Who Can Perform A Good Faith Exam
Good Faith Exam Requirements and Provider Guidelines
One of the most common—and most important—questions regulated medical practices ask is:
Who can legally and appropriately perform a Good Faith Exam?
The answer depends on several factors, including state regulations, scope of practice, and the type of service being evaluated. While requirements vary, one principle is consistent across jurisdictions:
A Good Faith Exam must reflect independent medical judgment exercised by a licensed medical provider.
This page explains how provider eligibility is determined, why requirements vary, and what practices should be understood when building a defensible compliance framework.
What Determines
Who Can Perform
Good Faith Exam
There is no single rule that applies in all cases when asking who can perform a good faith exam. Provider eligibility depends on several factors and good faith exam requirements that vary by state and service type.
Key factors include:
- The patient’s location
- The type of medical spa or med spa service being evaluated
- State-specific scope-of-practice laws
- Whether the provider is authorized to exercise independent judgment
In many states, requirements vary by state and are defined by the medical board and applicable regulations. Because of this, medical practices must align provider roles with current requirements to remain compliant and ensure patient safety.
Who Can Perform a Good Faith Exam?
A common question is who can perform good faith exam services in regulated settings. A Good Faith Exam must be conducted by a licensed healthcare provider with the authority to perform a full medical evaluation.
Qualified providers typically include:
Physicians (MD or DO)
often required for certain medical aesthetic treatment
Nurse practitioners
depending on state law and good faith exam nurse practitioner scope rules
Physician assistants
working within supervision or collaboration requirements
In some cases, good faith exams nurse practitioner roles are clearly defined under advanced practice laws, while in others, physician oversight is required.
Regardless of provider type, the exam must be performed by a licensed medical provider who can:
- Perform good faith exams using independent clinical judgment
- Conduct a physical examination when required
- Assess whether the patient is a good candidate for treatment
- Develop or inform a treatment plan
- Document findings and informed consent
The exam must reflect proper medical oversight and follow the standard of care. This applies whether the exam is conducted in person or through telehealth.
Unqualified staff cannot perform or administer a GFE. This includes:
- Registered nurses acting independently
- Estheticians
- Medical assistants
- Unlicensed personnel
Allowing unqualified individuals to perform good faith exams creates serious compliance risks and may violate regulatory requirements.
State-Specific
Good Faith Exam
Requirements
Good Faith Exam requirements vary significantly by state. While the core expectation is consistent, a licensed provider must evaluate the patient and exercise independent medical judgment, the way this is implemented can differ based on state law.
Some states allow telemedicine-based evaluations, while others may require in-person exams for certain procedures. Provider qualifications, documentation standards, and supervision requirements can also vary.
Examples include:
- Texas: Requires Good Faith Exams before medical aesthetic treatments. Telehealth is allowed, but strict corporate practice rules apply.
- California: Requires an appropriate prior examination before prescribing medications or devices. Telemedicine is permitted if it meets the standard of care.
- Florida: Allows telehealth but requires proper prescribing authority and oversight.
- Illinois: More restrictive, with some services requiring in-person evaluation.
- New York: Emphasizes proper patient-provider relationships and supervision rules.
Always verify current requirements with your state medical board or legal counsel, as regulations can change.
What Treatments Require a Good Faith Exam?
Good Faith Exams (or valid patient-provider relationship evaluations) are required before administering:
Injectable Treatments
- Botulinum toxin (Botox, Dysport, Xeomin, Jeuveau)
- Dermal fillers (Juvederm, Restylane, Sculptra, Radiesse)
- Kybella and other injectables
Medical Weight Loss & GLP-1 Medications
- Semaglutide (Ozempic, Wegovy)
- Tirzepatide (Mounjaro, Zepbound)
- Other prescription weight loss medications
IV Therapy & Hydration
- IV vitamin infusions
- Hydration therapy
- NAD+ treatments
- Myers’ cocktails
Aesthetic Procedures
- Laser treatments and IPL (Intense Pulsed Light)
- Chemical peels (medium to deep)
- Microneedling with prescription products
- PDO threads and other minimally invasive procedures
- Platelet-rich plasma (PRP) treatments
Hormone Therapy
- Hormone replacement therapy (HRT)
- Testosterone replacement therapy (TRT)
- Peptide therapy
Other Medical Services
- Prescription skincare products (tretinoin, hydroquinone)
- Medical-grade treatments requiring physician authorization
- Any service involving prescription medications or devices
If the treatment involves prescription medication, medical devices, or is medically supervised, a compliant Good Faith Exam is required before the first treatment.
Licensed Medical Providers and Independent Judgment
A Good Faith Exam is a medical decision, not an administrative task. It must be performed by a licensed medical provider with the authority to evaluate patients and make clinical decisions.
Qualified providers must be able to:
- Review medical history
- Assess risk factors
- Determine if care is appropriate
- Document clinical reasoning
A gfe is not about approval. It is about confirming that treatment is appropriate.
Who can perform a Good Faith Exam depends on state laws, scope of practice, and the type of service being evaluated. In most cases, this includes:
- Physicians (MD or DO), who can perform exams in all states
- Nurse practitioners, depending on state scope-of-practice rules
- Physician assistants, based on supervision and state requirements
Regardless of provider type, one principle remains constant. The exam must reflect independent medical judgment.
This means:
- No influence from business goals or treatment volume
- No guaranteed approvals
- Providers may approve, modify, defer, or decline care
- Documentation must reflect real clinical reasoning
If independence is compromised, compliance risk increases. This becomes especially important during audits, complaints, or legal reviews.
Building a Compliance Structure That Works
Good Faith Exams, or GFEs, are often reviewed after issues arise. These may include audits, complaints, or questions about medical spa compliance.
When that happens, reviewers focus on:
- Who performed the exam
- Whether the provider was a qualified medical professional
- Whether the exam must meet independence standards
- Whether documentation supports the decision
A structured process helps ensure patient safety and supports long-term compliance. It also ensures that each exam is conducted by a licensed healthcare provider and aligns with applicable legal and clinical standards.
How We Approach Provider Participation
At GoodFaithExams.com, provider participation is designed to answer the core question of who can perform GFE in a compliant and scalable way.
Our approach ensures:
- Exams are conducted by a licensed medical professional
- Provider roles align with state-specific requirement standards
- Medical decisions remain independent from business influence
- Documentation reflects a complete and defensible evaluation
This structure supports med spa and medical spa operations that need to perform good faith exams efficiently while maintaining compliance and ensuring patient safety.
Build a Process
You Can Defend
Good Faith Exams are more than a requirement. They are a core part of a compliant framework in modern healthcare and telehealth settings.
Understanding who can perform a good faith exam, how the exam must be performed, and how decisions are documented helps practices operate with confidence. It also ensures that each exam is conducted properly and supports safe and effective care.
At GoodFaithExams.com, our process is built to help practices perform good faith exams in a way that is clear, compliant, and aligned with real-world workflows.
Frequently Asked Questions
Who can perform a Good Faith Exam?
A Good Faith Exam must be conducted by a licensed medical provider with the ability to perform a proper medical evaluation. Who can perform a good faith exam depends on state law, scope of practice, and the type of service being evaluated.
Does a doctor always need to perform the exam?
Not always. In some cases, a good faith exam nurse practitioner or physician assistant may perform the exam under advanced practice rules or with a supervising or collaborating physician. In certain states or higher-risk medical procedures, it must be performed by a physician.
What is the purpose of the good faith exam?
The purpose of the good faith is to ensure a patient is a good candidate for the procedures being considered. It is a crucial first step in confirming that medical treatments are appropriate and safe.
What information is reviewed during the exam?
Providers note their medical history, current medications, and any relevant medical conditions. This helps assess a patient’s physical condition and determine if the treatment aligns with safe and effective care.
Can non-licensed staff conduct good faith exams?
No. Exams must be conducted by a licensed medical professional or qualified medical professional. Unlicensed staff cannot administer the good faith exam or make clinical decisions.
What is an initial Good Faith Exam?
An initial good faith exam is the first evaluation performed before treatment begins. A new good faith exam may be required if the patient’s health status changes or new medical procedures are introduced.
What happens if a patient is not approved?
If the provider determines the patient is not a good candidate for the procedures, they will decline or modify the treatment plan. This decision is documented as part of the medical evaluation conducted.
Are Good Faith Exams considered the practice of medicine?
Yes. Conducting good faith exams is considered the practice of medicine. That is why they must be performed by a licensed healthcare provider and follow all applicable regulations.
Who can perform GFE in a medical setting?
Who can perform GFE varies by jurisdiction, but it always involves a licensed healthcare provider acting within their authority. The ability to perform good faith exams depends on whether the provider meets good faith exam requirements under state regulations.
Can Good Faith Exams be done via telehealth?
Yes. Many providers conduct virtual good faith exams through secure systems. These telehealth exams must meet the same standard of care and include a proper medical evaluation conducted by a licensed healthcare provider.
What happens during a Good Faith Exam?
The provider will review the patient’s medical history, assess a patient’s health status, and evaluate their physical condition. This includes a medical history review and, when needed, an appropriate physical examination or physical examination of the patient.
Is a Good Faith Exam legally required?
In many states, a good faith exam is legally required before certain medical aesthetic treatments or prescription-based services. Requirements vary, so medical practices should always verify with the appropriate medical board.
What qualifies as a compliant Good Faith Exam?
A compliant faith examination must be conducted by a licensed medical provider, reflect independent judgment, and include proper documentation. It must also meet state-specific spa compliance and regulatory standards.
Do Good Faith Exams require a physical exam?
In some cases, an appropriate physical examination is required depending on the service and state law. For telehealth, providers may rely on visual assessment and patient-reported information when appropriate.
How do Good Faith Exams support med spa compliance?
Good Faith Exams help med spa’s and med spa owners meet regulatory requirements by ensuring proper medical oversight. They show that care decisions are made by a licensed healthcare provider and align with the standard of care.
How often should a Good Faith Exam be updated?
A new good faith exam may be needed if there are changes in the patient’s health status, new medical events, or updates to the treatment plan. This helps maintain safe and compliant patient care.
