With the newly released recommendations, what impact will the recommendations have on the Botox and cosmetic non-surgical industry? Further details will follow.
Registration: The central register that was to be enforced, is not going to occur immediately. This would have meant that unless a practitioner is registered, they should not be practicing either Botox or dermal fillers. This would stop those without the required qualifications, to be able to perform aesthetic procedures. It was reported that the majority of practitioners are already registered with a professional body, GMC, NMC and GDC so this aspect would be looked at in due course. The Government will work with the professional bodies to introduce standards as work is already being undertaken in this area. They are keen to be involved in “prescription models” which will only allow healthcare professionals to undertake aesthetic procedures or those individuals who are nominated by clinicians.
Clinician: According to the initial report, who should undertake the procedures? This is simply documented as a person who has obtained the qualification to independently prescribe medicine. Given who can obtain insurance, that insinuates a nurse prescriber who has successfully completed the V300 course, a dentist and a doctor. The latest report states that healthcare professionals should undertake appropriate training and supervision to improve competence and the clinical skills required when administering non surgical procedures.
Does this mean that a nurse who is not a prescriber cannot administer Botox or fillers? NO it does NOT, it means that they will have to maintain their usual high standards when it comes to administering prescription only medicine (POM).
Does that mean that beauty therapists can no longer inject Botox or fillers? The report references non-healthcare practitioners and states that they need to have achieved “accredited training”, which currently does not exist. Therefore, it is assumed that any current certificate is not valid and they will not be able to continue to practice. They would also need to administer the procedures under the supervision of a nurse prescriber or doctor. This prescriber would, it appears, then take full responsibility for the actions of the non-healthcare professional. One has to questions whether a prescriber would be willing to supervise such personnel and also take responsibility for their actions and omissions.
Appraisals: Annual appraisals should be performed to maintain the required central registration. Until such registration exists annual CPD is currently only required by registered healthcare professionals.
Advertisements: The report documents the agreement of sensible marketing although further information on this is limited.
Premises: Any premises used should meet the standards expected of acceptance on to the central register. As this is yet to exist, the standards expected of a clinical premise should be guidance in this instance.
Medical devices: It is recommended that UK legislation should be commenced to make dermal fillers only available as a POM. Current recommendations by the European Commission is being undertaken in this area. If this aspect is enforced, the UK will follow and this is actively supported by the Government.
Consultation forms: Through feedback via patients it is clear that some practices exist whereby no signature is obtained and no past medical history is taken. The newly introduced guidelines state that the practitioner should retain written consent forms and how a code of practice is to be developed to ensure high standards in record keeping occur.