Good Faith Exams and Telemedicine Clearance Exams: 2025–2026 Complete Guide for Med Spas, IV Therapy and Wellness Clinics

TL;DR – Good Faith Exams & Telemedicine Clearance Exams

• A Good Faith Exam (GFE) is industry slang for a pre-treatment patient evaluation. Most boards don’t formally recognize the term.
• Regulators require a valid patient-provider relationship (PPR) and documentation that meets the standard of care.
• Who can perform a GFE/clearance exam: Only MDs, DOs, NPs, or PAs. RNs cannot diagnose, prescribe, or establish a PPR.
• Telemedicine clearance exams are allowed in most states, but usually require synchronous video, documented exam notes, and prescribing authority.
• Shortcut models (blanket orders, RN-led GFEs, or third-party platforms that disclaim liability) are non-compliant and expose clinics to audit and malpractice risk.
• The future: regulators are moving away from the “GFE” label toward ongoing, documented patient-provider relationships.

What Is a Good Faith Exam in a Med Spa or IV Hydration Clinic?

In the aesthetics and IV hydration world, the term “Good Faith Exam” (GFE) has become shorthand for the pre-treatment assessment that happens before a patient receives care. Vendors and consultants toss it around casually — as if it’s a standardized, universally recognized requirement. The truth is, most state boards don’t even use the phrase “good faith exam.”

What they do recognize — and enforce — is the establishment of a valid patient-provider relationship (PPR) and adherence to the standard of care. That’s the real threshold.

At GuardianMD, we’ve seen firsthand how regulators are tightening their stance. Boards aren’t impressed by industry jargon. They care about whether a licensed provider actually evaluated the patient, made a clinical decision, and documented it properly.

Why Are Good Faith Exams Controversial?

Boards across the country are signaling that “GFE” is not enough. In the past 12–24 months, multiple boards — especially nursing and medical boards — have issued position statements clarifying:

• RNs cannot diagnose or treat.
• Standing orders are not substitutes for individualized care.
• A true provider exam and prescription must precede treatment.

Regulators have made it clear that vague GFEs don’t hold up. For example, in 2025 the Arkansas Nursing Board clarified in writing that “the term ‘Good Faith Exam’ is not within the NPA language” and warned that exams were not being conducted properly, especially regarding follow-up and prescribing standards.

As another example; one of our Ohio nurses was told directly by the state board that she needed a verbal order before every single infusion. That’s how seriously they are taking the requirement for provider involvement.

And then there’s Jennifer’s Law, where legislators specifically addressed IV therapy, making it clear that RNs cannot operate independently and that a provider-patient relationship and prescription must be established before IV administration.

The takeaway is simple: buzzwords don’t protect your license. Compliance with valid PPR standards does.

Can a Good Faith Exam Be Done via Telemedicine?

For many clinics, the natural question is: Can we do this virtually? The answer is generally yes — with conditions.

Most states allow telemedicine clearance exams if:

• They are conducted via live, synchronous video (not just forms or texts).
• The provider performing the exam has the legal authority to diagnose and prescribe (MD/DO, NP, PA).
• The documentation is thorough enough to establish a PPR and defend medical decision-making.

Key compliance nuances:

• Documentation: history, risks, exam findings, treatment rationale.
• Frequency: many states expect the exam to be updated annually, or sooner if clinical status changes.
• Provider type: RNs cannot conduct a clearance exam or prescribe based on it.

Who Can Legally Perform a Good Faith Exam?

A consistent point of confusion is who may actually perform the exam.

• Permitted: MDs, DOs, Nurse Practitioners, Physician Assistants (depending on state laws).
• Not permitted: RNs, estheticians, or unlicensed staff.

Every state has different nuances. For example:

• California: requires a prescriber to evaluate the patient and document a plan before delegation.
  “The good faith exam is tied to the requirement for an ‘appropriate prior examination’ under Business & Professions Code § 2242. It requires healthcare providers to carefully review a patient’s medical history, overall condition, and specific needs before proceeding with treatment.” (djholtlaw.com)
• Texas: specifies requirements for telemedicine PPRs.

“Texas rules expressly require physicians, PAs, or APRNs to conduct the good faith exam. These practitioners should be trained in or familiar with the delegated medical act and able to perform it in accordance with the standard of care.” (byrdadatto.com)

• Florida: allows telehealth PPRs but requires prescribing authority.

If your clinic needs a licensed provider to perform clearance exams, see our guide on how to find a medical director for your med spa.

Clarifying “Licensed Provider” Terminology
Many state position statements use the term “licensed provider” when discussing who can establish a patient-provider relationship. Clinics need to understand that this term, in regulatory and board language, usually means MD, DO, NP, or PA—not RNs or other licensed personnel who do not have prescribing authority or legal scope to diagnose and treat.

For example, in full practice-authority states, NPs are permitted by law to evaluate, diagnose, prescribe, and initiate treatment without required supervision or collaboration. But in reduced* or restricted* practice states, even licensed NPs must operate under collaboration or supervision for some or all of those functions.

Thus, when board statements or vendor agreements say “licensed provider,” it’s essential to verify what that means in your state—because relying on a broader interpretation can leave a clinic non-compliant.

Are Third-Party Good Faith Exam Platforms Actually Compliant with State Laws?

Many clinics now rely on third-party platforms that promise “fast, virtual GFEs.” On the surface, they seem convenient. But boards and malpractice attorneys ask a simple question:

Who actually established the patient-provider relationship and took responsibility for the order?

Here’s what’s often hidden in fine print:

• Many of these platforms explicitly state in their agreements that their evaluations do not create a patient-provider relationship.
• Their NPs may not have collaborating physicians in states that require it. Instead, the onus is pushed back onto the medical director — who often never sees the patient.
• That creates a compliance gap: a treatment order appears to come from the medical director, but without a true patient exam, it fails to meet board standards.
• When there’s a bad outcome, it’s often unclear whether the third-party NP will take responsibility for the patient — leaving the clinic and medical director exposed.

At GuardianMD, our NPs and physicians:

• Establish valid PPRs with documented exams.
• Write and own treatment orders.
• Take responsibility for patient outcomes.

That’s the difference between a compliance checkbox and compliance confidence.

What Are the Risks of Shortcut Approaches?

Shortcut models — whether blanket standing orders, one-time GFEs, or quick-sign vendor templates — may feel convenient, but boards and regulators are increasingly calling them out as non-compliant medical practice.

Key Risks:

• Regulatory enforcement: Multiple states (Ohio, Arkansas, Texas) have explicitly warned that vague GFEs and standing orders do not meet board standards.
• Professional liability: If there’s a patient harm event, the supervising physician or medical director is almost always named — even if they never saw the patient.
• Malpractice coverage gaps: Many insurers will deny claims if the documentation doesn’t demonstrate a valid PPR and SOAP note.
• Enterprise value erosion: During acquisitions or diligence, non-compliant workflows are flagged by buyers, often reducing valuations or killing deals.

Bottom line: regulators, insurers, and investors all see shortcuts as red flags. What looks efficient today can become a catastrophic liability tomorrow.

How to Do a Good Faith Exam the Right Way (Compliant Workflow)

A safe, compliant workflow looks like this:

1. Patient intake: demographics, history, consent.
2. Risk assessment: contraindications, meds, allergies.
3. Exam: in-person or video telehealth, documented thoroughly.
4. Provider decision: prescriber issues treatment plan and orders.
5. Documentation: chart notes, signed protocols, renewal tracking.
6. Treatment delivery: RN administers under valid orders.

Telemedicine checklist:

• HIPAA-compliant platform.
• Verify patient ID and location.
• Confirm provider licensure.
• Store notes and consents in the EMR.

Audit-ready templates: intake form, telehealth consent, exam note, treatment orders.

What Needs to Be in a Good Faith Exam Note?

One of the most common questions we hear is: “Do you have a Good Faith Exam template?” The reality is that there is no such thing as a separate GFE note. A Good Faith Exam is simply a patient evaluation, and the documentation should look exactly like any other SOAP note.

In other words: if your note wouldn’t satisfy board standards as a complete SOAP note, it won’t hold up as a Good Faith Exam note either.

Key Elements Every Good Faith Exam (SOAP) Note Should Include

• Subjective (S): Patient history — medical, surgical, medication, allergy, family/social history, and reason for visit.
• Objective (O): Physical exam findings appropriate to the planned treatment (e.g., vitals, focused systems review).
• Assessment (A): Clinical decision-making that supports whether the patient is a candidate for treatment.
• Plan (P): Treatment orders, prescriptions if needed, follow-up intervals, risks/benefits discussed, and patient education.
• Consent: Signed patient consent for treatment, stored in the chart.
• Provider Signature & Credentials: MD/DO, NP, or PA who performed the exam.

Why This Matters

Some clinics mistakenly believe a GFE note is “lighter” or somehow different from a full SOAP note. That misconception is part of the compliance problem. Boards expect full documentation of a valid patient-provider relationship — not a watered-down checklist.

FAQs About Good Faith Exams

General GFE Questions

Who Can Perform a Good Faith Exam

Telemedicine & Virtual GFEs

Treatment-Specific Questions

Documentation & Templates

Risk & Compliance

The Future of Good Faith Exams — From Buzzword to Patient-Provider Relationship

Regulators are moving away from “good faith exam” language and focusing on valid patient-provider relationships. Expect:

• More position statements clarifying roles (already happening in nursing and medical boards).
• More enforcement actions around IV hydration, injectables, and weight loss prescribing.
• Higher expectations for living protocols and documentation.

Clinics that treat clearance exams as compliance checkboxes will be left vulnerable. Those that operationalize true PPRs with audit-ready systems will thrive.

How GuardianMD Supports Clinics Without Vendor Buzzwords

At GuardianMD, we:

• Build CPOM-aligned structures to protect ownership.
• Provide audit-ready documentation that meets board expectations.
• Deliver oversight from MDs, NPs, and PAs who establish real patient-provider relationships.

Other vendors sell convenience. We deliver compliance confidence that protects patient safety and enterprise value.