Should doctors, nurses and dentists train non-medical personnel to administer injectable aesthetic treatments and prescribe for them? This question was raised on the British Association of Cosmetic Nurses (BACN) Facebook forum, culminating in a consensus of disapproval of the training of and prescribing for non-medical practitioners.
The principles of the Nursing and Midwifery Council's (NMC) Code (NMC, 2019a) must not be forgotten. These require aesthetic practitioners to act, at all times, within the patient's best interest and be able to demonstrate their own competency for all they do, as well as the competency of those they delegate to.
One could postulate training someone else in healthcare is akin to delegating a task, and that, therefore, those training others are responsible for ensuring that the training meets the NMC delegation requirements.
The same applies to prescribing for others and delegating the administration of medicines, which has its own set of standards (Royal Pharmaceutical Society, 2016).
Furthermore, there is now no ambiguity relating to the remote prescribing of aesthetic medicines including toxins, and the NMC has issued the following:
‘All prescribers must take individual responsibility for their prescribing decisions and should recognise that there are certain areas of practice where remote prescribing is unlikely to be suitable, for example, when prescribing medicines likely to be subject to misuse or abuse, or injectable cosmetic treatments’ (NMC, 2019b)
» The training of a non-medical individual who has no medical qualification, clinical knowledge or acumen, no pathway or requirement to demonstrate competency, evidence or accountability, unable to consult or consent adequately as clinical knowledge is absent, unable to prescribe and cannot manage complications is baffling «
According to the NMC, delegation is defined as the transfer to a competent individual of the authority to perform a specific task in a specified situation. The NMC has set out expectations of people on its register and that the delegation of tasks will be in the other person's scope of practice of competence to ensure that they fully understand what is being asked of them. Additionally, they must guarantee that they are adequately supervised and supported so they can provide safe and compassionate care, as well as meeting the required standard.
Safeguarding the patient
Within the NHS, there are many situations where healthcare assistants (HCAs) are trained to carry out specified tasks and support the medical team, so they become invaluable team members. This may include an HCA who has been trained to do venepuncture and provide patients with information on their treatment or a sexual health HCA who takes an initial consultation and initial diagnostics. The HCA will work within a team and will be answerable to a medical lead. At no point does the HCA take on autonomous care for the patient. The patient is safeguarded.
While the task of injecting a botulinum toxin or a dermal filler (implant) at its most basic level can be relatively easy to teach, a much wider knowledge and clinical acumen is required. If the answers to the questions are not understood and acted upon, the tick-box consultation method in medicine does not work. A practitioner's own patients may present with certain medical conditions or medications and will be subject to clinical judgement, scrutiny and reasoning when considering and planning their treatment. A practitioner may decide not to treat or may refer. A qualified nurse is furnished with competency in multiple clinical skillsets, judgement and critical thinking.
Priorities and patient safety
The training of a non-medical individual who has no medical qualification, clinical knowledge or acumen, no pathway or requirement to demonstrate competency, evidence or accountability, unable to consult or consent adequately, as clinical knowledge is absent, unable to prescribe and cannot manage complications is baffling. As they are not part of a multidisciplinary team or answerable or accountable for their actions, surely this must conflict with the NMC's Code, where maintaining patient safety is a priority (NMC, 2019a).
The BACN has no doubt that the practice of teaching the non-regulated beauty sector or lay people to administer cosmetic injectable treatments is contrary to the NMC Code (NMC, 2019a).
Ongoing reviews and improvements
Currently, the BACN is in the process of reviewing its governance and its Code of Conduct, but, in advance of this, the BACN committee has agreed to not accept members into the association who train the non-medical sector in injectables or prescribe for them.
Once our revised governance policies and new Code of Conduct is signed off, it will then be available to access on the BACN website (www.bacn.org.uk).
Onwards and upwards
In the meantime, the BACN is preparing for its autumn conference, which is held on 7–8 November and awaits an impressive list of wonderful speakers and workshops.
As always, there is never enough time to fit in everything. Such a cross section of nurses are attending, both novice and experienced, but I for one always come away with something new and meet such passionate fellow nurses. We are a unique, extraordinary and pioneering group. I am always in awe of the speakers who demonstrate the professionalism and expertise that nurses in aesthetics hold.
Finally, the BACN has a bursary scheme available to help nurse members. This may be used to help towards the V300 or postgraduate study or research. If you are a member and would like to know more, please contact Sarah, Tara or Gareth on the BACN administration team, and they will provide further information (Box 1).