Draw & Injection Authority
A physician sets who may draw blood, process PRP/PRF and inject it, and under what supervision.
PRP and PRF pathways combined with compounded topical and oral therapy are medical treatment with a long follow-up tail. A director sets the protocol, the response checkpoints, and who is allowed to draw blood and inject.
Each of these is a decision your director owns, in writing, before it happens in your clinic.
A physician sets who may draw blood, process PRP/PRF and inject it, and under what supervision.
Topical, oral and peptide adjuncts approved together, not layered on ad hoc by whoever is on shift.
Documented review at four and eight months, with stop rules for non-responders built in up front.
Consistent baseline and follow-up imaging your director can actually compare, not whatever the last provider happened to capture.
A hair restoration program runs over months, not one visit — baseline photography, response checkpoints and maintenance scheduling all need to be built in before you start drawing blood.
Standing orders for PRP/PRF collection, processing and injection
Combination-therapy protocols — topical, oral and peptide adjuncts such as GHK-Cu
Baseline photography standards and consistent documentation angles
Response checkpoints at four and eight months, with defined stop/continue criteria
Consent forms covering blood draw, injection and compounded prescriptions
Maintenance scheduling and long-term follow-up protocol
Still not sure? Twenty minutes on the phone answers what a page can't.
Yes — it involves a blood draw, processing and injection, which puts it under standing orders and delegation rules in virtually every state.
Often, yes — topical and oral therapy alongside PRP or PRF is common. Combining them safely is exactly what your protocol has to spell out.
That follows your state’s delegation rules for the provider type doing it. Standing orders set out who qualifies.
Your protocol sets review checkpoints at four and eight months with defined stop or continue criteria, so a non-responder is identified on schedule rather than kept on an open-ended plan.
Consent covering the blood draw, injection and any compounded prescriptions, plus consistent baseline and follow-up photography your director can actually compare.
Can a non-physician own a hair restoration clinic? Not the entity managing the medical side. PRP draws and injects blood product, and combining it with prescription topical or oral therapy makes the program the practice of medicine in nearly every state.
That is what the corporate practice of medicine doctrine decides — and it is the single rule that shapes how your business is built. Most states hold that medical judgment belongs to licensed clinicians, so a non-physician or a general corporation may not own or control an entity that practices medicine. The MSO model is the answer the industry settled on.
A doctrine in state law, not a company or a service. The professional entity — the PC — must be owned by a licensed physician, and control counts as much as ownership: who hires the clinicians, who sets the fees, who decides what gets treated.
The company that provides everything a Hair Restoration clinic needs that is not the practice of medicine, under a written management services agreement with the PC. You can own the MSO outright, whatever your license.
How the two meet: a physician-owned PC employs the clinical team and holds the medical decisions; your MSO holds the brand, the lease, the staff, the systems and the supply; a fair-market management fee moves between them; and the line is drawn in writing where your state says it must be. PRF and microneedling add their own device and blood-handling rules on top of the prescribing question.
How money actually moves through a PC/MSO structure — patient revenue landing in the PC, the fixed management transfer to the MSO, MedGrid's retainer, and physician compensation — the same CPOM flow of funds covered on this page, walked through step by step.
This isn't just how we recommend running the accounts. In a state that enforces corporate practice of medicine, this exact flow is required to keep a PC structure compliant: revenue lands in the PC first, the MSO is paid a fixed, fair-market amount rather than a share of medical revenue, MedGrid is paid a fixed retainer by the MSO, and the accounts stay separate.
It's also why MedGrid only builds on a PC — never a PLLC — in every state we work in. A PLLC lets revenue flow straight into a member's account with no equivalent separation, which is exactly the structure this flow of funds is built to avoid. Why that distinction matters.
These are the arrangements we most often find in place when a clinic comes to us, usually built in good faith, on advice from someone who had not read the state's rules.
The clinical entity was formed as a plain LLC owned by a non-physician. In a strict state that is the whole problem, and it usually surfaces at diligence or renewal.
A physician agreed to "be the medical director" with no management agreement, no delegation document and no standing orders. There is nothing to show a board.
The MSO takes a percentage of clinical revenue. Many states read that as fee-splitting regardless of what the contract calls it.
Treatment protocols copied from a training weekend, never adapted to this state or signed by the director who is supposed to own them.
General information about how these structures work, not legal advice for your clinic. Your director and your counsel confirm the specifics before you treat.
Twenty minutes tells you what direction costs in your state, what has to be on file before the first patient, and how fast you can start.