The Complete Guide to Good Faith Exams (GFE) for MedSpas
Updated
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.
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.
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.
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.
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?
| 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.
| 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 of practice. A product or device marketed for cosmetic use may still involve medical practice. Confirm borderline services against the applicable rules and instructions before offering them.
Virtual GFEs in California
California allows Good Faith Exams by telehealth. Business and Professions Code section 2290.5 sets the key rule: before care is delivered by telehealth, the clinician must tell the patient that telehealth will be used and get the patient's verbal or written consent, and that consent must be recorded in the patient's record.
A virtual evaluation workflow should address the following:
- An appropriate examination method. California recognizes synchronous and asynchronous telehealth. The clinician must decide whether the chosen method supplies enough information and meets the standard of care; an in-person assessment may be needed.
- A clinician authorized to care for a patient in California, with the patient's physical location confirmed and any requirements where the clinician is located also addressed.
- Telehealth consent captured at the start of the visit.
- Privacy and security controls, including a business associate agreement when a vendor is acting as a business associate under HIPAA. A BAA alone does not establish compliance.
- The note in the chart before treatment begins.
Telehealth can reduce travel and scheduling steps when clinically appropriate. It does not guarantee immediate availability or treatment clearance. See California telehealth guidance and HHS business-associate guidance.
What the exam covers
A good GFE note answers four questions: who is the patient, what do they want, is it safe for them, and who decided.
Documentation checklist
- Patient identity verified
- Telehealth consent recorded (virtual exams)
- Medical history, including pregnancy or breastfeeding status
- Current medications and supplements
- Allergies, including anesthetics and product ingredients
- Previous aesthetic treatments and complications
- Assessment of the treatment area
- Treatments approved, or the reason for declining
- Clinician's name, credentials and license number
- Date and time, recorded before treatment starts
The consent to treatment itself (risks, benefits and alternatives of the procedure) is a separate document, usually completed at the point of care by the treating team. Keep GFE records for the period set by your practice's record-retention policy and any legal or payer requirements that apply.
How often should a GFE be repeated?
Do not assume a universal validity period or an automatic annual clearance. The responsible clinician should set reassessment requirements for the actual services, patient changes and applicable rules. Review the patient again when:
- a new patient is treated for the first time;
- a patient asks for a different type of treatment;
- the patient's health changes (new medications, new diagnosis, pregnancy);
- a reassessment interval in the clinician-approved protocol has been reached.
Five mistakes that cause problems
An RN or aesthetician "clears" a patient. Confirm the examiner's authority before relying on the assessment.
Complete the required assessment before treatment. Record the actual examination time and documentation time accurately.
Do not assume an assessment for Botox also covers a newly requested laser or filler. The clinician must determine what further assessment is needed.
The video visit happened, but the chart doesn't show the patient agreed to telehealth.
A bare "patient cleared" statement may not adequately explain the assessment, clinical decision and authorized treatment plan.
Good Faith Exam vs Good Faith Estimate
The names are almost identical, and the two are often confused.
| Comparison | Good Faith Exam | Good Faith Estimate |
|---|---|---|
| What it is | A clinical evaluation before treatment | A written estimate of expected charges |
| Where it comes from | State medical practice rules | The federal No Surprises Act |
| Who it protects | Patient safety | Patients paying without insurance |
| Who does it | A licensed clinician | The provider's billing or front-desk team |
This article is about the exam. For billing obligations affecting uninsured or self-pay patients, review CMS guidance on good faith estimates.
How MedicalGFE fits into your workflow
MedicalGFE connects your med spa with California-licensed clinicians for virtual Good Faith Exams, to coordinate evaluations and return documentation to the practice. The clinician determines suitability; a referral or an in-person examination may be needed. The platform itself does not practice medicine.
How a MedicalGFE exam works
- The patient checks in at your front desk, or before arriving, and completes intake.
- Your team requests an exam through MedicalGFE.
- A California-licensed clinician joins by secure video, records telehealth consent, and reviews history, medications and the treatment area.
- The clinician approves or declines each requested treatment and signs the note.
- The signed exam note returns to your practice, for the treating team to review before any authorized treatment begins.
What your practice gets
Examine new patients on video instead of waiting for a clinician to be on site.
Keep the assessment and clinical decision available to the authorized treating team. Confirm the documentation provided during onboarding.
MedicalGFE coordinates access to clinicians; your practice retains its applicable treatment, supervision and follow-up responsibilities.
Review MedicalGFE's current pricing and confirm eligibility and terms with the team.
Book a 15-minute demo to discuss the clinic workflow, available services and documentation.
Frequently asked questions
Is a Good Faith Exam required in California?
Yes, before treatments that use prescription drugs or devices, such as neurotoxins and fillers. California requires an appropriate prior examination before those products are prescribed or furnished.
Can a GFE be done by telehealth in California?
Yes, when the clinician determines telehealth is appropriate and it meets the standard of care. The clinician must have authority to care for a patient in California, and telehealth consent must be obtained and documented before care is delivered.
Can a registered nurse perform a GFE in California?
No. An RN can administer an approved treatment, but the exam must be done by a physician, or by a nurse practitioner or physician assistant acting within their legal scope.
How long is a GFE valid?
Do not assume a universal validity period. The responsible clinician determines reassessment based on the proposed treatment, health or medication changes, applicable requirements and the practice protocol.
Is a Good Faith Exam the same as a Good Faith Estimate?
No. The exam is a clinical safety evaluation; the estimate is a cost disclosure under federal billing law.
Build a clearer evaluation workflow
Discuss how your practice can coordinate evaluations and documentation while preserving independent clinical judgment.
Request your MedicalGFE demo A demo discusses your practice workflow; it does not provide patient clearance.Disclaimer: This article is for general educational purposes only and does not constitute legal, regulatory or medical advice. Laws and regulatory guidance change, and requirements depend on your practice's structure and services. Consult a qualified California healthcare attorney and your medical director before making compliance decisions.