Regulatory guidance from the Illinois Department of Financial and Professional Regulation (“IDFPR”) clarifies that med spas may be owned and operated by Advanced Practice Registered Nurses (“APRNs”), including those that possess full practice authority (“FP-APRNs”).
FP-APRNs are authorized, within their scope of practice, to operate without a written collaborative agreement with a physician. That being said, certain services offered at med spas have been determined by the IDFPR to be outside of the scope of practice of an APRN without supervision, including lasers, whether ablative or non-ablative. The reason for this is that such lasers constitute “the practice of medicine.”
It is the current opinion of the IDFPR that an FP-APRN cannot perform non-ablative laser services without a physician first delegating those services to them. Relatedly, the Medical Practice Act states a physician must at least be available by telephone or other electronic means while the laser services are being performed. Ablative laser services also cannot be performed by an FP-APRN without a physician first delegating those services to them, and may have different supervision requirements. This means that even FP-APRNs need to be sure they have a supervising physician relationship if they elect to offer laser services to patients.
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