Good Faith Exam Services for Texas Med Spas

Every medical aesthetic treatment delivered in Texas begins with a clinical evaluation by someone licensed to make that call. We supply the providers who perform those exams, the protocols they work from, and the documentation that shows the evaluation actually happened.

Key takeaways

  • A good faith exam is a clinical evaluation, not a form. It has to be performed by a physician, or by an NP or PA working under proper delegation.
  • It comes before the first medical treatment, and again whenever the treatment plan materially changes.
  • Texas expects a physician, PA or APRN to be onsite or immediately available while the procedure runs.
  • We provide the licensed provider, the exam workflow and the records. You keep your practice, your staff and your schedule.

What the exam has to establish

The exam answers one question: should this particular patient receive this particular treatment. That is a clinical judgment, and in Texas it is a medical one. The Medical Board has been explicit that the procedures a med spa sells are the practice of medicine rather than a cosmetic service that happens to involve a needle.

Nonsurgical medical cosmetic procedures (including but not limited to the injection of medication or substances for cosmetic purposes, the administration of colonic irrigations, and the use of a prescription medical device for cosmetic purposes), have been determined by the TMB to be the practice of medicine. Such medical acts can be properly delegated by a physician to individuals who have the appropriate training.

Because the treatment is a medical act, the decision to proceed with it has to come from someone with the authority to make medical decisions. A working evaluation covers the patient’s medical history, including chronic conditions, past surgeries, current medications, allergies and any previous aesthetic treatments along with how those turned out. It covers what the patient is actually trying to achieve, which is often different from what they booked. And it covers informed consent: the contraindications, the risks, the realistic alternatives and how long results are expected to last.

What comes out the other side is a treatment plan a provider is willing to put their license behind. If the evaluation cannot produce that, it has not done its job.

Who is allowed to perform it

A physician can perform the exam. So can a nurse practitioner or physician assistant working under appropriate delegation and, where prescribing is involved, a prescriptive authority agreement. A registered nurse cannot. An RN can take a history, administer treatment under a valid order and monitor the patient afterwards, but establishing the plan is the part that sits outside the role. An esthetician cannot perform it either, and no weekend certification changes that.

TDLR states the boundary in plain terms:

Anyone offering services at a medspa must have the appropriate license and training for the services they are providing, or be under the delegation of a licensed physician, when providing medical treatments.

The reverse also holds, and it catches people out. A physician cannot delegate cosmetology procedures. The two licensing systems do not convert into each other in either direction, which is why a practice with a mixed menu can find itself answering to TDLR and the Medical Board at the same time. We cover what that means for specific roles on our pages for registered nurses, nurse practitioners and estheticians.

What our good faith exam service covers

Practices come to us in one of two states. Either they are opening and need the clinical side stood up before the first patient, or they are already trading and have discovered that their current arrangement does not cover everything on the menu. The service is the same in both cases.

A licensed provider

A Texas-licensed physician, NP or PA matched to what you actually offer. Aesthetic experience matters here. Providers without it tend to narrow what they will authorize once they understand the exposure, and you find out late.

Protocols that match your menu

Delegation is specific to the procedures and devices it names. Protocols get written around your treatment list, your devices and your provider mix, then updated when you add something rather than a year later.

Records you can produce

Completed evaluations, stored where your practice can retrieve them. The test of any documentation system is whether you can produce a specific patient’s exam quickly when somebody asks for it.

How it runs once you are live

The sequence below is the order the steps actually happen in, because each one depends on the one before it.

  1. We read your treatment menu. It determines everything downstream: which provider you need, what the protocols have to cover, and which agencies you answer to.
  2. You are matched with a provider whose license and experience cover that menu, and whose availability fits your operating hours.
  3. Protocols and delegation documents are written around the specific procedures and devices you use.
  4. The patient completes their history and goals ahead of the visit, so the provider is reviewing real information rather than starting cold.
  5. The provider evaluates and decides. Approve, modify or decline, with the reasoning recorded either way.
  6. Your team treats within the approved plan. Anything outside it goes back for a fresh evaluation rather than being absorbed into the existing one.

Step six is where most of the value sits. A plan that quietly stretches to cover treatments it was never written for is the same problem as having no plan.

Availability is part of the service

An exam performed by a provider nobody can reach afterwards solves the paperwork and not the requirement. The Medical Board sets out what has to be true while a procedure is happening:

Please note, a physician, PA or APRN must either: be onsite during the procedure; or be immediately available for emergency consultation in the event of an adverse outcome; and if necessary, the physician must be able to conduct an emergency appointment with the patient.

Read that as an operational constraint rather than a clause. It means your open hours and your provider’s availability have to overlap, every hour you treat. A practice running evenings and Saturdays needs an arrangement built for evenings and Saturdays. This is the single most common reason a cheap agreement turns out not to cover what the practice assumed it covered, and it is worth reading alongside what genuine remote oversight can and cannot do.

Where practices most often get caught short

Four patterns account for most of what we find when we look at an existing arrangement.

  • The intake form is doing the exam’s job. A self-reported form feeds the evaluation. It is not the evaluation.
  • The menu grew and the protocols did not. A new device or a new injectable needs delegation that names it.
  • The provider is credentialed but unreachable during the hours the practice actually treats.
  • The exam happened once, years ago, and has never been revisited despite the plan changing repeatedly since.

None of these are exotic. They accumulate quietly in practices that are otherwise running well, which is why they tend to surface at the worst possible moment. For the wider regulatory picture, see our summary of Texas med spa laws, and for the requirement itself in more depth, our guide to good faith exams in Texas.

Coverage across Texas

We support practices statewide, including the major metros and the communities around them. Availability depends on your location and the oversight your menu requires, so the practical answer comes out of the consultation rather than a coverage map. Start with the areas we serve, which lists the metros with a dedicated page and the physicians covering them.

Questions we get asked

Which treatments on our menu trigger the exam requirement?
Anything that counts as a medical procedure. Injectables, medical-grade lasers, prescription therapies and microneedling that goes past the surface all sit on the medical side. Surface-level esthetics generally do not. The line moves the moment you add a device or a prescription product, which is why we start by reading your menu rather than your license.
What happens when an evaluation turns up a contraindication?
The provider declines or modifies the plan, and that decision is documented alongside the reasoning. A service that only ever approves is not really evaluating anything. Your team is told what was ruled out and why, so the patient is not simply rebooked for the same treatment a month later.
Who holds the exam records, and can we get them out?
They belong with the clinical documentation your practice keeps, and you should be able to export them on demand. Ask any prospective provider this before you sign. An arrangement where completed exams live somewhere you cannot reach becomes a problem the first time a regulator, an insurer or a patient’s attorney asks to see one.
Can you cover evening and weekend hours?
That depends on your schedule and the provider you are matched with, and it is a genuine constraint rather than a formality. Texas expects someone with authority to be reachable while treatments are running. Tell us your real operating hours at the start, because they narrow the pool of physicians who can commit.
Does the same provider have to perform every exam?
Not necessarily. Continuity helps, but reliable coverage matters more than a single name on every record. What has to hold is that whoever performs a given evaluation is authorized to and has your current protocols in front of them. We build the arrangement so that a planned absence does not stop you treating.
How is this different from the exam guidance already on your site?
Our guide explains what Texas requires and why. This page is about who actually performs the exams for your practice once you need them covered. Read the guide first if you are still working out whether a treatment needs an evaluation at all.

Sources

Last reviewed 25 August 2026. This page is general information about how good faith exams work in Texas, not legal advice and not a substitute for it. Rules change and enforcement positions shift, so confirm current requirements with the Texas Medical Board or TDLR directly. Entity structure and management services agreements are legal work and need a Texas healthcare attorney.

Talk with our team

Tell us what is on your treatment menu and what hours you run. We will tell you what the exam side needs to look like, and whether your current arrangement already covers it.

The first conversation is free and there is no commitment. Call (210) 939-8373 or use the form.