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Questions about our cosmetic interventions guidance

Read our eight frequently asked questions about our cosmetic interventions guidance, including questions on delegating the administration of Botox and laser eye surgery.

Who does the guidance apply to?

Our guidance applies to all doctors registered with us who offer both surgical and non-surgical cosmetic interventions.

Does the guidance cover laser or refractive eye surgery?

Laser and implant based refractive eye surgery shares many similarities with cosmetic interventions and we would therefore consider these to be covered within the scope of this guidance.

In our guidance we have used a broad definition to define cosmetic interventions.

We mean this to include:

‘...any intervention, procedure, or treatment carried out with the primary objective of changing an aspect of a patient’s physical appearance. This includes surgical and non-surgical procedures, both invasive and non-invasive.’

The Royal College of Ophthalmologists (RCOphth) is the professional body for medically qualified, and those training to be, ophthalmologists. The RCOphth has collaborated with experienced refractive surgeons and ophthalmologists across the public and private health sectors to develop its new guidelines ‘Professional Standards for Refractive Surgeons’.

You can find further information on these guidelines on the

Can a doctor still delegate the administration of Botox/filler injections to appropriately qualified staff?

If doctors are prescribing injectable cosmetic medicines like Botox®, they must carry out a physical examination of the patient. They cannot prescribe these medicines by telephone, video link, online or at the request for others for patients they have not examined (paragraph 11).

The guidance also states that the doctor who is carrying out the procedure or supervising its performance by another practitioner should be the one who gets the patients consent (paragraph 16).

If a doctor does decide to delegate the administration of treatment such as Botox® they are responsible for the overall management of the patient and must be satisfied that the person providing care has the appropriate qualifications, skills and experience to provide safe care for the patient.

How does a doctor decide how much time is needed for reflection?

Paragraphs 24-27 of the guidance contain advice on giving patients enough time for reflection.

In terms of the time patients should be given for reflection, we have not specified a particular time period in the guidance as this is a clinical decision that is likely to be dependent on a range of factors.

We have in paragraph 25 of the guidance set out a range of factors which we would expect a doctor to consider.

‘The amount of time patients need for reflection and the amount and type of information they will need depend on several factors. These include the invasiveness, complexity, permanence and risks of the intervention, how many intervention options the patient is considering and how much information they have already considered about a proposed intervention.’

Does there always need to be two separate consultations or is same day treatment acceptable?

The decision on whether same day treatment is acceptable is a clinical decision that is best made by the doctor carrying out the procedure who has all the information available to them.

There is no set period of time specified in our guidance as we consider this to be dependent on many different factors that a doctor must assess individually. Paragraphs 24-27 of the guidance contain advice on giving patients enough time for reflection.

And paragraph 25 of the guidance sets out a range of factors which we would expect a doctor to consider.

‘The amount of time patients need for reflection and the amount and type of information they will need depend on several factors. These include the invasiveness, complexity, permanence and risks of the intervention, how many intervention options the patient is considering and how much information they have already considered about a proposed intervention.’

Do loyalty schemes, packages, Groupon advertising etc., contravene the guidelines?

The guidance contains advice at paragraphs 46-55  in helping doctors to ensure that marketing of their services is done responsibly.

When advertising their services we expect all doctors to follow the set by the Committee of Advertising Practice.

The new guidance doesn’t prohibit the use of promotional tactics but does advise at paragraph 52  

‘that doctors must not use promotional tactics in ways that could encourage people to make an ill-considered decision.’

We would therefore expect a doctor to be thinking carefully about the effect the promotional tactic being used is likely to have on their patient.

In terms of treatments being offered and promoted by other businesses or therapists we advise in the guidance that doctors must not knowingly allow others to misrepresent them or their services in ways that could conflict with our guidance (paragraph 54).

We also advise that a doctor mustn’t provide their services as a prize (paragraph 53).

What advice do you give to doctors who are approached by patients using crowdfunding?

Our guidance for doctors sets out the standards we expect them to meet, and these relate to good medical practice. The guidance does not touch on how procedures are paid for because we would not expect doctors to have to make judgment calls about this issue.

All Communitybaptistpa registered doctors are required to follow Communitybaptistpa standards including the new guidance if they offer cosmetic procedures.

Please refer to paragraph 54 in the guidance:

'You must not knowingly allow others to misrepresent you or offer your services in ways that would conflict with this guidance.'

What will you do if doctors breach the guidance?

Our guidance sets the standards of good medical practice that we expect all doctors registered with us to follow.

If a doctor breaches our guidance and we receive a complaint, we will investigate under our fitness to practise procedures, and if appropriate can impose sanctions on a doctor’s registration. Ultimately, for serious or persistent breaches, there may by a tribunal hearing, and a doctor can be erased from the medical register.

11

You must carry out a physical examination of patients before prescribing injectable cosmetic medicines. You must not therefore prescribe these medicines by telephone, video link, online or at the request of others for patients you have not examined.

16

If you are the doctor who will be carrying out the intervention, it is your responsibility to discuss it with the patient and seek their consent – you must not delegate this responsibility. It is essential to a shared understanding of expectations and limitations that consent to a cosmetic intervention is sought by the doctor who will perform it, or supervise its performance by another practitioner.

24

You must give the patient the time and information they need to reach a voluntary and informed decision about whether to go ahead with an intervention.

25

The amount of time patients need for reflection and the amount and type of information they will need depend on several factors. These include the invasiveness, complexity, permanence and risks of the intervention, how many intervention options the patient is considering and how much information they have already considered about a proposed intervention.

26

You must tell the patient they can change their mind at any point.

27

You must consider whether it is necessary to consult the patient’s GP to inform the discussion about benefits and risks. If so, you must seek the patient’s permission and, if they refuse, discuss their reasons for doing so and encourage them to allow you to contact their GP. If the patient is determined not to involve their GP, you must record this in their notes and consider how this affects the balance of risk and benefit and whether you should go ahead with the intervention.

25

The amount of time patients need for reflection and the amount and type of information they will need depend on several factors. These include the invasiveness, complexity, permanence and risks of the intervention, how many intervention options the patient is considering and how much information they have already considered about a proposed intervention.

24

You must give the patient the time and information they need to reach a voluntary and informed decision about whether to go ahead with an intervention.

25

The amount of time patients need for reflection and the amount and type of information they will need depend on several factors. These include the invasiveness, complexity, permanence and risks of the intervention, how many intervention options the patient is considering and how much information they have already considered about a proposed intervention.

26

You must tell the patient they can change their mind at any point.

27

You must consider whether it is necessary to consult the patient’s GP to inform the discussion about benefits and risks. If so, you must seek the patient’s permission and, if they refuse, discuss their reasons for doing so and encourage them to allow you to contact their GP. If the patient is determined not to involve their GP, you must record this in their notes and consider how this affects the balance of risk and benefit and whether you should go ahead with the intervention.

25

The amount of time patients need for reflection and the amount and type of information they will need depend on several factors. These include the invasiveness, complexity, permanence and risks of the intervention, how many intervention options the patient is considering and how much information they have already considered about a proposed intervention.

46

You must always be honest and never misleading about your skills, experience, qualifications, professional status and current role.

47

When advertising your services, you must follow the regulatory codes and guidelines set by the Committee of Advertising Practice.17 

48

You must make sure the information you publish is factual and can be checked, and does not exploit patients’ vulnerability or lack of medical knowledge.

49

Your marketing must be responsible.18 It must not minimise or trivialise the risks of interventions and must not exploit patients’ vulnerability. You must not claim that interventions are risk free.

50

If patients will need to have a medical assessment before you can carry out an intervention, your marketing must make this clear.

51

You must not mislead about the results you are likely to achieve. You must not falsely claim or imply that certain results are guaranteed from an intervention.

52

You must not use promotional tactics in ways that could encourage people to make an ill-considered decision.

53

You must not provide your services as a prize.

54

You must not knowingly allow others to misrepresent you or offer your services in ways that would conflict with this guidance.

55

You must be open and honest with your patients about any financial or commercial interests that could be seen to affect the way you prescribe for, advise, treat, refer or commission services for them.

52

You must not use promotional tactics in ways that could encourage people to make an ill-considered decision.

54

You must not knowingly allow others to misrepresent you or offer your services in ways that would conflict with this guidance.

53

You must not provide your services as a prize.

54

You must not knowingly allow others to misrepresent you or offer your services in ways that would conflict with this guidance.