1. Pennsylvania medical practice status
In accordance with the Pennsylvania Medical Practice Act of 1985 and 49 Pa. Code § 16.61:
- Medical Practice Definition: [Clinic Name] is a physician-owned medical practice. All aesthetic treatments (including Botox, fillers, and lasers) are defined as "cosmetic medical procedures" and are held to the same clinical standards as any other medical treatment in the Commonwealth.
- Supervision & Delegation: All medical services are performed by licensed practitioners (MD, NP, PA, or RN) under the active supervision of our Medical Director, [Insert Physician Name], as required by the Pennsylvania State Board of Medicine.
2. Mandatory 42 cfr part 2 alignment (federal)
As of February 16, 2026, federal law requires the following protections for all medical entities:
- Proceedings Protection: Any records we receive or maintain regarding substance use disorder (SUD) carry heightened federal protections. These records shall not be used or disclosed in any civil, criminal, administrative, or legislative proceedings against you without your specific written consent or a court order.
- Single Consent for TPO: You may provide a single, general consent for all current and future disclosures of SUD records for Treatment, Payment, and Health Care Operations.
- Redisclosure Warning: Information disclosed pursuant to your authorization may be subject to redisclosure by the recipient and may no longer be protected by federal privacy rules.
3. The "good faith exam" (gfe) & consent
Under Pennsylvania law, a valid patient-provider relationship must be established before medical treatment:
- Initial Evaluation: Before receiving your first prescription-strength treatment (e.g., Botox® or GLP-1s), you must undergo a Good Faith Exam (GFE) performed by a physician, NP, or PA to determine medical candidacy.
- Informed Consent: You will be provided with a detailed informed consent form for each procedure, outlining the specific risks, benefits, and alternatives.
4. Biometric data & photography
We utilize high-resolution clinical photography and facial mapping ("Biometric Data") to track treatment progress and ensure patient safety.
- Storage: These images are part of your protected medical record and are stored on HIPAA-compliant, encrypted servers.
- Consent for Social Media: We will never post your images to social media or marketing channels without a separate, specific Social Media Release Form signed by you.
5. Data security & the pa shield act
We maintain "Reasonable Safeguards" to protect your information from unauthorized access:
- Breach Notification: In the event of a data breach, we will notify you in accordance with Pennsylvania’s breach notification standards.
- Non-Compete Compliance: In accordance with the Fair Contracting for Health Care Practitioners Act (2025/2026), we maintain ethical staffing and patient-transfer protocols that do not interfere with your continuity of care.
6. Digital marketing & advertising
- Truth in Advertising: All before-and-after imagery used by [Clinic Name] represents actual patients and unretouched results. Individual outcomes vary.
- Safety Links: In compliance with 2026 FDA/FTC standards, all advertisements for prescription medications include a link to our mandatory safety and risk disclosure page.
7. Contact our privacy officer
To request a copy of your records, correct your information, or report a concern:
- Privacy Officer: [Name/Role]
- Address: [Insert Pennsylvania Office Address]
- Email: [Compliance Email]
- Phone: [Office Phone Number]
Talking Points for your Call (The "Pennsylvania" Focus):
- Physician Ownership (CPOM): "Pennsylvania is a 'Physician-Owned' state. We have updated our policy to explicitly state we are a professional medical practice, not just a retail spa, to satisfy the State Board of Medicine."
- The Feb 16th Mandate: "The federal 42 CFR Part 2 alignment is now in our policy. This protects us and the patient by ensuring that any sensitive history they share can't be used against them in legal proceedings."
- GFE Requirement: "We are emphasizing the Good Faith Exam. PA is very strict about an MD, NP, or PA seeing the patient before the RN touches them with a needle."
