Medical spas in Illinois

Illinois law does not list the licences that may inject. The joint memo says a physician may perform cosmetic procedures that affect the living layers of the skin, prescribe and give drugs including Botox, and supervise and delegate them.⁷ IDFPR's statement lists Botox as the practice of medicine, outside what a cosmetologist or an esthetician may do.⁸ Diagnosing or treating a condition without a licence is unlicensed practice under the Medical Practice Act.²

The Act lets a physician delegate patient care tasks to a nurse or another licensed person working within their own licence. A physician may also delegate to an unlicensed person who has the training and experience, in an office or practice setting and within a physician-patient relationship, if a health care professional is on site to assist. A physician may not delegate a task that a statute or rule requires a physician to do.¹ IDFPR's statement says the person treated must be the physician's patient, and that the physician must examine the patient and decide the appropriateness and course of treatment before a delegate carries it out.⁸

Physician assistants work under a written collaborative agreement, and one physician may hold such agreements with no more than seven full-time-equivalent physician assistants, with exceptions.¹ An advanced practice registered nurse (APRN) who files a notarized attestation of 250 hours of continuing education or training and 4,000 hours of clinical experience after national certification needs no written collaborative agreement, and may prescribe legend drugs and Schedule II to V controlled substances.⁵ Without that authority, an APRN works under a written collaborative agreement with a physician.¹⁵ We found no Illinois text that lists which cosmetic procedures a physician assistant or an APRN may do on their own licence.

Registered nurses and licensed practical nurses may receive delegated tasks within their own licence.¹ We found no Illinois text that says whether injecting cosmetic toxin or filler is within a nurse's licence, or whether an unlicensed medical assistant may be delegated an injection. Ask who will inject you, which physician examined you and ordered the treatment, and who is in the building.

In Illinois, lasers, intense pulsed light, radiofrequency and medical microwave devices used for skin conditions or cosmetic procedures that disrupt the epidermal surface are the practice of medicine, whether ablative (removing skin tissue) or non-ablative. A physician must examine the patient and set a course of treatment before any laser procedure. A procedure that can disrupt the eye, from the cornea to the retina, may be done only by a physician and cannot be delegated.⁴

A physician may delegate ablative procedures to a nurse or other persons with the physician on site. Non-ablative procedures may be delegated with the physician on site, or with the physician available by phone or other electronic means. Anyone who is delegated needs appropriate, documented training in each system they use.⁴ The rule does not restrict APRNs or physician assistants who are authorised by their written agreement or guidelines, or licensed electrologists doing permanent hair removal with a solid probe electrode.⁴

Since 1 January 2025, the memo says, a laser hair removal facility needs no on-site physician exam before a non-ablative procedure when four things hold: it follows a physician's delegation protocol, an APRN does the examination, an RN or LPN with documented training does the procedure, and a physician is available by phone or electronically.¹⁷

Illinois does not license laser operators: we found no operator licence or certificate. Delegation is the route. The rule refers to lasers registered with the state's emergency management agency.⁴ An esthetician's licence does not cover lasers, because the law bars estheticians from techniques, products and practices intended to affect the living layers of the skin.⁶ An esthetician who performs a procedure delegated by a physician may not hold out as an esthetician while doing it.⁷⁸ If you are booked for a laser treatment, ask whether a physician has examined you, who will run the device, and how they were trained.

Illinois defines an esthetician's work as superficial: cosmetic preparations, cleansing, massage and exfoliating the outer layer of the skin on the face, neck, arms, hands or body, and not for treating medical disorders.⁶ Estheticians are barred from techniques intended to affect the living layers of the skin.⁶

IDFPR's statement lists chemical peels other than superficial ones, microneedling and radiofrequency as the practice of medicine, not within an esthetician's or cosmetologist's scope.⁸ The memo repeats that list and says a med spa may employ an esthetician, who may not hold out as practising under their esthetics licence while doing delegated medical procedures.⁷ If you are booking a peel or microneedling, ask who will do it, what their licence is, and which physician ordered it.

The joint memo says a physician may prescribe and give weight-loss medication injections.⁷ APRNs prescribe as set out under Botox and fillers.⁵

In December 2024 the Attorney General sent cease-and-desist letters to five Chicagoland med spas, asking them to stop language that misleads consumers about the products they buy. The office's alert says some sellers state or imply name-brand GLP-1 medicine while offering compounded drugs, and that compounded drugs are not the same as generic drugs. Its red flags include no prescription or licensed supervision, "research-grade" products, and split pens or vials.¹¹ That is an enforcement notice, not a rule. Ask whether your medicine is FDA-approved or compounded, and which pharmacy prepares it.

We found no Illinois statute, rule, board statement or agency memo that deals with IV hydration or drip bars. The general rules above apply to any treatment a physician orders: the person treated is the physician's patient, and the physician examines them and decides the course of treatment before a delegate carries it out.¹⁸ Ask who examined you, who ordered the drip, and who will place the IV.

We found no Illinois statute or rule that creates a medical director role for med spas. The memo speaks of physicians who operate a med spa and supervise and delegate its procedures.⁷

On ownership, the memo says the Medical Practice Act and the Nurse Practice Act require med spas to be owned and run by physicians and, for some services, by APRNs. Only physicians may organise under the Medical Corporation Act, which requires every officer, director and shareholder to be a licensed physician and requires a certificate of registration from IDFPR, posted on the premises.⁹ Physicians may also organise under the Professional Service Corporation Act or the Professional Limited Liability Company Act. The memo says APRNs may use only those two, and that a business that is not a corporate entity must be owned and run by physicians or APRNs.⁷ The Medical Practice Act bars a licensee from splitting a professional fee in exchange for a referral or otherwise, and allows pooling inside an entity organised under one of those acts when every owner is licensed, among other conditions.³

A shop or salon registered for cosmetology or esthetics may not use "medical" in its business name, the memo says.⁷ The Act also bars claims of superior quality of care to entice the public, and requires the licensee's title in every advertisement for regulated services.³

Illinois requires a tattoo and body piercing establishment to hold a registration from the Department of Public Health before it operates. The Act counts permanent makeup, such as permanent lip colouring and eyeliner, as tattooing. It does not count a physician's use of pigments to obscure scar tissue or add colour to the skin for cosmetic or medical purposes.¹⁰ The memo says a physician may microblade without a body art licence from the Department of Public Health.⁷ IDFPR's statement lists microblading as outside an esthetician's scope while excepting it from its "practice of medicine" label.⁸ We could not reconcile the two, and we did not find a licence for individual tattoo artists.