New York — Good Faith Exam
Who can perform the good faith exam in New York, whether an RN can, the telehealth nuance, and why the GFE gates every injectable treatment — from New York board and statutory sources, reviewed by Faisal Darwiche, NP.
Last reviewed 2026-06-27 · Faisal Darwiche, NP. General guidance, not legal advice — confirm with your New York board and counsel.
In New York, before a med-spa injectable a Good Faith Exam (history, appropriate exam, diagnosis, treatment plan, informed consent) must be performed by a licensed provider who can diagnose and order — a physician, NP, or PA acting within their scope. An RN may assist and collect data but may NOT perform the GFE or generate the treatment order; that's a scope violation in New York. New York does permit the GFE by telehealth as long as the in-person standard of care is met and the performing provider holds an active New York license — which is why per-patient telehealth-GFE services fit a compliant structure. Confirm your GFE protocol and provider arrangement with a New York healthcare attorney.
Sources: NY Education Law §6521 (Article 131 — GFE/diagnosis is the practice of medicine) · NY Education Law Article 139 (Nursing) — RN cannot diagnose/order · Verified 2026-06-26.
The GFE isn't paperwork — it's the legal hinge of the whole treatment. It establishes the patient relationship, the diagnosis, the plan, and the order that makes the injection a delegated medical act instead of unlicensed practice. In New York, skipping or shortcutting it is the single most common compliance failure for a new med spa. Build the exam into your patient flow from day one — it protects the patient, the injector, and the owner.
Many states allow the GFE to be performed by compliant synchronous (live audiovisual) telehealth, which is why per-patient telehealth-GFE and medical-director services have become a standard way to source the exam and order before an RN injects. Whether New Yorkpermits a telehealth-only GFE with no prior in-person visit — and under what conditions — should be confirmed with the New York board and your healthcare attorney before you build your protocol around it.
The free 17-question assessment returns a New York-specific plan: how to source the GFE and orders for your credential, your medical-director path, and your exact next action. 7 minutes, no card. Built by Faisal Darwiche, NP.
In New York the good faith exam must be done by a provider who can diagnose and order treatment — a physician, nurse practitioner, or physician assistant. The exam establishes the treatment plan and the order for the product before any injectable is administered.
No. An RN in New York can gather history and assist, and can administer injectables under a valid order, but cannot perform the GFE or write the treatment order — that is the practice of medicine. The exam and order come from a physician, NP, or PA.
In many states a GFE can be done by compliant synchronous (audiovisual) telehealth, which is why per-patient telehealth-GFE services are common. The exact New York rule and any in-person requirement should be confirmed with the New York board and your healthcare attorney.
Treating without a valid GFE is one of the most common ways a New York med spa draws enforcement — it means treating without an order, i.e. the unlicensed practice of medicine. Every patient needs a documented exam, plan, and order before their first treatment.