Can the pre-treatment exam be done by telehealth in California?

Intake · part of The Practice Perimeter

Short answer
Yes — the appropriate prior exam can be done by telehealth and need not be synchronous; even a self-screening tool or questionnaire can suffice if the standard of care is met. It still can't be delegated to an RN — a physician, NP, or PA must do it.

An appropriate prior examination does not require a synchronous interaction between the patient and the licensee and can be achieved through the use of telehealth, including but not limited to a self-screening tool or a questionnaire, provided that the licensee complies with the appropriate standard of care.

Cal. Bus. & Prof. Code §2242(a) · verified Sep 8, 2026 · regulatory monitoring, not legal advice

The rest of what California says on this

  • Prescribing, dispensing, or furnishing a dangerous drug (such as Botox or fillers) without an appropriate prior examination and a medical indication is unprofessional conduct.

    Cal. Bus. & Prof. Code §2242(a) · verified Jul 26, 2026 · read at Public.Law — California Codes

  • The Medical Board’s medical-spa guidance says the required prior examination may not be delegated to a registered nurse. It describes a physician, physician assistant, or nurse practitioner acting within the authority applicable to that licensee as performing the examination and issuing the patient-specific order. For nurse practitioners, current authority must be evaluated under Sections 2837.103 and 2837.104 rather than assuming every NP requires standardized procedures.

    Medical Board of California — Medical Spas guidance; Cal. Bus. & Prof. Code §§2837.103–2837.104 · verified Oct 22, 2026

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