What to know in Illinois
Start with these state-specific findings, then use the checklist below to review the rest of your practice. The linked authorities explain the conditions and exceptions behind each point.
Professional entities have ownership restrictions
The joint memo describes physician-owned practices and APRN-owned practices for some services, with different permitted professional entity forms. It also identifies IDFPR professional-entity registration in addition to Secretary of State filings.
Source: IDFPR and IDPH: Medical Spa Services memorandum, October 30, 2025A salon registration cannot operate a medical spa
The memo separates medical services from cosmetology and esthetics. It also distinguishes ablative and non-ablative laser supervision, with a specific non-ablative examination pathway effective in 2025; avoid a single supervision rule for every device.
Source: IDFPR and IDPH: Medical Spa Services memorandum, October 30, 2025Your next steps
- Review the planned owners, officers, entity form and services against the memo’s ownership section.
- Document which entity provides each medical or esthetics service and obtain the relevant professional-entity or salon registrations.
Questions to resolve before opening
- Does this service fit the authority of the physician or APRN-owned entity being formed?
- Which current laser examination and supervision pathway applies to this specific device and performer?
Bring your actual ownership chart, service menu, devices and staff credentials to the relevant board or healthcare counsel. The same answer may not apply to a different procedure or business model.