Medical director requirement
Medical director/supervising physician required
Corporate Practice of Medicine
Strict; Corporate Practice of Medicine enforced—physician ownership or MSO with physician control required This is the doctrine that decides whether a non-physician can own or control the practice, and it usually travels hand-in-hand with the medical-director question.
Who can supervise or delegate
NP/PA cannot inject neurotoxins/fillers; physician collaboration does not permit independent injection
How the exam ties in
Good-faith exam required; in-person only
What to verify in Illinois
Ensure a licensed MD/DO owns or controls the medical spa and performs all injections; verify CPOM compliance with Illinois Department of Financial and Professional Regulation.
Primary source: Illinois Department of Financial and Professional Regulation (IDFPR), Medical Board
General business information for Illinois medical-spa owners, current as of 2026 — not legal advice. State boards update rules often; confirm specifics with the Illinois board (and your own counsel) before you act.