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California compliance guide · 2026 The Complete Guide to Good Faith Exams (GFE) for MedSpas Updated October 12, 2026 The short answer: In California, a patient must be examined by an appropriately licensed clinician before a med spa gives them a treatment that uses a prescription drug or device, such as Botox or dermal filler. That exam is usually called a Good Faith Exam (GFE). It can happen in person or by telehealth, but it must come before treatment, be done by the right license, and be documented. This guide explains what that means in practice for California med spa owners, medical directors and injectors. In this guide Key takeaways What is a Good Faith Exam? Why California requires it Who can perform a GFE Which treatments need one Virtual GFEs in California What the exam covers How often to repeat it Five common mistakes Exam vs Estimate How MedicalGFE helps FAQ Key takeaways California treats injectables and most energy-based treatments as the practice of medicine, so a clinician's prior exam is required before treatment. Only certain licenses can perform it: physicians, and nurse practitioners or physician assistants within their legal scope. Registered nurses and aestheticians cannot. Telehealth exams are allowed in California, but the patient's consent to telehealth must be obtained and documented. Document the prior examination, assessment and treatment plan. Clear records help demonstrate what was evaluated and when. A Good Faith Exam is not the same as a Good Faith Estimate, the cost estimate required under federal billing law. What is a Good Faith Exam? A Good Faith Exam is a focused medical evaluation done before an aesthetic treatment. The clinician reviews the patient's health history, medications, allergies and previous treatments, looks at the treatment area, and decides whether the planned treatment is medically appropriate for that patient. It is narrower than a general check-up. The question it answers is specific: is this patient a safe candidate for this treatment, today? If the answer is yes, the clinician documents the decision and, where a prescription product is involved, authorizes the treatment. If the answer is no, or not yet, the patient is told why and treatment does not go ahead. Why California requires it Three parts of California law drive the requirement. 1. Prescription products need an appropriate prior exam Botulinum toxins, dermal fillers and many other med spa products are prescription drugs or devices. California prescribing rules require an appropriate prior examination and medical indication, subject to applicable statutory exceptions. Review the Medical Board's prescribing guidance for context. 2. Aesthetic treatments are medical procedures The Medical Board of California treats injections and similar cosmetic treatments as the practice of medicine. An RN does not independently diagnose or prescribe. The examining and treating professionals must follow the authority, orders and supervision requirements applicable to their roles. 3. Lay businesses can't practice medicine California restricts unlicensed ownership and control of a medical practice. Permitted structures and statutory exceptions require individual legal review. The GFE is one of the clearest points where medical judgment, not the business, decides whether a patient is treated. How California's corporate practice of medicine (CPOM) rules shape your GFE California generally bars businesses owned by non-physicians from practicing medicine or employing physicians to do so (Business and Professions Code sections 2400 and 2052). For a med spa, that usually means: The medical practice must have a lawful ownership structure, often involving a physician-owned professional medical corporation. An NP or PA credential alone does not establish ownership authority. The business side can be separate. An MSO may provide administrative services under an appropriate arrangement. It cannot control clinical judgment; decisions about medical records, billing, staffing and equipment can also involve physician control. Clinical decisions stay clinical. Whether a patient passes a Good Faith Exam is a clinician's decision. An owner or manager can't override a "not cleared" result. Outsourcing GFEs does not by itself establish a lawful practice structure. Confirm clinical responsibilities, ownership, supervision and contracts with qualified California healthcare counsel. Hiring a medical director alone does not cure an unlawful arrangement. See the Medical Board's CPOM guidance. Who can perform a GFE in California? Physician (MD or DO) Can perform the GFE?: Yes Notes: Must hold an active California license Nurse practitioner (NP) Can perform the GFE?: Yes, within scope Notes: Must act under the standardized procedures or practice authority that applies to them Physician assistant (PA) Can perform the GFE?: Yes, within scope Notes: Must have a practice agreement with a supervising physician Registered nurse (RN) Can perform the GFE?: No Notes: May administer treatment after a qualified clinician has examined and authorized it Aesthetician or medical assistant Can perform the GFE?: No Notes: Cannot independently perform the medical evaluation; other permitted duties depend on their role Whoever performs the exam must be licensed in California, because the patient is in California, even when the clinician joins by video from elsewhere. Nurse practitioners and the AB 890 pathways AB 890 created two additional NP practice pathways. Authority depends on BRN certification, setting, population focus and the applicable requirements: "103" nurse practitioners may practice without standardized procedures in certain settings that include physicians, after completing a transition-to-practice period. "104" nurse practitioners may practice more independently, outside those settings, after gaining further experience. Nurse practitioners who haven't moved into either category continue to work under standardized procedures agreed with a supervising physician. Whichever pathway applies, confirm the NP's actual authority, including furnishing requirements, rather than relying on the NP title alone. See the BRN's current AB 890 guidance. Which treatments need a GFE? Treat the following as examples to review with your responsible clinician. The actual examination, prescribing, operator and documentation requirements depend on the product, device, procedure and clinician authority. Neurotoxins (Botox, Dysport, Xeomin and similar) Examples of non-medical services: Facials and cleansing Dermal fillers Examples of non-medical services: Light exfoliation Lasers and energy-based devices Examples of non-medical services: Massage Microneedling Examples of non-medical services: Over-the-counter skincare Medium and deep chemical peels Examples

California compliance guide · 2026 The Complete Guide to Good Faith Exams (GFE) for MedSpas Updated October 12, 2026 The short answer: In California, a patient must be examined by an appropriately licensed clinician before a med spa gives them a treatment that uses a prescription drug or device, such as Botox or dermal filler. That exam is usually called a Good Faith Exam (GFE). It can happen in person or by telehealth, but it must come before treatment, be done by the right license, and be documented. This guide explains what that means in practice for California med spa owners, medical directors and injectors. In this guide Key takeaways What is a Good Faith Exam? Why California requires it Who can perform a GFE Which treatments need one Virtual GFEs in California What the exam covers How often to repeat it Five common mistakes Exam vs Estimate How MedicalGFE helps FAQ Key takeaways California treats injectables and most energy-based treatments as the practice of medicine, so a clinician’s prior exam is required before treatment. Only certain licenses can perform it: physicians, and nurse practitioners or physician assistants within their legal scope. Registered nurses and aestheticians cannot. Telehealth exams are allowed in California, but the patient’s consent to telehealth must be obtained and documented. Document the prior examination, assessment and treatment plan. Clear records help demonstrate what was evaluated and when. A Good Faith Exam is not the same as a Good Faith Estimate, the cost estimate required under federal billing law. What is a Good Faith Exam? A Good Faith Exam is a focused medical evaluation done before an aesthetic treatment. The clinician reviews the patient’s health history, medications, allergies and previous treatments, looks at the treatment area, and decides whether the planned treatment is medically appropriate for that patient. It is narrower than a general check-up. The question it answers is specific: is this patient a safe candidate for this treatment, today? If the answer is yes, the clinician documents the decision and, where a prescription product is involved, authorizes the treatment. If the answer is no, or not yet, the patient is told why and treatment does not go ahead. Why California requires it Three parts of California law drive the requirement. 1. Prescription products need an appropriate prior exam Botulinum toxins, dermal fillers and many other med spa products are prescription drugs or devices. California prescribing rules require an appropriate prior examination and medical indication, subject to applicable statutory exceptions. Review the Medical Board’s prescribing guidance for context. 2. Aesthetic treatments are medical procedures The Medical Board of California treats injections and similar cosmetic treatments as the practice of medicine. An RN does not independently diagnose or prescribe. The examining and treating professionals must follow the authority, orders and supervision requirements applicable to their roles. 3. Lay businesses can’t practice medicine California restricts unlicensed ownership and control of a medical practice. Permitted structures and statutory exceptions require individual legal review. The GFE is one of the clearest points where medical judgment, not the business, decides whether a patient is treated. How California’s corporate practice of medicine (CPOM) rules shape your GFE California generally bars businesses owned by non-physicians from practicing medicine or employing physicians to do so (Business and Professions Code sections 2400 and 2052). For a med spa, that usually means: The medical practice must have a lawful ownership structure, often involving a physician-owned professional medical corporation. An NP or PA credential alone does not establish ownership authority. The business side can be separate. An MSO may provide administrative services under an appropriate arrangement. It cannot control clinical judgment; decisions about medical records, billing, staffing and equipment can also involve physician control. Clinical decisions stay clinical. Whether a patient passes a Good Faith Exam is a clinician’s decision. An owner or manager can’t override a “not cleared” result. Outsourcing GFEs does not by itself establish a lawful practice structure. Confirm clinical responsibilities, ownership, supervision and contracts with qualified California healthcare counsel. Hiring a medical director alone does not cure an unlawful arrangement. See the Medical Board’s CPOM guidance. Who can perform a GFE in California? Clinician roles and evaluation authority License Can perform the GFE? Notes Physician (MD or DO) Yes Must hold an active California license Nurse practitioner (NP) Yes, within scope Must act under the standardized procedures or practice authority that applies to them Physician assistant (PA) Yes, within scope Must have a practice agreement with a supervising physician Registered nurse (RN) No May administer treatment after a qualified clinician has examined and authorized it Aesthetician or medical assistant No Cannot independently perform the medical evaluation; other permitted duties depend on their role Whoever performs the exam must be licensed in California, because the patient is in California, even when the clinician joins by video from elsewhere. Nurse practitioners and the AB 890 pathways AB 890 created two additional NP practice pathways. Authority depends on BRN certification, setting, population focus and the applicable requirements: “103” nurse practitioners may practice without standardized procedures in certain settings that include physicians, after completing a transition-to-practice period. “104” nurse practitioners may practice more independently, outside those settings, after gaining further experience. Nurse practitioners who haven’t moved into either category continue to work under standardized procedures agreed with a supervising physician. Whichever pathway applies, confirm the NP’s actual authority, including furnishing requirements, rather than relying on the NP title alone. See the BRN’s current AB 890 guidance. Which treatments need a GFE? Treat the following as examples to review with your responsible clinician. The actual examination, prescribing, operator and documentation requirements depend on the product, device, procedure and clinician authority. Examples of medical and non-medical services Medical services requiring clinical assessment Examples of non-medical services Neurotoxins (Botox, Dysport, Xeomin and similar) Facials and cleansing Dermal fillers Light exfoliation Lasers and energy-based devices Massage Microneedling Over-the-counter skincare Medium and deep chemical peels — IV therapy and vitamin injections — Weight-management injections — These examples do not determine scope