Med spa marketing in Texas: the delegation, laser and advertising rules that shape your ads, and a 90-day plan to book more consults

By Benjamin Chua·Published October 19, 2026·31 min read

A Texas med spa works like a highway interchange. Your clinic is the main road. Google, Meta, referrals and your content are the feeder ramps. When the ramps are signed clearly and the lights are timed, traffic merges into your lane without thinking about it. When a ramp is closed or the signage is confusing, cars go past you and take the next exit. Nobody blames the highway. They just never arrive. Broken booking links, slow callbacks and ads that say nothing specific are closed ramps.

In Texas the signage on those ramps is partly written for you. The Texas Medical Board rewrote its delegation rules for cosmetic procedures in January 2025, and some of that rewrite is literally about signs: what gets posted on the wall, what goes on a name tag, what a physician must disclose when they delegate at a location that isn't their main practice. That is marketing material whether you planned it or not. This guide covers what is different about marketing a med spa in Texas, with the rule text quoted, then a 90-day plan to book more consults that fits inside those rules. For the federal layer on claims, HIPAA, FTC endorsements and Meta policy, read the med spa marketing compliance guide alongside this one. Owners in California and Florida have their own guides, and the rules are nothing alike.

What is different about marketing a med spa in Texas?

Five things. Two of them are gaps rather than rules, and the gaps matter as much as the rules do. The table gives the short version. The sections after it go into the three that change your ads the most.

1. Nobody registers a med spa in Texas, and nobody tells you who can own one

The Texas Medical Board's own FAQ answers the registration question in one line: "There is currently no registration for Med Spa clinics in Texas." That surprises owners moving from states with a clinic licence. It also means there is no licence number for a patient to check, which makes the people in your clinic the proof. The FAQ adds that nonsurgical procedures "are required to be delegated by a licensed physician", and that is where the real rules live.

Ownership is the gap. The Attorney General's opinion JC-0304 states that "The corporate practice of medicine is prohibited under the Occupations Code" and points to section 164.052(17), under which a physician is "prohibited from aiding or abetting the practice of medicine by a person, partnership, association, or corporation not licensed to practice medicine by the Board." That opinion is from 2000 and was about nonprofit health organisations. We found no Texas Medical Board page, statute or rule that says who may own a med spa or how a management services organisation must be structured. The delegation rules in 22 TAC 169.25 to 169.28 say nothing about ownership either. So we take no position. If a non-physician owns or part-owns your clinic, or an MSO sits between the business and the physician, get a Texas health lawyer to sign off on the structure and on how you describe it. Then describe it the same way on your website, your Google Business Profile and in your bios. A nonprofit health organisation certificate exists under Occupations Code 162.001(b); the fee and renewal details we saw came from a search snippet only, so confirm them with the Texas Medical Board.

2. Every injectable is a delegated medical act, and the delegation rules changed in January 2025

22 TAC 169.25 to 169.28, effective 9 January 2025, replaced the Board's older delegation rule for cosmetic procedures. We read the new text on Cornell LII, which cites the Texas Register adoption of 10 January 2025; the repeal of the old rule (22 TAC 193.17) we saw only in vendor and insurer summaries, so treat the repeal itself as a point to confirm with the Board. The new rules cover "the injection of medication or substances for cosmetic purposes" and "the use of a prescription medical device for cosmetic purposes", and treat both as the practice of medicine that "can be properly delegated and supervised".

Four requirements in 169.26 and 169.27 shape how you market, per the rule text as published; confirm the current version on the Texas Medical Board site:

• The delegating physician must ensure the injector "has appropriate training" in the technique, contraindications and complications, and "signs and dates a written protocol." Under 169.27 the physician delegates only after having "reviewed and approved in writing the business' or facility's existing written order" or having "developed their own written orders", including "selection criteria for screening patients" and "procedures for common complications, serious injuries, or emergencies". Your consult is where that screening happens, so sell the consult as the safety step it is.
• Before the act, a physician, PA or APRN must "establish a practitioner-patient relationship" and "disclose the identity and title of the individual who will perform the delegated act". Put the provider's name and title in the booking confirmation and in your meet-the-injector video. You are required to disclose it anyway; doing it early builds trust.
• The physician must "ensure at least one person trained in basic life support is present while the patient is onsite", and a physician, PA or APRN must "be onsite during the procedure; or be immediately available for emergency consultation". An ad headline like "Medically supervised treatments" is only honest if this is how your clinic runs.
• Under Occupations Code 157.001, "The delegating physician remains responsible for the medical acts of the person performing the delegated medical acts." The physician's name belongs on your about page, not buried in a footer.

Who can hold the syringe is a Board of Nursing question as much as a Medical Board one. The Board of Nursing's 2025 position statement synopsis says delegated medical acts need "documentation of individual training and competency, procedures to be performed, physician order to initiate, and appropriate medical and nursing back up", and that "what is delegation to an APRN by a physician cannot be delegated by the APRN to others." For RNs and LVNs doing laser work, the nurse "must have the appropriate education, knowledge, and experience to engage in laser therapy". The Board's APRN FAQ page would not load for us, so confirm the current APRN position with the Texas Board of Nursing. TDLR's own summary sheet adds the esthetician line: a cosmetology licence does not authorise using "hypodermic needles to inject botulinum toxin (for example, Botox) or other substances, even for cosmetic procedures", and "A physician cannot delegate cosmetology or barbering procedures." If an ad or bio implies an esthetician injects, it is wrong on two counts.

3. The signage rule is a marketing rule

22 TAC 169.28 is the section most owners have never read, and it is the one that touches your brand most directly. Any individual, business or facility providing delegated cosmetic acts "must post the following in each public area and treatment room": the Board's complaint notice and "the name(s) of the delegating physician(s) including their Texas medical license number." Each person performing a delegated act "must be readily identified by a name tag or similar means that clearly delineates the identity and credentials of the person."

22 TAC 164.3(b)(8) connects to this. It is deemed misleading to fail "to disclose medical directorship, supervision of, or delegation to non-physicians at a location that is not the physician's primary practice location and where care is delivered pursuant to standing orders and protocols." Most med spas are exactly that: a location that isn't the physician's main practice, run on protocols. Our reading as marketers is that the disclosure belongs on the website and in ads, not just on the wall. Ask counsel to confirm the wording.

4. Laser hair removal is TDLR territory, with a physician contract attached

Texas splits lasers across two agencies. TDLR licenses the people and facilities doing laser hair removal. DSHS registers the lasers themselves. TDLR's "Laser Hair Removal at a Glance" sheet says "Anyone in Texas practicing laser hair removal (LHR) ... must be licensed." The technician path is a 40-hour course, an apprentice stage and then 100 supervised procedures within 12 months. The facility needs "a written contract with a consulting physician" that meets Health and Safety Code 401.519, plus a backup physician, and "An Advanced Nurse Practitioner may not serve in the capacity of the consulting or designated physicians." The statute itself says "A laser hair removal facility must have a written contract with a consulting physician to" set protocols and audit operations. The research summary we worked from notes a 75-mile limit on how far away that consulting physician can be; confirm the current distance rule with TDLR before you print it. One exemption worth knowing: TDLR does not regulate laser hair removal in "a facility owned or operated by a physician for the practice of medicine."

On the device side, 25 TAC 289.301 (effective 17 December 2024) says "A person must not use a Class 3B or Class 4 laser or perform laser services except as authorized in a certificate of registration issued by the Texas Department of State Health Services". IPL devices "are not required to be registered" but must follow the rest of the rule, and lasers and IPL "must not be used on humans or animals unless under the supervision of a licensed practitioner of the healing arts". For your marketing: a laser service page should name the TDLR facility licence and the consulting physician, use the exact title on the technician's certificate, and go live after the DSHS certificate is issued, not before.

5. Texas advertising rules: consent, archive, testimonials and the word "board"

22 TAC Chapter 164 is the Texas Medical Board's advertising rule, also carrying a 9 January 2025 effective date. Three mechanics first. Under 164.2, "Patients must consent prior to any use of photographs or other representations in any advertising by a physician, practice, or entity." The physician is "deemed to have reviewed and approved any and all advertisements", and a copy must be kept "for a period of two years". So: signed consent before any before-and-after is posted (the before-and-after photo rules guide has the consent workflow), a folder where every ad, post and landing page is saved with its run dates for two years, and a physician who actually sees the ads before they go live.

164.3 then lists what the Board deems false, deceptive or misleading. The ones that bite med spas: using "board eligible," "board qualified," or any similar language "calculated to convey the same meaning as 'board certified'"; "providing a testimonial without: (A) a disclaimer or warning as to the credentials of the person making the testimonial; and (B) a disclosure of compensation"; "failing to explicitly identify individuals as models or actors instead of actual patients"; and "claiming a unique or exclusive skill without substantiation and basis for such claim". We did not find a Texas rule text that defines "board certified" beyond that line, so confirm with the Texas Medical Board before any bio uses the phrase, and match it to the actual certifying board.

101.201 also bans advertising that "makes a representation likely to create an unjustified expectation about the results of a health care service or procedure" and advertising that "causes confusion or misunderstanding as to the credentials, education, or licensing of a health care professional". In plain terms: no promised outcomes, no "permanent", no "painless", and no "nurse injector" on a bio when the person is a medical assistant. Pending legislation we saw mentioned in press releases (SB 378, SB 2696) was never confirmed on an official page, so we do not describe it here; check the Texas Medical Board's rules page for anything newer than January 2025.

What this means for your consult offer

Texas gives you a physician who must be named, injectors who must be identified, and a consult that doubles as the screening step the written protocol requires. Build the offer around those three. One front door, one promise, no price in the headline. ACQ's working version:

“Book a 15-minute Aesthetic Consult in [City].”

Every channel points at one scheduler page. Not a DM, not a contact form, not a phone number on one ad and a booking link on another. One page, one tracking source. The page names the delegating physician and licence number, names the provider the patient will meet with their actual title, and says what happens in the 15 minutes: a conversation about what they want to change, a screening against the protocol, and a written plan. If you treat the same day when appropriate, say so. If you take a deposit, the no-show fix guide covers how to word it.

The playbook logic behind this is the value equation (Hormozi, $100M Offers, p. 59 and p. 61; $100M Leads, p. 59): make the dream outcome clear (a plan from a named, supervised team), stack proof (the physician, the posted licence, reviews on your profile), shorten the delay (consult within 48 hours) and cut the effort (15 minutes, online booking). Texas hands you the proof part for free.

The 90-day Texas consult plan

Start with the maths so the plan has a number to hit. These are ACQ's working assumptions for a single location in a big Texas metro. Swap in your own figures; the formula holds.

1. 1

   Days 1 to 30: compliance memo, front door, profile, search ads

   Counsel approves a one-page marketing constraints memo built from the rules above. Scheduler page live with the physician's name and licence number, provider names and titles, and the deposit policy. Google Business Profile rebuilt (name, categories, 20 photos, weekly cadence). Google Search campaign on with exact and phrase match. Follow-up scripts printed and the desk phone set up.

2. 2

   Days 31 to 60: Meta, content, measurement

   Meta lead campaign on at the low end of the budget, with one provider-to-camera video and two images. First city treatment page and two short posts published. Weekly scorecard reviewed every Monday: leads by source, schedule rate, show rate, close rate, cost per shown consult.

3. 3

   Days 61 to 90: reactivation, partners, scale what works

   First five-day reactivation offer to past patients. First partner event booked. Budget moved toward whichever channel produces shown consults at the lowest cost. Second city page live. Photo and testimonial consent workflow audited against 22 TAC 164.

Google Business Profile: the cadence that compounds

Name the profile "[Brand] Med Spa, [City]" if it matches your legal name and your counsel is comfortable with "med spa" given your structure; we found no Texas rule restricting the words themselves, but we also found no rule blessing them, so this is one for the memo. Primary category "Medical spa", secondary "Skin care clinic" and "Laser hair removal service" where true. Service area covering your metro and the suburbs within roughly 20 to 30 minutes' drive (working rule). At least 20 photos to start: front, lobby, rooms, staff headshots with name tags, non-identifiable treatment scenes, and the posted physician notice. Add four or more a month. The Google Business Profile guide covers the setup in detail.

“Hi [First Name], this is [Name] from [Clinic] in [City]. Thanks again for coming in today. If you're comfortable sharing about your experience, would you leave a quick review here? It helps other people find us: [short review link]. Thank you. Reply STOP to opt out.”

Two HIPAA notes on reviews. Never reply to a public review in a way that confirms the person was a patient or what they had done, even when they said it themselves. "Thank you for the kind words, we'd love to see you again" is as far as a public reply goes. And whether you may republish a review as an ad is the testimonial question above, so keep reviews on the profile until counsel has answered it.

Google Search ads: buy the intent

Working rule: $50 to $100 a day for a single location, so $1,500 to $3,000 a month, aiming for 3 to 7 consult leads a week inside the first 30 days. One campaign, "Consult, [City], Core", with three ad groups: brand-name wrinkle relaxer searches near you (people type the brand, your ad copy does not need to), "[City] med spa", and "[City] lip filler". Exact and phrase match only to start. Negatives from day one: jobs, school, training, Groupon, cheap. The Google Ads guide has the full build. ACQ's copy template, with our compliance edits:

“Headline 1: Aesthetic Consult in [City]. Headline 2: Physician-Delegated Treatments (only if that is how your clinic runs under 22 TAC 169). Description: Talk with our licensed team about non-surgical options for your goals. 15-minute consult in [Neighborhood]. Appointments often available within 48 hours. Call or book online.”

We removed "safe" from ACQ's description because a blanket safety claim is the kind of representation 101.201 treats as not readily verifiable. No drug brand names in the copy, no prices, no results language. Google's own healthcare policies sit on top of all of this and change often, so confirm what your account allows before launch.

Meta ads: the provider on camera

Working rule: $30 to $70 a day ($900 to $2,100 a month), expecting lower intent than search and aiming for 10 to 20 consult leads a month. Objective: leads with a native form, or messages. Audience: adults 25 to 60 within a 5 to 10 mile radius of the clinic (we dropped ACQ's gender targeting; keep the audience broad and let the creative do the selecting). Creative: two or three images plus one short video of the provider talking to camera, name tag visible. ACQ's primary text, adjusted:

“Thinking about refreshing your look before [local event or holiday]? At [Clinic] in [City], our physician-delegated team walks you through your options in a short consult, with no pressure to treat the same day. Tap Learn More to see times this week. Headline: 15-Minute Aesthetic Consult in [City].”

Lead form: first name, best mobile number, email, and one short-text question, "What would you like to improve most?". Nothing that asks for health history inside a Meta form. If your ads are getting rejected or going nowhere, the Meta ads troubleshooting guide and the piece on advertising neuromodulators on Instagram and Facebook cover the platform side.

Follow-up and show rate: where the money is

You only get paid on consults people show up for. ACQ frames this with the four pillars of the Lead Nurture playbook: availability, speed to contact, personalisation and volume (Acquisition.com Lead Nurture playbook, p. 10 and p. 11). Working rules: call or text new leads within 60 seconds during business hours, and within 15 minutes after hours using an on-call rotation. The setter script, verbatim from ACQ:

“Hi [First Name], this is [Name] with [Clinic] in [City]. You just requested more info about [their main concern]. I've got a couple quick questions so we can match you with the right provider and time. One, what's the main thing you'd like to improve? Two, have you had any treatments for this before? Based on that, I'd recommend a [in-person or virtual] consult with [Provider Title]. We have [two time options within 48 hours]. Which works better for you?”

Never end the call without a next appointment on the calendar. ACQ calls it BAMFAM, book a meeting from a meeting (Lead Nurture playbook, p. 46). Note that the script names the provider title. In Texas that lines up with the 169.26 duty to disclose the identity and title of the person performing the delegated act, so the setter is doing compliance work and sales work in the same sentence. Then the reminder cadence, adapted from the same page: automated SMS and email at 24 hours, automated SMS at 3 hours, a manual text from a real staff line the night before, and a manual "We're ready when you are" text 60 minutes out.

“Hi [First Name], it's [Name] from [Clinic]. Quick reminder of your [time] consult today at [address or video link]. If anything changes, please reply so we can help you reschedule. Reply STOP to opt out.”

Content that ranks in your city

Working rule: one long guide and two or three shorter posts a month. ACQ's priority is city-specific treatment pages, "[City] wrinkle relaxer", "[City] lip filler", "[City] laser hair removal", each covering who is a good candidate without off-label claims, what to expect, time to results and a clear consult call to action. Then authority guides: "How to choose a med spa in [City], Texas" and "What to ask at your first injectable consult in [City]". Every page links back to the consult page. This is Hormozi's puddles, ponds, lakes and oceans idea: write for Dallas, not for the internet, and win the puddle first ($100M Leads, p. 96). The med spa SEO guide goes deeper on the page structure. For the video side, a one-day content shoot with the physician and injectors on camera, name tags on, gives you a year of clips, and our free 12-month content plan at /free-plan maps what to post when.

Reactivation, Fast Cash style

Once a quarter (working rule), run a short offer to past patients and warm leads using the Fast Cash structure: warm list, limited spots, high touch, clear deadline (Acquisition.com Fast Cash playbook, p. 7 and p. 21). ACQ's example: a consult plus a written skin plan plus one small, low-risk in-office treatment, 10 to 20 spots, five-day deadline. Keep the language aesthetic and educational, no disease words, no off-label promises, and no price in the ad itself if your counsel prefers it on the booking page. The patient reactivation guide has the full sequence.

“Hi [First Name], it's [Name] at [Clinic]. This week only we opened a few slots for a Skin Reset Consult in [City]: short consult, written plan, and [treatment] bundled together. Limited spots. Want details? Reply STOP to opt out.”

Referral partners without the kickback

Salons, barbers, bridal planners, Pilates and yoga studios, cosmetic dentists. You want introductions, not paid referrals. Any payment or thing of value tied to a referred patient can raise Texas and federal anti-kickback, fee-splitting and patient-brokering questions, so no cash or service credit per patient, and no percentage arrangements, until a healthcare lawyer has reviewed the specific deal. The safe version is a quarterly "Skin and Aesthetics Night" at the clinic: partners invite their lists, you educate, give a tour (posted notice and name tags in view) and book consults on the spot. Shared event costs are a counsel question too. The influencer marketing guide covers the paid-creator version of the same problem.

How does the plan change across Houston, Dallas-Fort Worth, Austin and San Antonio?

The machine is the same in every metro. The hooks are not. Everything below is observation from working in and around these markets, not data, and your own numbers should overrule it within a quarter.

• Houston. Heat and humidity for most of the year make pigmentation, melasma and oil-control angles land, and summer is when people start thinking about it. The patient base skews toward energy and medical professionals who book around work. Inside the Loop the competition is dense, so neighbourhood positioning ("your River Oaks med spa", "your Memorial med spa") beats a generic Houston pitch.
• Dallas-Fort Worth. A heavier corporate and professional crowd, so weekday lunchtime and after-work consult slots convert. We see strong interest in injectables, body contouring and a polished look. Clinics cluster in the suburban hubs (Plano, Frisco, Southlake), and pages built for one suburb outperform anything labelled "DFW".
• Austin. Tech and creative professionals with a clear preference for natural, subtle outcomes and wellness-adjacent services. Google and Instagram are crowded, and long-form educational content, the kind that explains the protocol and names the physician, does more work here than anywhere else in the state.
• San Antonio. A large military and family population that is price-aware but loyal once they trust you. Packages and memberships with plain value framing work (see the membership guide). Spanish-language content and bilingual staff are a real differentiator, and your posted physician notice and provider titles should appear in both languages on your site.

Five expensive mistakes we see Texas owners make

1. 1Running generic "anywhere" marketing in Texas. The cost is wasted spend and legal exposure. The fix is the constraints memo: have counsel approve one page built from the rules above, and build every ad and script against it.
2. 2No single front door. Leads scattered across DMs, calls and forms, and no idea which source produces shown consults. One scheduler, one link in bio, one phone number, and a source-to-consult-to-treatment record for every lead.
3. 3Slow or timid follow-up. Most lost leads never scheduled. Install the 60-second working rule, a daily contact dashboard and a scripted setter role that owns schedule and show rates (Lead Nurture playbook, p. 10 and p. 46).
4. 4Treating Instagram as the main thing. Pretty grid, few consults. Instagram is a traffic source. Every post either points at the consult or supports a proof page that does. The reels to booked consults guide shows the hand-off.
5. 5Sloppy photos and testimonials. Regulatory complaints and lost trust. Standardise written consent per 22 TAC 164.2, pre-approve the disclaimer language, label any model or actor, and put a physician review step before any image or story goes live.

What the playbooks say

ACQ maps this plan onto six Hormozi and Acquisition.com ideas. The value equation ($100M Offers, p. 59 and p. 61; $100M Leads, p. 59) explains why a short, named, physician-supervised consult inside 48 hours is an easy yes. Puddles, ponds, lakes and oceans ($100M Leads, p. 96) is why the content is written for one city. The Marketing Machine playbook (p. 9 and p. 28) is the argument for a checklist you run weekly instead of promos you invent monthly. Lead Nurture (p. 10, p. 11 and p. 46) is the follow-up and reminder system. Fast Cash (p. 7 and p. 21) is the quarterly reactivation. Lifetime Value (p. 16) is why you keep emailing past patients between offers. None of these change in Texas. What Texas adds is a set of disclosures that, used well, become proof.

Where this comes from

• Texas Medical Board FAQ 313 ("How do I register as a Med Spa?") and FAQ 312 (licence and training for med spa services), tmb.texas.gov, read via summariser 18 October 2026.
• Texas Attorney General Opinion JC-0304 (10 November 2000), PDF read 18 October 2026. Texas Occupations Code 155.001, 157.001 and 101.201, read on texas.public.law (mirror, verified May 2025) 18 October 2026.
• 22 TAC 169.25, 169.26, 169.27 and 169.28 (Texas Medical Board delegation of nonsurgical cosmetic procedures, effective 9 January 2025) and 22 TAC 164.1, 164.2 and 164.3 (physician advertising, effective 9 January 2025), read on Cornell LII (mirror of the Texas Administrative Code, citing Texas Register Vol. 50 No. 2) 18 October 2026. Quoted per the rule text as published; confirm the current version on the Texas Medical Board site.
• Texas Board of Nursing Position Statement Summary 2025 (PDF), items 15.9 and 15.11, read 18 October 2026. The Board's APRN FAQ page did not load.
• TDLR "Medspas at a Glance" and "Laser Hair Removal at a Glance" (PDFs, revised 2025 to 2026), read 18 October 2026. Texas Health and Safety Code 401.519, read on texas.public.law 18 October 2026. The 75-mile consulting physician distance comes from our research summary, not a quoted line; confirm with TDLR.
• 25 TAC 289.301 (DSHS laser and IPL registration, effective 17 December 2024) PDF and the DSHS laser registration landing page, read 18 October 2026.
• Not stated as rules because we saw them only in search snippets or secondary sources: the nonprofit health organisation fee and renewal cycle, the repeal of 22 TAC 193.17, the Board of Nursing APRN FAQ, and the status of SB 378 and SB 2696. Confirm each with the Texas Medical Board, TDLR or the Board of Nursing.
• Hormozi and Acquisition.com references as cited inline via the ACQ AI advisor: $100M Offers p. 59 and p. 61, $100M Leads p. 59 and p. 96, and the Lead Nurture (p. 10, 11, 46), Marketing Machine (p. 9, 28), Fast Cash (p. 7, 21) and Lifetime Value (p. 16) playbooks.
• Working rules, not benchmarks: the $30,000 goal, $1,000 package, 60% close, 75% show, 60% schedule and 112 leads in the formula; $50 to $100 and $30 to $70 daily budgets; 3 to 7 and 10 to 20 lead targets; 20 photos and 4 a month; 3 review asks a week; the 60-second and 15-minute response rules; the 24-hour, 3-hour, night-before and 60-minute reminders; one guide and two or three posts a month; 10 to 20 reactivation spots; 8 to 15% of target revenue in the FAQ; 5 to 10 consult slots a day.
• Everything about what the Texas rules mean for your marketing is our reading as marketers, not legal advice. The metro section is observation, not data.

Questions owners ask

Written by Benjamin Chua

Founder of Trueframe and Med Spa Launch. Nine years building video systems for founders and clinics, including a Melbourne plastic surgeon whose account went from 12,043 to 36,236 followers in ten weeks.