In New York, a nurse practitioner cannot be a medical director at most regulated healthcare facilities. State regulations covering nursing homes, diagnostic and treatment centers, substance use disorder programs, hospice agencies, and medical spas all require the medical director to be a licensed physician (MD or DO). NPs can run clinical operations and hold senior leadership titles in these settings, but the medical director designation itself is reserved for physicians.
Where the Physician Requirement Applies
The rule is set facility by facility in New York’s regulatory code, and it lands the same way each time.
Diagnostic and Treatment Centers
Every Article 28 diagnostic and treatment center must appoint a medical director who is “a physician licensed by and currently registered with the New York State Education Department” under 10 NYCRR 751.4.1Legal Information Institute. New York Code 10 NYCRR 751.4 Dental centers may use a licensed dentist. Neither pathway includes NPs.
Nursing Homes
Nursing homes must “designate a full-time or part-time physician to serve as medical director” under 10 NYCRR 415.15.2New York Codes, Rules and Regulations. New York Code 10 CRR-NY 415.15 – Medical Director Federal Medicare and Medicaid rules independently require a physician in the role.3eCFR. 42 CFR 483.70 – Administration An NP with twenty years running the clinical side of a skilled nursing facility still cannot hold the title.
Substance Use Disorder Programs
Programs licensed by the New York Office of Addiction Services and Supports (OASAS) must designate a physician as medical director under 14 NYCRR 800.4. The physician must be “licensed and currently registered as such by the New York State Education Department” and have at least one year of education, training, or experience in substance use disorder services.4Legal Information Institute. New York Code 14 NYCRR 800.4 – Definitions The regulation says this overall responsibility cannot be delegated.
Hospice Programs
Hospice regulations at 10 NYCRR 793.7 require the medical director to be “a doctor of medicine or osteopathy who is licensed and registered to practice in New York State.”5New York Codes, Rules and Regulations. New York Code 10 CRR-NY 793.7 The federal hospice Conditions of Participation mirror this.6eCFR. 42 CFR 418.102 – Condition of Participation: Medical Director
Medical Spas
A medical spa offering Botox injections, laser treatments, or other services requiring medical oversight must operate under a physician’s authority. Only an MD or DO can serve as the medical director. An NP can perform clinical work at the spa, but cannot hold the title.
Why Full Practice Authority Doesn’t Change This
New York treats NPs as independent practitioners with broad clinical authority. Under Education Law Section 6902, NPs diagnose conditions, develop treatment plans, and prescribe within their specialty.7New York State Senate. New York Education Law 6902 – Definition of Practice of Nursing NPs with more than 3,600 hours of practice can work without a written collaborative agreement with a physician, a provision currently extended through July 2026.8New York State Senate. Nurse Practitioner Association of New York State
That independence governs how NPs practice. It does not govern who can be named medical director. The medical director title sits in a separate set of facility-licensing regulations, and those regulations name physicians by license type. Making NP full practice authority permanent, which Senate Bill S2360 would do if enacted, would not open the medical director title.9New York State Senate. New York Senate Bill S2360 A separate change to the facility rules would be needed. None was pending as of early 2025.
The reasoning behind the physician requirement is tied to what the medical director does: credential other physicians, review physician privileges, and intervene when a physician’s care falls short of acceptable standards. New York has treated these supervisory functions as requiring the same license held by the providers being supervised.
Leadership Titles an NP Can Hold
The medical director designation is closed, but senior clinical leadership is not. NPs in New York regularly hold roles that carry real operational authority:
- Clinical Director, overseeing day-to-day clinical workflows, provider schedules, and care standards.
- Program Director, running a specific service line with budget and outcome responsibility.
- Chief Nursing Officer, setting nursing practice standards organization-wide and representing nursing at the executive level.
- Director of Quality or Patient Safety, managing quality assurance programs and performance improvement initiatives.
In NP-owned practices that fall outside facility-licensing rules, the NP can be the owner and highest clinical authority. The functional work of leading a clinical program is available; the specific statutory title of medical director in a licensed facility is not.
The Certified Medical Director Credential
NPs considering long-term care leadership will also hit a credentialing wall. The Certified Medical Director (CMD) designation from the American Board of Post-Acute and Long-Term Care Medicine requires a current unrestricted MD or DO license. The application offers no alternative pathway for NPs.10American Board of Post-Acute and Long-Term Care Medicine. Certified Medical Director Initial Certification Application In post-acute settings where the CMD is valued, this closes off another route to the role.
For an NP mapping a career in New York, the practical takeaway is that leadership is open, the medical director title is not, and that boundary is set by facility regulations rather than by anything in the NP scope of practice itself.