Ohio is the state that breaks every national compliance chart, because it went the opposite way from everyone else.
Ohio has declared that the corporate practice of medicine doctrine no longer exists in Ohio. The law does not prohibit licensed physicians from rendering medical services as employees of a corporation or any other business entity. Corporations, LLCs, partnerships and professional associations may employ physicians. A non-physician may own a med spa outright.
For an operator coming from California or New York, that reads like a holiday. It is not.
Ownership is open. Control is not.
The line Ohio draws is not around who holds the equity; it is around who makes the clinical decision. A corporation may employ physicians and may not control their clinical judgment regarding patient care. Physicians must retain control of diagnosis, treatment, prescribing, delegation and quality assurance, and the State Medical Board enforces that through the unprofessional-conduct provisions at ORC 4731.22.
So the structure question changes shape. In California you spend your effort proving the entity is properly owned. In Ohio you spend it proving the physician actually decides — which, in a business owned by someone else, needs to be visible in documents and in behaviour, not asserted in a recital.
Then the treatment room, which is stricter than most
Having opened ownership, Ohio tightened delegation. Its laser rules are the most demanding in this batch:
- Delegated laser hair removal is governed by ORC 4731.33 and the Medical Board’s rules at OAC ch. 4731-18.
- The delegate must have observed fifteen procedures and performed twenty under direct physical oversight, for each specific device type.
- Direct physical oversight means the supervising physician is in the same room, directly observing. Off-site supervision does not satisfy it.
- A physician may not delegate the application of light-based devices for ablative procedures at all.
The arithmetic of that is worth its own article.
What this means for how you buy medical direction
Because ownership is open, Ohio operators often conclude they need a medical director less than operators elsewhere. The opposite is closer to true. Ohio has removed the ownership constraint and left you with a supervision constraint that requires a physician who is genuinely present for certain procedures and genuinely in charge of clinical policy for all of them.
A remote name on a certificate satisfies neither ORC 4731.22 nor the direct-physical-oversight rule. It just costs less.
Related reading
Frequently asked questions
Can a non-physician own a med spa in Ohio?
Yes. Ohio has declared that the corporate practice of medicine doctrine no longer exists, and business entities may employ physicians.
Does that mean we do not need a medical director?
No. Physicians must retain control of diagnosis, treatment, prescribing, delegation and quality assurance, and certain delegated procedures require the physician in the room.
Can our corporation set clinical protocols?
A corporation may not control physician clinical judgment regarding patient care. Clinical policy belongs to the physician even where the equity does not.
Is Ohio easier than California?
On ownership, considerably. On supervision of laser procedures, Ohio is stricter. It is a different trade, not a smaller one.
General information about Ohio practice structure, not legal advice. Statutes and board rules change. Confirm your obligations with healthcare counsel licensed in Ohio.