The Future of the Industry

By Andrew Rankin / 01 Aug 2014

Andrew Rankin gives an insight into the BACN’s role in the HEE Expert Reference Group

The BACN is privileged to be involved in the work of Health Education England (HEE) in reviewing education and qualifications within the medical aesthetics industry. We have, in the past several months, led the project’s phase 1 work on assessing the education and training requirements for delivering the treatment modalities of botulinum toxins and dermal fillers. This project will undoubtedly shape the future of the cosmetic medical industry and will have an impact on all those yet to be involved. Most of all, it will have an impact on the patient – the end user who forms the focus of our every objective. Transparency at every level, user involvement, informed consent, standards; these are but a few of the buzz words which signal the drive towards a new, cohesive, patient-centred industry. From the perspective of the BACN, work began as early as November 2013 when we presented our report (Medical aesthetics. An educational framework. A Review of the Industry for the purpose of regulation (2013)) to HEE. This 6,000-word report complemented the BACN competencies framework, and provided significant detail for nonexperts (i.e. HEE) in terms of outlining the industry. It described the various problems and concerns evident to those familiar with the industry, and made recommendations that would close loopholes and promote a secure future for the industry.
The Expert Reference Group (ERG), set up by Health Education England to advise and work with them to create a formal framework of education for the non-surgical cosmetic industry, is broad. Representatives include nurses, doctors, dentists, surgeons, pharmacists, beauty and industry spokespersons and experts from laser and hair transplant fields. Importantly, the table at which we sit is, metaphorically speaking, round. That is to say, all have an equal opportunity to present their perspective, and decisions made are a consensus reflecting the breadth and depth of the group. It is perhaps the first time the industry has been so unified and working in this way is hugely rewarding. This unified approach is important on several levels. We are able to more readily agree on (and therefore influence) the issues where there is such strength of feeling.

Training Framework

Hair Restoration Surgery

Chemical peels and skin rejuvenation

Botulinum toxin

Dermal fillers

Lasers, IPL & LED treatments


Module(s)
Module(s)
Module(s)
Module(s)
Module(s)

LEVEL 8
PRO level

Module(s)
Module(s)
Module(s)
Module(s)
Module(s)

LEVEL 7
Masters Degree level

Module(s)
Module(s)
Module(s)
Module(s)
Module(s)

LEVEL 6
Ba/Bsc Degree level

Module(s)
Module(s)
Module(s)
Module(s)
Module(s)

LEVEL 5
Foundation Degree level

Modality specific
Modality specific
Modality specific
Modality specific
Modality specific

LEVEL 4
(Year 1 Foundation Degree Level)

Foundation qualification - Core knowledge, skills, competencies

Entry requirement to be determined
Various access courses available which are likely to meet education provider requirements


Phase 1

The remit of phase 1 has been to agree the framework of education which will lead to a formal qualification, and then to populate it with the relevant indicative content. The framework, set out in the table, describes a process for medics and non-medics alike, enabling them to achieve minimum standards at various levels for specific treatment modalities. With regard to botulinum toxins and dermal fillers, Levels 4 and 5 represent theoretical knowledge only, developing to the point where at level 6, practical experience can begin. The principle of Accreditation of Prior Experiential Learning (APEL) is key and it is anticipated that as nurses, we can demonstrate many of the prerequisites required for levels 4 and 5. During phase 1 the Department of Health (DoH) have also signalled their intent to support this work with legislation. The form this will take will not involve a prescription status for dermal fillers, as anticipated. Instead, legislation is aimed at a requirement for all dermal filler treatments (in the first instance, and other treatments later) to require a face to face consultation with a (statutory) regulated (e.g. NMC, GMC) practitioner who holds the above qualification. They would then be able to delegate treatment administration to any practitioner who also holds the appropriate qualification. Further work is still required on what this will mean in practice and any ‘supervision’ requirements.

Phase 2

Following our report to HEE, the BACN sought to agree the principles it contained with the British College of Aesthetic Medicine and the British Association of Dermatologists, thereby setting the foundation for the close working relationship we currently enjoy. As mentioned above, supervision will be one of a number of factors to consider during this second phase. Who can supervise – doctors, dentists and nurses only, or are there others? What does supervision entail? Will it be open to abuse? These have to remain questions at the moment, rather than answers, but it is important to consider the factors involved in reaching an eventual decision. As part of our initial recommendation for HEE, BACN defined supervision as the following:

  • Under supervision
    Under supervision means to work within the same legal entity as the supervisor, that the supervisor is in-house at the time of treatment, able to assist where required and respond to emergency situations.
  • Independent practice
    Holistic management of a patient’s assessment, treatment and intervention in complication and emergency - without immediate recourse to peers or superiors. These definitions should give a flavour of what we wish to achieve. Further, the ERG will make recommendations to close loopholes where we see a potential for abuse of the system. From experience so far, it is fair to say that Expert Reference Group recommendations are given the merit they deserve by HEE and the Department of Health.

Regulation

The DoH has been actively considering options for governance within the industry. The prospect of a voluntary register is a real one, as is an overarching “competent authority” to provide industry oversight. The BACN has made recommendations to HEE and the DoH, suggesting the format that a new industry structure might take. Such potential change affects everyone. However, the fact that we have been able to work so closely with our medical colleagues to agree on this direction is testament to a developing, cohesive industry, as described earlier. The BACN have also been advising a new organisation — Save Face – of the requirements of a voluntary register. They are committed to providing both a voluntary register, and significantly adding value to patients and members alike. We have described to them what such a register should look like, providing them with the insight necessary to achieve these patient-centred aims. Finally, the position of nurse prescribers holding prescription medicines as stock will need to be addressed as the project moves forward. Of the developments, HEE performance and delivery manager Carol Jollie, said, “It is clear that there is genuine and unanimous stakeholder desire for greater consistency in training standards to contribute to improved patient/user safety in the non-surgical cosmetics industry. HEE will shortly be publishing its report on phase 1 of its project reviewing the qualifications required for non-surgical cosmetic interventions, and we look forward to continuing to lead this important and challenging programme.”
Phase 2, due to be completed in April 2015, will provide more answers, and result in a picture of the industry emerging with greater clarity. Contrary to various criticisms, concerns and uninformed opinions, I am confident the medical nature of our industry will not be compromised. To my mind, the future is bright. It may not be faultless, but nevertheless a single, unified industry, based on a formal qualification and designed around both the patient and the principle of professional, statutory responsibility is a significant stride in the right direction. Importantly, the voluntary professional bodies have demonstrated that they can work together to achieve a common objective. A process of continuous improvement is feasible, and should go a long way towards securing the future of the industry.

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