A medical director can perform the good faith exam directly, and many do. Others delegate the good faith exam to a qualified nurse practitioner or physician assistant and spend their own time on protocol development, chart review, and oversight across the practice. Both models can meet good faith exam requirements. The right one depends on your practice’s size, patient volume, and how many locations the medical director actually covers.

When a Medical Director Performs Exams Directly

A medical director performs the good faith exam directly, most often at single-location practices with lower patient volume. These practices frequently have no other licensed provider on staff qualified to take on the exam. The medical director then becomes the default choice for both the exam and the oversight that follows it.

• Single-location setup: The medical director is the only clinician on site, making direct good faith exams the most practical option.
• Lower patient volume: A smaller patient base keeps the good faith exam workload manageable for one provider to handle personally.
• No qualified delegate on staff: Without a licensed nurse practitioner or physician assistant credentialed to perform the good faith exam, the medical director must perform it.
• Early-stage practices: A practice still building its patient base often has not yet hired a delegate, so the medical director defaults to handling exams directly.
• Continuity-focused treatment models: Some practices are built around direct medical director involvement, so the good faith exam stays with the medical director to protect that continuity.

Performing the good faith exam directly simplifies staffing, but it does not simplify the documentation standard. Every exam still needs to meet the same physician good faith exam responsibilities a delegated model would require, including a documented finding, a signed record, and a clear basis for the treatment plan that follows.

When Delegation Makes More Sense

Delegation becomes the more practical model as a practice adds locations, increases patient volume, or shifts to a telehealth-based structure. A single medical director cannot be on site for every appointment once a practice scales past one location. Delegating the good faith exam to a licensed nurse practitioner or physician assistant, acting within their scope of practice, keeps the exam workflow moving without the medical director as a bottleneck.

• Multi-location practices: A medical director covering several sites cannot be physically present for every good faith exam, so delegation keeps each location running.
• Telehealth-based oversight: A remote medical director relies on an on-site or local licensed provider to perform the good faith exam in person.
• High patient volume: A practice processing a large number of good faith exams per week needs more than one qualified provider handling them.
• Rapid growth or expansion: A practice scaling quickly often outpaces what one medical director can personally examine.
• Specialized staffing models: Some practices hire nurse practitioners or physician assistants specifically to handle good faith exams, freeing the medical director for oversight and protocol work.

Delegation changes the medical director’s role from performer to supervisor, but the good faith exam still has to meet the same clinical standard. That means the delegate needs documented qualifications, the exam protocol needs to specify what the delegate is checking for, and the medical director needs a set schedule for reviewing charts rather than an informal or occasional check-in. Without that structure, delegation becomes a liability.

What Matters More Than Who Does the Exam

Regulators, malpractice carriers, and state medical boards care less about who physically performs the good faith exam and more about whether proper oversight exists behind it. A medical director who delegates but never reviews a chart carries more liability than one who delegates and audits consistently. Whether a practice performs exams directly or delegates them, the same oversight standards determine whether the model holds up under review.

• Provider qualification: The person performing the good faith exam is licensed and qualified to do so within their scope of practice.
• Documented review process: The medical director has a written process for reviewing the delegate’s work, not an informal habit.
• Scheduled chart audits: The review actually happens on a set schedule, rather than only when a problem arises.
• State-specific compliance: Good faith exam rules vary by state, including who can perform the exam, whether telehealth exams are permitted, and how often the exam must be renewed.

A policy that skips any of these stops matching how the practice actually operates. State requirements decide whether a delegation model works, so always confirm them before finalizing one. The American Med Spa Association is a useful resource for tracking how these standards continue to develop across the industry.

How Medical Director Co. Structures This Based on Your Practice

How Medical Director Co. Structures This Based on Your Practice

No two practices run the same way, and treating them like they do is how compliance gaps slip through. A single-location med spa with a handful of weekly appointments doesn’t need the same oversight structure as a multi-site practice seeing hundreds of patients a month, and assuming otherwise either overloads a small practice with unnecessary process or leaves a growing one dangerously under-supervised.

That’s why we start by looking at the specifics of your operation before deciding who performs the exam, how often charts get reviewed, and what the documentation protocol actually requires. Here’s what we assess and build for your specific situation.

• Practice Assessment: We review your patient volume, location count, and current staffing to determine who should perform the exam and how oversight should work, so the structure fits how your practice actually operates.
• Exam Assignment: We assign the good faith exam to the medical director or a qualified delegate based on that review, ensuring the right person is handling the evaluation given your state’s requirements and your team’s qualifications.
• Documented Protocol: We build a documented protocol specifying exactly what the exam must cover and who signs off on it, so there’s no ambiguity about what constitutes a complete evaluation.
• Chart Review Schedule: We set a chart review schedule tied to your patient volume, weekly for high-volume practices, monthly for smaller ones, and confirm the medical director follows it consistently.
• State-Specific Compliance Check: We check the structure against the specific rules of the state where you operate, since a model that’s compliant in one state can fail in another.