. These models focus on integration, operational efficiency, and scaling regional or national footprints. 
  2. Outright Acquisitions: Strategic buyers and larger platforms are also executing full buyouts, especially when targeting high-performing or well-positioned practices. 

Each structure comes with different implications for physicians—particularly around autonomy, equity rollover, and long-term upside—making deal structuring just as important as valuation.

Looking Ahead

The current M&A environment in healthcare is not slowing—it’s shifting.

  • Sectors tied heavily to reimbursement uncertainty are experiencing temporary slowdowns 
  • Specialties with diversified revenue streams and strong margins are accelerating 

For practice owners, this creates both a cautionary signal and an opportunity:

  • Timing matters more than ever 
  • Positioning your business correctly can significantly impact valuation 
  • Being prepared operationally is no longer optional—it’s essential 

As 2026 unfolds, we expect continued momentum in dermatology and similar specialties, while reimbursement clarity will be the key factor in unlocking stalled segments like primary care and pediatrics.

Not Anti-Regulation, Just Better Regulation: Florida MedSpa Bill (HB 1429) Dies in Committee

MedSpa staff reviewing medical form

By: Caitlin A. Koppenhaver

Florida’s effort to create a new licensure framework for medical spas has come to an end for the 2026 legislative session. HB 1429, which would have established a new Board of Pharmacy-driven oversight structure for certain medical spa operations, last saw action on March 13, 2026, when it died in the House Health Professions & Programs Subcommittee.

That is a welcome result, and not because the medical spa and wellness space should exist without oversight.

Our earlier article explained that HB 1429 would have created the Medical Spa Prescription Drug Oversight Act, placing a broad range of medspa activities into a new Board of Pharmacy-centered licensing structure. As written, the bill was not limited to one narrow practice model or one isolated concern. It was expansive enough to touch businesses involved in weight-loss services, hormone therapy, longevity care, botulinum toxin treatments, IV therapies, and other wellness services involving prescription products.

The concern was never whether Florida should promote patient safety and accountability in this area. Those goals are important, and they are shared across the healthcare industry. Medical spas, pharmacies, and other healthcare participants operate in a setting that involves prescribing, supervision, drug handling, advertising, documentation, and professional responsibility. Meaningful regulation has an important role in supporting those objectives.

The more difficult question was whether this particular bill was the right fit for the industry as it exists today.

Florida already has an established regulatory framework in this space. Physicians, physician assistants, nurse practitioners, pharmacists, pharmacies, and other licensed professionals are already governed by licensure laws, scope-of-practice rules, prescribing requirements, delegation standards, and disciplinary oversight. Consumer protection laws also remain in play. In addition to those standards, HB 1429 would have added another layer, this time at the facility level, under a pharmacy-oriented model that may have been appropriate for some circumstances, but not necessarily for the full range of businesses that could have been swept in.

That is why the bill’s failure should not be read as opposition to regulation. It is better understood as recognition that regulation is most effective when it is closely tailored to the specific concerns it is intended to address.

If there are particular concerns about unsafe prescribing, insufficient supervision, improper storage or handling of drugs, misleading marketing, or poor documentation, those issues can and should be addressed directly. But a bill that casts a very wide net across an already regulated and highly varied industry can create burden without enough precision. When that happens, the law can begin to function less like a targeted public-safety measure and more like a broad structural framework.

That concern was especially pronounced here because Florida already has tools to investigate and respond to misconduct. Businesses that cut corners, misstate services, prescribe inappropriately, or otherwise fall short of legal requirements are not operating in a vacuum. Existing law already gives regulators multiple avenues to review and discipline that conduct.

It is important to keep in mind that none of this means the industry gets a pass. Medspas and wellness businesses in Florida still need to pay close attention to how they are structured, how services are provided, who is prescribing, who is administering, how products are sourced and handled, what their marketing says, and how records are maintained. Those obligations did not disappear because HB 1429 died.

Still, the bill’s failure leaves Florida in a better position than a hurried or overinclusive licensing scheme would have. It preserves room for a more thoughtful legislative approach in the future, one that is narrower, more deliberate, and better matched to the specific risks lawmakers may want to address.

That is why this outcome should be viewed positively. Not because oversight is unnecessary, but because broad new regulation is not always the best form of regulation, particularly where a substantial body of existing law is already in place.

Florida RN Renewal Guide (2026): Requirements, Deadlines, CE Credits, and Common Mistakes

Florida RN license

Renewing your Florida RN license can be simple and stress-free. This complete guide helps registered nurses understand Florida RN renewal requirements, CE hours, deadlines, fees, and the online renewal process—so you can stay compliant, confident, and focused on your nursing career with total peace of mind.

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Attorney Jeff Cohen: Leading Legal Advocate for Justice & Results

Attorney Jeff Cohen

Discover the remarkable career of Attorney Jeff Cohen, a trusted Florida legal expert known for his success in personal injury, civil litigation, and business disputes. With a client-first approach and a commitment to justice, Cohen’s work not only achieves results but also sets a standard of excellence in the legal profession.

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