Pharmacists can practise in many areas of medicine. Independent prescribing pharmacists can autonomously assess patients and prescribe any medicines within their scope of practice. This practice is legal, insured and supported by their regulatory body – the General Pharmaceutical Council (GPhC).1 Pharmacist involvement in clinical care is widely accepted by medical colleagues in the NHS where they are considered safe, competent prescribers.
In the sector of aesthetic medicine, however, our ability is neither understood nor supported. Many of the reasons for not supporting pharmacists in aesthetics are not aligned with the current accepted scope of practice of pharmacists in modern healthcare systems.
Pharmacy training
At its core, pharmacy has always been a degree that combined a scientific aspect (drugs and formulation) with a significant clinical aspect. The qualification is a five-year undergraduate Master’s degree with a base focus on disease, which includes gross anatomy, clinical assessment, diagnosis and management of clinical conditions and monitoring of disease outcomes.2
To understand the application of drugs, one must understand clinical disease states, signs and symptoms, and thus how to assess drug efficacy and improvement of disease outcomes. Risk assessment of treatments and their applications fenestrate throughout. The degree also includes additional facets of training like consultation skills, risk assessment and critical appraisal of information. Pharmacists are trained to critically appraise all information and to work from an evidence-based standpoint, where it’s clinically applicable, and apply this to practice.2
There are also various postgraduate pathways a pharmacist can take, including hospital, general practice or community pharmacy. There is a significant opportunity to advance clinical skills in either general practice or more specialist areas, widening clinical autonomy which is not unlike our advanced nurse practitioner colleagues. In this sense, pharmacists can be found undertaking minor illness clinics in GP practices, specialist outpatient clinics, prescribing in an acute hospital setting or chronic disease management. These areas of practice include physical assessment and undertaking procedures in line with a pharmacist’s.
Until recently, many universities required the completion of a postgraduate diploma in clinical practice prior to applying for the prescribing course. In addition, pharmacists have a minimum of five years of undergraduate and two to five years of postgraduate clinical training (depending on UK location) on average prior to applying. Aside from the many postgraduate clinical courses a pharmacist can undertake, the Royal Pharmaceutical Society (RPS), our professional body, has a validated framework for advanced practising pharmacists. The ‘Advanced Pharmacy Framework’ (APF) allows professional credentialing.3,4
At the highest clinical level, pharmacists can work in advanced practice or as ‘consultant pharmacists’. The main remit of these roles is clinical practice and autonomy over patient care. The APF and professional credentialing is specialty specific, with pharmacists working as specialists in various areas of practice. These roles are approved by a higher education institute (a university) and must include a body of research, an NHS organisation with the pharmacist demonstrating a patient case load, the RPS with APF credentialling and Health Education England (HEE) agreed funding for the role. The ‘consultant pharmacist’ title cannot be awarded without approval from all four.3,4
Prescribing is the core of new pharmacy courses
There has been a notable change to pharmacists’ undergraduate training. By 2025, the Government has mandated that all pharmacists graduate as prescribers aligning in this sense with our doctor and dentist colleagues. A large body of work, under the direction of HEE and the GPhC, has been undertaken to vastly change our undergraduate courses to provide enhanced levels of clinical training, physical assessment and disease management skills, in addition to procedures in line with minor illness.1
Despite the fact prescribing was not a feature of the undergraduate course until recently, we polled our aesthetic network of 200 pharmacists, and 89% are prescribers, with 8% currently undertaking the course and 3% who have not yet. This is an incredibly positive statistic, and we urge any pharmacist considering aesthetics to ensure they are qualified prescribers.
What the pharmaceutical regulator says about aesthetic medicine
Pharmacists have the full support of the GPhC to work autonomously in aesthetics. Within the GPhC In Practice: Guidance for Pharmacists Prescribers there is a section dedicated to aesthetic medicine. Within this document it is stated:5
“A Pharmacist Independent Prescriber (PIP) is responsible for and accountable for the clinical assessment and management of people (with diagnosed or undiagnosedconditions), without needing to consult another prescriber.”
This formalises the GPhC’s stance regarding pharmacists in autonomous clinical practice, and that pharmacists can be struck off the register for malpractice within aesthetic medicine, much like the General Medical Council. Furthermore, the prescribing document also provides standards on delegation of administration in an aesthetic setting and is the only regulator that specifies this must be to a healthcare professional (and not a ‘lay injector’).
This aligns with the fact the GPhC is giving considered thought to the safety of the aesthetic sector and protecting its profession and the patient.1 GPhC also has memorandums of understanding with Save Face and the Joint Council for Cosmetic Practitioners (JCCP), and will be present during the discussions around the new licensing scheme.6,7,8
The stance of HEE
Following the 2013 Keogh report into patient safety in aesthetic medicine, HEE published a report aiming to standardise training for all practitioners involved in providing and delivering these services.9
The HEE report stated that pharmacist prescribers could operate within this specialty as ‘Level 7’ practitioners. Pharmacists were included in the list of those able to provide oversight; meaning they can supply, prescribe and administer cosmetic injectables and train others to do so. This practice is also supported by the MHRA, NHS, Save Face and the GPhC.7,10-12
Neither the HEE nor the Keogh report called for mandatory regulation of the industry, but instead recommended self-regulation and the principle of a ‘joint council’. Formally established in 2018, the JCCP aims to ‘enable practitioners delivering the aesthetic treatments set out in the CPSA Framework of Standards and Competences to be accredited’. Pharmacist prescribers are considered Level 7 practitioners in accordance with these standards.12-14
As the JCCP has memorandums of understanding with both the GPhC and the RPS in the UK, it was hoped that this would allow access to appropriate training for pharmacists in aesthetic medicine.6,14 However, this has not been universal, with many companies within aesthetic medicine continuing to exclude pharmacists from their training academies and professional resources.
When enquiring about the reasons as to why, the main feedback we received was that there is a common misconception that pharmacists don’t cover anatomy in training. We also had people noting that pharmacists are seen as the ‘unknown’ in medical aesthetics, and that the general assumption of what we do is based on what they see some pharmacists do in a community setting, which is not reflective of our training and our pathways.
In line with safe practice, companies should provide information and support to professionals who are able to prescribe and use their products. This is outlined in both the Association Of The British Pharmaceutical Industry (ABPI) code of conduct 2021 and the MHRA blue book.15,16
The ABPI code of conduct outlines the rules in relation to how pharmaceutical companies share information with patients and healthcare professionals. They refer to pharmacists within the definition of a healthcare professional which falls into the remit of information sharing.15 The MHRA blue book equally outlines pharmacists as within the scope of PQPS (person qualified to prescribe or supply medicines).16
Pharmacists can help progress medical aesthetics in the UK
Pharmacists, in addition to the clinical aspects of training, are educated in rheology, formulation, legalities including sale/supply and procurement of medicines and devices, parallel imports, unlicensed medicines, legalisation and many more legal aspects of drug-based care. The list is not exhaustive. This is an extremely useful knowledge base for a specialty like aesthetics.
In the wider scheme, aesthetic medicine has no mandatory regulated standards of education or practice. It can be difficult to navigate the legalities of products and to interpret information from organisations such as the MHRA without a fundamental understanding of medicines and device legislation. Pharmacists who work in this sector as practitioners can work with our surgical, medical, nursing and dental colleagues to support and advise, pushing safety agendas and educating on legal supply and compliance with MHRA rules.
By allowing pharmacists a ‘seat at the table’, they can strengthen the facts when challenging Government diktat around aesthetics and work together for a united safety agenda.
The future of pharmacists within aesthetic medicine
Pharmacists are currently excluded from some training pathways within the ‘cosmetic arms’ of pharmaceutical companies, and we thank those who have embraced our profession thus far. Many independent training companies also deny us access to their training, and we understand this is entirely their prerogative and in line with what they feel comfortable with.
We hope that this article gives some information and assurance to those companies/independent trainers, as well as colleagues within the industry, regarding the clinical training and level of responsibility a pharmacist has, in addition to the fact that we have full regulator support.
We believe that cohesive collaboration, working interprofessionally is the best way to drive change and make the sector safer.
