Good Faith Exams in Texas: Who, When and How
A qualified clinical evaluation supports an individualized treatment plan. It works together with appropriate orders, delegation, informed consent, and ongoing supervision.
What the exam establishes
The evaluating physician, or appropriately authorized NP or PA, reviews the patient’s history, relevant findings, contraindications, and proposed services. The resulting assessment and plan must support the care ordered for that patient. An exam alone does not establish compliance with every requirement.
How it works in practice
Who performs it
A physician, or an NP or PA operating under appropriate delegation and, where prescribing is involved, a prescriptive authority agreement.
When it is required
Before the initial course of treatment, and again when the plan materially changes: a new service, a new device, or a significant change in the patient’s history.
What gets documented
History, relevant contraindications, the assessment, and the resulting plan. The documentation is the evidence the exam happened.
Integrated evaluations through Spa Clear
Spa Clear, offered through We Treat’s Spa Suite, is $10 per completed GFE. An encounter typically reviews approximately three proposed services; each requires an individualized decision, and the fee is per exam rather than per service.
Our workflow connects the evaluator, chief medical officer or supervising physician, and treating nurse or other licensed clinician through the patient record, applicable standing orders, and protocols. Our practice does not accept disconnected external clearances as a substitute for this workflow; this is our service policy, not a blanket legal ban on external clinicians.
Audit your own process
- Who performs the exam, and what authorizes them to
- Whether it happens before treatment, every time it should
- Whether it is repeated when the treatment plan changes
- Whether the documentation would hold up if requested
Our active supervision standard
Our medical practice provides 100% chart review, with at least 10% of all good faith exams personally performed by the active supervising physician. On-site visits, over-the-shoulder training, skills certification and verification, and a documented supervision work ledger support ongoing care.
These are our service commitments, documented in the supervision plan, rather than universal legal minimums. The supervising physician remains responsible for delegated medical acts, and each clinician retains their individual license obligations.
Questions about good faith exams
Can it be done by telehealth?
Can an RN perform the exam?
An RN can perform nursing assessment, gather history, and support the evaluation within nursing scope. An RN does not independently diagnose or prescribe the medical treatment plan. Medical evaluation and ordering are performed by a physician or appropriately authorized NP or PA.
How often does it need to be repeated?
Reassess as clinically indicated, when patient circumstances or proposed treatment change, and as required by applicable rules, orders, and protocols. An initial exam does not automatically authorize all future services.
Does a patient intake form count?
Is the exam the same thing as informed consent?
What has to end up in the patient’s file?
Document the evaluator, relevant history and findings, assessment, proposed services, treatment decision, orders, and follow-up. The treating clinician must have access to the information needed for safe care. Our Spa Clear workflow connects that record with the supervising physician and applicable protocols.
Key takeaways
- Medical treatments require an appropriate evaluation and individualized plan.
- An RN may contribute nursing assessment and history but does not independently diagnose or prescribe.
- For covered cosmetic procedures, a physician, PA, or APRN must be on site or immediately available for emergency consultation.
- If needed, the physician must be able to conduct an emergency appointment.
- Consent and intake forms do not replace the clinical evaluation.
Evaluation is part of a complete care process
The assessment supports a clinical decision about the proposed care. Qualified personnel, scope of practice, delegation, patient consent, records, and emergency arrangements remain separate obligations. No form or clearance alone makes a treatment lawful.
Availability during treatment
For nonsurgical medical cosmetic procedures, TMB describes on-site presence or immediate emergency consultation by a physician, PA, or APRN. If necessary, the physician must be able to conduct an emergency appointment with the patient. The coverage plan should identify who is available and how staff escalate concerns.
What separates an exam from an intake form
This is where most of the real exposure sits, and it is usually a process problem rather than a knowledge problem.
An intake form collects history. It records allergies, medications, prior treatments and what the patient wants. All of that is useful and none of it is a decision. The exam is the point at which a qualified person reviews that information against the specific treatment proposed and concludes, on the record, that it is appropriate for this patient now.
Three things that usually go wrong
The first is timing. An evaluation done once at the first visit and never revisited stops describing the patient after the treatment plan materially changes.
The second is scope. An evaluation covering neurotoxin does not silently extend to a device treatment or an infusion added to the menu six months later.
The third is authorship. The chart should make clear who reached the judgment and what they were relying on. If the note cannot answer that, the exam is difficult to evidence afterwards even when it genuinely happened.
Sources
- Texas Medical Board FAQ 312 — nonsurgical medical cosmetic procedures, delegation and availability
- TDLR, Medspas at a Glance
- Texas Department of Licensing and Regulation, Medical Spas
- Texas Board of Nursing, Delegation FAQ
This page is general information for Texas practice owners and is not legal or medical advice. The Texas Medical Board consolidated its rules on nonsurgical medical cosmetic procedures in 2025, and requirements change. Confirm the current rule text and your own structure with the Board and with counsel before relying on this page.
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