The Technology Standard for Telehealth Exams

A telehealth good faith exam requires technology that allows the provider to perform an adequate clinical evaluation. In states that permit remote examinations, the accepted standard is typically a live, synchronous audio-video connection that allows the provider and patient to communicate in real time.

A live audio-video examination allows the provider to:

• Observe the treatment area: Evaluate visible clinical findings relevant to the proposed aesthetic treatment.
• Ask follow-up questions: Clarify the patient’s medical history, symptoms, treatment goals, and any potential contraindications.
• Review the patient’s medical history: Confirm medications, allergies, underlying medical conditions, and prior procedures that could affect treatment.
• Assess whether treatment is appropriate: Exercise independent medical judgment before approving or declining the requested procedure.
• Establish a physician-patient relationship where required: Meet state-specific requirements for initiating care before delegated medical services are performed.

Video quality should be sufficient for the provider to accurately evaluate the treatment area. If the connection prevents an adequate clinical assessment, the examination may not satisfy state requirements.

Some states also recognize store-and-forward technology in limited circumstances. Patients submit photographs or recorded videos for provider review before treatment. Depending on state law, these materials may supplement a live audio-video examination or satisfy specific telemedicine requirements.

Practices should not assume that audio-only telephone calls satisfy telehealth good faith exam requirements. Unless state law expressly authorizes that format for the services being provided, a live audio-video examination remains the most widely accepted standard.

Documentation Standards Remain the Same

A telehealth good faith exam requires the same documentation as an in-person examination. The medical record should clearly support the provider’s clinical evaluation and treatment decision.

The medical record should include:

• Patient history: Document the patient’s medical history, current concerns, and other information necessary to evaluate whether treatment is appropriate.
• Relevant medical conditions and medications: Record existing health conditions, allergies, current medications, and other clinical factors that could affect treatment or patient safety.
• Examination findings: Document the provider’s observations during the telehealth evaluation, including findings from the visual assessment and information obtained during the patient interview.
• Clinical assessment: Record the provider’s assessment of the patient’s condition and whether the requested treatment is clinically appropriate.
• Treatment plan: Document the recommended treatment, patient instructions, follow-up recommendations, and any alternatives discussed.
• Provider’s clinical decision making: Explain the clinical reasoning that supports the decision to approve, modify, postpone, or decline treatment.

Many practices document telehealth encounters using the SOAP (Subjective, Objective, Assessment, and Plan) note structure commonly used for clinical documentation. The medical record should also indicate that the examination was conducted through telehealth and identify the technology used during the encounter.

When applicable, retain supporting photographs, patient-submitted images, consent forms, and treatment recommendations as part of the patient’s permanent medical record.

Complete documentation demonstrates that the provider exercised independent medical judgment before treatment, regardless of whether the examination occurred remotely or in person.

State Laws Determine Whether Telehealth Is Allowed

State law determines if a telehealth good faith exam can be used before aesthetic treatment. While many states permit telemedicine, they do not all allow a virtual examination to satisfy physician oversight requirements for delegated medical procedures.

State laws vary in several important areas, including:

• Whether a telehealth good faith exam satisfies physician oversight requirements: Some states recognize remote examinations for certain treatments, while others require an in-person evaluation or impose additional conditions.
• Which providers may perform the examination: State law specifies if the exam must be completed by a physician or whether certain advanced practice providers may perform it under physician oversight.
• If physician delegation rules permit remote evaluations: Delegation rules determine whether a supervising physician can authorize treatment based on a telehealth examination.
• How frequently the examination must be renewed: Some states require a new good faith exam after a specified period or when the patient’s condition or treatment plan changes.
• Which aesthetic procedures require an updated examination before additional treatment: Certain treatments or changes to the treatment plan may require a new good faith exam before services continue.

California, Texas, Florida, Arkansas, Louisiana, Kentucky, and Arizona each have telemedicine laws that operate alongside their medical practice regulations. Because these requirements differ by state, practices should verify both telemedicine and physician oversight rules before relying on telehealth for good faith exams.

How Medical Director Co. Supports Telehealth Practices

Practices offering telehealth good faith exams need physician oversight that complies with both state telemedicine laws and physician delegation requirements. Medical Director Co. helps med spas establish compliant physician relationships by providing:

• Qualified physician matching: Match practices with physicians licensed in the appropriate state who understand the regulatory requirements that apply to aesthetic medicine.
• State-specific physician oversight: Support physician oversight that aligns with applicable telemedicine laws, delegation requirements, and board guidance.
• Attorney-reviewed agreements: Provide attorney-reviewed agreements that support compliant physician oversight and provider relationships.
• Ongoing compliance support: Help practices maintain compliant physician relationships as state laws and regulatory requirements change.

By combining qualified physician placement, compliant documentation, and ongoing compliance support, Medical Director Co. helps med spas build physician oversight programs that support safe patient care and long-term regulatory compliance.