A little known fact (at least in the minds of consumers) is that injectable treatments such as Botox, Restylane and others require a prescription in the state of California. Because of this fact, a physician, nurse practitioner or physician assistant is supposed to examine the patient before a prescription can be written and before the injections are to proceed. While we understand and accept that this examination is largely a formality, we do require every patient at our facility to go through it because we believe in strictly adhering to the laws and regulations set forward by the medical and nursing boards of California.
Each state dictates its own legislation through their State Medical Board and/or Board of Registered Nursing to determine the scope of practice for those performing injection procedures such as Botox, Restylane and Perlane. Currently, California has determined that the administration of Botox Cosmetic must be carried out by an RN, PA, NP, or MD. If the physician is not the one performing the first procedure, it is mandated that a “Good Faith Exam” must be performed by the physician overseeing the practice or by an individual with an advanced practice degree before the first injection may take place. Most medical practices that we polled do not perform this exam for several reasons. The first is that it is viewed as a unnecessary formality and the second is that the medical office is not owned by or employ an advanced degree practitioner and as such does not have the correct personnel to perform the exam. In these cases, the practitioner (most often a nurse) is breaking the law by administering a prescription drug without the proper examination.
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The good faith exam is a brief meeting wherein the physician (or an advanced practice practitioner such as a Nurse Practitioner or Physician Assistant) assesses the patient, makes note of their medical history, and explains the procedure prior to the first treatment at that particular facility. Thereafter, no further exams are required and those properly licensed medical professionals may then administer future treatments. Although this requirement may seem uneventful and more of an inconvenience for not only patients but practitioners as well, we believe that it is a very necessary step in ensuring that current California laws and regulations are respected and carried out as mandated. For those practitioners that knowingly disregard current state requirements or plead ignorance, we question where else in their practice they are cutting corners.
As a patient, know your practitioner, their record and whether or not they are in compliance with California medical regulations.
Lori Haney, RN, MEP-C
Certified Medical Laser Safety Officer