The short answer for Illinois. Physician, or an FPA APRN acting independently.
A good faith exam is a clinical evaluation by a licensed provider, before treatment, establishing that the treatment is appropriate for that patient. What differs between states is who is allowed to perform it, whether it may happen remotely, and what has to be documented. This page sets out what we have verified for Illinois against primary sources, and says so plainly where a question is unsettled.
Who may perform the good faith exam in Illinois
Physician, or an FPA APRN acting independently.
Medical director. MD or DO, or an APRN holding full practice authority (attested 250 CE hours plus 4,000 post-certification clinical hours).
Delegation and supervision. Standard delegation, with the FPA carve-out removing the collaborative-agreement requirement for qualifying APRNs.
The gate that catches operators in Illinois
BIPA. A photograph alone is not a biometric identifier; a scan of face geometry is. $1,000 negligent / $5,000 intentional, private right of action, no proof of harm required.
SB 2979 ended per-scan damages accrual and the Seventh Circuit held that retroactive in 2026 — but the exposure itself is untouched.
What makes the exam defensible
Nobody is ever asked to produce a good faith exam on a good day. The request arrives after a complication, a board complaint, an insurance audit or a buyer’s diligence. Five things decide whether what you hand over helps you:
- A qualified practitioner, permitted in that state, actually performed it.
- A real evaluation happened — history, indications, contraindications, and a decision.
- The treatment plan and the order are specific: drug or device, site, dose or settings.
- Informed consent was taken and recorded before treatment, not after.
- The record still exists, unaltered and retrievable, two years later when somebody asks.
Only the first of those is state-specific. The other four fail in exactly the same way in Illinois as everywhere else, and they are where most exam processes actually break — not on the licence question, but on documentation nobody kept.
How Illinois sits on structure
Corporate practice of medicine. Yes, by the Medical Corporation Act — but an APRN with full practice authority may own and practise.
The exam and the structure are separate questions and they fail separately. A perfectly documented exam performed inside an entity that may not lawfully deliver the service is still a problem, and a clean entity does not save a rubber-stamped exam. See medical direction in Illinois for the structure side.
What MDside provides in Illinois
- Illinois-licensed physicians performing the exam themselves — not a queue of signatures.
- A written evaluation, treatment plan and order per patient, in a record you keep and can export.
- Protocols and delegation written to Illinois, matched to the services actually on your menu.
- A named Illinois medical director doing the work, where your structure needs one.
- 503A and 503B pharmacy relationships and in-house lab draws where the treatment calls for them.
Book a call and we will read your current exam process against the five tests above, in Illinois and any other state you operate in. The review is free and you are not obliged to use us for the fix.
Read the detail on Illinois
Frequently asked questions
Who can perform a good faith exam in Illinois?
Physician, or an FPA APRN acting independently.
Can the exam be done by telehealth in Illinois?
That depends on the state rule above and on the treatment. Where we have verified a restriction it is stated on this page; where the position is unsettled we say so rather than guess, and we confirm it with the board before you build a remote funnel.
Does Illinois require a physician medical director?
MD or DO, or an APRN holding full practice authority (attested 250 CE hours plus 4,000 post-certification clinical hours).
What happens if the exam is not documented?
The exam effectively did not happen. In a complaint, an audit or a sale, an undocumented evaluation is treated as no evaluation — which is why the record, not the call, is the thing you are actually buying.
Primary sources for Illinois: 805 ILCS 15 (Medical Corporation Act); 740 ILCS 14 (BIPA); SB 2979 (signed 2 Aug 2024). Last reviewed 2026-09-03. Corrections are welcome and get made: contact us.
General information about good faith exams and practice structure in Illinois, not legal advice. Requirements differ by state and change often. Confirm your obligations with healthcare counsel licensed in Illinois.