Most practices have a policy manual. The harder question is whether it matches what actually happens in the treatment room. A manual written for a different practice, a different state or last year's treatment menu can look complete on the shelf and still leave gaps when someone asks to see it.
In my review of 32 aesthetic Board accusations, 22 cited missing or insufficient standardized procedures. Other frequently cited gaps were physician oversight and the good faith exam. Those are documentation questions, and you can check them yourself.
Set a timer for 10 minutes, open your manual and answer these ten questions with a simple yes or no.
Documentation: Is It Really Your Policy?
- Does every policy name your practice, your medical director and an effective date? A document that could belong to any practice doesn't show that these are the rules your team follows.
- Was it written for your state? Scope, delegation, supervision and good faith exam rules vary by state. In California, RN standardized procedures must address the elements in 16 CCR § 1474.
- Does it cover every treatment you offer today? Compare your current treatment menu, including anything added this year, against the protocols in your manual.
- Does each treatment protocol state the product, dosing or settings, and limits? "Per provider discretion" isn't a protocol your team can follow consistently.
Implementation: Who Approves It, Who Uses It and How Is That Recorded?
- Is each policy signed and dated by the people authorized to approve it? A signature on the cover page alone doesn't show who approved each procedure.
- Does it say who may perform each treatment, and under what supervision? Name the roles (RN, NP, PA, physician), how the medical director is reached and the backup when they aren't available.
- Does it say who performs the good faith exam, and where it's documented? The Medical Board of California's guidance says an appropriate prior exam is required before prescription drugs or devices are used, and that exam may not be delegated to an RN.
- Is there a dated record of each provider's training and competency for each procedure? This is the record that connects your policy to the people performing it.
Maintenance: Is It Still Current?
- Has every policy been reviewed on schedule, with the date and reviewer recorded? California standardized procedures must provide for a method of periodic review.
- Does it reflect current product labeling? For example, on September 15, 2026, the FDA updated the Kybella label with a warning against use outside the area under the chin. See our Kybella label update post.
What Your Answers Mean
- Ten yes answers: Your manual is working as a system. Keep your review dates on the calendar.
- One to three no answers: Fix those items first, starting with signatures, supervision and the good faith exam.
- Four or more no answers: Your manual may describe a practice that isn't yours. A structured review is the faster route than patching one page at a time.
A self-check doesn't replace a full review, and no document guarantees a regulatory outcome. But it shows you where your paperwork and your practice have drifted apart, before anyone else asks.
Educational information only, not legal advice. Requirements vary by state; confirm with your state board. Findings from the 32-accusation review describe what those accusations alleged and are not a national enforcement rate.
