Med Spa Compliance Series: Area of Focus – Proposed Med Spa Facility Licensure Requirements in Iowa and Indiana

Iowa and Indiana have recently introduced legislation that would establish new registration and licensure requirements for medical spas. Iowa House Study Bill 591 (HSB 591)¹, also referred to as the "Medical Spa Oversight Act," and Indiana Senate Bill 282 (SB 282)² (together referred to as the “Proposed Bills”) would create regulatory frameworks governing medical spa operations, including mandatory registration, designation of responsible practitioners, adverse event reporting, and enforcement mechanisms. Medical spa operators in these states should closely monitor these legislative developments, as they may impact business operations.

1. Definitions of "Medical Spa"

Iowa. Under HSB 591, a "medical spa" is defined as a business licensed under the proposed chapter to provide "wellness services." "Wellness service" is defined as a medical service for which a person is not required to have a license to practice medicine, surgery, osteopathic medicine, or pharmacy, and that is primarily used to enhance an individual's health or physical appearance rather than to address an underlying medical condition. Examples of wellness services include Botox injections, laser hair removal, skin pigmentation treatment, microneedling, intravenous nutrient therapy, and intramuscular injections of vitamins, minerals, or other nutrients.

Indiana. Under SB 282, a "medical spa" is defined as a facility or practice that offers or provides medical health care services, engages in the preparation, administration, or dispensing of prescription drugs (including intravenous, intramuscular, or subcutaneous delivery), and holds itself out as a facility focused on cosmetic or lifestyle treatments. Covered treatments include weight loss, wellness, longevity, and cosmetic or aesthetic health services such as Botox injections and dermal fillers, hair loss treatments, hormone therapies, and parenteral nutrient therapies. The definition does not apply to facilities otherwise licensed by the state.

2. Overview of the Proposed Bills

Medical spa owners and operators should be aware of the following critical points from both of the Proposed Bills:

• Mandatory Licensure/Registration. Both Iowa and Indiana would prohibit medical spas from operating without state licensure or registration. In Iowa, a business would be prohibited from operating as a medical spa, providing wellness services, or handling, storing, administering, dispensing, or distributing prescription drugs unless licensed by the Iowa Board of Medicine (Board). In Indiana, beginning January 1, 2027, medical spas would be required to register with the Medical Licensing Board of Indiana (Board) in order to conduct business in the state.
• Designated Responsible Person/Practitioner. Both bills require medical spas to designate a licensed professional who is responsible for ensuring compliance with state requirements. In Iowa, this individual must be licensed under the state's medicine, surgery, osteopathic, or pharmacy statutes. In Indiana, the responsible practitioner must have prescriptive authority and possess education and training in the health care services and treatments being performed at the medical spa. The responsible practitioner in Indiana must be “physically present for a sufficient amount of time” to ensure compliance. Both Proposed Bills contemplate Board approval for individuals to serve as the responsible person of more than one medical spa location.
• Adverse Event Reporting. Both states would require medical spas to report serious adverse events to the applicable regulatory board within five (5) business days in Iowa and five (5) days in Indiana.
• Location Restrictions (Indiana Only). Indiana's bill would prohibit medical spas from providing health care services and cosmetic and lifestyle treatments at a location other than the medical spa office, a physician's office, or another licensed health care facility.
• Penalties for Non-Compliance. Both bills establish penalties for violations. Iowa authorizes administrative penalties of up to $500 per violation. Indiana authorizes fines of up to $5,000 for operating an unregistered medical spa and permits the Board to take disciplinary action, including suspension of a medical spa's registration.
• Oversight and Endorsement. With respect to HSB 591, the Iowa Board of Medicine would have primary oversight and could seek injunctions to prevent violations. Enforcement would involve the attorney general, disciplinary actions would be public, and certain misrepresentations by a medical spa would constitute consumer fraud. For SB 282 The Medical Licensing Board of Indiana would have primary oversight, with the authority to inspect facilities and investigate alleged violations. Denying access for an inspection would constitute a violation.

3. Prescription Drug Requirements

Iowa – HSB 591. A medical spa would be considered a "dispenser" under the federal Drug Supply Chain Security Act and must comply with its requirements. Prescription drugs and devices must be stored appropriately (e.g., in a well-lit, clean, and ventilated area and in accordance with manufacturer instructions) and maintained under appropriate supervision and controlled distribution.

Indiana – SB 282. Registration applications must identify all prescription drugs to be used at the medical spa, including compounded drugs. The bill also includes additional provisions related to pharmacy compliance with the federal Food, Drug, and Cosmetic Act, particularly for drug compounding.

4. Effective Dates (If Enacted)

Iowa HSB 591 does not specify a proposed effective date; however, the Iowa Board of Medicine would be required to adopt rules to implement and administer the chapter. Indiana SB 282 has a proposed general effective date of July 1, 2026, with the medical spa registration requirement taking effect, if passed, on January 1, 2027.

Next Steps

Medical spa operators in Iowa and Indiana should take the following steps in anticipation of these proposed regulations:

1. Monitor the progress of both Proposed Bills through the legislative process.
2. Review current operational practices to identify any gaps relative to the proposed requirements.
3. Identify licensed practitioners who could serve as the designated responsible person or practitioner should the Proposed Bills be enacted.
4. Evaluate prescription drug handling, storage, and security procedures.
5. Establish or enhance adverse event tracking and reporting protocols.
6. Consult with legal counsel regarding compliance strategies and the potential impact on business operations.

We will continue to monitor these legislative developments and provide updates as warranted. If you have any questions about how these proposed regulations may affect your medical spa operation, please contact your Quarles attorney or:

• Amy Cotton-Peterson: (602) 229-5530 / amy.cottonpeterson@quarles.com
• Bailey Walden: (602) 229-5432 / bailey.walden@quarles.com

END NOTES

¹ Iowa H.S.B. 591, 91^st Gen. Assemb., 2026 Sess. (introduced January 20, 2026), available here. 

² Ind. S.B. 282, 124^th Gen. Assemb. 2d Reg. Sess. (introduced January 12, 2026), available here.