What is a Good Faith Exam?
A Good Faith Exam (GFE) is the clinical evaluation a Texas medical board-licensed clinician performs and documents before a patient receives a covered nonsurgical cosmetic procedure. Under 22 TAC §169.25, the GFE is what makes the procedure a legally delegable medical act rather than an unlawfully administered treatment.
The exam isn't about ticking a box. It's about a clinician taking professional responsibility for the patient's suitability for the specific procedure, in writing, before it happens.
Who can perform a GFE in Texas?
The GFE must be performed by a clinician licensed in Texas with a scope of practice that includes the procedure being authorized. In practice that's:
- MD or DO licensed by the Texas Medical Board
- APRN (advanced practice registered nurse) — Nurse Practitioner, CNS, CRNA, CNM — with Texas Board of Nursing licensure and a documented supervisory or collaborative arrangement where required
- PA (Physician Assistant) licensed by the Texas Medical Board, operating under physician delegation
An RN cannot perform a GFE in most Texas contexts. RNs may perform supportive clinical tasks under delegation (taking vitals, administering an injection authorized by an upstream GFE, etc.), but they may not be the clinician of record on the GFE itself for nonsurgical cosmetic procedures.
What must a Texas GFE actually include?
The defensible GFE record contains, at minimum:
- Patient identification — full name, date of birth, address (or unique identifier)
- Date and time of the exam
- Identity of the clinician performing the exam — full name, credential, license number
- Mode of exam — in-person, video telehealth, or audio-only (where authorized)
- Relevant history — medical history, current medications, allergies, prior similar procedures, contraindications
- Examination findings — assessment of the area being treated, photos or notes as appropriate
- Risks, benefits, and alternatives discussed
- The specific procedure(s) authorized, with dose ranges or units where applicable
- The patient's informed consent — signed, dated
- The clinician's signature and date of authorization
Telehealth GFE — what's allowed
Texas permits GFEs to be performed via telehealth, including video-only and (in some narrow cases) audio-only encounters, provided the clinician determines the mode is clinically appropriate for the patient and the procedure. The TMB and the Texas Board of Nursing have published parallel telehealth standards that apply.
The technology used for telehealth GFEs must be HIPAA-compliant. Free consumer-grade video tools without a Business Associate Agreement (BAA) are not appropriate. The encounter must be documented, including the technology used, the clinician's location, and the patient's location.
How long is a GFE good for?
Texas does not specify a single hard expiration. The defensible practice in 2026:
- Botox / filler: re-evaluate at least annually, and any time the patient reports a new condition, medication change, or relevant pregnancy status
- IV therapy / wellness drips: re-evaluate at least every 12 months, often shorter for patients with chronic conditions
- Laser, energy devices: re-evaluate at least annually and any time the treatment area or device class changes
- Hormone pellets, sclerotherapy: typically per pellet/treatment cycle
- New procedure type: a fresh GFE is required any time a patient is being authorized for a procedure not covered by the current exam
The five GFE mistakes that get clinics cited
1. Generic intake forms treated as GFEs
A new-patient questionnaire — even an extensive one — is not a GFE. The exam requires a licensed clinician's professional evaluation and authorization, not the patient's self-report.
2. The supervising physician "approves all patients"
A blanket attestation from the medical director that all patients seen by the clinic are approved is not a GFE. The exam must be patient-specific and procedure-specific.
3. Backdated or undated GFEs
A GFE record with no date, or with a date that doesn't match the appointment timeline, undermines the entire document. Each GFE must be timestamped and the timestamp must be auditable.
4. RN-performed GFEs
An RN can administer a delegated procedure authorized by a GFE. They cannot be the clinician of record on the GFE itself for nonsurgical cosmetic procedures. Many clinics have made this mistake unknowingly.
5. Lost or unverifiable telehealth GFEs
Telehealth GFEs that lack documentation of the clinician's identity, location, or mode of encounter are indistinguishable from no GFE at all on inspection. The mode must be specified.
How to organize GFE evidence
The pragmatic test: can you produce, within ten minutes, the GFE for any patient on today's schedule? If yes, the system is working. If not, here's the minimum:
- One central location (digital, ideally inside or linked to the EMR) where every GFE lives
- A consistent naming convention or tagging scheme tied to patient ID and procedure type
- A daily check that surfaces any patient on the schedule whose GFE is missing or expired
- A clean handoff protocol when a new clinician joins or a current clinician departs — the GFEs they authored must remain retrievable
Frequently asked
Can my medical director do all my GFEs remotely from another state?
Only if they hold an active Texas Medical Board license. A physician licensed in another state cannot perform a Texas GFE without Texas licensure.
Does my front desk need to verify the GFE before each appointment?
Operationally, yes. The licensed provider performing the procedure is responsible for verifying that a documented GFE exists and is current. Many clinics build this verification into the front-desk check-in workflow so the issue is caught before the procedure.
What happens if a patient asks for treatment but the GFE is missing?
The defensible answer: the procedure does not proceed until a GFE is performed and documented. This is a clinical decision, not a software decision. Tools like ProofOps surface the missing GFE before the appointment so the clinician has a chance to perform it (or reschedule) without the patient being inconvenienced at the door.
Do GFE rules differ for IV therapy vs. injectables?
The GFE framework is the same. The supervision and delegation rules around who can initiate the procedure differ — see HB 3749 / Jenifer's Law for IV-specific requirements.
How ProofOps Medical helps with GFEs
Our Good Faith Exam tracker reads from your EMR (Aesthetic Record, Boulevard, Symplast, PatientNow) and surfaces scheduled treatments where GFE documentation appears missing or expired according to the rules your clinic has configured. The agent SMS-flags the medical director and front desk before the appointment so the clinical team can act in time. The clinical decision to proceed remains with the licensed provider.
Get a free Texas documentation audit — we'll review what's publicly visible plus a brief intake on your clinic and send a one-page PDF showing where the GFE gaps are. No card. 24-hour turnaround.
Informational, not legal advice. For interpretation specific to your clinic, consult your healthcare attorney and your medical director. Cite/source: Texas Medical Board, 22 TAC §169.25, Texas Board of Nursing telehealth standards.