Massachusetts good faith exam requirements

Who can perform a good faith exam in Massachusetts

Massachusetts-licensed physicians (MD/DO), advanced practice registered nurses (APRNs) with prescriptive authority, and physician assistants under physician supervision. APRNs in Massachusetts have prescriptive authority after fulfilling supervision and continuing education requirements per the Board of Registration in Nursing.

Visit format rules in Massachusetts

Synchronous visit required: Yes. Audio-only permitted: No. Prior in-person exam required: No. Synchronous audio-visual is required for telehealth GFE. Audio-only telehealth has limited permitted use under Massachusetts rules but is not sufficient for new-patient GFE for higher-risk prescribing.

When a good faith exam is required in Massachusetts

Massachusetts requires GFE before any new prescription via telehealth, before initiating compounded medication therapy, before aesthetic medical procedures, and before ordering diagnostic studies. The Board of Registration in Medicine has been active in disciplining telehealth providers for inadequate GFE in 2025-2026.

What must be documented

Patient identification verification Medical history and current medication review Clinical assessment supporting the prescribed treatment Medical decision-making with documented rationale Treatment plan with dosing and follow-up Synchronous audio-visual telehealth encounter documentation Provider signature with Massachusetts license credentials

Enforcement context in Massachusetts

The Massachusetts Board of Registration in Medicine has issued multiple disciplinary actions against telehealth aesthetic and weight-loss prescribers in 2025-2026, citing inadequate GFE workflows, template-only chart notes, and no documented medical decision-making. The state has been particularly attentive to compounded GLP-1 telehealth programs.

Statutes and rules cited

243 CMR 2.07 — Massachusetts telemedicine policy: Board of Registration in Medicine policy on telemedicine practice, including examination, documentation, and standard-of-care requirements. M.G.L. c.94C §18 — Massachusetts Controlled Substances Act: Requires a bona fide practitioner-patient relationship before prescribing controlled substances, the statutory basis for Massachusetts GFE enforcement on controlled prescribing. M.G.L. c.112 §80B — APRN prescriptive authority: Massachusetts APRN prescriptive authority statute including the conditions under which APRNs can independently prescribe in the Commonwealth.

Frequently asked questions

Does Massachusetts require an in-person GFE for compounded GLP-1?

Massachusetts does not require an in-person visit for initial compounded GLP-1 prescribing if a synchronous audio-visual telehealth GFE establishes the practitioner-patient relationship per 243 CMR 2.07. However, the Board of Registration in Medicine expects documented clinical evaluation at appropriate follow-up intervals.

Can Massachusetts APRNs independently perform GFE?

Yes — Massachusetts APRNs with prescriptive authority can independently perform GFE within their scope after fulfilling supervision and continuing education requirements per M.G.L. c.112 §80B. APRNs in initial practice years typically require collaborative arrangements.

What does Massachusetts enforcement look like for non-compliant GFE?

Board of Registration in Medicine disciplinary actions in 2025-2026 cite: asynchronous-only GFE, template chart notes without clinical decision-making, no synchronous interaction with the patient, missing medical history, and prescribing without Massachusetts licensure. Penalties range from reprimand to license suspension.

Does FaceTime or Zoom satisfy the Massachusetts GFE requirement?

FaceTime, Zoom, and other synchronous audio-visual platforms can satisfy Massachusetts GFE requirements provided the encounter is documented in compliance with 243 CMR 2.07 and the standard of care is met. HIPAA-compliant platforms are strongly preferred to avoid additional regulatory exposure.