Key takeaways
- A good faith exam is the medical evaluation a patient must receive before treatment; it is what makes a med spa procedure a legitimate medical act instead of a retail service.
- Florida requires a good faith exam before injectables, lasers, and similar treatments; skipping it is one of the fastest ways to lose your clinic.
- In Florida the exam must be performed by a physician (MD or DO), nurse practitioner, or physician assistant. A registered nurse cannot perform it.
- A telehealth good faith exam can be valid in Florida when done correctly, but a rubber-stamp video call is a liability, not compliance.
- The good faith exam is your medical director\u2019s responsibility, tied to your protocols and standing orders.
The good faith exam is the medical evaluation that must happen before any treatment; it is the legal gate for your clinic.
A good faith exam is the documented medical evaluation a physician, nurse practitioner or physician assistant performs before a med spa treatment: history, focused examination, indication and a treatment order. Florida statute never uses the phrase; the duty comes from Rule 64B8-9.014 and Statute 458.331, which make prescribing without an appropriate examination grounds for discipline. A registered nurse cannot perform it.
The good faith exam is the single compliance step most likely to close a Florida med spa when it is skipped. If you own or run a clinic, this is the evaluation that turns a treatment into a legal medical act, and getting it wrong is not a paperwork problem, it is an existential one.
What is a good faith exam?
A good faith exam is the initial medical evaluation a patient must receive before a med spa treatment. A qualified provider reviews the patient history, assesses whether the treatment is appropriate, and authorizes or declines the procedure. In Florida it is the legal gate that has to happen before injectables, lasers, or other medical services.
It exists because these treatments are the practice of medicine. The exam is what documents that a real clinician, not a front-desk upsell, decided the treatment was safe for that specific patient.
Does Florida require a good faith exam?
Yes. Any Florida med spa performing medical procedures must complete a good faith exam before treatment. There is no version of a compliant injectables or laser practice that skips it. Because enforcement and specifics evolve, confirm your exact obligations with a Florida healthcare attorney and verify current requirements with the Florida Board of Medicine.
The two texts behind the requirement are short. Rule 64B8-9.014 of the Florida Administrative Code sets the standard for prescribing and requires a documented history and physical examination first, and Florida Statute 458.331 lists prescribing inappropriately and failing to keep adequate records among the grounds for disciplinary action.
Who can perform a good faith exam in Florida?
Only a qualified medical provider. In Florida a good faith exam must be performed by a physician (MD or DO), a nurse practitioner, or a physician assistant. A registered nurse cannot perform it, and neither can an esthetician or front-desk staff.
In Florida the good faith exam must be performed by a physician, NP, or PA, never an RN.
| Provider | Can perform the good faith exam in Florida? |
|---|---|
| Physician (MD / DO) | Yes |
| Nurse Practitioner (NP) | Yes |
| Physician Assistant (PA) | Yes |
| Registered Nurse (RN) | No |
This is the same credential line that governs injecting. Our breakdown of what an aesthetic RN can legally do in Florida explains why the RN sits below that line, and it is why the exam ties directly back to your physician oversight.
Can a good faith exam be done via telehealth in Florida?
It can, when it is done correctly. A telehealth good faith exam is valid in Florida if a qualified provider actually reviews the patient, evaluates suitability, and documents the decision in real time. What is not compliant is a rubber-stamp: a provider clicking approve on a batch of patients they never assessed. That is the practice that turns telehealth from a convenience into evidence against you.
A telehealth good faith exam is valid in Florida only when a real provider genuinely evaluates the patient.
What happens if your med spa skips the good faith exam?
Compliance attorneys call the good faith exam the med spa widow-maker for a reason. Skip it and you are running treatments that legally count as the unauthorized practice of medicine. The exposure stacks: board complaints against your medical director, malpractice liability if a patient is harmed, insurance that will not defend an out-of-scope claim, and a clinic that can be shut down. It is the cheapest step to get right and the most expensive one to get wrong.
Good faith exam, standing orders, and the medical director
The exam does not stand alone. It sits inside your medical oversight structure: your medical director sets the protocols and standing orders, and the good faith exam is where those protocols meet the individual patient. If your oversight is weak, your exam process is weak by definition. This is exactly why the medical director hire matters so much; our guide on the med spa medical director in Florida covers who is accountable for this. If you are still setting up, our guide on how to open a med spa in Florida puts the exam in the context of the full legal build.
Documentation is half the exam: an undocumented good faith exam is treated as one that never happened.
How to keep your good faith exam process compliant
Build the exam into the flow so it cannot be skipped:
- Every new patient receives a good faith exam before their first treatment.
- The exam is performed by a physician, NP, or PA, never an RN or an esthetician.
- It is documented in the chart with history, assessment, and a clear treatment authorization.
- Telehealth exams run through a compliant platform with a real, reachable provider.
- Patients are re-evaluated per your protocols when the treatment plan changes.
- Your medical director owns the process and signs off on the protocols behind it.
This sits inside our complete Florida med spa compliance guide, which covers medical direction, good faith exams, ownership rules, and the delegation limits every clinic must follow so you can see how each requirement connects.
The oversight duties are covered in how to become a medical director for a med spa in Florida, including the physician oversight responsibilities, good faith exam duties, and delegation rules the role carries.
How often does a good faith exam need to be repeated?
A good faith exam is not one-and-done. In practice it is required before the first treatment, refreshed at least annually, and repeated whenever the patient's health status or treatment plan changes materially. Treating a returning client on a stale exam is one of the most common compliance failures Florida med spas make.
A consultation is not a good faith exam
This confusion is costly. A front-desk or provider consultation about pricing and goals is not a GFE. A compliant GFE is a documented clinical workflow performed by a qualified provider:
- Review the patient history and medications.
- Perform the relevant physical assessment.
- Document the clinical decision and the treatment authorization.
- Only then may the treatment proceed.
Which services trigger a GFE in a Florida med spa:
| Service | GFE required? |
|---|---|
| Botox / neurotoxin and dermal filler | Yes |
| Laser and IPL | Yes |
| IV therapy and vitamin injections | Yes |
| Weight-loss injections (semaglutide, tirzepatide) | Yes |
| Facials and non-medical skincare | Generally no |
The staffing question: who your med spa must hire to run good faith exams
Compliance is ultimately a hiring problem. Only an MD, DO, NP, or PA can perform the GFE, and the clinic needs a medical director standing behind the protocols. Many Florida med spas fail inspections not because they misunderstand the rule but because they never staffed for it. Florida Statutes Chapter 458 govern the practice of medicine and delegation behind the exam, and AmSpa tracks the med spa compliance standards state by state. If you need to build that team, post your medical director, nurse practitioner, or injector roles through Enhance.work and reach vetted South Florida med spa professionals.
→ which credential Florida requires for laser hair removal and how physician supervision must be documented covers the employer side of the laser rule.
What goes in a good faith exam, item by item
Search this term and most of page one is companies selling you the exam. That is useful if you want to outsource it, and useless if you are trying to work out what the record has to contain. Worth knowing first: good faith exam is industry shorthand, not a term Florida statute defines. What the law actually requires is a pre treatment evaluation by a qualified provider, documented well enough to show the treatment was medically appropriate for that patient. The label matters less than the record.
| Element | What the record must show | Who signs it |
|---|---|---|
| Patient identity and history | Medical history, current medications, allergies, prior treatments and outcomes | Provider performing the exam |
| Focused physical assessment | Examination of the treatment area, documented findings, not a checkbox | Physician, PA or APRN |
| Indication and appropriateness | Why this treatment suits this patient now, and what was ruled out | Physician, PA or APRN |
| Contraindication screening | Pregnancy, neuromuscular disease, active infection, anticoagulation, prior reactions | Provider performing the exam |
| Treatment plan and product | Product, planned dose or settings, treatment areas | Physician, PA or APRN |
| Informed consent | Risks discussed, alternatives offered, patient signature and date | Patient and provider |
| Delegation record | Who will perform the treatment and under what standing order | Supervising physician |
| Date and re examination trigger | Exam date, and what change requires a new exam | Provider performing the exam |
Two failure modes account for most of the problems we see. The first is the exam that exists but is not documented, which in an audit is the same as no exam. The second is the exam performed by someone who cannot perform it. In Florida the evaluation belongs to a physician, physician assistant or advanced practice registered nurse, and delegation of the treatment does not delegate the evaluation. Our breakdown of what an aesthetic RN can legally do in Florida under physician delegation covers where that line sits, and the underlying scope language is in section 464.003 of the Florida Statutes, which defines professional nursing practice.
Good faith exam checklist: what the chart must show
This is the template people search for. It is not a form to download, because the exam has to be adapted to the treatment; it is the list of what a defensible record contains. Copy it into your EMR as required fields.
- ☐ Patient identity, date of birth and date of the exam
- ☐ Medical history: conditions, medications, allergies, prior aesthetic treatments and their outcomes
- ☐ Contraindication screen for this treatment: pregnancy or breastfeeding, neuromuscular disease, active infection at the site, anticoagulation, prior reactions, keloid history for devices
- ☐ Focused examination of the treatment area, findings written out rather than ticked
- ☐ Indication: why this treatment suits this patient now, and what was considered and ruled out
- ☐ Plan and order: product or device, dose or settings, areas, number of sessions
- ☐ Informed consent: risks, alternatives, patient signature and date
- ☐ Delegation: who will perform the treatment and under which standing order
- ☐ Examiner's name, credential (MD, DO, NP or PA), license number and signature
- ☐ Re-examination trigger: what change requires a new exam, and the interval your written protocol sets
Keep the completed record with the treatment note, not in a separate binder; when the Board asks, it asks for the chart. Train every provider on the record before they treat, as our guide to med spa staff training requirements in Florida sets out, and check that your malpractice policy expects the exam, because carriers do, as our med spa insurance guide explains.
In-house or outsourced: the good faith exam services on the market
Search for good faith exam and half of page one is companies selling the exam by telehealth. That is a legitimate model if the provider is Florida licensed and your medical director still owns the protocol. Here is what the ones ranking for Florida published on 4 September 2026.
| Option | How it works | Published price | What to verify |
|---|---|---|---|
| Your own NP or PA on staff | Exam in person or by video before each treatment | Payroll; see what each clinical hire costs | Availability during every treatment hour; delegation record |
| Your medical director by telehealth | Director performs the exam remotely under your protocol | Included in or added to the director fee | Florida telehealth standards; time to respond |
| Qualiphy | Pay per exam telehealth network | $27.99 per exam, no monthly fee | Florida licensed provider on each exam; record delivered to your chart |
| GoodFaithExams.com | Pay per exam telehealth, no contract | $26.99 per exam | Provider license, turnaround, record format |
| Spakinect | Membership plus per patient evaluations | From $99 a month plus per exam | What the membership includes beyond the exam; provider licensing |
Two checks before you sign with any of them. Florida Statute 456.47 sets the standard of care and registration rules for telehealth providers treating Florida patients, and the examiner must hold a Florida license in one of the three qualifying professions. Compare the per exam price against the loaded cost of your own NP or PA using our breakdown of what each aesthetic hire actually costs. If you are the NP or PA reading this, good faith exam work is now a role of its own; our nurse practitioner injector guide covers the Florida provider position it sits inside.
Frequently asked questions
What is a good faith exam?
A good faith exam is the initial medical evaluation a patient must receive before a med spa treatment. A qualified provider reviews the patient history, assesses suitability, and authorizes or declines the procedure.
Does Florida require a good faith exam?
Yes. Any Florida med spa performing medical procedures such as injectables or lasers must complete a good faith exam before treatment. Confirm specifics with a Florida healthcare attorney and the Florida Board of Medicine.
Who can perform a good faith exam in Florida?
A physician (MD or DO), a nurse practitioner, or a physician assistant. A registered nurse cannot perform the good faith exam, and neither can an esthetician or front-desk staff.
Can a good faith exam be done via telehealth in Florida?
Yes, when done correctly. A telehealth good faith exam is valid if a qualified provider genuinely evaluates the patient and documents the decision. A rubber-stamp video approval is not compliant.
Is a good faith exam required for Botox?
Yes. Botox and other injectables are medical treatments, so a good faith exam is required before the first treatment, performed by a qualified provider.
What happens if a med spa skips the good faith exam?
Skipping it means running treatments that count as the unauthorized practice of medicine, exposing the clinic to board complaints, malpractice liability, denied insurance claims, and potential closure.
How often is a good faith exam required?
Before the first treatment, at least once a year after that, and again whenever the patient's health or treatment plan changes.
Is a consultation the same as a good faith exam?
No. A consultation covers goals and pricing; a good faith exam is a documented clinical evaluation by an MD, DO, NP, or PA that authorizes treatment.
Who does a Florida med spa need to hire to perform good faith exams?
A licensed MD, DO, NP, or PA, plus a medical director overseeing protocols. Estheticians and RNs cannot perform the GFE.
What does a good faith exam consist of?
A history, a focused physical assessment of the treatment area, a contraindication screen, a documented indication and a treatment order, followed by informed consent. The checklist above lists the ten elements a Florida chart should show.
Can an RN do a good faith exam?
No. In Florida the examination must be performed by a physician, a nurse practitioner or a physician assistant. An RN can take the history and prepare the chart, but the assessment and the order have to be the qualifying provider's own.
What does GFE mean in aesthetics?
GFE is industry shorthand for good faith exam, the pre treatment evaluation. You will see it in job ads for telehealth NP roles and in vendor pricing. It is not a term Florida statute defines, which is why the record matters more than the label.
Is there a good faith exam template or PDF?
Vendors sell them, but a generic form is the weak point in an audit. Use the checklist in this guide as the required fields of your own record and adapt the contraindication screen to each treatment on your menu.
Get the exam right and the rest is defensible
The good faith exam is cheap to do correctly and ruinous to skip. Put a qualified provider on every patient before treatment, document it, and anchor it to a real medical director. Do that and the rest of your compliance has a foundation to stand on.
This article is general information, not legal advice. Florida rules and enforcement change; confirm your requirements with a Florida healthcare attorney and the Florida Board of Medicine.
