As we stand on the cusp of significant change in the regulation of medical aesthetic treatments, staying informed is imperative for clinicians. This article aims to shed light on the next key priorities and plans in medical aesthetics licensing. These are proposed by the Joint Council of Cosmetic Practitioners (JCCP) following the recent Department of Health and Social Care (DHSC) consultation.
Background on the Consultation
The DHSC’s first consultation on the proposed licensing system for non-surgical cosmetic procedures concluded on October 28, 2023. With a remarkable response of over 11,800 submissions, this consultation marked a pivotal moment in shaping the future of medical aesthetics in England. This was the second largest in DHSC history. It reflects a collective and determined effort towards enhancing patient safety and professional standards in the field.
The JCCP has identified several key areas requiring immediate attention:
Implementation of a National Licensing Scheme
Firstly, the JCCP advocates for the establishment of a comprehensive licensing system that encompasses both the facilities and practitioners involved in non-surgical cosmetic procedures. This initiative is fundamental in ensuring that all practitioners adhere to stringent safety and competence standards. For more details on what we know about the licensing scheme, read our latest blog here.
Requirement for Adequate Medical Insurance
The JCCP underscores the necessity for practitioners to possess proper medical insurance. This measure is integral to safeguarding both the practitioners and their patients.
Guidelines on Training and Qualifications
Emphasising the importance of education, the JCCP calls for clear and official guidelines on the requisite training and qualifications for practitioners. This includes a thorough understanding of infection control measures and first aid. This is a key piece of the new legislation, but the standards have yet to be set.
There have been proposals put forth for training standards in the past. In the aftermath of the Keogh Report in 2013, Health Education England made its own recommendations for practising medical aesthetics. It was recommended in 2014 that all practitioners performing injectable treatments should be qualified to a postgraduate degree level. In particular, training course providers must either have their own degree-awarding powers (as with universities) or be Ofqual-regulated. A minimum of 50% of the curriculum must be focused on practical and procedural skills. Those providing clinical oversight must have at least 3 years of experience in the field. From these recommendations, the Level 7 qualification in aesthetics was developed.
While these were recommendations from Health Education England, not requirements, the hope is that the incoming legislation will adhere to a similar framework as the minimum standard to practice in this field.
Prohibition of Remote Prescribing
A critical priority highlighted by the JCCP is the cessation of remote prescribing in aesthetics. This practice has been a point of contention and significant concern and is now under stringent scrutiny.
Stricter Control on Botulinum Toxin
The core of this issue revolves around botulinum toxin, a medication that requires a prescription and is governed by strict rules regarding its acquisition and use. Despite these regulations, the UK’s currently unregulated environment has seen an alarming increase in the illegal sourcing of botulinum toxin. Often facilitated through online channels and, regrettably, sometimes with the involvement of medical prescribers circumventing the law.
Only medical professionals with appropriate qualifications can legally prescribe regulated drugs like botulinum toxin. The procurement and use of unlicensed botulinum toxin is illegal in the UK. Injection of these products can result in significant harm. The legal prescriptions requirement is more than a formality – it is a crucial step to safeguard patient wellbeing.
Face to Face assessment
Equally important is also a requirement from all regulatory bodies that an in-person assessment is needed for the prescription of non-surgical cosmetic procedures. This face-to-face assessment is an ethical imperative. It ensures that the patient’s medical history, potential risks, and specific needs are thoroughly evaluated. This is the stance of the General Medical Council (GMC), General Dental Council (GDC), Nursing and Midwifery Council (NMC), and the General Pharmaceutical Council (GPhC). Of note, the GPhC does not support prescribing for non-medical practitioners.
Historically, there have been instances where clinicians have faced professional consequences, including being struck off, for remotely prescribing cosmetic procedures. With the introduction of new legislation, these standards are anticipated to be enforced more rigorously. The elimination of remote prescribing is a key measure in these efforts, aimed at upholding the credibility and trustworthiness of medical aesthetic practices.
In addition to the above qualifications, practitioners must also be accredited by a recognized professional body. The JCCP and the CPSA are two such bodies, and they require practitioners to meet certain standards in order to be accredited.
System for Recording Adverse Incidents
Lastly, the establishment of a robust system for documenting adverse incidents is proposed. This initiative is about tracking incidents and using these insights to enhance safety protocols and patient care. Moreover, this initiative is particularly significant in differentiating the accountability standards between registered medical professionals and non-medics, a distinction that the new legislation aims to address more effectively.
Registered healthcare professionals in the UK are already accountable to their respective regulatory bodies. These bodies ensure that professionals adhere to high standards of practice and conduct. In adverse incidents or malpractice cases, patients have the right to lodge complaints with these regulatory organisations. The professionals are then investigated, which can lead to disciplinary actions if necessary. This established framework provides a level of assurance and protection for patients undergoing procedures by registered professionals.
However, this level of accountability and oversight does not extend to non-medical practitioners in the aesthetics field. Currently, no comprehensive system is in place for recording adverse incidents caused by non-medics. This lack of oversight represents a significant gap in patient safety and professional accountability. As a result, patients treated by non-medics do not have the same avenues for recourse in the event of malpractice or adverse outcomes.
In addition to the regulatory bodies, several key stakeholders play a crucial role in this process. Organisations like Save Face and the JCCP provide platforms where members of the public can report concerns or submit evidence of bad practice. These contributions are invaluable in informing the ongoing consultation process and shaping the future regulatory landscape of medical aesthetics. Their involvement ensures that the voices and experiences of patients are heard and considered in the development of more robust and inclusive safety standards.
These key priorities are aimed at fortifying the standards of practice in medical aesthetics, ensuring the highest level of patient safety and care. As we navigate through these developments, we, as medical professionals, must adapt and contribute to the ongoing discourse in our field and ensure we remain up-to-date and aligned with the latest regulatory requirements.