Can a nonphysician own a clinic or medspa in Pennsylvania?

Yes. A nonphysician may own the business entity, but cannot control or influence medical decision-making. All clinical judgment, diagnosis, treatment protocols, and supervision must remain under a Pennsylvania-licensed physician to prevent unlicensed practice of medicine.

Do CRNPs and PAs require written agreements?

Yes. Certified Registered Nurse Practitioners (CRNPs) must have written collaborative agreements that are current and filed in the Pennsylvania Licensing System (PALS). Physician Assistants (PAs) must have written supervising physician agreements that outline delegated tasks, supervision methods, and chart review protocols.

Can RNs perform injectables or laser procedures?

Potentially, yes—if properly delegated. Registered Nurses (RNs) in Pennsylvania may perform medical procedures such as injectables or laser treatments under physician or CRNP orders, provided they have appropriate training, written protocols, documented competency, and direct or indirect supervision. Independent performance of these procedures is not permitted.

Is telemedicine permitted for weight-loss medications?

Yes. Telemedicine is allowed in Pennsylvania, but the same standard of care applies. A valid practitioner–patient relationship and adequate clinical evaluation must be established before prescribing. PDMP checks are mandatory when prescribing controlled substances, including medications like phentermine.

Are laser technicians licensed in Pennsylvania?

No. Pennsylvania does not license laser technicians as a separate profession. The use of lasers and other energy-based devices is classified as a medical act requiring physician or CRNP oversight, formal protocols, verified training, and supervision.

Illinois Medical Director Requirements for Medspas (2026 Compliance Checklist)

Disclaimer: This material is provided for general educational and informational purposes only. It is not intended as legal advice, medical advice, or official regulatory guidance. Laws, rules, and enforcement practices in Illinois may change, and their application can vary based on specific facts and practice structure. Always confirm current requirements directly with the Illinois Department of Financial and Professional Regulation (IDFPR), the Illinois Board of Nursing, and the Illinois Department of Financial and Professional Regulation’s Division of Professional Regulation, and consult qualified healthcare legal counsel before making operational or compliance decisions.

Executive Summary

Only an Illinois-licensed physician (MD or DO) may serve as the medical director for medical procedures. Nonphysicians may own or manage the business entity, but they may not practice medicine or exercise control over clinical decision-making. Most Illinois medspas operate with a physician-controlled clinical structure for patient care and a separate management entity for administrative functions.
Physicians may delegate medical services, including injectables and device-based treatments, to properly trained and licensed staff. Prescribing by APRNs and PAs must be supported by written collaborative or supervisory agreements consistent with the Illinois Medical Practice Act, the Nurse Practice Act, and applicable IDFPR rules. Illinois does not apply a single universal numerical cap across all settings, but physician oversight must be meaningful and appropriate to the services provided.
Collaborative or supervisory agreements should be documented in writing and address authorized services, prescribing authority, consultation and referral processes, communication expectations, and quality oversight measures such as chart or case review.
The Illinois Department of Financial and Professional Regulation (IDFPR) and related boards issue rules and guidance that shape delegation, supervision, and telehealth standards. Clinics should ensure internal policies reflect current statutory requirements and actual operational practices.
Illinois does not maintain a separate statewide medspa license for lasers; however, injectables and energy-based procedures are considered medical services when they affect living tissue. Physician-approved protocols, documented training, supervision structures, and device records are expected.
Although Illinois has not enacted a single aesthetics-specific statute, enforcement trends reflect increased attention to injectables, telehealth prescribing, physician oversight, and advertising accuracy. Clinics should routinely review agreements, documentation, and marketing to remain aligned with evolving regulatory expectations.

Illinois medspa compliance can be challenging because of corporate practice of medicine restrictions, physician supervision requirements, and IDFPR oversight of delegation and prescribing. With clear limits on who may control medical decision-making, expectations for physician involvement in aesthetic procedures, and increased scrutiny of injectables and device-based services, clinics can easily miss a requirement that later triggers a regulatory review or payer issue.

This guide consolidates the core compliance elements for Illinois medspas, including who may act as medical director, how collaborative and supervisory relationships function for APRNs and PAs, what proper delegation looks like in daily operations, what is permissible with injectables and energy-based devices, and how practices commonly structure their entities to stay compliant. Where appropriate, we point to Illinois statutes and regulatory bodies that providers are expected to understand.

The Illinois Quick Compliance Checklist

Use this as a monthly internal audit. Assign each item to a specific individual, such as the medical director, NP or PA lead, RN lead, or clinic manager.

Entity & Ownership Structure

Clinical services operate under a structure that maintains physician control over medical decision-making. Any management or administrative agreement separates business functions such as marketing, staffing, and nonclinical assets from the practice of medicine, consistent with Illinois corporate practice of medicine principles and the Illinois Medical Practice Act.

Medical Director Credentials

The medical director maintains an active, unrestricted Illinois MD or DO license and is familiar with the aesthetic and cosmetic services provided. The physician is available for supervision and quality oversight as reflected in written policies and agreements.

Delegation & Prescriptive Authority

Written collaboration or supervisory arrangements support delegation and prescribing by advanced practice registered nurses and physician assistants in accordance with Illinois law. These documents define the scope of services, physician availability, consultation and escalation pathways, and quality oversight expectations.

Scope of Practice Mapping

Maintain a written scope matrix that specifies which services may be performed by each role, including MD or DO, APRN, PA, RN, esthetician, or other clinical personnel. The matrix should align with Illinois licensure requirements, documented training, and physician delegation policies under the Illinois Medical Practice Act and applicable IDFPR rules.

Informed Consent & Protocols

Develop and maintain procedure-specific protocols for injectables, energy-based devices, microneedling, chemical peels, thread lifts, IV therapy, and related services. Documentation should include informed consent forms, complication management plans, emergency medications, and defined escalation pathways consistent with Illinois standards of care.

Laser Hair Removal Compliance

If laser or energy-based procedures are offered, ensure physician-approved protocols are in place. Maintain staff training records, competency verification, supervision documentation, and device maintenance logs in accordance with Illinois professional practice expectations.

Marketing & Representation

All advertising and website content must accurately reflect provider licensure, delegation, and supervision arrangements. Titles should be used correctly, and marketing must not imply independent medical practice by nonphysicians or suggest that unlicensed individuals perform medical procedures.

Quality Assurance Cadence

Implement an ongoing quality oversight program that may include chart or case reviews, adverse event monitoring, medication and device tracking logs, and periodic protocol updates based on clinical findings and regulatory guidance.

Recordkeeping & Access

Maintain current collaboration or supervision agreements, delegation policies, training documentation, competency sign-offs, incident reports, and quality oversight records. The medical director should have timely remote access to records for supervision and review when necessary.

Change Management

When introducing new services, technologies, or treatment modalities in Illinois, the clinic should update its scope-of-practice matrix, written clinical protocols, informed consent documents, staff training materials, and any applicable collaborative or supervisory agreements under the Illinois Medical Practice Act and related statutes. All affected personnel should complete documented training and competency verification before the service is launched to ensure alignment with Illinois licensure requirements and physician oversight standards.

The Legal Frame: CPOM + Who Can Be a “Medical Director”?

Who Can Be a Medical Director in Illinois?

In Illinois, a medical director must be an MD or DO licensed in Illinois and in active, good standing status under the Illinois Medical Practice Act. In medspa settings, medical directors are often physicians with backgrounds in dermatology, plastic surgery, family medicine, or other fields who have appropriate training in aesthetic and cosmetic procedures. The key requirement is that the physician is competent to oversee the services offered and is actively involved in supervision and clinical oversight.

Why a Nonphysician Medical Director Is Not Recognized in Illinois

Illinois follows corporate practice of medicine principles that prevent nonphysicians or business entities from practicing medicine or controlling medical judgment. Even if a nonphysician owns the business entity, clinical authority, delegation, supervision, and prescribing decisions must remain under the control of a licensed physician. Oversight structures that allow administrative personnel to direct medical care may raise concerns under Illinois law and IDFPR enforcement standards.

Collaboration and Delegation: APRNs and PAs in an Illinois Medspa

Prescribing Authority

In Illinois, advanced practice registered nurses and physician assistants may prescribe medications under written collaborative or supervisory arrangements with a licensed Illinois physician, as required by the Illinois Medical Practice Act and related statutes. These agreements should outline the scope of services, physician availability, consultation requirements, and ongoing clinical oversight consistent with Illinois law.

No Fixed Numerical Cap

Illinois does not impose a single statewide numerical cap identical to some other states. Instead, supervision and collaboration must be structured so that physician oversight, accessibility, and quality review are reasonable and appropriate for the number of clinicians and services involved. Certain statutory limits and ratio requirements may apply in specific contexts, so clinics should confirm current IDFPR rules.

Day-to-Day Delegation

Apart from prescribing authority, Illinois physicians may assign certain medical duties to APRNs and PAs when the clinician holds appropriate licensure, education, and training. Delegation must be supported by proper supervision, with the physician maintaining responsibility for oversight consistent with the Illinois Medical Practice Act and applicable IDFPR regulations.

Practical Tips That Survive Audits

Do not leave quality oversight undocumented or informal. During an IDFPR review or board inquiry, investigators typically request written collaboration or supervisory agreements, recent chart or case review records, and documentation showing that physician oversight is occurring as outlined in your clinic’s policies. Clear, organized records often matter as much as the policies themselves.

Injectables and Device Procedures: What “Legal” Looks Like in Practice

Injectables, including Botox® and Dermal Fillers

In Illinois, injectable treatments are considered medical procedures. They must be performed under physician oversight with appropriate delegation, supervision, and documentation consistent with the Illinois Medical Practice Act and IDFPR standards. Policies should clearly define who may perform injections, required training, and escalation pathways for complications.

Lasers, IPL, and Energy Devices

Illinois does not have a standalone statewide laser facility license for medspas, but laser and energy-based procedures are treated as medical services when they penetrate or affect living tissue. Clinics should maintain physician-approved protocols, documented staff training and competency, supervision arrangements, and device maintenance records.

Microneedling, Peels, Threads, IV Therapy

For microneedling, chemical peels, thread lifts, IV therapy, and similar services, clinics should maintain procedure-specific checklists, informed consent documentation, and training records that align with physician delegation policies and oversight expectations.

The Paperwork Illinois Regulators Expect to See

Entity Documents

Formation documents for the clinical entity demonstrating physician control over medical decision-making, along with any management or administrative agreements that clearly separate business operations from clinical authority in accordance with Illinois corporate practice of medicine principles.

Licenses & Credentials

An active Illinois medical license for the medical director, DEA registration when controlled substances are prescribed, current APRN and PA licenses, RN licenses, and documentation of training or certifications related to aesthetic or device-based services offered by the clinic.

Collaboration or Supervision Agreements

Maintain written collaborative or supervisory agreements for each APRN and PA engaged in prescribing or clinical care. These agreements should reflect Illinois statutory requirements, define prescriptive authority and oversight responsibilities, and remain aligned with actual day-to-day practice.

Delegation Policies and Clinical Protocols

Written policies specifying who may perform particular procedures, required qualifications or prerequisites, competency verification, and device or treatment parameters approved by the supervising physician.

Laser and Energy-Based Procedure File

Physician-approved protocols, staff training and competency documentation, device maintenance logs, and treatment records for laser or energy-based services, when applicable.

Marketing Review Documentation

Internal records showing medical director review or awareness of marketing content when claims relate to medical services, provider credentials, supervision, or clinical care.

Common Pitfalls We See (and How to Avoid Them)

Assuming a nonphysician may function as a medical director.
Reducing supervision to provider counts rather than documented physician oversight.
Allowing collaboration agreements and quality review records to become outdated.
Characterizing laser or energy-based procedures as nonmedical services.
Using marketing language that suggests unlicensed or unsupervised medical care.

FAQs

Can a nonphysician own my medspa?

Yes. In Illinois, a nonphysician may own or manage the business entity, but medical decision-making, supervision, and clinical care must remain under the authority of a licensed physician consistent with Illinois corporate practice principles and the Illinois Medical Practice Act.

How many APRNs or PAs can one physician support for prescribing?

Illinois does not apply a single blanket cap across all settings. Supervision must be reasonable and appropriate for the services provided, and collaborative or supervisory arrangements must reflect meaningful physician involvement.

Do my prescribing or supervision agreements have to list every drug and device?

Agreements should clearly define the scope of prescribing and services provided in practice. Keeping them aligned with actual operations helps prevent inconsistencies during audits or board reviews.

Are estheticians allowed to perform microneedling or laser procedures?

Scope depends on the specific procedure and how it affects living tissue. Many microneedling and laser services are treated as medical procedures in Illinois and require physician-approved protocols, appropriate licensure, and supervision.

What has changed recently in Illinois oversight of medspas?

Recent enforcement trends have emphasized documentation, delegation clarity, and telehealth standards, with increased focus on supervision and advertising practices.

Have Illinois regulators increased attention on injectables and medspas?

Yes. Reviews increasingly examine who performs procedures, how physician oversight is structured, and whether marketing accurately reflects provider credentials and supervision arrangements.

Templates and Operational Playbooks (What to Implement This Week)

Collaboration and Supervision Template

A written framework identifying participating providers, scope of services, physician availability, consultation pathways, emergency coverage, and ongoing quality review responsibilities consistent with Illinois requirements.

Delegation & Scope Matrix

A clear table linking each procedure to the authorized provider type, required qualifications or training, and the expected level of physician involvement or availability.

Monthly QA Pack

Core documentation tools for oversight, including a meeting agenda or summary and a chart or case review log with findings and any corrective actions.

Aesthetic and Device Procedure File

Centralized records for injectables, lasers, and energy-based services, including physician-approved protocols, staff training documentation, competency verification, and device maintenance logs.

Marketing Compliance Checklist

An internal review tool to ensure titles, credentials, service descriptions, and promotional language accurately reflect licensure, delegation, and physician supervision.

Building a Defensible Structure (the MSO + PC model)

Many Illinois medspas that are not physician-owned use a dual-entity structure to separate clinical services from business operations:

A physician-controlled clinical entity retains authority over diagnosis, treatment, prescribing, supervision, clinical protocols, and medical records, and employs or contracts the licensed clinicians providing care.
A separate management services organization or administrative entity handles nonclinical functions such as facilities, staffing support, marketing, billing, and general operations, without directing or influencing medical judgment.

Illinois corporate practice principles and enforcement under the Illinois Medical Practice Act emphasize that medical decisions must remain under physician control. Clinics should ensure both their contracts and day-to-day operations reflect this separation to reduce regulatory risk and avoid corporate practice concerns.

Implementation Plan (30/60/90 Days)

Days 1–30: Foundation & Paperwork

Inventory all active licenses in Illinois, including MD or DO, APRN, PA, RN, and esthetician where applicable, along with collaborative or supervisory agreements and DEA registrations for controlled substances. Address any deficiencies before expanding services.
Consolidate clinical protocols, informed consent forms, and medication or device logs. Ensure your scope matrix aligns with Illinois licensure requirements and IDFPR guidance.
Review collaboration and supervision agreements to confirm that prescribing authority, physician availability, consultation pathways, and quality oversight accurately reflect day-to-day operations. Document and date any revisions.

Days 31–60: QA in Action

Begin regular quality assurance meetings and chart or case reviews as outlined in your collaboration or supervision agreements. Select a realistic cadence and follow it consistently.
Perform an internal mock review focused on delegation, physician supervision, aesthetic procedures, and telehealth documentation standards under Illinois requirements.
Update marketing materials. Review website copy and promotional content to ensure no implication of unlicensed practice. Include clear language describing physician oversight where appropriate.

Days 61–90: Risk Hardening & Growth

Train injectors and device operators using competency checklists aligned with your written protocols. Document completion and maintain direct observation sign-offs where required.
Review management agreements and governance records to confirm that physicians retain control over clinical decision-making in practice, not just on paper.
Develop a brief public compliance or patient safety statement that references your medical director and summarizes physician oversight and supervision practices.

How Medical Director Co. Supports Illinois Medspas

Operating a compliant medspa in Illinois requires more than appointing a medical director. Clinics must align physician oversight, delegation practices, documentation, and day-to-day operations with the Illinois Medical Practice Act and IDFPR expectations. Medical Director Co. supports aesthetic practices that need Illinois-licensed physician oversight combined with structured compliance systems that function in real clinical settings.

What We Provide

Access to Illinois-Licensed Physicians
We connect medspas with Illinois-licensed MDs and DOs experienced in aesthetic and outpatient medicine. Physicians are matched based on familiarity with injectables, energy-based devices, and cosmetic procedures to ensure delegation and supervision are appropriate under Illinois law.

Collaboration and Supervisory Support
We assist with written supervisory or collaborative arrangements for APRNs and PAs consistent with Illinois scope-of-practice requirements. Documents are structured to reflect physician availability, consultation pathways, prescribing authority, and quality oversight obligations under Illinois regulations.

Sustainable Quality Oversight Systems
We help implement practical chart review processes, structured oversight meetings, and documentation templates that demonstrate active physician involvement. These systems are designed to withstand review by the Illinois Department of Financial and Professional Regulation (IDFPR).

Aesthetic and Device-Based Protocol Support
For injectables, lasers, and other device-based procedures, we assist with physician-approved protocols, staff training documentation, competency tracking, and supervision structures aligned with Illinois standards of care.

Practice Structure Review
Illinois enforces corporate practice of medicine restrictions through the Medical Practice Act. We review management agreements and governance structures to help ensure medical decision-making remains under physician authority while administrative entities handle nonclinical operations.

Regulatory Monitoring
We track developments from IDFPR, the Illinois Board of Nursing, and the Illinois Board of Pharmacy and provide guidance when policy or workflow updates may be appropriate.

Medical Director Co. supports Illinois medspas with more than physician placement. We help practices build defensible oversight structures, organized documentation systems, and operational safeguards designed to reduce regulatory exposure and support long-term growth.

Areas We Serve

We provide licensed medical directors and compliance support for clinics throughout Illinois, including major metropolitan areas:

Illinois Resources You Should Bookmark

Bolton Harris

Bolton M. Harris, J.D., is a seasoned attorney with a formidable background in criminal law and a focus on healthcare law and compliance. As the in-house legal counsel at Medical Director Co., Harris brings a unique blend of prosecutorial experience and regulatory expertise to support healthcare professionals across Texas. Her career spans roles as a prosecutor in multiple counties and now as a trusted advisor on the legal intricacies of medical practice operations.

Education & Early Career

Bolton Harris completed her undergraduate studies at Southern Methodist University (SMU) in 2013. During her time at SMU, she was not only a dedicated student but also a competitive athlete on the university’s women’s swimming team. She went on to earn her Juris Doctor from Texas A&M University School of Law in 2016 and became a member of the Texas Bar that same year. Armed with a strong academic foundation and discipline honed as a student-athlete, Harris embarked on a career in criminal law immediately after law school.

Prosecutorial Experience in Texas

Bolton Harris began her legal career in public service as a criminal prosecutor. She served as an Assistant District Attorney in multiple jurisdictions, where she quickly rose through the ranks and handled a broad spectrum of cases. Some highlights of her prosecutorial career include:

Assistant District Attorney, Dallas County, Texas: Prosecuted a high volume of criminal cases in one of the state’s busiest DA offices, gaining extensive trial experience in both misdemeanor and felony courts.
Assistant District Attorney, Ellis County, Texas: Continued to hone her courtroom advocacy skills, known for meticulous case preparation and a tenacious pursuit of justice on behalf of the community.
Assistant District Attorney, Navarro County, Texas: Broadened her legal expertise by handling diverse criminal matters in a smaller county, working closely with law enforcement and community leaders to uphold the law.

Through these roles, Harris built a reputation for being a tough but fair advocate. She brought numerous cases to trial and developed an in-depth understanding of the criminal justice system. This distinguished prosecutorial background laid a strong foundation for the next phase of her career in the private sector.

Healthcare Law & Compliance at Medical Director Co.

After her tenure as a prosecutor, Harris shifted her focus to healthcare law, applying her legal acumen to the medical field. She recognized that the same attention to detail and tenacity that served her in criminal law could benefit healthcare providers navigating complex regulations. Embracing this new direction, Harris became well-versed in the intricate laws governing medical practices – from licensing requirements to patient safety and privacy standards – and is passionate about helping practitioners stay compliant.

In her current role as the in-house attorney for Medical Director Co., Bolton Harris oversees all legal and compliance matters for the organization and its clients. Medical Director Co. is a nurse-owned firm that connects nurse practitioners (NPs), physician assistants (PAs), and registered nurses with qualified medical directors and collaborating physicians, offering fast placements and comprehensive compliance support for healthcare practices. Harris ensures that each of these partnerships and clinical ventures adheres to all applicable state and federal laws. She is responsible for drafting and reviewing collaborative practice agreements, advising on regulatory requirements, and providing ongoing legal counsel as clients establish and grow their clinics. Drawing on her prosecutorial eye for risk management, Harris proactively identifies potential legal issues and addresses them before they escalate, giving healthcare professionals peace of mind.

Bolton M. Harris’s multifaceted expertise – spanning high-stakes courtroom litigation to detailed healthcare compliance – makes her a formidable legal ally. Whether advocating in front of a jury or guiding a medical practice through regulatory hurdles, she remains committed to the highest standards of the legal profession. Her blend of courtroom-tested skill and healthcare law knowledge ensures that clients of Medical Director Co. receive elite-level counsel and steadfast protection in an ever-evolving legal landscape.