Medical spas in Ohio

No Ohio statute or rule names Botox or fillers, and the State Medical Board has not published a rule or statement on them. The answer has to be built from general rules.

Practising medicine includes giving a treatment for pay, and no one may do it without a Medical Board licence.⁷ A physician may not delegate the practice of medicine to an unlicensed person unless the Revised Code, or a Board rule in effect before 10 April 2001, specifically allows it. A physician also may not delegate a task beyond the person's competence.⁶ When a physician delegates giving a drug, the physician must be on site, unless responsibility has passed to another physician who has accepted it patient by patient.⁵ These rules do not say whether any unlicensed person may inject.

A registered nurse may give care beyond basic nursing preparation if the nurse has education from a recognised body of knowledge for that care, shows the knowledge and skill to give it, and keeps documentation of both that satisfies the Board of Nursing. Where the care is given under a prescriber's direction as described in division (B)(5) of section 4723.01 of the Revised Code, the nurse also needs a specific current order from someone authorised to practise in Ohio, and the care may not be prohibited by another law or rule.⁸ The rule for a licensed practical nurse has the same conditions, with "a specific current valid order or direction".⁹ Neither rule names an injection.

A certified nurse practitioner must have a written standard care arrangement with one or more collaborating physicians or podiatrists before practising.¹⁰ Collaboration means a physician has entered into that arrangement and is continuously available to communicate with the nurse, in person or electronically.¹¹ The rules do not say whether the arrangement covers cosmetic injections.

A physician assistant works under a supervision agreement. The supervising physician must be continuously available for direct communication, personally review the physician assistant's activities and keep a quality assurance system.¹²

Where the product comes from matters too. In 2025 the Board of Pharmacy revoked a business's licence after an inspection found Botox Cosmetic and Dysport vials with non-English labels, bought from sellers that were not licensed in the United States.²⁰ Ask who will inject you, what their licence is, which licensed professional is responsible for your treatment, and where the product is bought.

Ohio sets rules for two kinds of light-based work. They are separate, and their limits differ.

Non-ablative vascular laser treatment. A physician may delegate a vascular laser for a non-ablative dermatologic procedure only if the laser is cleared or approved by the FDA for that specific use, the use is within the physician's normal practice, and the physician has seen and evaluated the patient first and again after the first application, before treatment continues. The person who receives the delegation must be a physician assistant with an effective supervision agreement, or a registered or licensed practical nurse.⁴ A nurse must have eight hours of basic education, must have observed fifteen procedures of each type delegated, and must have done twenty under the physician's direct physical oversight. The physician must be on site at all times while the nurse applies the laser, and may supervise no more than two nurses under this rule at once.⁴ A delegate must report any clinically significant side effect to the physician immediately, and the physician must see the patient as soon as practicable.⁴ The rule covers vascular lasers only and sends hair removal to the statute below.

Hair removal. House Bill 377 amended section 4731.33 of the Revised Code and added section 4731.331. It took effect on 26 August 2026.³ A physician may delegate hair removal with a light-based medical device only to a physician assistant with a supervision agreement, a nurse (a registered or licensed practical nurse, not an RN who is also an advanced practice registered nurse), or a "laser hair removal professional".¹ That is someone who held a cosmetic therapist licence from the Medical Board on 11 April 2021, or who completed a cosmetic therapy course of at least 750 clock hours and passed the certified laser hair removal professional exam of the Society for Clinical and Medical Hair Removal. The device must be FDA-cleared for hair removal, and the physician must see and evaluate the patient first and again after the first application.¹ The law defines a light-based medical device by wavelength (180 to 1,064 nanometres), not by the word "laser".¹

A laser hair removal professional must have eight hours of basic education, have observed fifteen procedures and have performed twenty under the physician's direct physical oversight, for each type of device. People who were already doing the work under a physician's delegation for two years before 30 September 2021, and former cosmetic therapist licence holders who were authorised to use the device, are exempt from that training.¹

The supervising physician must be on site while a nurse or laser hair removal professional applies the device. "On site" means the physician is in the same location, not necessarily the same room, and includes the same office suite.¹ A physician may supervise from off site (continuously available for direct communication) instead if the nurse has finished a 40-hour training programme the physician has approved, or if a laser hair removal professional treats an established patient, has finished an approved course of at least 50 hours with at least 30 hours of clinical experience, and has worked under on-site supervision long enough for the physician to be satisfied. A physician may supervise no more than five nurses, or five laser hair removal professionals, at the same time.¹ A nurse or laser hair removal professional must report any clinically significant side effect to the physician at once.¹ An advanced practice registered nurse or physician assistant may delegate to and supervise nurses and laser hair removal professionals for hair removal on the same terms. An advanced practice registered nurse may do so only if the nurse's standard care arrangement does not prohibit it.² A laser hair removal professional who breaks the supervision or reporting rules is practising medicine without authority.¹

Neither the rule nor the statute covers lasers for any other purpose, such as resurfacing or tattoo removal. A cosmetologist may not use any device that produces or amplifies electromagnetic radiation at 180 nanometres or more.¹⁴ The esthetician rule has no such clause, but it bars any service that ablates, damages or alters living cells.¹³ If you are booked for a laser or light treatment, ask who will run the device, which physician is responsible, and whether that physician will be on site.

An esthetician's work is limited to beautification, relaxation and non-invasive services. Estheticians may not provide a service that claims a medical or healing benefit, and may exfoliate cells of the stratum corneum only, the dead outer layer of skin, by chemical, mechanical or electrical means.¹³ An esthetician may use a sterile single-use lancet to open a comedo or a milia, and may not pierce the stratum corneum for any other purpose.¹³

Peels by an esthetician must be at a concentration of 30 per cent or less, with a pH of 3 or more. The exception is a commercially available product approved for use by cosmetologists or estheticians, with the manufacturer's documentation that it does not penetrate below the stratum corneum when used as directed, the esthetician's documented training in it, and the manufacturer's directions followed.¹³ Estheticians may not provide services that ablate, damage or alter any living cells. Working under a physician's supervision does not widen the licence: the esthetician may provide only services within the scope of esthetics.¹³

The rule does not name microneedling. Its limits (the surface layer only, no piercing, no altering living cells) point against it. Ask who will do a peel or microneedling, what their licence is, and whether a physician or nurse oversees it.

Ohio's State Medical Board, Board of Pharmacy and Board of Nursing issued a joint statement on retail IV clinics on 15 May 2025. It says choosing, prescribing, preparing and giving IV therapy is the practice of medicine, nursing and pharmacy. The boards say the statement restates existing law.¹⁵

Only a physician, a physician assistant with a prescriber number and delegated authority, or a certified nurse practitioner, nurse-midwife or clinical nurse specialist may diagnose, treat or prescribe IV medication.¹⁵ Protocols or standing orders for recommending, compounding and giving IV medicines are not authorised under Ohio law.¹⁵ Mixing an IV "cocktail" is compounding, and a clinic that does it must hold a terminal distributor of dangerous drugs licence from the Board of Pharmacy.¹⁵ A licensed practical nurse has limited authority to give IV fluids, and in a retail IV clinic it depends on a physician or registered nurse being on site.¹⁵¹⁶ A physician may not delegate giving drugs by IV to an unlicensed person.⁶

Ask who examined you, who ordered the drip, who will place the IV, and whether the clinic holds the pharmacy licence.

The Board of Pharmacy's guidance of 17 July 2025 says compounding of copies of commercially available tirzepatide and semaglutide is no longer permitted, because neither is on the FDA shortage list. For pharmacies and prescribers the compounding ended on 18 February 2025 for tirzepatide and 22 April 2025 for semaglutide. For outsourcing facilities it ended on 19 March and 22 May 2025.¹⁷ A prescriber clinic that bought compounded product before those dates may keep dispensing it but may not compound more.¹⁷ A compounded drug that is not an essential copy needs the prescriber's reason, documented on the prescription: a name and a formulation alone are not enough.¹⁷ The Board says retatrutide and cagrilintide cannot be compounded and that licensees who sell, order or give them may face summary suspension.¹⁷

Ask whether your medicine is FDA-approved or compounded, who prescribed it after examining you, and which pharmacy prepares it.

Ohio has no med spa licence or registry, and no statute or rule that requires or defines a medical director. The Medical Board's own document says physicians are employed as medical directors in medical spas, ketamine clinics and IV hydration clinics, and that a medical director who supervises unlicensed people must follow the rules on delegating tasks and stays responsible for how the task is carried out.¹⁸ A physician who supervises a physician assistant needs a supervision agreement, and one who collaborates with a nurse practitioner needs a standard care arrangement.¹⁸

An Ohio physician may be employed by a corporation or another business entity: the Medical Board says the corporate practice of medicine doctrine no longer exists in Ohio. A physician must still use independent professional judgment. A professional association's ownership is limited to the licensed professionals who render the service, and a pain management clinic must be owned by physicians.¹⁹