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Do you need a medical director if you’re autonomous?

Autonomous practice for advanced practice registered nurses (“NP”) was a monumental change in law in 2021. Since then, NPs that qualify for autonomous practice have jumped at the opportunity to expand their offerings and create opportunities for themselves through a self-owned clinic, including Medspas and IV clinics. But where is the line for when an NP needs a medical director, or supervising physician, and when they don’t?


Florida’s autonomous practice law allows qualified nurse practitioners (2 years or 3000 hours supervised practice) to practice only in primary care practice, including family medicine, general pediatrics, and general internal medicine. The Florida Board of Nursing last updated its definition of “primary care practice” in February 2021 to include: “physical and mental health promotion, assessment, evaluation, disease prevention, health maintenance, counseling, patient education, diagnosis and treatment of acute and chronic illnesses, inclusive of behavioral and mental health conditions.” This would allow autonomous NPs to provide wellness services without supervision but not aesthetic services.

In Florida, when a physician supervises an NP that is at a location other than the physicians primary practice location and the NP is performing primarily dermatologic or aesthetic skin care services, the physician must be board certified dermatologist or plastic surgeon, within 25 miles of the physician’s primary practice location. The physician is limited to supervision of only one additional office location. If you are not primarily offering these services, then the specialty is not addressed under Florida law.  

The requirement of having a medical director, or supervising physician, is primarily dependent upon the services that you provide.