The JCCP's current position on future education and training standards/competencies and routes to qualification

The JCCP recently commissioned a Task and Finish Group to review these standards and to make proposals on how aesthetic practitioners should be prepared to evidence their compliance with forthcoming DHSC licensing standards (relating to requisite knowledge, practical competence and professional behaviours). The JCCP Task and Finish Group was independently Chaired by Juliet Anderson (until recently Operations Director with Health Education England – South East Region). Our aim was not to rewrite the current 2018 JCCP/CPSA competency standards at this time, but to seek opinion on whether the current standards are still ‘fit for purpose’ and to undertake a ‘gap analysis’ of the current 2018 standards that we consider should be reflected in our proposals to revise the standards in association with the DHSC ‘industry’ standards when they are crafted in 2025, as part of the proposed government licensing scheme for the non-surgical sector in England.

Members of the Task and Finish Group reviewed the 2018 JCCP/CPSA Competency Framework and provided feedback on the relevance and ‘fitness’ of these standards for adoption in the post-licensing era in England (and in the other three UK nations, subject to agreement with the relevant devolved Government Departments). In accordance with this aim, the Task and Finish Group gave consideration to potential new ‘modality’ specific standards that will need to be developed next year following the government's determination regarding which ‘licensable’ procedures will be included in their proposed ‘Green’, ‘Amber’ and Red’ categories.

Our second task related to consideration of how practitioners should use independently verified evidence to demonstrate their compliance with the yet to be determined government standards (education, training and practical competence and professional/ethical behaviours). The Task and Finish Group considered a range of routes to qualification, and potential ‘alternative’ routes for appropriately experienced regulated practitioners to demonstrate compliance with the new DHSC industry standards (when they are produced) and proposed a series of ‘principles’ and recommendations for the government to consider going forward.

Key principles for any new competency framework:

• Equal registration opportunity: ensure equal access to registration for all practitioners based on demonstrated knowledge and competence in accordance with forthcoming DHSC Licensing requirements/standards.
• Ensure that any future education and training framework complies fully with safeguarding and equality, diversity and inclusivity standards.
• Leverage of the experience and accountability of suitably qualified and experienced aesthetic healthcare professionals in promoting compliance and safety standards to benefit members of public and the cosmetic industry.
• Where relevant, expertise should be obtained from the MHRA and national and global pharmaceuticals and product manufacturers to inform future education and training standards.
• The revised competence framework should complement national quality assurance and external inspection (scrutiny) standards and requirements as determined by professional statutory bodies and other regulators such as the Professional Standards Authority, the CQC, HIS and the Institute of Licensing, etc.
• The level of educational achievement cited by any course provider should be related to, and determined by the complexity of the knowledge and skills required to demonstrate safe and effective practice for the specific aesthetic modality that is being studied. Procedures such as dermal fillers, botulinum toxin injectables and hair restoration surgery, for example are regarded as higher risk treatments and the current JCCP/CPSA Competency Framework (2018) outline the required level of knowledge and skills for such procedures to be set at Level 7 in order to ensure the provision of such treatments safely and effectively. The Task and Finish Group endorses the need for the continuation of this academic standard/level for all invasive forms of aesthetic treatments in the future.
• The assessment of practice knowledge and skills should be inclusive of physical, emotional health and wellbeing, socio-emotional influences, psychological risk factors.

How fit for purpose is the current JCCP/CPSA Competency Framework?

NHS England advise on their website that ‘We (Health Education England) have concluded our mandate for developing education and training standards for non-surgical cosmetic interventions. The Joint Council for Cosmetic Practitioners has now assumed responsibility for designing and implementing a new voluntary register to support the enactment of these standards’.

The JCCP Task and Finish Group concluded that the 2018 JCCP/CPSA Competency Framework remains ‘fit for purpose’ for the government's proposed future scheme of licensing (subject to a range of amendments being made – as cited below). The JCCP Task and Finish Group and the Cosmetic Standards Practice Authority (The CPSA) consider that the infrastructure (relating to the 2018 JCCP/CPSA Competency Framework) already exists and is in place to deliver the proposals contained in this paper.

However, we also agreed that greater attention should be included in the revised competency framework by:

• Adding a new standard for numeracy and literacy at a minimum of Level 4 for all licensed practitioners.
• Emphasising applicable legislation, including medicines, under 18's, health and safety.
• Reviewing the scope of dermal fillers to be included i.e. permanent, semi-permanent, absorbable, specifying the areas that can be treated, and appropriate volumes with reference to manufacturer and industry guidance
• Reviewing the scope of use for botulinum toxin i.e. specifying which areas that can be treated for cosmetic use, including specification of dosage ranges with reference to manufacturer and industry guidance.
• Updating prescribing guidelines and practice implications (including the proscription of remote prescribing for all elective aesthetic treatments, and professional responsibilities towards delegation).
• Requiring all licensed practitioners to obtain the equivalence of a Royal Society of Public Health Level 3 qualification in health protection/infection control.
• Adding new core competencies that will need to be written for new procedural modalities that the DHSC determines should be included in the new scheme of Licensing in England (i.e., for those procedural modalities for which the JCCP/CPSA has not yet set competency standards).
• Specifying standards for teachers, assessors, moderators and examiners that will need to be agreed for implementation across the sector – (possibly assisted/set by Ofqual).
• Aligning any revised curriculum to meet the DHSC's new premises license standards.

Proposed routes to demonstrating evidence of meeting the proposed DHSC industry standard

The Task and Finish Group concluded that the following routes to qualification should be endorsed by the DHSS as part of their proposed licensing scheme:

• Validated, approved and regulated qualifications awarded by UK universities and Ofqual designated and approved awarding bodies
• A Time limited Accelerated Route awarded by Ofqual designated and approved awarding bodies and delivered by their associated (and occupationally approved) Ofqual/SQA approved awarding organisations
• Apprenticeship route – Levels 3 - 7
• A new nationally approved ‘credentialing route’ for suitably experienced, qualified regulated healthcare professionals
• The JCCP considers that following conditions/principles should apply to these proposed routes:
• Approval should be restricted only to appropriate validated and regulated qualifications awarded by UK Universities and Ofqual (or other UK vocational regulators) designated awarding bodies that meet the standard, kind and content of the new DHSC standards, either following study of the whole curriculum or via an approved RPL route, including summative final outcome examinations of knowledge and practice competence.
• A new time limited (the time limit to be agreed by the DHSC during a pre-determined implementation phase for the new licence) accelerated route approved by Ofqual (or other UK vocational regulators) designated awarding bodies resulting in the award of an approved and regulated awarded qualification (including evidence of meeting defined entry and prior experience criteria and summative final outcome examinations of knowledge and practice competence).
• Apprenticeship routes (Levels 3 – 7) that meet the standard, kind and content of the new DHSC standards, including summative final outcome examinations of knowledge and practice competence.
• A new credentialing route should be designed and implemented for suitably experienced, qualified regulated healthcare professionals. This should also include routes set by the Royal College of Surgeons, designated GMC specialist registers, royal/professional colleges etc (such a route and designated registers/colleges etc to be endorsed by the DHSC as meeting their required governance and scrutiny standards).
• Where appropriate the expertise of national and global pharmaceutical training academies should be integrated into the design and delivery of relevant components of any new curriculum.

The Task and Finish Group identified the following issues for DHSC to consider (regarding credentialing):

• Who should\will be responsible\ accountable for commissioning or approving organisations to conduct the credentialling process for non-surgical practice?
• What organisations should be considered to award practising privileges via a credentialing route?
• Who should\will develop the standards for a credentialling process in non-surgical cosmetic practice?
• What should the credentialling process look like? What should the credentialling organisation's infrastructure look like?

Conclusion

The JCCP Task and Finish Group and the JCCP Education and Training Committee has approved and confirmed agreement with the 2018 JCCP/CPSA competency framework gap analysis (summarised earlier in this paper). The JCCP has endorsed and confirmed agreement with the above cited proposed routes to qualification (including consideration of designing and implementing a new credentialing route for suitably qualified aesthetic practitioners).

The JCCP's position remains as always that we are calling for a national education and training standard as part of the new proposed licensing system in England. We have recommended to the government that persons who are in possession of benchmarked and standardised qualifications awarded by UK universities or by JCCP approved Ofqual regulated awarding organisations, and which are provided by their associated JCCP approved training centres (i.e., those who have been proven to meet all of the HEE and JCCP/CPSA standards) should be regarded as meeting our current and future standards for Level 7 aesthetic practice.

Under no circumstances, do or will we accept CPD as evidence of proficiency to provide procedures that will be included in the new practitioner license. We do however accept that there will be some regulated healthcare practitioners who will be able to demonstrate their proficiency to practise procedures included in the new license by virtue of their current professional registration status and evidence of post qualifying training in the form of credentialing (to be confirmed by the government).

What is unacceptable is the proliferation of training providers who are selling qualifications to practitioners in the form of short courses in the belief that these will meet the new DHSC standards.

The proposals cited in this paper have been presented to the DHSC for consideration to inform their deliberations on education, training and competency standard setting in support of their proposed scheme of licensing for the aesthetic sector.