It was inevitable: an undercover reporter attending a training course based in London to expose the “illegal and unethical” side of Botox administration. The nurse secretly filmed Dr Harrison undertaking Botox training to a group of other nurses and revealed, what Sally Taber described as “wrong and unacceptable” practice.
This case highlighted the GMC’s need to clamp down on how doctors prescribe Botox, now mirroring the guidance by the NMC and GDC. In short it means that before a doctor prescribes Botox or any other cosmetic medicine they need to physically see the patient, this cannot be done via Skype or 3G telephone calls. So what does this mean for medical professionals who administer Botox?
Doctors – are now unable to prescribe Botox remotely, even for their own patients. To be able to inject patients the first time they see them is now impossible unless they order wholesale Botox from Allergan direct, as the prescription will then be written from the wholesale stock. If a pharmacy has dispensed the product against a prescription this is NOT wholesale and can legally only be used on the patient for whom it has been dispensed. If they prescribe for nurses they need to undertake a face-to-face consultation before they write the prescription.
Dentists – the GDC stated last year that their registrants should not remote-prescribe Botox. They should follow the same recommendations for how doctors prescribe as dentists can also purchase wholesale Botox.
Nurses – can only administer botox once a face-to-face consultation has taken place. Their prescriber can be either a doctor, dentist or independent nurse prescriber (who has completed a Botox training course). Nurses cannot hold stock of toxins and they can only receive wholesale Botox if they are employed by or employ a doctor in their Botox practice/business. If the nurse is not in the same physical legal entity as the doctor he/she cannot obtain such stock. All nurses must ensure their patient has a face-to-face consultation with the prescriber and once they receive the product they can administer it as per the direction to administer. Botox is like any other POM and needs to be prescribed before it is administered.
Paramedics – the HPC has not as yet stipulated any guidance for paramedics who inject Botox, however, they will have to in future ensure their patients have a face-to-face consultation as their prescriber can no longer issue a prescription for Botox remotely.
How does this change Botox training courses? With reference to how we work at Cosmetica Training, it doesn’t really change a thing. We have, since the NMC clarified their guidance, ensured we advise all doctors who work with nurses to comply with their regulations as we have with GDC registrants. Whilst previously, it has been acceptable for doctors to remotely prescribe Botox, this has not been advisable when prescribing for nurses and this is our advice for their own clients. Our guidance to doctors now will mirror the stance for nurses and dentists.
What does this mean for Botox administration? Patients may have an initial delay in receiving treatment, however, nurses are still able to administer Botox, nurse prescribers, doctors and dentists can continue to prescribe and administer Botox as long as the prescription is not written remotely.
The news report below shows undercover footage from the BBC.