Question 1

Who can inject Botox and dermal fillers in Indiana?

Accepted Answer

Botulinum toxin and dermal fillers are prescription drugs, so they must be ordered/prescribed by a physician (MD/DO), an advanced practice registered nurse with prescriptive authority, or a physician assistant with delegated prescriptive authority — the three license types SB 282 defines as a med-spa 'practitioner.' A registered nurse may administer the injection pursuant to a valid order because 'registered nursing' includes executing a regimen delegated by a physician (IC 25-23-1-1.1(b)(5)), but an RN cannot independently prescribe or order the product. Indiana has no statute expressly naming who may inject cosmetic injectables, so this is derived from prescribing law plus nursing scope, and some commentators read Indiana as excluding RNs.

Question 2

Does Indiana require a good-faith exam before treatment?

Accepted Answer

Indiana has no med-spa-specific 'good faith exam' statute, but because injectables are prescription drugs, a prescriber must establish a proper provider-patient relationship meeting the same standard of care as in-person care before prescribing (IC 25-1-9.5-7). A prescriber may issue the prescription even without a prior in-person exam if the applicable standard of care is satisfied and it is within the prescriber's scope, so the evaluation may be conducted via telehealth (IC 25-1-9.5-8).

Question 3

Does a med spa in Indiana need a medical director?

Accepted Answer

Under SB 282 every registered medical spa must designate a 'responsible practitioner' who has prescriptive authority (a physician, APRN, or PA) and education/training in the services offered; that person must be physically present at the spa a sufficient amount of time and must ensure each worker is licensed, within scope, and trained (IC 25-22.5-12.5-5). This functions as a medical-director requirement, though the term used is 'responsible practitioner,' and it applies with the registration framework (procedure set by Oct 1, 2026; registration required from Jan 1, 2027).

Question 4

Can a non-physician own a med spa in Indiana?

Accepted Answer

Indiana does not strictly prohibit corporate/non-physician ownership of a medical practice: IC 25-22.5-1-2 recognizes health care organizations and provides that an entity's employment of or contract with a licensed physician is not the unlawful practice of medicine so long as the entity does not direct or control the physician's independent medical acts, decisions, or judgment (IC 25-22.5-1-2(c)). SB 282 regulates med spas through registration and a responsible practitioner rather than by restricting ownership, and imposes no physician-ownership rule.

Question 5

What supervision does Indiana require for med-spa procedures?

Accepted Answer

Indiana is not a full-practice-authority state for nurse practitioners: an APRN must operate in collaboration with a physician evidenced by a written practice agreement (IC 25-23-1-19.4) and must separately obtain board prescriptive authority to prescribe legend/controlled drugs (IC 25-23-1-19.5). Physician assistants practice under a supervising physician and receive delegated prescriptive authority under IC 25-27.5-5-6 (as cross-referenced in SB 282); a 2025 bill (HB 1116) to remove the APRN collaboration requirement died in committee, so collaboration remains required.

Question 6

What can an esthetician legally do in Indiana?

Accepted Answer

Estheticians are licensed by the Indiana State Board of Cosmetology and Barber Examiners (IC 25-8), and their scope under 820 IAC 4-4-7.1 is non-medical skin care — facials, cleansing/exfoliation, comedone extraction, waxing/hair removal, and makeup. Estheticians are not among the professions excluded from the Medical Practice Act (IC 25-22.5-1-2), so they may not inject, prescribe, or perform procedures that constitute the practice of medicine; doing so would be unlawful practice of medicine.

Question 7

Who can operate a cosmetic laser in Indiana?

Accepted Answer

Indiana has no dedicated laser statute or laser-operator license, so cosmetic laser/energy-device use is treated as the practice of medicine that a physician may perform or delegate to appropriately trained personnel under supervision (IC 25-22.5-1-2(a)(20)). SB 282 now defines the nonsurgical use of a laser or energy device for cosmetic purposes (rejuvenation, anti-aging, hair removal) as a med-spa service, meaning it must be provided at a registered medical spa under a responsible practitioner; no rule sets a minimum operator credential, so delegation to trained unlicensed staff is legally gray.

Question 8

What are the rules for IV therapy and vitamin drips in Indiana?

Accepted Answer

IV vitamin/nutrient ('drip') therapy is expressly named as a med-spa service under SB 282 (parenteral nutrient therapies, IC 25-22.5-12.5-1(a)(3)(D)(v)), so from July 1, 2026 it must be provided at a registered medical spa under a responsible practitioner. The infused agents are prescription items requiring an order from a physician, APRN, or PA after a good-faith evaluation, and administration is by a physician or a nurse executing that delegated order; estheticians and unlicensed staff cannot order or independently administer it.

Question 9

Does a med spa have to register or hold a license in Indiana?

Accepted Answer

Yes — SB 282 creates IC 25-22.5-12.5, requiring every medical spa to register with the Medical Licensing Board of Indiana beginning January 1, 2027 (the Board must establish the registration procedure by October 1, 2026). Registration must identify the spa, its services, whether it compounds drugs, and its responsible practitioner and collaborating/supervising physician; the Board maintains a public database, spas must report serious adverse events within 15 days, may only provide services at the registered location (except for training), and must comply with advertising rules.

Question 10

What are the penalties for practicing outside scope in Indiana?

Accepted Answer

SB 282 authorizes the Medical Licensing Board to fine a person operating an unregistered medical spa up to $5,000 and to require registration (IC 25-22.5-12.5-3(c)); a licensee who violates the chapter is subject to discipline under IC 25-1-9, and a registration may be suspended for advertising violations. Separately, practicing medicine without a license is a Level 5 felony and acting as a physician assistant without a license is a Level 6 felony (IC 25-22.5-8-2), with the general prohibition in IC 25-22.5-8-1.

Indiana Med Spa Regulations