Can a non-physician own a med spa in Illinois?
Ownership · part of The Practice Perimeter
Short answer
Only if they're licensed — fee-splitting is barred, referral or not, and the entity exception requires every owner to be licensed under the Medical Practice Act; state guidance allows APRN ownership for some services, but leaves no route for a lay investor.
Illinois is among the strictest corporate-practice states, and its regulators say so in a document written for med spas specifically: a med spa is a medical practice, so it must be owned by physicians — or, for the services within their scope, by APRNs. There is no room for a non-clinical shareholder in the entity that delivers care.
Drawn from 8 verified rules in this section · regulatory monitoring, not legal advice
- 225 ILCS 60/22.2(a) · Sep 2, 2026
- 225 ILCS 60/22.2(b) · Sep 2, 2026
- 225 ILCS 60/22.2(c) · Sep 2, 2026
- IDFPR/IDPH Medical Spa Services memo (updated 2025-10-30) · Aug 17, 2026
- 805 ILCS 15/ · 805 ILCS 10/ · 805 ILCS 185/ (as stated in the IDFPR/IDPH med spa memo) · Aug 17, 2026
- IDFPR/IDPH Medical Spa Services memo (updated 2025-10-30) · Aug 17, 2026
- 805 ILCS 185/13(b)(1) · Sep 1, 2026
- 805 ILCS 185/13(a)(2) · Sep 1, 2026
Related Illinois rules
⚠️ Illinois has a dedicated fee-splitting section and its ban is not limited to referrals. “a licensee under this Act may not directly or indirectly divide, share or split any professional fee or other form of compensation for professional services with anyone in exchange for a referral or otherwise, other than as provided in this Section 22.2.” The words “or otherwise” do the work — an arrangement with no referral in it is still inside the section unless an exception applies.
225 ILCS 60/22.2(a) · verified Sep 2, 2026
The first exception is for genuine shared work, on three conditions. Two or more licensed health care workers may “each receive adequate compensation for concurrently rendering services to a patient and … divide the fee” — provided “the patient has full knowledge of the division” and the division “is made in proportion to the actual services personally performed and responsibility assumed by each licensee consistent with his or her license”. Concurrent work, proportionate split, patient knowledge.
225 ILCS 60/22.2(b) · verified Sep 2, 2026
How other states answer this
- Alabama
- Alaska
- Arizona
- Arkansas
- California
- Colorado
- Connecticut
- Delaware
- District of Columbia
- Florida
- Georgia
- Hawaii
- Idaho
- Indiana
- Iowa
- Kansas
- Kentucky
- Louisiana
- Maine
- Maryland
- Massachusetts
- Michigan
- Minnesota
- Mississippi
- Missouri
- Montana
- Nebraska
- Nevada
- New Hampshire
- New Jersey
- New Mexico
- New York
- North Carolina
- North Dakota
- Ohio
- Oklahoma
- Oregon
- Pennsylvania
- Rhode Island
- South Carolina
- South Dakota
- Tennessee
- Texas
- Utah
- Vermont
- Virginia
- Washington
- West Virginia
- Wisconsin
- Wyoming
Related Illinois questions
- What limits does Illinois place on a med spa's business structure?
- Can private equity invest in a med spa in Illinois?
- In Illinois, may a non-clinical owner or manager be paid a share of revenue?
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← All Illinois rules and changes · MedSpaRadar is regulatory monitoring and reference: it summarizes public laws, regulations and agency actions and links each to its source. It is not legal, medical, or compliance advice, and using it creates no attorney-client relationship. A summary can lag its source or leave out detail, and monitoring itself can be interrupted — so an absence of alerts means nothing reached you, not that nothing happened. Read the cited source, check its effective date, and confirm any change to your operations or clinical practice with qualified health-law counsel and your medical director. Legislative data via LegiScan (CC BY 4.0).