Telehealth good faith exam (GFE) rules by state: where a video exam works for med spas
In most of the 15 largest med spa states, a good faith exam can be done by telehealth if the prescriber is licensed in the patient’s state, the patient consents and the video visit meets the same standard of care as an in-person exam. California, Arizona and Florida say so directly in statute. Georgia, Washington and New York are less clear for cosmetic treatments, and some procedure rules still call for a physical exam, so those need a check before you build a remote-GFE workflow.
- Clearly allowed: California, Arizona and Florida statutes let the prior exam or evaluation happen by telehealth.
- Allowed under a standard-of-care test: Texas, New Jersey, Ohio, Illinois, Pennsylvania, Nevada, Virginia, North Carolina and Colorado.
- Verify first: Georgia, Washington and New York for cosmetic GFEs.
- Questionnaire-only "exams" are the model regulators criticize; use live video with the prescriber.
- The prescriber needs a license in the state where the patient is at the time of the visit.
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What every state asks of a telehealth GFE
Short answer: four conditions show up almost everywhere. If any one fails, treat the telehealth visit as a history call and do the exam in person.
- Same standard of care. Ohio’s telehealth statute lets a professional use telehealth for an initial visit “if the appropriate standard of care for an initial visit is satisfied”; Illinois’s Telehealth Act and Pennsylvania’s 2024 telemedicine law apply the in-person standard; the North Carolina Medical Board does not recognize a separate telemedicine standard.
- License where the patient is. Nevada, for example, requires a distant-site provider treating a patient in Nevada to hold a Nevada license (NRS 629.515).
- Consent to telehealth. California (B&P §2290.5) and Arizona (A.R.S. §36-3602) require it before telehealth care.
- A real evaluation. A history form is useful preparation, but North Carolina’s board, and Washington’s commission in its telemedicine guidance, treat a questionnaire alone as not enough.
Aesthetic GFEs add a fifth practical condition: the prescriber must be able to see what will be treated. Ask patients to join on a device with a good camera, in good light, and to show the area from the angles the protocol requires. If the prescriber cannot assess it, the protocol should say the exam converts to in-person.
Telehealth GFE permissibility in the 15 largest med spa states
How to read this table: “Allowed” means a statute or board publication says an exam or patient relationship may be established by telehealth, subject to the conditions shown. “Verify” means a rule points the other way for cosmetic treatments, or we could not confirm the point on a primary source. Checked October 2026. Not legal advice.
| State | Telehealth GFE | Key conditions and caveats | Source |
|---|---|---|---|
| Texas | Allowed (standard of care) | A valid practitioner-patient relationship can be established through telemedicine (including synchronous audio-video) if the standard of care is met. Delegated cosmetic procedures still need the relationship and records first (22 TAC §169.26). Telehealth exams for elective IV therapy under HB 3749: verify. | Occ. Code §111.005 |
| California | Allowed | §2242 says the appropriate prior examination may be done through telehealth if the standard of care is met. Telehealth consent required (§2290.5). | B&P §2242, §2290.5 |
| Florida | Allowed | “A telehealth provider may use telehealth to perform a patient evaluation,” at the in-person standard. Laser hair removal by electrologists requires an initial physician exam and assessment; whether video satisfies it: verify. | §456.47, 64B8-56.002 |
| New York | Verify | Telehealth is recognized in statute, but RN cosmetic injections need a patient-specific order after an adequate exam, and we did not find NYSED guidance saying a video exam satisfies that. | PHL §2999-cc, NYSED |
| Arizona | Allowed | An examination may be conducted during a telehealth encounter; boards may not require an in-person exam before prescribing (Schedule II excepted). Informed consent to telehealth required. | A.R.S. §36-3602 |
| Georgia | Verify | The telemedicine rule allows care where the provider has personally examined the patient or examines using technology “equal or superior” to an in-person exam. The cosmetic laser rule requires an exam before service (except hair removal and pulsed light). | 360-3-.07, 360-35-.05 |
| Illinois | Allowed (standard of care) | Telehealth within scope at the in-person standard. For laser hair removal, the delegating physician may supervise by two-way real-time communication. Physician exam before other laser procedures: format verify. | 225 ILCS 60/54.2, 225 ILCS 150 (Telehealth Act) |
| New Jersey | Allowed (standard of care) | A provider-patient relationship may be established by telemedicine if the standard of care can be met; the provider reviews history and records before an initial encounter. | P.L. 2017, c.117 |
| North Carolina | Allowed (standard of care) | Evaluation need not be in person if the technology allows an accurate diagnosis; a questionnaire alone may violate the law. The laser position statement requires an exam before the first laser hair or tattoo removal treatment; format: verify. | NCMB telemedicine, laser |
| Colorado | Allowed (standard of care), verify | Colorado Medical Board policy allows a provider-patient relationship to be established by telehealth under the same standards; confirm the current policy number and its application to medical-aesthetic delegation. | Colorado Medical Board telehealth policy (verify); Rule 1.17 |
| Nevada | Allowed (standard of care) | A relationship may be established by telehealth when clinically appropriate; Nevada license required. Filler injections themselves must happen in a medical facility or licensed office. | NRS 629.515, 629.086 |
| Washington | Verify | Cosmetic injection and laser rules require the physician to perform an “appropriate physical examination” before authorizing treatment. The commission’s telemedicine guidance holds telemedicine to the in-person standard and has said a questionnaire alone is not enough (confirm the current policy). Whether video meets the physical-exam rule: verify. | WAC 246-919-606, -605 |
| Pennsylvania | Allowed (standard of care) | Act 42 of 2024 covers synchronous, asynchronous and remote monitoring; same standard of care as in person. | PA DOS telemedicine FAQs |
| Ohio | Allowed (standard of care) | Synchronous or asynchronous telehealth may be used for an initial visit if the standard of care is met. Laser hair removal delegation has required the physician to personally evaluate the patient; HB 377 (effective August 25, 2026) changes this: verify. | ORC §4743.09, HB 377 |
| Virginia | Allowed (with conditions) | A prescriber may establish a bona fide relationship by real-time two-way communication or store-and-forward if history is obtained, a diagnosis made and the in-person standard met. | Va. Code §54.1-3303 |
Building a compliant remote-GFE workflow
Short answer: treat the telehealth GFE as a real appointment with a licensed prescriber, scheduled before the treatment, documented in the chart and able to say no.
Before the visit
- Collect history, medications, allergies and prior treatments through a secure intake form (no advertising pixels on that page; see HIPAA-safe website tracking).
- Confirm the patient’s state at booking and route to a prescriber licensed there.
- Send telehealth consent and instructions for camera and lighting.
During the visit
- Verify identity and the patient’s current location.
- Review the history live, examine the treatment area on camera and screen for contraindications.
- Agree the plan, write a patient-specific order and explain who will perform the treatment and their credentials.
- If the exam is not adequate on video, convert to an in-person exam and say so in the chart.
After the visit
- The order appears in the treatment record before the appointment; the treating clinician confirms it at check-in.
- Block the treatment slot automatically if the GFE is missing, incomplete or declined.
- Refund deposits when the prescriber decides the patient is not a candidate.
Platform and vendor checks
- Use a telehealth platform that will sign a business associate agreement; see HIPAA compliance by role.
- Keep recordings only if your policy and consent cover them.
- Make sure GFE status passes from the telehealth tool to your booking system, so front-desk staff are not deciding eligibility.
What to say in ads and on booking pages
- “Start with a short video consultation with a licensed provider” is accurate and sets expectations.
- Avoid “no consultation needed” or “instant approval”: they describe the model regulators criticize.
- Say treatment depends on the provider’s assessment and that deposits are refundable if it is not appropriate.
- Name the credential of the provider doing the GFE (physician, PA or NP) in line with your state board’s advertising rules: see the guides for Texas, California, Florida and Arizona.
For benchmarks, see the med spa marketing statistics for 2026 and our med spa Google presence report. More guides are in the US guides library; to work with us, read how we work or book a call.
Not legal advice. Telehealth and delegation rules change often and depend on the procedure and the clinician’s license. Confirm your remote-GFE process with your medical director, your state boards and a healthcare attorney before launch.
Sources
- Texas: Occupations Code §111.005 · 22 TAC §169.26
- California: B&P §2242, §2290.5
- Florida: §456.47 · 64B8-56.002
- New York: Public Health Law §2999-cc · NYSED non-patient specific orders
- Arizona: A.R.S. §36-3602
- Georgia: 360-3-.07 · 360-35-.05
- Illinois: 225 ILCS 60/54.2 · Telehealth Act, 225 ILCS 150
- New Jersey: P.L. 2017, c.117
- North Carolina: NCMB telemedicine and laser surgery position statements
- Colorado: 3 CCR 713-1, Rule 1.17
- Nevada: NRS 629.515 · NRS 629.086
- Washington: WAC 246-919-605 · WAC 246-919-606
- Pennsylvania: Department of State, telemedicine FAQs (Act 42 of 2024)
- Ohio: Revised Code §4743.09 · HB 377
- Virginia: Va. Code §54.1-3303
Related pages from the US team
Good faith exam (GFE) guide
Who performs it, timing, documentation and booking.
Medical director requirements
Delegation, supervision and a 15-state table.
Medical director agreement checklist
Write telehealth GFE terms into the agreement.
Med spa ownership rules by state
Ownership limits that apply to telehealth models too.
HIPAA compliance by role
Privacy duties for telehealth platforms and staff.
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Common questions
Is a telehealth good faith exam legal?
In most large med spa states, yes, when it meets the in-person standard of care, the prescriber is licensed where the patient is located and the patient consents to telehealth. California, Arizona and Florida say it directly in statute. A few states and procedure-specific rules are stricter, so check the table on this page and confirm with your board.
Does a telehealth GFE have to be on video?
Live audio-video is the safest choice for aesthetic treatments because the prescriber needs to see the treatment area. Some states allow store-and-forward or audio-only telehealth in general, but a phone call or form rarely lets a prescriber assess skin, anatomy and contraindications to the in-person standard.
Can a nurse practitioner do telehealth GFEs for several states?
Only for patients located in states where the NP holds a license and is allowed to perform the exam within their practice rules. Licensure follows the patient's location at the time of the visit, not where the clinician sits.
Can a med spa use an online questionnaire instead of a GFE?
No. A questionnaire can collect history before the visit, but regulators treat a questionnaire alone as inadequate. The North Carolina Medical Board warns that a simple questionnaire without an appropriate evaluation may violate the law, and Washington's Medical Commission has said a questionnaire does not by itself establish a patient relationship.
What extra documentation does a telehealth GFE need?
Record the modality (video, audio, store-and-forward), the patient's identity check and physical location, the prescriber's location and license, telehealth consent, and whether the visit allowed an adequate exam. If it did not, document that the patient was asked to come in for an in-person exam.
A note on this guide: it explains marketing practice, not legal advice. Rules on privacy, advertising and insurance change and vary by state, so confirm anything compliance-related with your own counsel.
Building a remote GFE booking flow?
A 30-minute benchmarking call with the US team. We'll review how your booking, intake and telehealth steps connect and tell you what we'd fix first.