A good faith exam is a medical evaluation completed before a patient receives prescription-only aesthetic treatment. During the exam, an authorized healthcare provider reviews the patient’s medical history, performs a focused physical evaluation, and determines whether the planned treatment is appropriate. Although the specific requirements vary by state, the purpose is consistent: to establish a patient-provider relationship and support safe clinical decision-making.
Key Takeaways
- A good faith exam is a medical evaluation performed by an authorized provider, not a form or questionnaire completed by the patient alone. (Jump to Section)
- The provider reviews the patient’s medical history, performs a physical assessment, and determines whether treatment should proceed. (Jump to Section)
- Skipping the medical evaluation or relying on unqualified staff creates significant compliance risks for med spas. (Jump to Section)
- State laws determine who can perform a good faith exam, whether telehealth is permitted, and when repeat evaluations are required. (Jump to Section)
- Medical Director Co. helps med spas establish physician oversight that supports compliant patient evaluations. (Jump to Section)
What Happens During a Good Faith Exam?
A good faith exam is a medical evaluation that helps the provider determine whether a patient is an appropriate candidate for prescription-only aesthetic treatment. Instead of relying solely on intake forms or a consultation about cosmetic goals, the provider performs a clinical assessment based on the patient’s medical history, current health, and the treatment being considered.
The evaluation allows the provider to identify potential contraindications, discuss treatment risks and benefits, and decide whether treatment should proceed, be modified, or be postponed. Every clinical decision should be documented in the patient’s medical record before prescription-only treatment begins. While individual state requirements vary, the overall purpose remains the same: to support safe patient care and establish an appropriate patient-provider relationship.
Although the exact process differs depending on the state and procedure, most good faith exams follow the same four basic steps.
Steps of a Good Faith Exam
Most good faith exams follow the same four steps, although specific requirements vary by state and treatment type. Together, these steps help the provider evaluate treatment candidacy and document the clinical findings before prescription-only treatment begins.
Step 1: Review the Patient’s Medical History
A good faith exam begins with understanding the patient’s overall health before any treatment decisions are made. Reviewing the patient’s medical history helps the provider identify conditions, medications, allergies, or previous procedures that could affect treatment safety or influence the treatment plan.
The discussion commonly includes:
- Current medications and supplements
- Allergies and previous adverse reactions
- Existing medical conditions
- Previous cosmetic procedures
- Pregnancy or breastfeeding status, when applicable
This information helps the provider identify contraindications, determine whether additional evaluation is needed, and decide whether the planned treatment is appropriate.
Step 2: Perform a Physical Examination
Reviewing the patient’s medical history is only part of the evaluation. The provider also performs a physical examination to assess the treatment area, identify clinical concerns, and confirm that the patient is an appropriate candidate for the planned procedure.
Depending on the treatment, the provider may evaluate:
- Skin quality and tissue condition
- Facial anatomy or the intended treatment area
- Signs of infection or inflammation
- Factors that could affect treatment safety or expected outcomes
The examination is tailored to the procedure being performed. An injectable consultation requires a different assessment than IV therapy or a medical weight loss program.
Step 3: Discuss the Recommended Treatment
After completing the evaluation, the provider explains the clinical recommendation based on the patient’s medical history and physical examination. This discussion helps the patient understand the proposed treatment, the expected results, and any factors that could affect the treatment plan.
The discussion often includes:
- Expected treatment results
- Appropriate treatment options
- Medical risks or precautions
- Whether another treatment would be more appropriate
Patients should have the opportunity to ask questions before deciding whether to proceed with treatment.
Step 4: Document the Evaluation
The final step is documenting the examination and the provider’s clinical findings in the patient’s medical record. Complete documentation demonstrates that the evaluation occurred before treatment and supports patient safety, continuity of care, and regulatory compliance.
Depending on state law and practice policies, documentation commonly includes:
- Medical history findings
- Physical examination note.
- The provider’s clinical assessment
- The recommended treatment plan
Documentation requirements vary by state, so practices should maintain records that reflect the evaluation performed and comply with the laws governing their jurisdiction.
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How the Provider Makes a Treatment Decision
A good faith exam concludes with a clinical decision. The provider determines whether the patient is an appropriate candidate based on the medical history, physical examination, and the risks associated with the planned treatment.
The provider generally reaches one of three decisions:
- Proceed with treatment: The patient is an appropriate candidate, and treatment can move forward.
- Modify the treatment plan: The provider recommends changes to improve safety or achieve better clinical outcomes.
- Decline treatment: Medical conditions, contraindications, or other clinical concerns make the planned treatment inappropriate.
This decision is one of the most important parts of the evaluation. A good faith exam is not simply a compliance requirement. It provides the clinical basis for determining whether treatment is appropriate for that individual patient.
Common Good Faith Exam Mistakes That Create Compliance Risks
A good faith exam should be a documented medical evaluation performed by an authorized provider before treatment begins. Shortcuts that bypass or reduce the evaluation can create compliance issues and expose both the patient and the practice to unnecessary risk.
Some of the most common mistakes include:
Treating the Consultation as the Good Faith Exam
A consultation explains treatment options and pricing. A good faith exam is a medical evaluation. While both can happen during the same appointment, discussing cosmetic treatment goals alone does not satisfy the clinical assessment required before prescription-only treatment.
Relying Only on Patient Forms
Medical history forms provide useful information, but they are only one part of the evaluation. The provider should review the patient’s responses, ask follow-up questions when necessary, and make an independent clinical assessment before approving treatment.
Allowing Unqualified Staff to Perform the Evaluation
Only providers authorized under state law can independently perform a good faith exam. Registered nurses and estheticians often play an important role in patient care, but they cannot independently determine treatment candidacy when state law requires a provider with prescriptive authority to perform the evaluation.
Using the Same Evaluation for Every Treatment
Different procedures require different clinical assessments. A patient who previously completed a good faith exam for Botox may still need another evaluation before beginning medical weight loss therapy or hormone replacement treatment. Many states also require repeat evaluations after a specified period or when the patient’s health status changes.
Failing to Document the Clinical Decision
The provider’s decision should be supported by clear documentation. Medical records should reflect the patient’s history, examination findings, treatment recommendation, and any clinical reasons for modifying or declining treatment.
Practices should also review their state’s requirements for telehealth evaluations, renewal frequency, and documentation standards, as these requirements vary across jurisdictions.
How Medical Director Co. Supports Compliant Good Faith Exams
A compliant good faith exam starts with the right physician oversight and clearly documented clinical responsibilities. Medical Director Co. helps med spas establish physician relationships that support state-specific compliance requirements and documented patient evaluations.
Every placement includes:
- Qualified physician matching: Physicians matched to your specialty, treatment offerings, and state oversight requirements.
- Attorney-reviewed agreements: Documentation defining physician oversight, delegation, and clinical responsibilities.
- State-specific compliance support: Guidance based on your state’s physician delegation and supervision requirements.
- Ongoing physician oversight: Continued support as your practice expands services, adds providers, or updates clinical protocols.
Medical Director Co. helps practices establish physician oversight that supports compliant patient evaluations before prescription-only treatments are performed.
Establish Compliant Good Faith Exams
Qualified physician oversight with attorney-reviewed agreements.
Frequently Asked Questions
Does the patient need to be examined in person?
Many states allow a good faith exam through a live, synchronous video consultation conducted by an authorized provider. Other states require an in-person examination or impose additional conditions. Practices should follow the telehealth requirements that apply in the state where they operate.
Can an aesthetician conduct the good faith exam?
Aestheticians are not licensed to diagnose medical conditions or determine whether a patient is an appropriate candidate for prescription-only treatment. The evaluation should be performed by a provider who has the authority to conduct the examination under state law.
How long does a good faith exam typically take?
The length of the examination depends on the patient’s medical history and the treatment being considered. The provider should have enough time to review the patient’s history, perform a focused examination, answer questions, and document the clinical findings before treatment begins.
What happens if the provider decides against treatment?
The provider documents the clinical findings and explains why the planned treatment is not appropriate. Depending on the circumstances, the provider may recommend modifying the treatment plan, postponing treatment, or declining the procedure altogether.
Is one exam enough for every future visit?
Many practices perform another evaluation when a patient’s health status changes, a new treatment is introduced, or state law requires a repeat examination. Renewal requirements differ by state, so practices should follow the rules that apply to their location.
Supporting Safe Treatment Starts Before the Procedure
A good faith exam helps providers determine whether prescription-only aesthetic treatment is appropriate before the procedure begins. Although the specific requirements vary by state, every evaluation should include a meaningful medical assessment, a documented clinical decision, and appropriate physician oversight where required. Following these steps helps support patient safety and long-term compliance.
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Bolton M. Harris, J.D., is a seasoned attorney with a formidable background in criminal law and a focus on healthcare law and compliance. As the in-house legal counsel at Medical Director Co., Harris brings a unique blend of prosecutorial experience and regulatory expertise to support healthcare professionals across Texas. Her career spans roles as a prosecutor in multiple counties and now as a trusted advisor on the legal intricacies of medical practice operations.
Education & Early Career
Bolton Harris completed her undergraduate studies at Southern Methodist University (SMU) in 2013. During her time at SMU, she was not only a dedicated student but also a competitive athlete on the university’s women’s swimming team. She went on to earn her Juris Doctor from Texas A&M University School of Law in 2016 and became a member of the Texas Bar that same year. Armed with a strong academic foundation and discipline honed as a student-athlete, Harris embarked on a career in criminal law immediately after law school.
Prosecutorial Experience in Texas
Bolton Harris began her legal career in public service as a criminal prosecutor. She served as an Assistant District Attorney in multiple jurisdictions, where she quickly rose through the ranks and handled a broad spectrum of cases. Some highlights of her prosecutorial career include:
- Assistant District Attorney, Dallas County, Texas: Prosecuted a high volume of criminal cases in one of the state’s busiest DA offices, gaining extensive trial experience in both misdemeanor and felony courts.
- Assistant District Attorney, Ellis County, Texas: Continued to hone her courtroom advocacy skills, known for meticulous case preparation and a tenacious pursuit of justice on behalf of the community.
- Assistant District Attorney, Navarro County, Texas: Broadened her legal expertise by handling diverse criminal matters in a smaller county, working closely with law enforcement and community leaders to uphold the law.
Through these roles, Harris built a reputation for being a tough but fair advocate. She brought numerous cases to trial and developed an in-depth understanding of the criminal justice system. This distinguished prosecutorial background laid a strong foundation for the next phase of her career in the private sector.
Healthcare Law & Compliance at Medical Director Co.
After her tenure as a prosecutor, Harris shifted her focus to healthcare law, applying her legal acumen to the medical field. She recognized that the same attention to detail and tenacity that served her in criminal law could benefit healthcare providers navigating complex regulations. Embracing this new direction, Harris became well-versed in the intricate laws governing medical practices – from licensing requirements to patient safety and privacy standards – and is passionate about helping practitioners stay compliant.
In her current role as the in-house attorney for Medical Director Co., Bolton Harris oversees all legal and compliance matters for the organization and its clients. Medical Director Co. is a nurse-owned firm that connects nurse practitioners (NPs), physician assistants (PAs), and registered nurses with qualified medical directors and collaborating physicians, offering fast placements and comprehensive compliance support for healthcare practices. Harris ensures that each of these partnerships and clinical ventures adheres to all applicable state and federal laws. She is responsible for drafting and reviewing collaborative practice agreements, advising on regulatory requirements, and providing ongoing legal counsel as clients establish and grow their clinics. Drawing on her prosecutorial eye for risk management, Harris proactively identifies potential legal issues and addresses them before they escalate, giving healthcare professionals peace of mind.
Bolton M. Harris’s multifaceted expertise – spanning high-stakes courtroom litigation to detailed healthcare compliance – makes her a formidable legal ally. Whether advocating in front of a jury or guiding a medical practice through regulatory hurdles, she remains committed to the highest standards of the legal profession. Her blend of courtroom-tested skill and healthcare law knowledge ensures that clients of Medical Director Co. receive elite-level counsel and steadfast protection in an ever-evolving legal landscape.
