Compounding Oversight—New Regulations for Medical Spas and Compounding Pharmacies
May 20, 2026
By: Grant M. Achenbach and Madison Hartman Harada
This is the first article in a two-part series regarding Senate Enrolled Act (“SEA”) 282 (2026)
One of two major substantive components enacted in SEA 282 is a new framework for regulating medical spas. States across the country have begun to pass and implement similar laws due to the rising popularity and prevalence of medical spas. Due to the novelty of the issue, the Indiana General Assembly characterized the medical spa provisions of SEA 282 as an initial approach to a topic that will certainly be further addressed in future sessions.
For the purposes of the new regulations passed in SEA 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, and holds itself out as being focused on cosmetic or lifestyle treatments, including weight loss, botox injections and dermal fillers, and the use of lasers for cosmetic purposes. Importantly, the term doesn’t apply to facilities that are otherwise licensed or physician offices.
Beginning on January 1, 2027, medical spas will be required to register with the Indiana Medical Licensing Board (“MLB”). The registration process will be established by the MLB by October 1, 2026, to give medical spas time to prepare. A public database will also be established and maintained by the MLB that will host information regarding registered medical spas. Medical spas that operate without registration risk a fine of up to $5,000.
Medical spas are also required to designate a responsible practitioner (a provider with prescriptive authority, such as a physician nurse practitioner, or physician assistant). The responsible practitioner must be physically present at the medical spa for a sufficient time to ensure compliance and that individuals working within the medical spa are appropriately licensed and trained. The MLB is granted authority to investigate medical spas and, if there are any violations of medical spa regulations, may forward substantiated claim’s to the responsible practitioner’s relevant licensing board.
Finally, SEA 282 requires medical spas to report serious adverse events and comply with Indiana’s health care provider advertising laws. It also prohibits medical spas from providing services to consumers at locations other than the medical spa—as a result, services may not be provided in individuals’ homes or other public places (with very limited exceptions).
If you have questions about whether your office or practice will be required to comply with SEA 282’s new regulations regarding medical spas, please don’t hesitate to contact Grant Achenbach or Madison Harada. Look for the second-part of this series soon, which will cover new Indiana regulations regarding compounded drugs.
Disclaimer: The contents of this article should not be construed as legal advice or a legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult with counsel concerning your situation and specific legal questions you may have.
Practices
Industries
May 20, 2026
By: Grant M. Achenbach and Madison Hartman Harada
This is the first article in a two-part series regarding Senate Enrolled Act (“SEA”) 282 (2026)
One of two major substantive components enacted in SEA 282 is a new framework for regulating medical spas. States across the country have begun to pass and implement similar laws due to the rising popularity and prevalence of medical spas. Due to the novelty of the issue, the Indiana General Assembly characterized the medical spa provisions of SEA 282 as an initial approach to a topic that will certainly be further addressed in future sessions.
For the purposes of the new regulations passed in SEA 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, and holds itself out as being focused on cosmetic or lifestyle treatments, including weight loss, botox injections and dermal fillers, and the use of lasers for cosmetic purposes. Importantly, the term doesn’t apply to facilities that are otherwise licensed or physician offices.
Beginning on January 1, 2027, medical spas will be required to register with the Indiana Medical Licensing Board (“MLB”). The registration process will be established by the MLB by October 1, 2026, to give medical spas time to prepare. A public database will also be established and maintained by the MLB that will host information regarding registered medical spas. Medical spas that operate without registration risk a fine of up to $5,000.
Medical spas are also required to designate a responsible practitioner (a provider with prescriptive authority, such as a physician nurse practitioner, or physician assistant). The responsible practitioner must be physically present at the medical spa for a sufficient time to ensure compliance and that individuals working within the medical spa are appropriately licensed and trained. The MLB is granted authority to investigate medical spas and, if there are any violations of medical spa regulations, may forward substantiated claim’s to the responsible practitioner’s relevant licensing board.
Finally, SEA 282 requires medical spas to report serious adverse events and comply with Indiana’s health care provider advertising laws. It also prohibits medical spas from providing services to consumers at locations other than the medical spa—as a result, services may not be provided in individuals’ homes or other public places (with very limited exceptions).
If you have questions about whether your office or practice will be required to comply with SEA 282’s new regulations regarding medical spas, please don’t hesitate to contact Grant Achenbach or Madison Harada. Look for the second-part of this series soon, which will cover new Indiana regulations regarding compounded drugs.
Disclaimer: The contents of this article should not be construed as legal advice or a legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult with counsel concerning your situation and specific legal questions you may have.