The Clinical Advisory Group is aiming to make supply chains safer for both patients and medical aesthetic practitioners
The provision of clinical aesthetic services in the UK continues to be characterised by its rapid growth. As a consequence, both members of the public and practitioners require the provision of honest, proportionate, risk-assessed and accurate advice and opinion based on informed consultation and assessment. The question is: where do they go to obtain this?
Safeguarding interests and protecting patients
The Joint Council of Cosmetic Practitioners (JCCP) is a charitable organisation. It is a recognised self-regulator of the non-surgical aesthetic industry in the UK, and the point of access for the public seeking information about this area of practice and, where appropriate, for raising concerns about practitioners. The JCCP places public protection and patient safety as the focus of its activities. The JCCP was founded on the principles of providing unbiased opinion and guidance to the public and the aesthetic sector. Therefore, it fulfils a vital role in the world of unmoderated practitioner and training forums, hyperbole and misinformation that is often formulated in the absence of empirical evidence or clinical judgement.
The JCCP has been fervent about the need to provide members of the public with accurate information to safeguard their interests and to reduce the likelihood of patients experiencing untoward psychological or physical harm as a consequence of their treatment or practitioner choices. Unfortunately, there are many instances where patient harm and complications have occurred, which have not been assisted by the many areas of uncertainty that exist around accountability linked to current inadequate regulatory frameworks and enforcement powers in the UK.
The Clinical Advisory Group
The broad-based, unbiased and non-commercial nature of the JCCP is considered to be a strength, and the influence of the JCCP continues to grow as a result. The rapidly changing landscape of aesthetic medicine demands the formulation and provision of fast, accurate advice on a range of subjects. To respond purposefully to this demand, the JCCP requires an increasing degree of clinical input to inform its decisions and activities and to ensure that it provides current, evidence-based and balanced opinions. It was for this reason that the board of trustees decided that it was necessary to establish a group to advise on all clinical matters. This has resulted in the creation of the Clinical Advisory Group (CAG).
The CAG is an advisory group of the JCCP that reports directly to the JCCP board of trustees. The membership includes patient group representatives, doctors, dentists, nurses, non-clinical aesthetic group representatives, pharmacies, pharmaceutical companies, experts in medical devices, the independent healthcare sector, the Medicines and Healthcare Products Regulatory Agency (MHRA) and medical insurance sector colleagues. The CAG is an eclectic group, including many eminent people within the sector. This breadth of experience provides a credible and balanced perspective that the JCCP board can draw upon when required to inform its opinion, policies and activities.
The CAG is co-chaired by two JCCP trustees, Dr Paul Charlson and Andrew Rankin, both of whom are experienced aesthetic clinicians who have worked in the sector for more than 35 years, collectively. The board of trustees proposes possible topics that might be investigated by the CAG, and the CAG subsequently decides whether it is feasible to focus on such matters.
The CAG aims to:
- Champion clinical excellence for patients and members of the public, in regard to both the quality of their personal experience and engagement with their practitioner, as well as personal treatment outcome measures
- Advise on clinically related professional healthcare aspects of operating the JCCP registers
- Provide clinical advice and oversight in relation to JCCP policies and activities
- Provide an overarching forum to coordinate discussion and to formulate opinions on matters relating to the use, supply and administration of safer products and medicines, the provision of standards and systems of inspection for safer premises and safe working practices
- Assist the JCCP in the formulation of any new policies that require a clinical input and focus
- Take account of the needs of different professional practitioner groups when advising the JCCP on clinically related matters
- Raise and respond to major issues of clinical concern on operational performance in the cosmetic sector.
To achieve these aims, the CAG has agreed to adopt the following approach to guide its activities:
- Facilitating best practice in the sector, by advising on and supporting the development of solutions to current and emergent clinical issues
- Hearing from leading UK and international thinkers on matters related to aesthetic practice and reform to remain at the forefront in terms of clinical knowledge and insight and contribute to related debate
- Ensuring that the JCCP board and its related committees are kept up to date on clinical developments
- Advising on compliance requirements relating to legal, policy and regulatory frameworks of practice in the four countries of the UK
- Building links in the clinical community and share best practice
- Maintaining a broad perspective, focusing on all elements of patient pathways, including social, emotional, mental and physiological health to identify opportunities for service and practice improvement
- Responding to and advise on clinically related enquiries from the media, Government agencies, members of the general public or practitioners
- Promote all aspects of Cosmetic Practice Standards Authority (CPSA) best practice and standards to ensure appropriate adoption by JCCP registrants and the wider practitioner community.
» This medical versus cosmetic debate has re-emerged during the COVID-19 pandemic, which has emphasised the need for a clear definition to be made to differentiate medical aesthetics and the beauty industry «
Proactive and reactive
The proactive role taken by the CAG is in the form of a number of ′task and finish′ groups to consider and formulate action plans in response to a range of key clinically related challenges that confront the aesthetics sector. However, it is not a case of delegating these groups with a task that they might get around to finishing at some point in time. The sector has witnessed too many such occurrences, and simply ‘kicking the can down the road’ is not helpful. Therefore, the plan is to get work finished in an accurate and timely fashion.
Ordinarily, the task and finish groups will consist of members of the CAG and, if required, outside experts. This forms part of an ongoing JCCP agenda to provide information for the Government, public bodies, expert groups, clinicians, practitioners and members of the public. It is hoped that this will positively shape the direction of regulation in the sector, with the aim of enhancing patient safety and public protection.
Medical or cosmetic?
The medical versus cosmetic debate has been ongoing for many years. This matter is considered to be a central debate for the CAG. This medical versus cosmetic debate has re-emerged during the COVID-19 pandemic, which has emphasised the need for a clear definition to be made to differentiate medical aesthetics and the beauty industry. This is not simply whether the procedure is considered to be medical from a health-related diagnostic and/or treatment perspective, but relates to the whole process of risk assessment and delivering that procedure. The consultation and the ethical framework underpinning both assessment and the implementation of an evidence-based treatment plan are essential. It is the clinician's professional and ethical judgement and approach (and the documentation that they use to record their decisions) that confirm a robust medical consultation has taken place.
» Untrustworthy and non-evidence-based products are freely available to purchase, as well as genuine products with no surety of their safety, storage or origin «
Mental health and wellbeing
Mental health problems and psychological issues have also increased during the past year. It is well-known that someone's perceived appearance can affect their mental health and wellbeing. It is easy to trivialise an aesthetic intervention, but it can transform someone's mental state and affect their health status and wellbeing. This fits well with the biopsychosocial model of medicine proposed by Engel (1977).
The assessment of the psychological and emotional status of a patient forms a significant part of any aesthetic consultation. It follows that the clinician must be suitably trained and have the tools to perform such an assessment both safely and effectively. One aspect of the debate that the CAG is addressing is whether all clinicians are trained and able to make the necessary assessments, closely followed by what validated assessment tools can be used to support their decision. For this reason, the CAG has established a specific task and finish group to consider the psychological and emotional effects related to cosmetic treatments, and it is working with the Mental Health Foundation (MHF) to produce three public-facing user guides relating to those aged under 18 years, parents and older adults aged between 45 and 65 years. These are planned for publication in June 2021. The shared JCCP and MHF group that is driving this work is also sharing political advocacy advice with the Government regarding the negative and harmful impact that cosmetic treatments can have on members of the public who elect to receive these treatments. This has also been extended to consider the harmful and abusive effects that unregulated social media posts can have on the mental health and wellbeing of members of the public (particularly younger people). Additionally, the JCCP has played an active role in advising the UK Government in regard to legislation linked to treatments provided to patients aged under 18 years.
Task and finish groups
Two other task and finish groups are currently active. One is focusing on the safe supply of products. This is a major issue. Untrustworthy and non-evidence-based products are freely available to purchase, as well as genuine products with no surety of their safety, storage or origin. This often places unsuspecting patients at increased risk of harm and complications that relate to their aesthetic treatment. Furthermore, it is a driver to encourage less ethical practitioners to source and use these products, which are less costly and freely available without restriction. The CAG task and finish group looking at this issue is also focusing on major pharmaceutical companies and distributors in the UK.
The second group is examining adverse incidence reporting. If safety is to be improved, an organised and better co-ordinated effective system is needed that encourages practitioners to report adverse incidences. The current process is considered by many to be arduous, particularly if the incident is reported to a large pharmaceutical company. Their regulatory systems create a bureaucracy that would deter the busy clinician from engaging with the reporting process. There has to be proportionality: minor incidences might be logged with minimal fuss, while major problems warrant an in-depth analysis. The JCCP is discussing such matters with the MHRA.
The reactive role of the CAG is to advise on trending topics as they develop, providing clarity and direction. An example would be possible late inflammatory reaction linked to dermal fillers and a particular COVID-19 vaccination. There are reports from the US regarding this matter, and the aim of the CAG would be to ensure accurate information is disseminated to practitioners and the public.
Conclusion
The aforementioned issues combine to illustrate how the CAG can be used to inform the JCCP and, ultimately, Government policymakers with regard to the major issues that affect public protection and patient safety.
Ultimately, while many regard increased regulation and bureaucracy to be an impediment to a free market, the JCCP and the CAG want to aid in discovering, co-designing and delivering a proportionate balance between freedom, entrepreneurialism and regulation. Commitment to the implementation of an uncompromised and positive culture of professionalism is the way forward, and that is something that all practitioners who engage in the aesthetics sector must embrace to provide public protection. The CAG aims to make a supportive and pragmatic contribution to this objective.