There is a line item on many med spa budgets that reads like a bargain: a medical director who lends a name, signs the necessary paperwork, collects a modest monthly fee, and is otherwise never seen. It's the cheapest compliance you'll ever buy. It is also, if a regulator or a plaintiff's attorney ever looks closely, potentially the most expensive — because the title was never the point. The duty was, and a director who performs the title without the duty is a liability with a signature attached.
The gap between medical director on paper and medical director in practice is exactly the gap regulators in several states have started closing, and owners who built on the paper version are the ones exposed.