Compliance
Good Faith Exam Requirements for Medspas: What Owners Need to Know
A good faith exam is the legal foundation for prescribing injectables and other treatments—here's what medspas must do to stay compliant.
Photo: Anna Shvets / Pexels
AI Inside MedSpa Intelligence · Jun 26, 2026
What Is a Good Faith Exam?
A good faith exam is an in-person medical evaluation performed by a licensed healthcare provider before prescribing or administering certain aesthetic treatments, particularly injectables like Botox and dermal fillers. It establishes a legitimate provider-patient relationship and ensures the patient is a suitable candidate for the treatment.
The core principle: a provider must personally assess the patient's medical history, current health status, and aesthetic goals before treatment begins. This isn't a formality—it's a legal and ethical requirement that protects both your practice and your clients.
Who Can Perform a Good Faith Exam?
The provider performing the exam must be licensed and authorized to prescribe or supervise the treatment in your state. This typically includes:
- Physicians (MDs, DOs)
- Nurse practitioners (NPs) with prescriptive authority
- Physician assistants (PAs) with prescriptive authority
- Licensed aestheticians or nurses may administer treatments under direct supervision, but cannot independently satisfy the GFE requirement
Verify your state's specific scope-of-practice rules, as requirements vary. Some states allow NPs and PAs to perform GFEs independently; others require physician oversight or co-signature.
Telehealth and Good Faith Exams
Telehealth GFEs are increasingly permitted, but with strict limitations:
A documented good faith exam demonstrates due diligence and protects your practice from regulatory complaints and liability claims.
- Many states allow initial consultations via telehealth if a licensed provider conducts a video assessment
- However, some treatments (especially injectables) still require an in-person component before the first injection
- Telehealth follow-ups or routine assessments are often acceptable after an initial in-person visit
- Check your state medical board and FDA guidance—rules are evolving and vary significantly by jurisdiction
Why Good Faith Exams Matter for Your Practice
Regulatory compliance: Skipping or inadequately documenting a GFE exposes your practice to state board complaints, fines, and license suspension.
Liability protection: A documented GFE demonstrates due diligence if a patient experiences an adverse event or files a complaint.
Insurance and credentialing: Many malpractice insurers and credentialing bodies require proof of GFE documentation.
Patient safety: The exam catches contraindications (medications, allergies, medical conditions) that could affect treatment safety or outcomes.
Best Practices for Your Medispa
- Document everything: Keep detailed notes on the exam, patient history, treatment plan, and informed consent
- Use a standardized intake form that captures medical history, current medications, and allergies
- Ensure the supervising provider reviews and approves treatment plans before administration
- Train your clinical staff on what constitutes adequate documentation
- Consult your state medical board and legal counsel on your specific requirements—don't assume telehealth or delegation rules from another state apply to yours
A solid GFE protocol is non-negotiable. It's the legal bedrock of your practice.
Frequently asked questions
Can a nurse or aesthetician perform a good faith exam for Botox and fillers?
No. Licensed aestheticians and nurses may administer treatments under direct supervision, but cannot independently satisfy the good faith exam requirement. The exam must be performed by a licensed provider with prescriptive authority—typically an MD, DO, NP, or PA—depending on your state's scope-of-practice rules.
Are good faith exams required to be in-person or can they be done via telehealth?
It depends on your state and the treatment. Many states allow initial telehealth consultations with a licensed provider, but most still require an in-person component before the first injection of injectables like Botox or fillers. Telehealth follow-ups after an initial in-person visit are often acceptable. Always check your state medical board and FDA guidance, as rules vary significantly.
What happens if a medispa doesn't document a good faith exam?
Inadequate or missing GFE documentation exposes your practice to state board complaints, fines, license suspension, and increased liability if a patient experiences an adverse event. Documentation also protects you with malpractice insurers and credentialing bodies, which often require proof of GFE records.
What should be included in a good faith exam for a medispa patient?
A documented GFE should capture the patient's medical history, current medications, allergies, medical conditions, aesthetic goals, and the provider's clinical assessment. Use a standardized intake form, have the supervising provider review and approve the treatment plan, and keep detailed notes on the exam and informed consent.
Can an NP or PA perform a good faith exam independently or do they need a physician?
This varies by state. Some states allow NPs and PAs with prescriptive authority to perform GFEs independently, while others require physician oversight or co-signature. You must verify your specific state's scope-of-practice rules—don't assume rules from another state apply to yours.
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