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What are the requirements for Good Faith Exams at a medical spa?

What is a GFE, and what Significance does it hold?

Almost all aesthetic services provided by medical spa offices are considered ‘practice of medicine’. Med spas must establish the physician-patient relationship and ensure that a med spa patient is a good candidate for the proceduresis safe. This is the purpose of the Good Faith Evaluation(GFE). Good faith evaluations go by many names, and in fact, the term “good faith evaluation” has been replaced in many states’ laws. It is common to hear the good faith evaluation referred to as the “good faith exam”, “initial exam,” “physical exam” “medical clearance” or “initial consult.” It is important to remember that the good faith evaluation must happen before a patient receives a treatment to assess their current condition, note their medical history and ensure they are fit for the procedure. The goal of the good faith evaluation is to make a diagnosis and determine an appropriate treatment plan for the patient.

Does the patient have to have a GFE before receiving a treatment?

Both the state medical and nursing boards have mandated that this is the “standard of care” for all aesthetic treatments. These laws exist to ensure patient safety and protection. GFE provides medical clearance prior to patient treatment.

Who can do it?

The good faith evaluation must be performed by a physician, physician assistant (PA) or nurse practitioner(NP). Both PA or NP must be delegated the ability to perform good faith evaluations by their supervising or collaborating physician. Registered nurses (RN) may aid the physician, PA or NP in administering the good faith evaluation, but they cannot clear patients for treatment based on the evaluation. A physician, PA or NP would need to review the RN’s findings and generate the treatment plan and order.

What constitutes a good faith evaluation ?

The good faith evaluation proceeds in two parts: obtaining a patient’s medical history and performing an appropriate physical examination of the patient. The medical history is a brief account of the patient’s general lifestyle, medical events and on-going treatments that may contain relevant information regarding the patient’s health. The appropriate physical examination is an assessment of the patient’s physical condition, generally and specifically, of the areas where the patient will receive treatment.

When does the good faith evaluation need to be performed?

The good faith evaluation should be performed prior to a patient receiving a treatment, but it does not have to be performed every time you see the patient. Especially in the med spa context, a treatment plan will likely encompass multiple treatments over a period of time. If a patient seeks additional treatments not covered in the initial treatment plan, the patient’s health substantially changes or enough time has elapsed since the initial good faith evaluation, a new good faith evaluation should be performed. It is a good rule of thumb that a good faith evaluation should be performed at least annually on a patient.