The Joint Council for Cosmetic Practitioners (JCCP) summarises its mission statement and values as ‘placing public protection and patient safety as the focus of its activities’. The JCCP and the Cosmetic Practice Standards Authority (CPSA) regard safe and responsible prescribing practice to be an essential component of public protection and have published advice on this matter in July 2019 (JCCP, 2019). The JCCP shared this advisory statement with the General Medical Council (GMC) and the General Dental Council (GDC), both of which confirmed that it was consistent with their own guidance. The Royal Pharmaceutical Society (RPS) has also advised that:
‘In our view as the professional body for pharmacy, the JCCP statement is consistent with the approach of the professional regulators and will be useful for the RPS to signpost to.’
The Nursing and Midwifery Council (NMC) has not provided any specific comment on this statement, but has advised that its own prescribing guidance reflects that provided by the RPS.
Remote prescribing
In line with several professional statutory regulators—the GMC, the GDC and (in accordance with guidance set down by) the RPS—the JCCP and the CPSA have set down their decision not to endorse or permit the remote prescription of any medicine when used specifically for non-surgical cosmetic treatments. When the prescriber delegates treatment to other practitioners, then the JCCP reminds the prescriber that the patient remains under the oversight of the prescriber, requiring that the prescriber must be familiar with the patient through an initial face-to-face consultation and diagnostic assessment of the patient's suitability for treatment. This applies to the routine/planned administration of medicines that are used specifically for cosmetic purposes, such as botulinum toxins, injected local anaesthetic or topical adrenaline, as well as the emergency use of medicines such as hyaluronidase.
The JCCP advises that, any time a designated prescriber prescribes medicines or treatments, the prescriber must:
This applies to all medicines used specifically for cosmetic purposes that are prescription-only medicines (POM), whether they be injectable, topical or oral. Prescribers should therefore conduct a physical examination of patients before prescribing injectable prescription-only cosmetic medicines. Patients should not be prescribed medicines by telephone, by video link, online or at the request of others, unless they have been examined personally by the prescriber.
Delegation
When delegating, the JCCP supports the GMC position that recommends, wherever possible, non-surgical cosmetic treatments are delegated to a professional standards authority (PSA)-regulated practitioner, but also recognises that prescribers may delegate the use of POMs for use by non-PSA registered practitioners whom they consider to be competent and proficient to administer the medication.
When the prescriber delegates the treatment following a face-to-face consultation, then the JCCP stipulates that the prescriber must be satisfied that it is safe to do so (in accordance with safe administration, safe premises and safe storage of medicines/products standards) and reminds prescribers that, if delegating to a non-registered practitioner, the legal and professional liability for the delegation of the use of the medicine remains with the prescriber. The prescribing practitioner, therefore, remains responsible, not only for oversight of the patient, but also for the medicines they prescribe and for their subsequent use, in accordance with expected professional practice and appropriate legal parameters.
Supply of prescription medicines
If, after a face-to-face consultation, a prescription is to be issued for an injectable POM, this medicine may then be dispensed by a pharmacy. In these circumstances, the purpose of the prescription is usually for the supply of the medicine only, and it is not commonly indicative of the treatment or dose required by the patient. Prescribers are also advised to comply fully with regulations that relate to patient-specific directions (PSD) as a legal method of prescribing. The Medicines and Healthcare Products Regulatory Agency (MHRA) (2008) advises that the supply of medicines from stock is permissible only where the doctor/dentist delegates to a practitioner who is employed by the same organisation. The JCCP reminds doctors and dentists that they are accountable for the safe use and storage of these medicines in these circumstances.
Repeat prescriptions
The JCCP does not consider an initial face-to-face consultation to have met the requirement for all future prescribing decisions but advises that a follow-up face-to-face consultation is required whenever:
When the prescriber is considering issuing a repeat prescription in the absence of a further face-to-face assessment of the patient, they must satisfy themselves that none of the above conditions apply and that mechanisms are in place to make an accurate assessment of these conditions.
Competing interests
All prescribers should recognise and address the existence of competing interests. When making a prescribing decision, practitioners must place the needs of the patient first and be transparent about their actions. The approach to shared decision-making with the patient should allow for consideration of the patient's psychological needs and signs of vulnerability and should not be influenced by personal gain or commercial interest. In support of this, the JCCP endorses the Nolan principles to be adopted as an ethical framework for safe and ethical cosmetic prescribing practice (Box 1).
» The approach to shared decision-making with the patient should allow for consideration of the patient's psychological needs and signs of vulnerability and should not be influenced by personal gain «
Further guidance
The JCCP refers practitioners to further guidance on prescribing that has been published by the professional statutory healthcare regulators, with specific acknowledgement that all regulators (both statutory and voluntary) advocate paramount responsibility for prescribing, as well as promoting ethical and professional behaviours within the context of the relevant codes and associated fitness-to-practice procedures. In particular, with Responsible Prescribing for Cosmetic Practitioners, the JCCP (2019) has considered and built on advice provided to registrants by the GMC, GDC, NMC, General Pharmaceutical Council, Health Care Professions Council and the Royal Pharmaceutical Society.
Conclusion
Alberto Costa, MP for South Leicestershire and Chair of the All-Party Parliamentary Group on Beauty, Wellbeing and Aesthetics, said:
‘I very much welcome this step made by the JCCP; remote prescribing for non-surgical cosmetic procedures can be unsafe and harmful and should not be used under any circumstances. This is a great first step to further protect consumers who choose to undergo non-surgical cosmetic procedures. This will help to close the ‘loopholes’ that currently exist, in which injectables, which are prescribed by healthcare professionals, can be remotely prescribed and delegated to anyone without first assuring that professional face-to-face patient assessment and clinical oversight is provided in all circumstances.’
The JCCP recognises the important role that professional prescribers make to public protection and of the contribution that they make to the development and maintenance of a robust and effective patient safety culture in the aesthetic sector. The JCCP (and the CPSA) continue to strive to promote and develop standards and best practice across the whole of the non-surgical and hair-restoration surgery sector, as well as to promote and publicise the same to the public. The JCCP's primary purpose is to raise public awareness and improve patient safety. The publication of our guidance on Responsible Prescribing for Cosmetic Practitioners demonstrates the JCCP's commitment to signposting and promoting safe and effective practice within the aesthetic sector. The JCCP team commends the adoption and application of this guidance statement in accordance with a shared aim of protecting the public.