Virginia good faith exam requirements

Who can perform a good faith exam in Virginia

Virginia-licensed physicians (MD/DO), nurse practitioners with prescriptive authority (autonomous after 2 years post-graduate or with a practice agreement), and physician assistants under physician supervision. The performing provider must hold a current Virginia license and prescriptive authority appropriate to the medication.

Visit format rules in Virginia

Synchronous visit required: Yes. Audio-only permitted: No. Prior in-person exam required: No. Synchronous audio-visual is required for establishing the bona fide practitioner-patient relationship. Audio-only is not generally sufficient for new-patient GFE for compounded medications, controlled substances, or aesthetic treatments under Virginia rules.

When a good faith exam is required in Virginia

Virginia requires GFE before prescribing controlled substances, compounded medications including GLP-1 and hormone therapy, before performing aesthetic medical procedures, and before ordering diagnostic studies. Va. Code §54.1-3303 explicitly prohibits prescribing controlled substances without a bona fide practitioner-patient relationship.

What must be documented

Verification of patient identity and Virginia residency Medical history and medication reconciliation Chief complaint and clinical assessment Medical decision-making documented with rationale Treatment plan including dosing and titration Informed consent for the prescribed therapy Documentation of synchronous audio-visual telehealth encounter Provider signature with Virginia license number and credentials

Enforcement context in Virginia

Virginia has joined the multi-state enforcement wave against compounded GLP-1 telehealth programs in 2025-2026. The Board of Medicine and Board of Pharmacy have coordinated audits of telehealth aesthetic and weight-loss programs, citing inadequate GFE and chart documentation as primary deficiencies.

Statutes and rules cited

Va. Code §54.1-3303 — Prescribing controlled substances: Requires a bona fide practitioner-patient relationship before prescribing controlled substances — Virginia's statutory GFE framework for controlled prescribing. Va. Code §54.1-2952 — Practice of medicine via telemedicine: Establishes telemedicine practice standards in Virginia, including the requirement that telemedicine providers meet the same standard of care as in-person practice. 18 VAC 85-20-26 — Board of Medicine standards for prescribing: Virginia Board of Medicine regulations on prescribing standards, including examination, documentation, and chart review requirements.

Frequently asked questions

What is a 'bona fide practitioner-patient relationship' in Virginia?

A bona fide practitioner-patient relationship under Va. Code §54.1-3303 requires that the practitioner has established a treatment relationship with the patient through documented medical evaluation, has access to relevant medical history, and is available for follow-up care. For telehealth, this typically requires synchronous audio-visual interaction with documented medical decision-making.

Can Virginia nurse practitioners independently perform GFE?

Yes — Virginia NPs with autonomous practice (2+ years post-graduate clinical experience plus attestation, or a current practice agreement) can independently perform GFE and prescribe within their scope. NPs operating autonomously must still meet the bona fide practitioner-patient relationship requirement and document the synchronous examination.

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

Virginia does not require an in-person visit for initial compounded GLP-1 prescribing if a synchronous audio-visual telehealth GFE establishes the bona fide practitioner-patient relationship. However, the Board of Medicine expects documented clinical evaluation, not refill-only authorizations, at appropriate follow-up intervals.

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

Virginia Board of Medicine disciplinary actions cite: prescribing without examination, inadequate chart documentation, no synchronous interaction with the patient, template-only chart notes, and missing medical decision-making. Penalties range from reprimand to license suspension depending on severity and pattern.