Illinois medical director requirements for med spas

Physician supervision & delegation in Illinois

Illinois treats energy devices that disrupt the skin as the practice of medicine, then grades the supervision by whether the procedure is ablative. Ablative means the physician is on site. Non-ablative means the physician can be at the end of a phone. That distinction is the one an Illinois operator has to get right.

• The use of a light-emitting device — including intense pulsed light, red light therapy, low-level, cold and soft laser therapy, non-thermal LED, radiofrequency and medical microwave devices — for dermatologic conditions or cosmetic procedures that disrupt the epidermal surface of the skin, whether ablative or non-ablative, is the practice of medicine and may be performed only by a licensed physician or under delegation.

  68 Ill. Adm. Code 1285.336 (as stated in the IDFPR/IDPH med spa memo) · verified Aug 17, 2026

• A physician may delegate ABLATIVE procedures to a licensed practical nurse, a registered professional nurse, a full practice authority APRN or another person only with on-site supervision by the physician. For NON-ABLATIVE procedures the physician may instead be available by telephone or other electronic means to respond promptly to any question or complication.

  68 Ill. Adm. Code 1285.336 · verified Aug 17, 2026

• Anyone delegated an ablative or non-ablative procedure must have received appropriate, documented training and education in the safe and effective use of each system used — competence on one device is not competence on the next.

  68 Ill. Adm. Code 1285.336 · verified Aug 17, 2026

• In an office or practice setting and within a physician-patient relationship, a physician may delegate patient care tasks to an unlicensed person who has appropriate training and experience, provided a health care professional is on site to provide assistance. Delegation may be by oral, written or electronic means, by standing orders, protocols, guidelines or verbal orders.

  225 ILCS 60/54.2(b), (f) · verified Aug 17, 2026

• A task that is mandated by statute or by rule to be performed by a physician may not be delegated at all, and anything that is delegated must sit within the scope of practice, education, training or experience of the delegating physician.

  225 ILCS 60/54.2(a), (c) · verified Aug 17, 2026

Recent Illinois changes

• IL HB4281: Certified Medical EstheticianJan 7, 2025