Resolved complaints reveal much about low-quality practices
This article will bring readers up to date on a range of ongoing issues that have been raised by members of the public as part of the Joint Council for Cosmetic Practitioners' (JCCP) complaints procedure.
Training concerns
The JCCP provides a Professional Standards Authority (PSA)-accredited register for the non-surgical aesthetics sector. It offers an informed and legitimate point of enquiry for members of the public who are seeking to learn more about standards that operate within in the sector. The JCCP is an appropriate authority to enable members of the public to raise issues of concern about practitioners when these concerns have not been responded to locally. The JCCP places public protection and patient safety as the focus of its activities. For example, the JCCP is concerned, but not surprised, to receive a significant number of complaints regarding courses that are provided by some training companies. These companies claim that practitioners who do not possess a regulated qualification are safe to undertake training at Level 3 (non-invasive cosmetic procedures) and then can be fast tracked within a matter of weeks or months to practise invasive aesthetic procedures, such as the injection of toxins or the insertion of dermal fillers at Level 7. At these higher levels, there is a requirement for a practitioner to have achieved a significant body of clinical knowledge, as well as the possession of specialist information and practical skills to treat patients both safely and effectively. In the JCCP's opinion, accelerated training pathways, such as those used by many of these companies, fall far short of the required Level 7 standard set out in both the Health Education England (HEE) (2015) and JCCP frameworks (2018). In the absence of such standards being met, the claims that these companies make in regard to their students being able to practise safely are both misleading and exaggerated. Rapid and unmoderated acceleration through such training pathways occurs for regulated professionals just as much as it does for unregulated beauty therapists and lay personnel. The result is to expose fee-paying members of the public to unduly risky, and possibly sub-optimum, treatments performed by inexperienced and inappropriately trained practitioners. The JCCP recognises the pressures faced by the industry, but it suggests that closer attention should be paid to promoting professional standards and to encourage appropriately qualified and experienced practitioners to discourage inadequately trained practitioners from practising unsupervised. All education and training companies should also be required confirm to one nationally approved standard to promote safe practice for members of the public.
Body image and self-perception
Non-surgical cosmetic treatments are intended to alter appearance and self-image. Such invasive interventions usually result in significant changes in the emotional and psychological wellbeing and perception of the consumer, often for the better, but, sometimes, for the worse. Only people who are knowledgeable, appropriately trained and always place the interest of the patient foremost should be permitted to provide any procedure that results in changes in self-perception or body image. Unfortunately, the JCCP believes that, too often in the non-surgical cosmetics sector, patient safety is not always promoted with the rigour required to ensure public protection. This assertion is based on an analysis of concerns and complaints received by the JCCP. Unfortunately, direct action to remedy situations revealed by complainants is rarely possible, since the JCCP is an advisory body without statutory powers of investigation. Therefore, it is only able to promote and disseminate best practice and report specific issues to regulatory bodies, such as the professional statutory regulatory bodies and the Advertising Standards Authority (ASA).
Healthcare Market News has been advised by Mansfield Advisors LLP, which has much experience in this field: ‘We are convinced that it is only a matter of time before this market receives some sort of legalisation’.
Complaints
Resolved complaints reveal much about low-quality practices. In the surgical cosmetics field, the route for resolving complaints (recognised by all the statutory regulators, namely the Care Quality Commission, Healthcare Improvement Scotland, Healthcare Inspectorate Wales and Regulation and Quality Improvement, Northern Ireland) is through the Independent Sector Complaints Adjudication Service (ISCAS). Relevantly, one of the recommendations (recommendation 6) still being discussed from the Paterson Enquiry is that ‘all private patients (should/shall) to have right to mandatory resolution’. In addition to this, information about the means to escalate a complaint to an independent body should be communicated more effectively in both the NHS and independent sectors.
The JCCP believes that now is time for medical aesthetic practitioners to work together to ensure that the people who are permitted to provide aesthetic treatments are only those who are appropriately experienced, trained and qualified to do so. Achieving this will require conscious improvement in collaboration between all those who are committed to the promotion and enactment of high patient safety standards. The golden route to understanding what patients really think about their treatments includes ensuring that medical practitioners pay attention to their complaints and determining what changes must be made to remedy them. Continuous quality and service improvement should be everyone's aim. All patients deserve an external review of their complaint that provides closure and results to an overall improvement in consumer experience, effectiveness and safety.
Therefore, organisations should work more collaboratively to improve communication channels and ensure that patient safety issues, such as the requirement for practitioners to work from safe premises, use safe and appropriately sourced products and ensure that the safe delivery of aesthetics treatments are only permitted by appropriately trained and experienced practitioners. The JCCP also recognises that training organisations should monitor the impact that the training they offer has on patient safety and clinical quality, with the aim of encouraging continuous quality improvement.
Goals that need to be achieved include the need for organisations to demonstrate how they use learning to improve the services they offer and to promote a culture within which members of the public feel able to raise issues of concern to members of their frontline staff and managers without fear of reprisal or feeling that they are being ignored.
» All patients deserve an external review of their complaint that provides closure and results to an overall improvement in consumer experience, effectiveness and safety «
Further reading
Petch H, Scott A. Beauty is in the eye of the investor. LaingBuisson. 2021. https://tinyurl.com/533rcda8