Ohio Med Spa Regulations

Who can inject Botox and dermal fillers in Ohio?

Administering a prescription injectable (neurotoxin or dermal filler) is administering a drug, which in Ohio may be done by physicians (MD/DO), and by certified nurse practitioners, clinical nurse specialists, and physician assistants who hold prescriptive authority. Registered nurses do not prescribe but may administer injectables pursuant to a valid, current order from an authorized prescriber; unlicensed persons generally may not inject prescription drugs because such administration involves medical judgment and, if delegated, would require on-site physician supervision.

Full guide: Who Can Inject Botox in Ohio? (2026 Scope & Delegation) →

Source: ORC 4723.43 — CNP/CNS/CNM may prescribe drugs in collaboration with a physician, OAC 4723-4-03 — RN implements orders from an authorized prescriber, ORC 4731.053 — physician delegation of medical tasks

Does Ohio require a good-faith exam before treatment?

Ohio has no statute or rule using the term 'good faith exam,' and the controlled-substances chapter (OAC 4731-11) does not govern neurotoxins or dermal fillers, since these are not controlled substances. The requirement to examine and evaluate a patient before administering a prescription drug such as a neurotoxin instead rests on Ohio's general unprofessional-conduct statute: ORC 4731.22(B)(2) makes 'failure to maintain minimal standards applicable to the selection or administration of drugs' a disciplinable offense, and 4731.22(B)(6) likewise disciplines 'a departure from, or the failure to conform to, minimal standards of care of similar practitioners' — together these require a physician to evaluate a patient before selecting/administering any drug, controlled or not. Telehealth is expressly permitted for this establishing evaluation: OAC 4731-37-01 states the standard of care for a telehealth visit is the same as for an in-person visit, requires a medical evaluation appropriate to the patient as part of any telehealth encounter, and allows non-controlled prescription drugs (such as neurotoxins) to be handled via telehealth simply by complying with that rule's own requirements. Only when the drug is a controlled substance does 4731-37-01 layer on the extra requirements of OAC 4731-11-09 — which is the rule that mandates an initial in-person physical exam, and only for Schedule II controlled substances. Because neurotoxins and dermal fillers are neither controlled substances nor Schedule II, that in-person-exam mandate does not reach them, and the telehealth-permissible evaluation under 4731-37-01 satisfies the standard-of-care exam requirement.

Source: OAC 4731-37-01 — telehealth standard of care equals in-person standard; medical evaluation required; non-controlled prescription drugs (e.g., neurotoxins) may be furnished via telehealth by complying with this rule, while controlled substances require additional compliance with 4731-11-09, OAC 4731-11-09 — initial in-person physical exam is required only before prescribing a Schedule II controlled substance; neurotoxins/fillers are not controlled substances and are not reached by this exam mandate, ORC 4731.22(B)(2) and (B)(6) — general statutory basis (not limited to controlled substances) making failure to maintain minimal standards for drug selection/administration, and departure from minimal standards of care, disciplinable — the actual legal hook for a general examine-before-administering requirement

Does a med spa in Ohio need a medical director?

Ohio imposes no titled 'medical director' requirement on med spas, but because applying light-based devices and administering/prescribing drugs are the practice of medicine, a licensed physician is functionally required to authorize, order, and delegate the medical procedures — only a physician may delegate a medical task or the use of a light-based medical device. In practice a supervising/delegating physician (commonly called the medical director) must stand behind every medical service the spa offers.

Full guide: Ohio Med Spa Medical Director Requirements (2026) →

Source: OAC 4731-18-02(A) — application of light-based devices is the practice of medicine, ORC 4731.053 — only a physician may delegate medical tasks, OAC 4731-23-02 — physician delegation prerequisites

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

Ohio does not enforce a corporate-practice-of-medicine prohibition. ORC 4731.226 authorizes physicians to render professional services through corporations, LLCs, partnerships, professional associations, or other business entities, and permits multi-disciplinary entities co-owned by physicians and other listed licensed professionals (including nurses). Non-physicians may therefore own a med spa, provided the medical services are ordered and performed/delegated by appropriately licensed clinicians; the narrow exception is pain-management clinics, which must be physician-owned and are not med spas.

Full guide: Who Can Own a Med Spa in Ohio? (2026 CPOM Rules) →

Source: ORC 4731.226 — offering services through authorized business entities; multi-discipline ownership

What supervision does Ohio require for med-spa procedures?

The delegating physician must determine the appropriate level of supervision for any delegated medical task (OAC 4731-23-02(B)(3)); when a physician delegates drug administration to an unlicensed person, on-site supervision is required unless responsibility is transferred to another physician or the drug is a routine topical (ORC 4731.053(C); OAC 4731-23-02(C)). For non-ablative vascular-laser procedures delegated to an RN/LPN the physician must provide on-site supervision at all times and may supervise no more than two delegates simultaneously (OAC 4731-18-03(A)(8)-(9)); hair removal likewise requires on-site supervision, with limited off-site supervision allowed only for established patients treated by a qualified cosmetic therapist (ORC 4731.33(F)-(G)). Licensed nurses, APRNs, and PAs administering injectables act under their own license pursuant to a valid prescriber order and do not require the physician's physical presence.

Source: OAC 4731-23-02 — supervision level determination; on-site supervision for delegated drug administration, ORC 4731.053 — on-site supervision requirement for delegated drug administration, OAC 4731-18-03 — on-site supervision and two-delegate cap for non-ablative laser delegation, ORC 4731.33(F)-(G) — on-site vs. limited off-site supervision for laser hair removal

What can an esthetician legally do in Ohio?

Ohio estheticians are limited to beautification, relaxation, and non-invasive services and may not provide any service that claims a medical or healing benefit. They may exfoliate only stratum corneum cells and may NOT perform any service that ablates, damages, or alters living cells (excluding injectables, microneedling, and energy/ablative procedures). Chemical peels are capped at 30% concentration with pH not below 3 unless specific manufacturer-documentation and training conditions are met, and a sterile single-use lancet may be used only to open a comedo or milia — estheticians may not otherwise pierce the stratum corneum.

Full guide: Ohio Esthetician & Advanced Skin Scope 2026: What's Allowed →

Source: OAC 4713-8-04 — standards for competent practice as an esthetician

Who can operate a cosmetic laser in Ohio?

Applying a light-based medical device is the practice of medicine in Ohio. Ablative procedures may NOT be delegated and must be performed by a physician. A physician may delegate non-ablative vascular-laser procedures to a PA (with a supervision agreement) or to an RN/LPN who completes prescribed training, subject to on-site supervision (OAC 4731-18-02/03). Laser hair removal may be delegated to a PA, RN/LPN, or a qualified cosmetic therapist / certified laser hair removal professional under ORC 4731.33. (An APRN, being licensed as an RN, is covered by the RN delegation category.)

Full guide: Ohio Laser Safety for Med Spas 2026: Who Can Operate →

Source: OAC 4731-18-02 — light-based device use is practice of medicine; ablative non-delegable, OAC 4731-18-03 — delegation of non-ablative vascular laser to PA/RN/LPN, ORC 4731.33 — delegation of light-based devices for hair removal, OAC 4731-18-01 — definitions (ablative, non-ablative, vascular laser, supervision)

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

IV therapy is a medical act requiring a valid order from an authorized prescriber (physician, APRN, or PA). Registered nurses may administer IV medications and therapy under such an order; LPNs may perform only limited IV therapy at the direction of an RN or physician and are barred from IV-push medications (except heparin/saline flush), blood products, TPN, central-line administration, chemotherapy, and mixing/reconstituting IV drugs (ORC 4723.18). A physician may NOT delegate intravenous drug administration to an unlicensed person, so med-spa IV hydration/vitamin drips must be ordered by a prescriber and administered by nursing staff, never unlicensed personnel.

Source: ORC 4723.18 — administration of adult intravenous therapy; LPN restrictions, ORC 4731.053(D)(3) — physician may not delegate IV drug administration to unlicensed persons

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

Ohio has no med-spa-specific licensing, facility permit, or registration statute — there is no dedicated 'medical spa' license. Med spas operate under general business law; what the state regulates is the licensure of the individual practitioners and the physician oversight/delegation of the medical procedures, with unlicensed operation of a place for the practice of medicine prohibited under ORC 4731.41. Physicians may deliver services through business entities under ORC 4731.226.

Source: ORC 4731.41 — practicing medicine / conducting an office for practice without a license prohibited, ORC 4731.226 — physicians may render services through business entities

What are the penalties for practicing outside scope in Ohio?

Practicing medicine (including opening or conducting an office for such practice) without a license is prohibited and, under Chapter 4731, is a criminal offense as well as grounds for injunction. The State Medical Board may limit, suspend, revoke, refuse, reprimand, or place on probation a license for violations including failure to maintain minimal drug-selection/administration standards, furnishing/administering drugs for other than legitimate therapeutic purposes, and violating board rules (ORC 4731.22(B)). Violations of the delegation, laser, and telehealth-prescribing rules are expressly deemed departures from minimal standards of care or rule violations subject to discipline.

Source: ORC 4731.22 — disciplinary actions by the State Medical Board, ORC 4731.41 — practicing medicine without a license