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Medical Spa Professionals and the Procedures They Can Perform

Offering services at a medical spa includes a lot of challenges, and the more services you offer, the more careful you need to be about the staff who provide each of the services. Illinois carefully regulates who is able to legally perform treatments. It is always important to ensure you have the right staff performing the different treatments you offer.

Collagen Induction Therapy

Also known as microneedling with platelet-rich plasma (PRP) or platelet rich fibrin (PRF), this treatment method can be performed by three types of medical professionals:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and have the procedure within their scope of work
  3. Physician assistants (PA) and NPs who don’t have full practice authority as long as they are under physician supervision and working under a collaborative agreement

Physicians may delegate the performance of the procedure to one of three other providers:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Medical assistants (MAs)

These three roles may only perform the procedure if they have proper qualifications and training, including proper safety practices. The staff delegated to perform the procedure must be acting within their specific scope of practice. During the performance of the procedure, one of two conditions must be met:

  1. There is onsite supervision by a physician.
  2. The physician who delegated the procedure is available by electronic means (including by phone) to immediately respond in the event of complications or questions arise. Another medical professional must also be onsite.

NPs may who have full practice authority and whose scope of practice includes the procedure, may delegate to the following three providers:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Other personnel with nursing activities under NP supervision

Cryolipolysis

Also known as Coolsculpting and Fat Freezing, Illinois considers this procedure the practice of medicine. It is a method of nonsurgical reduction of fat. This treatment method can be performed by three types of providers:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and have the procedure within their scope of work
  3. Physician assistants (PA) and NPs who don’t have full practice authority as long as they are under physician supervision and working under a collaborative agreement

Physicians may delegate the performance of the procedure to one of three other staff members:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Medical assistants (MAs)

These three roles may only perform the procedure if they have proper qualifications and training, including proper safety practices. The staff delegated to perform the procedure must be acting within their specific scope of practice. During the performance of the procedure, one of two conditions must be met:

  1. There is onsite supervision by a physician.
  2. The physician who delegated the procedure is available by electronic means (including by phone) to immediately respond in the event of complications or questions arise. Another medical professional must also be onsite.

NPs who have full practice authority and whose scope of practice includes the procedure may delegate to the following three providers:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Other personnel with nursing activities under NP supervision

Dermaplaning

Illinois considers this procedure the practice of medicine. The procedure removes the top layers of skin to get rid of wrinkles and deep scarring. This treatment method can be performed by three types of providers:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and have the procedure within their scope of work
  3. Physician assistants (PA) and NPs who don’t have full practice authority as long as they are under physician supervision and working under a collaborative agreement

Physicians may delegate the performance of the procedure to one of three other staff members:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Medical assistants (MAs)

These three roles may only perform the procedure if they have proper qualifications and training, including proper safety practices. The staff delegated to perform the procedure must be acting within their specific scope of practice. During the performance of the procedure, one of two conditions must be met”

  1. There is onsite supervision by a physician.
  2. The physician who delegated the procedure is available by electronic means (including by phone) to immediately respond in the event of complications or questions arise. Another medical professional must also be onsite.

NPs who have full practice authority and whose scope of practice includes the procedure may delegate to the following three providers:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Other personnel with nursing activities under NP supervision

Energy Based Skin Tightening

This treatment includes both radio frequency devices and Fibroblast. Illinois considers this procedure the practice of medicine. This treatment method can be performed by three types of providers:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and have the procedure within their scope of work
  3. Physician assistants (PAs) and NPs who don’t have full practice authority as long as they are under physician supervision and working under a collaborative agreement

Physicians may delegate the performance of the procedure to one of three other staff members:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Medical assistants (MAs)

These three roles may only perform the procedure if they have proper qualifications and training, including proper safety practices. The staff delegated to perform the procedure must be acting within their specific scope of practice. During the performance of the procedure, one of two conditions must be met:

  1. There is onsite supervision by a physician.
  2. The physician who delegated the procedure is available by electronic means (including by phone) to immediately respond in the event of complications or questions arise. Another medical professional must also be onsite.

NPs who have full practice authority and whose scope of practice includes the procedure may delegate to the following three providers:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Other personnel with nursing activities that are covered under NP supervision

IV Treatments

Illinois considers this procedure the practice of medicine. This treatment method can be performed by three types of providers:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and has the procedure within their scope of work
  3. Physician assistants (PAs) and NPs who don’t have full practice authority as long as they are under physician supervision and pursuant to any collaborative agreement

Physicians may delegate the performance of the procedure to one of three other staff members:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Medical assistants (MAs)

These three roles may only perform the procedure if they have proper qualifications and training, including proper safety practices. The staff delegated to perform the procedure must be acting within the specific scope of practice. During the performance of the procedure, one of two conditions must be met:

  1. There is onsite supervision by a physician.
  2. The physician who delegated the procedure is available by electronic means (including by phone) to immediately respond in the event of complications or questions arise. Another medical professional must also be onsite.

NPs who have full practice authority and whose scope of practice includes the procedure may delegate to the following three procedures:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Other personnel with nursing activities under NP supervision

Light-Emitting

Illinois considers this procedure the practice of medicine. This treatment method can be performed by three types of providers:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and have the procedure within their scope of work
  3. Physician assistants (PAs) and NPs who don’t have full practice authority as long as they are under physician supervision and working under a collaborative agreement

Physicians may delegate the performance of the procedure to one of three other staff members:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Medical assistants (MAs)

These three roles may only perform the procedure if they have proper qualifications and training, including proper safety practices. The staff delegated to perform the procedure must be acting within their specific scope of practice. During the performance of the procedure, one of two conditions must be met:

  1. There is onsite supervision by a physician.
  2. The physician who delegated the procedure is available by electronic means (including by phone) to immediately respond in the event of complications or questions arise. Another medical professional must also be onsite.

NPs who have full practice authority and whose scope of practice includes the procedure may delegate to the following three providers:

  1. Registered nurses (RNs)
  2. Licensed practical nurses (LPNs)
  3. Other personnel with nursing activities under NP supervision

Microdermabrasion

Illinois considers this a cosmetic treatment affecting only the outermost layer of the patient’s skin. Physicians may delegate regular care duties of patients for this treatment to licensed and unlicensed staff members as long as it is conducted in an office setting or at a medical practice. Personnel to whom the care is delegated must have the treatment within their scope of practice, and they must have the necessary training, education, and experience to be able to provide the proper care. The physician must be onsite during the execution of these care duties.

If you have a licensed cosmetologist onsite, they may perform dermabrasion.

PDO Threads

Illinois considers placing PDO threads the practice of medicine. This treatment method can be performed by three types of providers:

  1. Physicians
  2. Nurse practitioners (NPs) who have full practice authority and have the procedure within their scope of work
  3. Physician assistants (PAs) and NPs who don’t have full practice authority as long as they are under physician supervision and working under a collaborative agreement

Physicians may delegate the performance of this procedure only to registered nurses (RNs) who are under physician supervision. The RN must be duly qualified and trained in how to safely administer the procedure and it must be within the RN’s scope of practice.

Your NPs who have the procedure within their scope of practice may delegate to RNs who are under NP supervision. The RN must be duly qualified and trained in how to safely administer the procedure and it must be within the RN’s scope of practice.

Permanent Makeup and Microblading

Illinois considers both of these to be methods of tattooing, so the performance of these procedures is regulated under the Illinois laws and regulations for body art establishments. Two conditions must be met:

  1. The person conducting these procedures must be at least 18 years old.
  2. The facility where the procedure is performed must comply with the regulations for body art establishments.

We Can Help

If you need help setting up a medical spa or have other regulatory questions, then we invite you to call 1818 – An Advocacy Group to help you with your efforts.  We are experienced attorneys who are ready to help you protect the value of your business.  Call us today at (312) 968-9600 or fill out our online contact form.  Remember, 1818 knows government.

The information in this blog post is provided for informational purposes only and is not intended to be legal advice. You should not make a decision whether or not to contact an attorney based upon the information in this blog post. No attorney-client relationship is formed nor should any such relationship be implied. If you require legal advice, please consult with an attorney licensed to practice in your jurisdiction.

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