After the official launch of the Joint Council for Cosmetic Practitioners, Aesthetics asks how the practitioner register aims to promote patient safety.
On January 8, 2016, the concept of the Joint Council for Cosmetic Practitioners (JCCP) was announced. From the start, its aim was to provide credible regulation, protection and guidance for the public in an unregulated sector.1
It followed training qualification recommendations published by Health Education England in October 2015 that outlined different levels of learning (Levels 4-7) for practitioners delivering aesthetic treatment. HEE also acknowledged that the specialty needed a joint professional council to assume ownership of the cosmetic industry standards for education and training.2 This guidance was commissioned by the Department of Health in response to the 2013 Keogh report, which stated, ‘It is our view that dermal fillers are a crisis waiting to happen… In fact, a person having a non-surgical cosmetic intervention has no more protection and redress than someone buying a ballpoint pen or a toothbrush.’3
Two years later, on March 1 of this year, the JCCP’s voluntary registers for approved practitioners and education and training providers launched. This was alongside the launch of the Cosmetic Practice Standards Authority (CPSA), a group of specialists who set the practice Standards for the JCCP.4
The official unveiling took place on February 22 at the House of Lords in London. On the evening, consultant plastic surgeon and chair of the CPSA, Mr Simon Withey, said, “If practitioners abide by the code of conduct and follow the CPSA’s standards, then this will hopefully avert the crisis that Sir Bruce Keogh anticipated when he wrote his report.”4 Professor David Sines, chair of the JCCP, added that the JCCP now has charitable status, and is currently awaiting formal accreditation by the Professional Standards Authority (PSA).4,5 They have also signed an agreement with Ofqual for training standards and signed a memorandum with the Advertising Standards Authority (ASA) to ensure that the public receive honest declarations of practitioner and treatment information.4,5
The registers are now open to join. However, there is disagreement amongst the medical aesthetics community about how exactly the voluntary register for practitioners will work to promote patient safety.
Before the JCCP could launch, it needed a clear set of standards that could be used as a benchmark for education and training. These standards have now been developed by the JCCP. In addition, practice standards have been developed by the CPSA, which have now been adopted by the JCCP as a benchmark of practice proficiency for practitioners in each of the modalities that they recognise.6 Consultant plastic surgeon Mr Alex Woollard, CPSA board member and trustee, explains, “The CPSA’s first role has been to create practice standards based on clinical risk, which have been produced by a number of experienced practitioners in consultation with representatives from the wider sector. These will help to improve patient safety, raise standards and standardise practice across the aesthetics specialty.”
In addition, the CPSA has a specific group focused on ‘horizon scanning’. The Authority will monitor new devices and treatments to assess whether they require inclusion in their guidelines. “Horizon scanning is important because in this industry, new things come out almost every week. So, even if we produce the standards today, next week there could be new treatments that are not included as they don’t yet exist,” he says. Data gathering, such as adverse events, and product safety and efficacy, is also a stated priority for the CPSA. Mr Woollard explains, “Scientific data in the cosmetic world is dismal. We will gather reports on adverse incidents and near misses as well as patient-reported outcomes. This will provide data on treatments that are associated with poor outcomes or higher risk. The idea is that practitioners and patients will report to the CPSA information and data on products, devices, treatments and adverse events so that we can raise the standards across the board and protect patient safety. The CPSA would then feed this data regarding concerning products, devices or practices on to the Medicines and Healthcare products Regulatory Agency (MHRA) or the regulatory bodies.”4,7
The JCCP has two separate registers, one for practitioners who can demonstrate that they have met the appropriate education, clinical and practice standards as outlined by the JCCP and the CPSA; and a separate register of approved education and training providers.8
The JCCP Practitioner Register is divided into two parts. The first is for those registered with a professional statutory regulatory body (PSRB), including the General Medical Council (GMC), the Nursing and Midwifery Council (NMC), the General Dental Council (GDC), the Health and Care Professions Council (HCPC) or the General Pharmaceutical Council (GPhC). The second is for practitioners who are not in current membership with, or are not eligible to join a PSRB, for example, aestheticians and beauty therapists.9
“The idea is that practitioners and patients will report to the CPSA information and data on products, devices, treatments and adverse events so that we can raise the standards across the board and protect patient safety”
Mr Alex Woollard
When asked about therapists who simply choose not to join the JCCP register, Professor Sines states, “It is a voluntary register and I will always argue that nothing less than statutory regulation will protect the public. At present, all we can do is make the register as accessible as possible to all individuals, without diluting the standard or the supervision level that we require for patient and public safety.”
Professor Sines says that joining the JCCP register involves a straightforward online application. He states, “It costs £450 per annum. For PSRBs, applicants must provide evidence of their PSRB PIN number, declare they are of good character and willing to abide by the JCCP and CPSA Joint Code of Practice,10,11 agree that their premises of operation are named and meet the JCCP Premises Standards, evidence of indemnity, and confirm that they meet all the CPSA’s standards for education and training.” Professor Sines says that the same process will be followed by all registrants, although non- PSRB registered practitioners will not provide a PSRB PIN number.
Mr Woollard also notes that only practitioners who have trained with a JCCP-accredited training provider, or who are able to demonstrate that they have undertaken an equivalent standard of education and training with another provider, will be accepted onto the JCCP register.6 He states, “The standards have been written for both experienced practitioners and to guide those who have just come out of a training establishment and want to set up a practice. At present, we are in a transition period that requires a complex grandfathering process. In in a few years’ time, once this has been established and hopefully the landscape has evolved, I would be questioning why someone had gone to a trainer who was not JCCP-accredited.”
For those already on the Treatments You Can Trust (TYCT) register, a voluntary register which lists practitioners tested against published guidelines, Professor Sines explains that registrants will be invited to transfer to the JCCP Register as provisional members of the JCCP. However, he states, “No TYCT registrant is being automatically accepted onto the JCCP register and they still have to meet all of our standards in exactly the same way as any other registrant. At their next renewal date, they will be invoiced by the JCCP and go through the formal process, should they choose.”12
Professor Sines doesn’t yet know how long the registration process may take, but estimates that most applicants should hear back within four to six weeks. Registration lasts three years, but Professor Sines says, “There will be an annual subscription fee, and practitioners must provide an updated copy of indemnity insurance, as well as perform several other declarations, including advising the Council of any untoward or adverse incidents that have occurred during the previous twelve months.”
Many medically qualified practitioners have expressed concern regarding the JCCP allowing beauty therapists who perform dermal filler and botulinum toxin treatments onto the register. In response to this, Professor Sines has said that the JCCP is trying to make patients as safe as it is feasibly possible in the absence of statutory regulation.
“Legally, there is nothing to prevent a therapist injecting into the head, neck or face,” he explains, adding, “We have made it clear in our standards that any beauty therapist administering botulinum toxin and dermal filler injections can only do so under the supervision of a JCCP-registered clinical prescriber who must remain personally accountable.13 It’s clear that until there is change the legislative framework, then we must do our absolute best to regulate and to bring people to account.”
All practitioners on the register will be responsible for continuing to maintain the high standards as outlined by the JCCP and the CPSA. However, Professor Sines says there are several key notable responsibilities that should also be mentioned. He explains, “What is crucial is that every year practitioners must disclose the adverse events they have come across over the past year. If we find that a practitioner on our register hasn’t been declaring such incidents, this could well be a reason for us to seek their removal from the register because it’s a condition of best practice to be open and transparent in the interests of patient safety.”
As well as this, once registered, practitioners must abide by the CPSA’s Supervision Matrix (Figure 1).13 This is a document that outlines the requirements for supervision for different types of practitioners.
The document is too complex to detail in this article, but the level and nature of supervision varies according to the procedure risk, HEE level, background of practitioner and the discretion of the supervisor. Practitioners should visit the CPSA’s website to find out more.13
One purpose of the Supervision Matrix, Mr Woollard notes, is to discourage ‘lone practitioners’ and ‘ghost supervision’ and instead encourage the development of geographically local support networks. This is to ensure support for practitioners at all levels and provide a clear process of accountability, as well as encourage shared learning and quality improvement.
He explains, “People have in their heads that supervision means they are never able to have an independent practice. But, for any healthcare professional, supervision is something that should be part and parcel of their working life. Everyone, no matter how senior they are, will have a supervisor – someone who oversees and looks at your practice. It’s part of appraisal as recognised by the GMC, and it is part of a network of support.”
As an example, a practitioner performing microneedling treatments at Level 4 must have a supervisor who is at least Level 5 for microneedling. If a practitioner is a Level 7 for a particular treatment, they will need to be supervised by one of their peers who is also at Level 7 for that procedure. Mr Woollard says that a supervision register will be set up in the future, and encourages potential supervisors to get involved.
If the practitioner does not abide by the JCCP and CPSA’s requirements, they may be subject to investigation and potentially be removed from the register.14 Professor Sines adds, “We have made it very clear to the PSRBs and have agreed that if we discover a complaint, or investigate one of our members, we will also notify their professional regulator. The JCCP has now signed a memorandum of understanding with the CEO of the GMC in this regard with plans to extend to other PSRBs. Registrants will be advised that the JCCP will always refer to their respective PSRB if there have been any concerns or complaints about their proficiency or fitness to practise.”13
The JCCP register will open to the public in early April 2018, allowing them to view practitioners who have met the requirements. However, Professor Sines acknowledges that creating awareness and getting patients to search the register is a challenge.
“I think a major challenge now is both practitioner and patient adoption, so marketing and promoting the JCCP is going to be key. We are already working with a major social media company and we have been on the radio to disseminate the message. We also have celebrity Leslie Ash supporting both the CPSA and JCCP, which is helping our campaign,” he says. Professor Sines concludes by arguing that if they can achieve public awareness, it will help promote patient safety. He states, “We are seeking to become a thoughtful organisation. An organisation that encourages the pursuit of trustworthiness and effective collaboration amongst its partners to protect the public and provide excellence in practice. It’s not easy – we’ve had many pushbacks – but we are resilient.”
Mr Woollard adds, “This is a voluntary register; we hope that it eventually becomes statutory, but at this point in time it is voluntary. The big message is that we have a real opportunity here to radically change the status of the industry and tighten up loopholes. I hope that people see this in a positive light. This is an attempt to lift things up, to give credibility to the sector and raise the bar. Above all, to protect our patients. It’s gaining real momentum.”