A good faith exam (GFE) is the clinical evaluation that has to happen before a patient receives a medical aesthetic, weight-management, or hormone treatment. It is the step that turns a cosmetic transaction into a treatment delivered under a provider-patient relationship — and it is the single most common thing regulators find missing when they look at a med spa, IV lounge, or wellness clinic.
This guide covers who is allowed to perform a good faith exam, when one is required, how telehealth changes the answer, and what the documentation actually has to contain.
What a good faith exam actually is
A good faith exam is an evaluation by a licensed provider who is authorized to diagnose and prescribe. The provider reviews the patient’s history, assesses whether the requested treatment is appropriate, identifies contraindications, and either authorizes the treatment or does not.
It is not a form the patient fills out. It is not a waiver. It is not a consent signature. Intake paperwork feeds the exam; it does not replace it.
The reason the requirement exists is that most aesthetic and wellness treatments are the practice of medicine. Neurotoxins, dermal fillers, prescription weight-management drugs, hormone therapy, and IV infusions all require a prescription or an order from a licensed provider. Someone has to make that clinical decision, and that person has to be qualified to make it.
Who can perform a good faith exam
Depending on the state and the scope of the treatment, a good faith exam is performed by a physician (MD or DO), a nurse practitioner, or a physician assistant. These are the license types that can evaluate, diagnose, and issue orders.
Registered nurses, licensed practical nurses, medical assistants, estheticians, and laser technicians cannot perform a good faith exam. They may collect intake information, assist during the encounter, and — where state law and delegation rules permit — administer a treatment after it has been authorized. What they cannot do is make the authorizing decision.
| Role | Can perform the GFE? | Typical role in the encounter |
|---|---|---|
| Physician (MD/DO) | Yes | Evaluates, authorizes, supervises |
| Nurse practitioner | Generally yes, scope varies by state | Evaluates and authorizes within scope |
| Physician assistant | Generally yes, under a practice agreement | Evaluates and authorizes within scope |
| Registered nurse | No | Administers under an existing order |
| Esthetician / laser tech | No | Performs delegated non-medical services |
Two qualifiers matter. First, nurse practitioner and physician assistant authority is state-specific — some states grant full practice authority, others require a collaborative or supervisory relationship with a physician. Second, the provider must hold an active license in the state where the patient is physically located at the time of the exam, not where the business is incorporated.
When a good faith exam is required
There are three moments that generally trigger a new exam:
- A new patient. Before the first treatment, always.
- A new treatment category. A patient cleared for neurotoxins has not been cleared for a GLP-1 prescription or hormone therapy. Different drug class, different risk profile, different evaluation.
- A material change in health status. A new diagnosis, a new medication, a pregnancy, a significant adverse reaction — any of these can invalidate a prior authorization.
Many operators assume a single exam covers a patient indefinitely across everything on the menu. It does not. This is one of the most common structural gaps we see when reviewing an existing operation.
Telehealth good faith exams
In most states a good faith exam may be conducted over telehealth, and this is how a large share of exams are performed today. The conditions that generally apply:
- Licensure follows the patient. The provider must be licensed in the state where the patient is sitting.
- Modality matters. Some states require synchronous audio-video. Others permit asynchronous review for certain treatment categories. This varies meaningfully, and it varies by drug class as well as by state.
- Controlled substances carry extra rules. Federal requirements around remote prescribing of controlled substances are separate from, and stricter than, state telehealth rules.
- The record has to prove it happened. A telehealth exam with no durable documentation is, for practical purposes, an exam that did not occur.
What the documentation has to show
If a board or a payer reviews the chart, the record should make the clinical reasoning visible. At minimum:
- Patient identity and the state they were located in during the encounter
- Relevant medical history, current medications, and allergies
- The specific treatment or drug class evaluated
- Contraindications considered and ruled out
- The authorizing decision, with the provider’s name, license, and credentials
- Date and time, and the modality if conducted remotely
- Informed consent appropriate to the treatment
A good test: could a reviewer who has never met the patient reconstruct why this treatment was appropriate for this person on that date? If not, the documentation is thin.
Where operations go wrong
The failure patterns are consistent:
- The exam is retroactive. Paperwork is completed after the treatment to make the file look complete. This is the worst version of the problem.
- The wrong person signs. An RN or medical assistant documents the evaluation because the provider was unavailable.
- One exam, every service. A patient cleared for filler is then given semaglutide on the same authorization.
- Licensure mismatch. The provider is licensed in the business’s home state but the patient was in another.
- No standing orders behind delegated work. Staff administer treatments with no written protocol authorizing them to do so.
How the structure supports the exam
A good faith exam requirement is not really a paperwork problem — it is a structural one. Someone has to employ or contract the providers, hold the clinical records, write the protocols, and maintain licensure across every state where patients are located. In most non-physician-owned businesses, that entity is a professional corporation operating alongside a management services organization.
MDside builds and operates that structure. We form the state-specific professional corporation, place licensed providers, maintain the protocols and standing orders, and run the exam and documentation workflow on software we build and own. See how the structure works, or look at the businesses we support.
Frequently asked questions
Can a registered nurse perform a good faith exam?
No. An RN may administer a treatment under an existing order and written protocol, but cannot perform the evaluation that authorizes it. That requires a physician, nurse practitioner, or physician assistant acting within their state scope.
Does a good faith exam expire?
There is no single national expiration. A new exam is generally required for a new treatment category or a material change in health status, and many operations set an internal validity period. The safer practice is to define that period in your protocols rather than leave it open-ended.
Can the good faith exam be done by video?
In most states, yes, provided the provider is licensed where the patient is located and the modality meets that state’s telehealth standard. Some states and some drug classes require live audio-video rather than asynchronous review.
Who is responsible if the exam was not performed?
Exposure typically runs to the treating provider and to the professional entity, and depending on the arrangement and the state, to the business operating the location. This is one of the reasons the entity structure matters as much as the clinical workflow.
Does a med spa need its own medical director if it uses a PC-MSO structure?
The professional corporation needs a physician in the medical director or supervising role. Whether that person also carries a separate title with the operating business depends on state law and how the arrangement is documented.
This article is general information about how good faith exam requirements are commonly structured. It is not legal advice, and requirements vary by state and by treatment type. Confirm your obligations with healthcare counsel licensed in the states where you operate.