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Start a clinic / Illinois

How to start a medical clinic in Illinois.

What a founder needs to know in Illinois: who can own a practice, which state approvals apply, how nurse practitioners and PAs can work, and where to register. Every fact links to its source.

Updated October 2026Sources linked
ILIllinoisStarting a clinic, at a glance
Corporate practice of medicine
StrictOwnership generally limited to licensed physicians
Certificate of need program
YesState review for some facilities or equipment
Nurse practitioner authority
Reduced practiceAANP classification
Register your business with
Illinois Secretary of State, Department of Business Services
Checked October 2026

Ownership: Illinois enforces the corporate practice of medicine doctrine: physicians may share fees only within entities wholly owned by Illinois-licensed physicians (medical corporations, professional associations, LLCs), licensed hospitals and hospital affiliates, physician-owned ASTCs and certain academic nonprofits.

Certificate of need: Illinois has a CON (permit) program run by the Health Facilities and Services Review Board covering hospitals, long-term care, dialysis centers, ambulatory surgery centers, freestanding emergency centers and birthing centers, plus major medical equipment and capital spending over the minimum.

Nurse practitioners: AANP classifies Illinois as reduced practice; NPs generally need a written collaborative agreement with a physician (Nurse Practice Act Sec. 65-35), and those who complete the continuing education and clinical experience hours set in Sec. 65-43 can obtain an IDFPR Full Practice Authority (APRN-FPA) license to practice without one.

Who can own a medical clinic in Illinois

Illinois enforces the corporate practice of medicine doctrine: physicians may share fees only within entities wholly owned by Illinois-licensed physicians (medical corporations, professional associations, LLCs), licensed hospitals and hospital affiliates, physician-owned ASTCs and certain academic nonprofits. Management companies are common, but the Medical Practice Act bars paying anyone a percentage of professional fees for marketing or managing the practice, while fair market value billing and collection fees (including percentage fees) are allowed if the practice controls collections.

Sources: law.justia.com, ndlegis.gov

Business entity and registration

Physicians usually form a medical corporation under the Medical Corporation Act (805 ILCS 15) or a physician-owned LLC; all owners, officers and directors must be Illinois-licensed physicians, and the entity must also hold a certificate of registration from IDFPR for each practice location, renewed every three years. The entity itself is formed with the Illinois Secretary of State.

Sources: law.justia.com, law.justia.com

Certificate of need in Illinois

Illinois has a CON (permit) program run by the Health Facilities and Services Review Board covering hospitals, long-term care, dialysis centers, ambulatory surgery centers, freestanding emergency centers and birthing centers, plus major medical equipment and capital spending over the minimum. An ASC needs HFSRB approval, but ordinary physician offices are not listed as covered; the CON law is scheduled for repeal in December 2029.

Sources: ncsl.org, hfsrb.illinois.gov

Licenses, registrations and state agencies

The Illinois Department of Public Health licenses ambulatory surgical treatment centers (facilities devoted primarily to surgical procedures) under the ASTC Act; IDPH does not license ordinary physician offices. The separate IDFPR medical corporation registration applies to each corporate practice location.

Sources: law.justia.com, law.justia.com

Illinois-specific requirements to know

Practitioners need an Illinois controlled substance license from IDFPR in addition to DEA registration (720 ILCS 570/302). Under Public Act 104-0512, effective January 1, 2027, prescribers or their designees must document an attempt to review the patient's ILPMP profile before prescribing any C-II opioid or C-IV benzodiazepine and before an initial C-II stimulant. Medical corporations need an IDFPR certificate of registration for every location before operating.

Sources: law.justia.com, ilpmp.org, law.justia.com

Agencies you will deal with

Nurse practitioners and physician assistants

Nurse practitioners: AANP classifies Illinois as reduced practice; NPs generally need a written collaborative agreement with a physician (Nurse Practice Act Sec. 65-35), and those who complete the continuing education and clinical experience hours set in Sec. 65-43 can obtain an IDFPR Full Practice Authority (APRN-FPA) license to practice without one.

Sources: aanp.org, law.justia.com, idfpr.illinois.gov

Physician assistants: PAs practice under a written collaborative agreement with a physician, who must consult at least monthly and may collaborate with up to 7 full-time-equivalent PAs (hospitals, FQHCs and ASTCs are exempt from the ratio), and the physician must file notice of collaboration with IDFPR within 60 days.

Sources: law.justia.com

Med spas, injectables and IV therapy in Illinois

Because of the strict CPOM rules and fee-splitting ban, a non-physician cannot own the medical side of a med spa or take a percentage of its professional fees for management. Confirm the details with the state board and a healthcare attorney.

Sources: law.justia.com

Planning an aesthetic or IV business? See how to start a med spa and how to start an IV therapy business.

Step-by-step checklist in Illinois

  1. Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Illinois’s corporate practice of medicine rules. Illinois enforces the corporate practice of medicine doctrine: physicians may share fees only within entities wholly owned by Illinois-licensed physicians (medical corporations, professional associations, LLCs), licensed hospitals and hospital affiliates, physician-owned ASTCs and certain academic nonprofits.
  2. Form the entity with the Illinois Secretary of State, Department of Business Services. Physicians usually form a medical corporation under the Medical Corporation Act (805 ILCS 15) or a physician-owned LLC; all owners, officers and directors must be Illinois-licensed physicians, and the entity must also hold a certificate of registration from IDFPR for each practice location, renewed every three years.
  3. Get federal numbers. Apply for an EIN from the IRS, then a Type 2 NPI for the practice and Type 1 NPIs for each clinician through NPPES.
  4. Confirm licenses with the Illinois Department of Financial and Professional Regulation (Medical Licensing Board). Every physician needs a Illinois license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
  5. Check certificate of need and facility licensing. Illinois has a CON (permit) program run by the Health Facilities and Services Review Board covering hospitals, long-term care, dialysis centers, ambulatory surgery centers, freestanding emergency centers and birthing centers, plus major medical equipment and capital spending over the minimum.
  6. Register to prescribe. Register with the DEA for controlled substances and complete any Illinois controlled substance registration and prescription monitoring program enrollment. Practitioners need an Illinois controlled substance license from IDFPR in addition to DEA registration (720 ILCS 570/302).
  7. Set up lab, safety and privacy basics. Get a CLIA certificate if you will run any lab tests, including waived tests, and put HIPAA privacy and security and OSHA policies in place.
  8. Enroll with Medicare, Medicaid and insurers. Enroll in Medicare through PECOS, enroll with Illinois Medicaid (HFS IMPACT) and start commercial credentialing early, because payer enrollment often takes months.
  9. Plan staffing around NP and PA rules. AANP classifies Illinois as reduced practice; NPs generally need a written collaborative agreement with a physician (Nurse Practice Act Sec. 65-35), and those who complete the continuing education and clinical experience hours set in Sec. 65-43 can obtain an IDFPR Full Practice Authority (APRN-FPA) license to practice without one.
  10. Launch your marketing before opening day. Claim your Google Business Profile, publish a website with online booking and start ads and content four to eight weeks before you open, so the schedule is not empty on day one.

The national steps are explained in more detail in our guide to how to start a medical clinic, and costs are broken down in how much it costs to start a clinic.

Marketing a new clinic in Illinois

New clinics usually fail on cash flow before they fail on care. The fastest fix is patients booked before opening day: a complete Google Business Profile, a website with online booking, local search ads and a few weeks of social content showing the team and the space. We run that launch for new clinics and keep it going once the doors open.

Plan your Illinois launch with us →

Important. This guide is general information checked against official and professional sources in October 2026. It is not legal advice. Rules change and details depend on your services, so confirm your plan with a healthcare attorney licensed in Illinois and with the agencies listed above.

Sources

  1. https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-60/
  2. https://ndlegis.gov/assembly/67-2021/testimony/SHUMSER-2128-20210125-3125-F-TRAYNOR_PAT.pdf
  3. https://law.justia.com/codes/illinois/chapter-805/act-805-ilcs-15/
  4. https://www.ncsl.org/health/certificate-of-need-state-laws
  5. https://hfsrb.illinois.gov/
  6. https://www.aanp.org/advocacy/illinois
  7. https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-65/article-65/
  8. https://idfpr.illinois.gov/profs/nursing.html
  9. https://law.justia.com/codes/illinois/chapter-225/act-225-ilcs-95/
  10. https://law.justia.com/codes/illinois/chapter-210/act-210-ilcs-5/
  11. https://law.justia.com/codes/illinois/chapter-720/act-720-ilcs-570/article-iii/
  12. https://www.ilpmp.org/

Nearby state guides

WisconsinIowaMissouriKentuckyIndianaAll states
Illinois questions

Starting a clinic in Illinois, answered.

Can a non-physician own a medical clinic in Illinois?
Illinois enforces the corporate practice of medicine doctrine: physicians may share fees only within entities wholly owned by Illinois-licensed physicians (medical corporations, professional associations, LLCs), licensed hospitals and hospital affiliates, physician-owned ASTCs and certain academic nonprofits. Management companies are common, but the Medical Practice Act bars paying anyone a percentage of professional fees for marketing or managing the practice, while fair market value billing and collection fees (including percentage fees) are allowed if the practice controls collections.
Does Illinois require a certificate of need to open a clinic?
Illinois has a CON (permit) program run by the Health Facilities and Services Review Board covering hospitals, long-term care, dialysis centers, ambulatory surgery centers, freestanding emergency centers and birthing centers, plus major medical equipment and capital spending over the minimum. An ASC needs HFSRB approval, but ordinary physician offices are not listed as covered; the CON law is scheduled for repeal in December 2029.
Can nurse practitioners open their own practice in Illinois?
AANP classifies Illinois as reduced practice; NPs generally need a written collaborative agreement with a physician (Nurse Practice Act Sec. 65-35), and those who complete the continuing education and clinical experience hours set in Sec. 65-43 can obtain an IDFPR Full Practice Authority (APRN-FPA) license to practice without one.
Who can perform Botox, laser or IV therapy in Illinois?
Because of the strict CPOM rules and fee-splitting ban, a non-physician cannot own the medical side of a med spa or take a percentage of its professional fees for management. Confirm the details with the state board and a healthcare attorney.
Where do I register a medical practice in Illinois?
Physicians usually form a medical corporation under the Medical Corporation Act (805 ILCS 15) or a physician-owned LLC; all owners, officers and directors must be Illinois-licensed physicians, and the entity must also hold a certificate of registration from IDFPR for each practice location, renewed every three years. The entity itself is formed with the Illinois Secretary of State.