Core Responsibilities of a Medical Director
The primary Illinois sources we reviewed do not define a med spa medical director's duties item by item. What the IDFPR and IDPH medical spa memo (updated October 30, 2025) and IDFPR's Statement on Prohibited Practices do confirm is below. This is general information, not legal advice.
Ownership: Illinois medspas must be owned and operated by one or more physicians or, for some services, APRNs, and a cosmetology or esthetics salon registration cannot be used to operate a medspa (IDFPR and IDPH memo, citing the Medical Corporation Act and related statutes).
Delegation: Physicians may operate a medspa, prescribe and administer drugs including Botox, and supervise and delegate these procedures. A delegated task must be within the scope of practice, education, training, or experience of the delegating physician and within a physician-patient relationship (225 ILCS 60/54.2).
Exam before delegated treatment: The person treated must be a patient of the physician, and the physician must examine them and determine the course of treatment before the delegate carries it out (IDFPR Statement on Prohibited Practices).
Physician assistants: PAs work under a written collaborative agreement. The physician need not be on site, but communication must be available for consultation (225 ILCS 95).
Lasers: A physician may delegate laser procedures that disrupt the skin's surface to an LPN, RN, or APRN with full practice authority, with on-site supervision, or, for non-ablative procedures, with the physician available by phone or electronic means (68 Ill. Admin. Code 1285.336, per the IDFPR and IDPH memo).
Many clinics also keep written treatment protocols, review charts, and stock emergency medications. Those are reasonable things to ask about, but the Illinois sources above do not list them as specific legal duties; check with IDFPR if you need a definitive answer.
Before you book, ask what happens if a complication occurs, such as a vascular occlusion after filler or a severe allergic reaction: who responds, whether hyaluronidase is on site, and how the physician is reached. You can check the physician's license with our license verification guide, and our Illinois med spa laws guide covers who may perform which procedures.
Frequently Asked Questions
Does the Medical Director have to be present in the room during Botox?
Not necessarily, and the rules depend on who treats you. For physician assistants, the Physician Assistant Practice Act says a written collaborative agreement does not require the physician's personal presence where services are provided, but communication must be available for consultation by radio, telephone, or telecommunications (225 ILCS 95). For laser procedures, the IDFPR and IDPH memo describes on-site supervision, or physician availability by phone or electronic means for non-ablative procedures. The sources we reviewed do not set a specific presence rule for a nurse giving Botox under physician delegation, so ask the clinic how supervision works and check with IDFPR for a definitive answer. This is general information, not legal advice.
Sources
- IDFPR, IDPH Issue Memo Regarding Medical Spa Services (updated October 30, 2025), Illinois Department of Financial and Professional Regulation and Illinois Department of Public Health
- IDFPR Statement on Prohibited Practices (dated April 6, 2026), Illinois Department of Financial and Professional Regulation
- Physician Assistant Practice Act of 1987 (225 ILCS 95), Justia US Law