A good faith exam (GFE) is a medical evaluation used to determine whether a patient is an appropriate candidate for a proposed treatment. In medical aesthetics, the term commonly refers to the assessment performed before certain prescription-based or physician-delegated procedures. Although many med spas use the phrase, state laws may refer to an appropriate prior examination, a medical evaluation, or the establishment of a patient-provider relationship instead.
Medical Director Co. works with med spas that need physician oversight for these evaluations. Knowing what a GFE involves, who can perform one, and when it is required can help clinic owners establish appropriate treatment procedures and avoid preventable compliance problems.
Key Takeaways
- A good faith exam evaluates whether a patient is medically suitable for treatment, although the exact legal requirements differ by state. (Jump to Section)
- A GFE typically includes reviewing the patient’s medical history and conducting an appropriate clinical examination. (Jump to Section)
- Physicians and certain advanced practice providers may perform these evaluations when authorized under state law. (Jump to Section)
- Medical evaluations are commonly required before certain injectable treatments, medical aesthetic procedures, and prescription-based wellness services. (Jump to Section)
- Appropriate physician oversight can help med spas establish clinical protocols and clarify responsibility for patient evaluations. (Jump to Section)
The Real Regulatory Standard Behind the Good Faith Exam
The phrase good faith exam is familiar to people working in the medical aesthetics industry. However, it does not appear as a separately defined requirement in every state’s medical practice laws.
Instead, medical boards commonly regulate the clinical steps that need to take place before certain treatments. These may include establishing a patient-provider relationship, obtaining a relevant medical history, performing an appropriate examination, and documenting the decision to proceed.
California and Texas offer useful examples of how those requirements differ.
California: The Medical Board of California treats many cosmetic procedures as medical services. Its guidance addresses appropriate prior examinations, physician delegation, and the qualifications of individuals performing treatment.
Texas: The Texas Medical Board regulates nonsurgical medical cosmetic procedures as medical acts. Its rules address patient evaluation, treatment authorization, physician delegation, and clinical responsibilities.
Other states may apply different requirements based on the procedure, the provider’s license, and how care is delivered. A process accepted in one state should not automatically be used in another.
For med spa owners, the important question is not simply whether a form labeled “Good Faith Exam” has been completed. The patient must receive the evaluation required for the planned treatment, performed by a properly authorized clinician and documented in the medical record.
Build a Compliant Patient Evaluation Process
Your clinic's evaluation procedures should reflect the treatments you offer and the professionals responsible for patient care. Medical Director Co. can help you find physician oversight suited to those needs.
The Two Parts of a Good Faith Exam
A good faith exam helps a healthcare provider decide whether treatment is appropriate for a particular patient. It also provides an opportunity to identify medical concerns that might otherwise be missed during a routine cosmetic consultation.
The scope of the evaluation depends on the planned procedure and applicable state requirements. Most assessments involve two main components.
Medical History Review
A medical history review gives the evaluating provider a better understanding of the patient’s health and any factors that could affect treatment.
Depending on the procedure, this may include:
Current medications and supplements.
Drug allergies or previous allergic reactions.
Existing medical conditions.
Previous cosmetic procedures.
Pregnancy or breastfeeding status, when relevant.
Past complications from similar treatments.
Consider a patient requesting Botox who has a neuromuscular condition or takes medication that could affect treatment safety. That information may influence the provider’s decision, even if the patient has received cosmetic injections before.
The medical history should help guide the assessment, not simply satisfy a documentation requirement.
Physical Examination
The second component is an examination appropriate to the treatment being considered. For many aesthetic procedures, this includes assessing the treatment area and identifying findings that could affect safety or results.
The provider may evaluate:
Skin condition and tissue health.
Anatomy relevant to the planned procedure.
Signs of infection, inflammation, or injury.
Other clinical findings that could affect treatment suitability.
The examination should reflect the service involved. A patient seeking Botox injections will not necessarily need the same assessment as someone beginning an online medical weight loss program.
The provider should document the relevant findings, clinical assessment, and treatment decision. A signed checklist alone may not establish that an adequate evaluation took place.
Who Can Perform a Good Faith Exam?
The person conducting a GFE must have the clinical authority to evaluate the patient and make the treatment decision required by applicable law. This is particularly important in clinics where registered nurses, estheticians, or other staff administer treatments under physician-authorized protocols.
Physicians generally have the broadest authority to perform medical evaluations, while nurse practitioners and physician assistants may be authorized depending on their licenses, scope of practice, and state requirements.
| Provider | Can Perform a Good Faith Exam? | Important Considerations |
|---|---|---|
| Physician (MD or DO) | Yes | Must be appropriately licensed and authorized to provide the evaluation. |
| Nurse Practitioner (NP) | Often | Depends on state scope-of-practice and prescribing rules, including applicable collaboration requirements. |
| Physician Assistant (PA) | Often | Depends on state law, practice authority, and applicable physician supervision or collaboration requirements. |
| Registered Nurse (RN) | Generally not independently | RNs cannot independently make medical diagnoses or prescribing decisions outside their licensed authority. |
| Esthetician | No, for medical evaluations | An esthetician’s license does not authorize independent medical diagnosis or prescription treatment approval. |
The Medical Board of California’s medical spa guidance provides an example of why these distinctions matter. It explains that nurses may perform certain delegated procedures, but an appropriate prior medical examination remains a separate responsibility.
Having an RN administer an injectable treatment does not necessarily mean that the RN can independently conduct the examination used to authorize it.
Med spas should verify both who may perform the initial evaluation and who may administer the treatment. These are related, but separate, scope-of-practice questions.
When Is a Good Faith Exam Required?
Not every med spa service requires the same type of medical evaluation. The need for an exam depends on the treatment, the provider’s authority, and the laws that govern the practice.
Evaluations are particularly relevant when services involve prescription medications, regulated medical devices, or procedures classified as the practice of medicine.
Injectable Treatments
Injectable services commonly require an authorized provider to assess the patient before treatment. The evaluation helps identify contraindications, review relevant health concerns, and establish an appropriate treatment plan.
Examples include:
Botox and other botulinum toxin products.
Dermal fillers.
Other prescription injectable treatments.
For example, a patient requesting dermal fillers may need an assessment of the proposed injection area, previous procedures, and any relevant medical concerns before treatment is authorized.
The evaluation must meet the applicable requirements even when another qualified professional administers the injection.
Energy-Based Procedures
Some laser and energy-based treatments are regulated as medical procedures, particularly when prescription medical devices or physician-delegated services are involved.
Depending on the state and device, these may include:
Certain laser treatments.
Intense pulsed light (IPL) procedures.
Radiofrequency treatments classified as medical procedures.
Requirements are not identical for every device or service. Clinics should verify the device’s regulatory status, provider qualifications, and any examination or supervision requirements before adding a new procedure.
An evaluation appropriate for one treatment should not automatically be treated as authorization for every other service offered by the clinic.
Medical Wellness Services
Medical wellness practices may also need to establish appropriate patient evaluations before initiating prescription treatments.
Examples include:
Intravenous (IV) hydration therapy.
Prescription medical weight loss programs.
Hormone replacement therapy.
Each service has different clinical considerations. A patient seeking IV hydration may need an assessment of relevant medical conditions, medications, and reasons for receiving fluids. Someone beginning prescription weight loss treatment may require a broader review of medical history and treatment suitability.
The exact evaluation requirements depend on state law and the proposed treatment. Some services may also involve separate prescribing, supervision, or follow-up requirements.
For clinics offering several treatment categories, it is worth reviewing whether the existing evaluation process adequately addresses each one.
How Medical Director Co. Makes Sure Every Exam Holds Up
A good faith exam process needs more than a form in the patient’s chart. Clinics also need clear clinical responsibilities, appropriate treatment protocols, and access to qualified physician oversight when required.
Medical Director Co. helps medical spas establish physician relationships that support their clinical operations and applicable state requirements.
Our services include:
Qualified Physician Matching: Connecting clinics with physicians licensed in the relevant state and suited to the services being offered.
Attorney-Reviewed Agreements: Coordinating documentation that defines applicable physician oversight, delegation, or collaboration responsibilities.
State-Specific Support: Helping practices address physician relationship requirements that may differ across jurisdictions.
Ongoing Physician Oversight: Supporting appropriate clinical communication, treatment protocols, and physician responsibilities as the practice develops.
A medical director can play an important role in establishing clinical expectations, but the clinic must still ensure that individual patient evaluations are performed and documented by authorized providers.
Establish Appropriate Physician Oversight
If you're unsure whether your current physician arrangement supports the treatments your med spa offers, Medical Director Co. can help you explore suitable oversight options.
Frequently Asked Questions
Is a Good Faith Exam a Legal Requirement?
The term good faith exam is not used uniformly across state laws. However, many medical aesthetic procedures require an appropriate medical evaluation before treatment. These obligations may arise from rules governing prescribing, physician delegation, patient-provider relationships, or professional standards of care.
Who Can Perform a Good Faith Exam?
Physicians and appropriately authorized nurse practitioners or physician assistants may perform the necessary evaluation, depending on state law. Registered nurses and estheticians generally cannot independently perform medical examinations that require diagnosis or prescribing authority.
Does Every Med Spa Treatment Require a Good Faith Exam?
No. Nonmedical cosmetic services may not require the same evaluation as prescription-based or physician-delegated treatments. The clinic should review the specific services it provides and the applicable state requirements before deciding which examinations are necessary.
Is a Good Faith Exam the Same as Informed Consent?
No. A good faith exam evaluates whether the patient is medically suitable for treatment. Informed consent is a separate process through which the patient receives information about the procedure, risks, expected benefits, and alternatives before deciding whether to proceed. Both may be required.
Can a Good Faith Exam Be Done Online?
In some states, an appropriate medical evaluation may be performed through telehealth. The provider must be authorized to practice where the patient is located, and the examination method must meet applicable clinical and legal requirements. A questionnaire alone is not necessarily sufficient. For more details, see our virtual good faith exam guide.
Building Compliance Starts With the Right Evaluation
A good faith exam gives the treating provider an opportunity to identify patient risks, determine whether a procedure is appropriate, and document the decision before treatment begins.
For med spas, the priority is ensuring that the evaluation meets the requirements of the treatment and state involved. The right physician relationship can help clarify clinical responsibilities and support a safer, more consistent process.
Medical Director Co. works with clinics seeking qualified physician oversight. If your current setup needs attention, our team can help you discuss the next steps.
