Indiana med spa & injectable regulations

Physician supervision & delegation

Indiana defines the practice of medicine broadly; injectables and energy procedures are the practice of medicine unless performed by a licensed professional within scope or under proper delegation.

• The “practice of medicine” includes prescribing or administering any form of treatment and procedures that cut, burn, or vaporize tissue by mechanical means, laser, or penetration of the skin — the statutory basis for treating cosmetic injectables and energy-device procedures as medicine.

  Ind. Code §25-22.5-1-1.1

Good-faith examination

Botox and fillers are legend (prescription) drugs, so a valid prescriber and a lawful prescribing relationship are required.

• A prescriber may issue a prescription without a prior in-person exam only if the applicable standard of care is satisfied, the prescription is within the prescriber’s scope, and a valid provider-patient relationship has been established — including identity/location verification, informed consent, a medical history sufficient to establish a diagnosis, and discussion of the diagnosis and risks/benefits.

  Ind. Code §25-1-9.5-7, §25-1-9.5-8

Ownership & corporate practice of medicine

Indiana is comparatively permissive and does not impose a strict corporate-practice-of-medicine ban.

• An employment or other contractual relationship between an entity and a licensed physician is not the unlawful practice of medicine, as long as the entity does not direct or control the physician’s independent medical acts, decisions, or judgment. So a non-physician-owned entity may employ physicians without controlling their clinical judgment.

  Ind. Code §25-22.5-1-2(c)

RN / NP scope for injectables

• Registered nursing includes executing regimens delegated by a physician or other authorized prescriber. An RN does not independently prescribe; an RN administers injectables pursuant to a valid order within the delegated regimen.

  Ind. Code §25-23-1-1.1

• An advanced practice registered nurse may obtain independent prescriptive authority only through the Board of Nursing’s program, renewed on two-year cycles.

  Ind. Code §25-23-1-19.5

• A collaborating physician may delegate authority to a physician assistant to prescribe legend drugs and medical devices.

  Ind. Code §25-27.5-5-6

Med-spa registration & licensing

Indiana is one of the first states with a dedicated med-spa law — a registration regime taking effect over 2026–2027.

• Indiana enacted a dedicated Medical Spas chapter (Senate Enrolled Act 282), effective July 1, 2026. A “medical spa” is a facility that offers medical health care services, prepares/administers/dispenses prescription drugs (including IV/IM/subcutaneous delivery), and holds itself out as focused on cosmetic/lifestyle treatments — expressly including botulinum toxin injections, dermal fillers, weight loss, hormone therapies, and non-surgical laser/energy-device use. A physician’s office and otherwise state-licensed facilities are excluded.

  Ind. Code §25-22.5-12.5-1 (SEA 282, 2026)

• Beginning January 1, 2027, a medical spa must be registered to do business in Indiana; the board must establish the registration procedure by October 1, 2026, and the application must identify the responsible practitioner and their collaborating/supervising physician. The board may fine an unregistered operator up to $5,000.

  Ind. Code §25-22.5-12.5-3 (SEA 282, 2026)

• Each med spa must have a responsible practitioner (a physician, a qualifying APRN, or a PA with delegated prescriptive authority) with relevant training, who must be physically present enough to ensure compliance and must ensure every worker is licensed and trained for the services they perform.

  Ind. Code §25-22.5-12.5-2, §25-22.5-12.5-5 (SEA 282, 2026)

• A medical spa must notify the board within 15 days of a patient’s serious adverse event (a death, a life-threatening event, or a hospitalization or its prolongation).

  Ind. Code §25-22.5-12.5-6 (SEA 282, 2026)

Advertising rules

• An advertisement that names a practitioner must state the profession/license held and must not include deceptive or misleading information — anything misrepresenting a practitioner’s profession, skills, training, expertise, degree, board certification, or license. Violations subject the practitioner to board discipline.

  Ind. Code §25-1-10.3-2, §25-1-10.3-7

• Deceptive med-spa marketing to consumers is also unlawful under the Deceptive Consumer Sales Act, enforceable by the Attorney General.

  Ind. Code §24-5-0.5-3

Disciplinary landscape

• Knowingly or intentionally practicing medicine without a license is a Level 5 felony.

  Ind. Code §25-22.5-8-2

• The Attorney General, a prosecuting attorney, the board, or any citizen may bring an action in the name of the state to enjoin a person from practicing medicine without a license.

  Ind. Code §25-22.5-8-4

• A practitioner is subject to board discipline for grounds including fraud or material deception in providing professional services and advertising services in a false or misleading manner.

  Ind. Code §25-1-9-4