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GUIDE

Good Faith Exam for Med Spas and What It Must Document

Updated August 24, 2026 · MedSpaForms

A good faith exam is the evaluation a licensed prescriber performs before a patient is treated with a prescription drug or prescription device, and it is what makes the resulting treatment a lawful medical act rather than an unlicensed one. It establishes the provider-patient relationship, documents medical appropriateness, and generates the patient-specific order the injector or technician works under. Here is who can perform it, when telehealth is allowed, and what the note has to contain.

Good Faith Exam Template

Good Faith Exam Template

The GFE done right: identity verification, focused history and exam, candidacy determination and treatment-plan authorization — plus a telehealth section with the state-law caution (CA/TX/FL differ), and a matching chart note.

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What a good faith exam actually is

Most state statutes never use the phrase. What they require is an appropriate prior examination and a medical indication before a prescription drug or device is ordered or administered, plus a valid provider-patient relationship. "Good faith exam," or GFE, is the industry shorthand that grew up around that requirement in aesthetic medicine.

The practical trigger is the product, not the setting. If a treatment involves a prescription drug or an FDA-regulated prescription device, it needs a prescriber's evaluation first. In a typical med spa that captures neurotoxins, dermal fillers and biostimulators, IV hydration and vitamin infusions, prescription weight-management medications, hormone and peptide therapy, prescription-strength topicals, medical-grade lasers and energy devices, and PRP where state rules treat it as a medical procedure. Purely cosmetic esthetician services performed within a cosmetology or esthetics license generally do not.

The GFE is also not the same thing as consent. The exam answers "should this patient receive this treatment," and the consent answers "does this patient agree, knowing the risks." You need both, in that order, and they are separate documents.

Who is allowed to perform the exam

Because the exam involves diagnosis and an order for a prescription item, states restrict it to prescribers: a physician, a nurse practitioner or a physician assistant, each working within their state scope and any required supervision, collaboration or delegation agreement. Registered nurses, medical assistants, estheticians and laser technicians can gather intake information and vitals, but the evaluation, the clinical decision and the patient-specific order have to come from the prescriber.

California is the clearest example. Business and Professions Code section 2242 requires an appropriate prior examination and medical indication before prescribing dangerous drugs, and the Medical Board has taken the position that this examination may not be delegated to a registered nurse. Separately, California's corporate practice of medicine rules, reinforced by SB 351 effective January 1, 2026, restrict non-clinical owners and investors from controlling clinical decisions, which is worth understanding if your GFE workflow is designed by a management company rather than by the prescriber.

Texas approaches the same question through its standing delegation order framework for nonsurgical medical cosmetic procedures, which places responsibility on the delegating physician, requires written protocols the physician has approved or authored, requires documented hands-on training for the delegated procedure, and requires a physician or midlevel practitioner on site or available for emergency consultation. The Texas Medical Board reorganized these cosmetic-procedure rules in 2025, so confirm the current section numbering before citing it in your policies.

Telehealth good faith exams by state

Remote GFEs are common and, in many states, lawful. The limits are about modality and about who is on the other end of the call.

StateWho may perform the examRemote examPractical note
CaliforniaPhysician, NP or PA; not delegable to an RNPermitted where the evaluation meets the standard of care; asynchronous review has been recognized in some circumstancesConfirm the current Medical Board position before relying on questionnaire-only screening
TexasPhysician, or PA or APRN under a proper delegation and protocolTelemedicine permitted under the state telemedicine framework with a valid practitioner-patient relationshipDelegating physician must have approved written protocols and documented training
FloridaLicensed prescriber acting within scopeSection 456.47 allows a telehealth evaluation sufficient to diagnose and treat, with no separate in-person requirementTelehealth documentation must meet the same standard as in-person care
New YorkLicensed prescriberWidely reported as permitted before the first administration of a prescription drug or deviceVerify with the Office of the Professions and your medical director
Other statesPrescriber within scopeVaries; some require synchronous audio-video, some restrict audio-onlyBoards that never use the term still enforce the underlying prescribing rule

Three constraints show up repeatedly and are worth designing around regardless of state. Synchronous audio-video is the safer default, because a written questionnaire alone is the weakest form of evaluation and the first thing challenged. The prescriber must be licensed in the state where the patient is physically located at the time of the encounter, not where the clinic is. And a remote exam does not lower the standard of care; if the evaluation cannot be completed properly on video, the answer is an in-person visit, not a shorter note.

What the good faith exam note must document

A GFE note that says "cleared for treatment" is worth very little. The note is what proves an evaluation happened and that the order was patient-specific rather than a standing blanket authorization.

ElementWhat to record
Identity and encounterPatient name and date of birth, date and time, modality used, patient's physical location for telehealth, identity verification method
PrescriberName, license type and number, and the delegation or supervision relationship with the treating staff
HistoryMedical and surgical history, current medications and supplements, allergies, prior aesthetic treatments and reactions, pregnancy or breastfeeding status
Focused examinationFindings relevant to the requested treatment, including skin assessment, treatment area, vitals where indicated, and photographs where relevant
ContraindicationsConditions specifically considered and excluded, such as neuromuscular disorders, active infection at the site, anticoagulant use, keloid history, or relevant endocrine and gastrointestinal history for weight-management therapy
AssessmentMedical indication and a candidacy determination in the prescriber's own words
Patient-specific orderNamed treatment, product or device, dose or parameter range, treatment areas, and who is authorized to perform it
Follow-upReview interval, when a new exam is required, and escalation instructions for complications

Two details are worth flagging. The order should name the product and range rather than authorizing "aesthetic treatment as needed," and the note should be signed by the prescriber, not by the staff member who typed it. An unsigned or countersigned-days-later GFE is a common audit finding.

How often a new exam is required

There is no universal interval. The workable rule is that a new exam is required whenever the clinical picture, the treatment or the risk changes. In practice that means before the first treatment of any kind, before adding a new treatment category such as moving from neurotoxin to IV therapy or weight management, after a change in health status, new diagnosis, new medication, surgery or pregnancy, and when the patient returns after an extended gap.

Many practices set an annual re-exam as an internal floor for ongoing patients receiving the same treatment, and shorter intervals for prescription therapies that require monitoring, such as monthly or quarterly review for weight-management or hormone protocols. That is a reasonable policy, but it is a policy, not a legal ceiling; some states or product categories will demand more frequent evaluation. Whatever interval you choose, write it into your protocols and follow it consistently, because inconsistent intervals across similar patients are what an investigator notices.

Where good faith exams go wrong in med spas

The failure patterns are predictable. A blanket standing order for a whole patient list, rather than an order naming a specific patient and treatment. An RN or medical assistant performing what is functionally the exam, with the prescriber signing later. A GFE performed by a remote prescriber licensed in a different state than the patient. A questionnaire with no clinician contact used for injectables. A GFE note that never mentions contraindications, so there is nothing showing they were considered. A treatment plan that quietly expands over months, with new areas and new products added without a new evaluation. And a chart where the GFE note and the consent form were signed at the same minute, which suggests the exam and the consent were a single rushed step rather than an evaluation followed by a decision.

Each of these is a documentation problem more than a clinical one, and each is fixable with a template and a sequencing rule: exam first, order second, consent third, treatment fourth, all timestamped in that order.

The bottom line

The good faith exam is the step that makes a med spa treatment lawful medicine, and it must be performed by a prescriber, be specific to that patient and treatment, and be documented well enough to show what was considered and excluded. Telehealth is broadly workable but the prescriber must be licensed where the patient sits, and synchronous video is the defensible default. Build the sequence into your chart so exam, order, consent and treatment always appear in that order with real timestamps. When a board asks how a patient was cleared, that sequence is the answer.

Frequently asked questions

What is a good faith exam at a med spa?

A good faith exam is the evaluation a licensed prescriber performs before a patient receives a treatment that involves a prescription drug or a prescription device, such as neurotoxin, filler, IV therapy, weight-loss medication or medical lasers. It establishes the provider-patient relationship, confirms medical appropriateness, and produces the patient-specific order the treating staff work under. Most state statutes call this an appropriate prior examination rather than a good faith exam.

Can a registered nurse perform a good faith exam?

Generally no. The exam is a diagnostic and prescriptive act, so states typically restrict it to a physician, nurse practitioner or physician assistant acting within their scope, and California's Medical Board has stated the exam may not be delegated to a registered nurse. An RN may collect history and vitals, but the evaluation and order must come from a prescriber.

Can a good faith exam be done over telehealth?

Many states permit it when the encounter meets the same standard of care as an in-person visit, and some require synchronous audio-video rather than a questionnaire or audio-only call. Rules differ significantly by state and by treatment type, so confirm your state board's current position before building a remote GFE workflow.

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This guide is educational and is not legal or medical advice. Verify requirements with your own advisors and your state board before applying them in your practice.