NP / RN / PA Aesthetic Practice FAQ
What is a good-faith exam in a medspa?
A good-faith examination (GFE) is the clinical assessment a licensed prescriber performs before issuing an order for aesthetic medication. It must be performed by an NP, MD, or DO. Most states permit telehealth GFE for established patients and many for new patients. The GFE is what establishes the prescriber-patient relationship that authorizes RN-administered injections.
The good-faith exam (GFE) is the foundation of legally compliant aesthetic injection practice. Every state's nurse practice act, medical practice act, or board guidance requires a GFE before aesthetic medication is administered.
What the GFE establishes: - Prescriber-patient relationship (necessary for the prescription/order to be valid) - Patient's medical history relevant to the planned treatment - Identification of contraindications (active infection, pregnancy, neuromuscular disease, medication interactions) - Aesthetic treatment plan including medication, dose, anatomical sites - Discussion of risks, benefits, alternatives, and informed consent
Who performs the GFE: - Licensed prescriber: NP, MD, or DO - In some states, PA under physician supervision - In some states, the GFE for an established practice patient can be delegated to a defined protocol; first-visit GFE generally cannot be delegated
When the GFE happens: - Before first treatment - Re-evaluation typically required annually or when new medications/sites are added - For new patients in a multi-clinician practice, the first GFE typically must be done by the prescribing clinician
In-person vs telehealth GFE:
In-person was the historical standard but telehealth GFE is now permitted in the majority of states for aesthetic context, subject to state-specific telehealth statutes.
States that explicitly permit telehealth GFE for aesthetic services include Arizona, Nevada, Florida (with specific provisions under §456.47), Texas (under Medical Board Rules §174.5), California (under specific telehealth statutes), New York, and most other states.
States with stricter rules: - Some states require an in-person component on first visit and permit telehealth for follow-up - A few states have prescriber-physical-location requirements (prescriber must be physically located in the patient's state) - Schedule II prescribing has stricter telehealth rules under the Ryan Haight Act — relevant if your practice includes weight-loss or wellness services that involve Schedule II drugs
Documentation requirements: - Patient identification verification - Medical history including allergies, current medications, prior aesthetic treatments - Physical assessment relevant to the planned treatment - Documented informed consent - Treatment plan including medication, dose, anatomical sites - Adverse event protocol acknowledgment
What can go wrong: - GFE performed by a non-prescriber (RN, esthetician) — this is the most common compliance violation and a major regulatory risk - GFE not documented or documented retroactively - Telehealth GFE in a state that requires in-person, or telehealth GFE performed by a prescriber not physically located in the patient's state - Standing orders used in place of patient-specific GFE in a state that doesn't permit standing orders for aesthetic context
This is one of the highest-stakes compliance areas in aesthetic practice. The penalties for GFE violations range from civil fines to license suspension to criminal charges (in extreme cases).
State-specific GFE rules are detailed at /scope-of-practice/[state] and /open-medspa-in-[state].