Med spa · Ohio

Ohio med spa MSO-PC: who may inject, laser rules, and who owns the practice

Ohio treats light-based medical devices as the practice of medicine, limits who may receive a laser delegation, and keeps drug administration off an esthetics license. See where the physician-owned PC fits.

Updated November 4, 2026

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Direct answer

An Ohio med spa that injects a drug or applies a light-based medical device is practicing medicine under the State Medical Board of Ohio. OAC 4731-18-02 says application of a light-based medical device is the practice of medicine and bars delegation of ablative procedures. Hair removal follows ORC 4731.33 (amended effective August 26, 2026). A vascular laser for non-ablative work follows OAC 4731-18-03. Esthetics, in ORC 4713.01 and OAC 4713-8-04, is beautification and non-invasive care, not injections. The clinical entity is usually a professional association under ORC chapter 1785. A lay founder owns the MSO. Foundry forms that MSO-PC for $15,000 one-time and matches an Ohio-licensed friendly PC owner for $3,000/mo.

Ohio is nuanced on the CPOM 50-state guide. Ownership, the nonprofit carve-out in ORC 4731.226, and the fee overlay in ORC 4731.65 are on Ohio CPOM. For the general aesthetics build, start at the med spa MSO-PC hub. After papers, run CPOM compliance. Adding virtual consults? Read the Ohio telehealth MSO-PC guide. General information only, not legal advice. Foundry is not a law firm.

Who may do what in an Ohio med spa

Service	Who the rule names	Ohio rule
Cosmetic injection of a drug	Physician, or a PA or nurse under that license. An unlicensed delegate only if 4731-23-02 allows the task	OAC 4731-23-02 (effective October 31, 2026). On-site supervision if drug administration is delegated to an unlicensed person
Ablative light-based procedure	Physician. Delegation is barred	OAC 4731-18-02(B)
Non-ablative vascular laser	PA with a supervision agreement, or an RN or LPN, after the physician evaluates the patient	OAC 4731-18-03. RN or LPN: on-site, and no more than two delegates under that rule at once
Light-based hair removal	PA with a supervision agreement, a qualifying laser hair removal professional, or a nurse as ORC 4731.33 defines nurse	ORC 4731.33, amended effective August 26, 2026. The nurse category is an RN or LPN and does not include an APRN
Esthetics: cosmetics, facials, non-invasive skin beautification	Licensed esthetician, inside that definition	ORC 4713.01 and OAC 4713-8-04. No service that claims a medical or healing benefit

The State Cosmetology and Barber Board device list says a cosmetologist or esthetician may not provide a service that claims a medical or healing benefit, and that services which ablate, damage, or alter living cells are outside that license. The list names microneedling and plasma or fibroblast skin tightening as examples. An esthetics license does not add Botox, filler, or a light-based medical device.

ORC 4731.33 is the hair-removal statute. The physician may delegate only to a physician assistant with an effective supervision agreement, a laser hair removal professional who qualifies under the section (including the cosmetic-therapist path or the 750-hour course plus the certified exam), or a nurse as the section defines that word. For a laser hair removal professional, the physician evaluates the patient before the device is used and again after the first application before treatment continues. On-site supervision is the default. Off-site supervision is allowed only after the extra training in the statute. The physician supervises no more than five laser hair removal professionals at the same time, and no more than five nurses at the same time. Delegating hair removal to anyone outside that list is tied to unlicensed practice under ORC 4731.41.

PAs, nurses, and the medical director question

A physician assistant practices under a supervision agreement. An RN or LPN who receives a vascular-laser delegation still needs the training and on-site rule in OAC 4731-18-03, including the physician visit before treatment and again after the first application before it continues. An APRN is not the "nurse" delegate in ORC 4731.33, because that definition excludes an RN who is also an APRN. An APRN practices under the nursing statutes, not under that delegate slot. A medical director title on a lay-owned LLC is not ownership. Read physician PC owner before you hire for the role.

Who owns the Ohio practice

Role	Where it sits	Ohio note
Physician owner	Owns the professional entity	Ohio-licensed MD or DO. Professional association under ORC chapter 1785, or a PLLC owned by licensed physicians
Clinical authority	The PC, not a lay LLC	ORC chapter 4731 licenses people. ORC 4731.41 is unlicensed practice. ORC 4731.226 is a nonprofit path, not a digital-health waiver
Injectors and laser staff	Employed or contracted by the PC	Only the license or delegation that the table above actually allows
Founder and investors	Own the MSO	Lease, brand, booking, retail products, marketing
MSO fee	Written management services agreement	Fixed or cost-plus at fair market value. Read it against ORC 4731.65 and the MSA red-flag audit

Treatment revenue belongs to the PC. Retail skincare that is not a professional service can sit in the MSO. A Delaware LLC can own the MSO. It cannot be the employer of record for the Ohio physicians. If any patient is in Utah, Utah requires a domestic professional entity. See Utah CPOM. To file the two companies, use MSO-PC formation.

Setup steps for an Ohio med spa

List every treatment. Mark injections, ablative devices, vascular lasers, and light-based hair removal separately.
Match an Ohio-licensed physician to own the professional entity through friendly PC owner matching ($3,000/mo).
Form the Ohio professional association and the MSO, and sign a fair-market-value MSA. See MSO-PC formation ($15,000). Typical formation is 1 to 3 days after the menu, the states, and the physician match are scoped. Payer enrollment runs on the payer's clock.
Write the delegation file for each device: who the statute names, the physician evaluation, the training record, and whether supervision is on site. Keep esthetics services inside ORC 4713.01.
Route all treatment payments to the PC and pay the MSO its fixed fee. Then run CPOM compliance.

Pricing

MSO-PC formation

$15,000

One-time. The MSO and the Ohio physician-owned PC, scoped to your service menu.

Friendly PC owner

$3,000/mo

An Ohio-licensed physician who owns your PC.

Ohio med spa MSO-PC FAQ

Who can inject Botox in an Ohio med spa?

The practice of esthetics in ORC 4713.01 is skin beautification, and OAC 4713-8-04 limits an esthetician to beautification, relaxation, and non-invasive services. A cosmetic injection is administration of a drug. OAC 4731-23-02, effective October 31, 2026, says a physician may delegate a medical task only after determining it can be done without medical judgment and without immediate serious harm, and drug administration delegated to an unlicensed person requires on-site supervision. The exceptions are another physician accepting that supervision, a routine topical drug, and correctional distribution. A physician, or a PA or nurse acting under that profession's own license, is who the Medical Practice Act and the nursing statutes describe. Confirm a specific injector plan with Ohio counsel.

Can an esthetician run a laser in an Ohio med spa?

OAC 4731-18-02 says application of a light-based medical device to the human body is the practice of medicine, and a physician shall not delegate ablative procedures. Hair removal may be delegated only under ORC 4731.33. A vascular laser for a non-ablative dermatologic procedure follows OAC 4731-18-03, which names a physician assistant with a supervision agreement, or a registered nurse or licensed practical nurse. The Cosmetology and Barber Board device list puts services that ablate, damage, or alter living cells, including microneedling and plasma or fibroblast tightening, outside cosmetology and esthetics.

Does Ohio require the physician on site for laser hair removal?

On-site supervision is the default in ORC 4731.33. On-site means the same location, including the same office suite, not necessarily the same room. Off-site supervision is allowed only after the training that section lists. A physician supervises no more than five laser hair removal professionals at once, and no more than five nurses at once, for hair removal. For a laser hair removal professional, the physician evaluates the patient before the first use and again after the initial application before treatment continues. For a non-ablative vascular laser delegated to an RN or LPN, OAC 4731-18-03 requires on-site supervision and a cap of two delegates under that rule at the same time.

Can a lay founder own an Ohio med spa?

Not the medical side. ORC chapter 4731 reserves the practice of medicine to licensees, and the clinical entity is usually a professional association under ORC chapter 1785 owned by an Ohio-licensed physician. A lay founder can own the MSO that runs the brand, lease, booking, and retail, and pay it a fixed fair-market-value fee. ORC 4731.226 is a nonprofit pathway, not a startup waiver. Ohio is nuanced on the CPOM guide. That label is not permission for a lay LLC to hold the practice.

How much does Foundry charge for an Ohio med spa MSO-PC?

MSO-PC formation is $15,000 one-time. An Ohio-licensed friendly PC owner is $3,000/mo.

Ready to open your Ohio med spa?

Book a free 20-minute call with your service menu. We will scope the PC, the MSO, and the physician owner.