The General Medical Council (GMC) has provided advice to the Joint Council for Cosmetic Practitioners (JCCP) on returning to work post-COVID-19.
The GMC considered how it would respond to any doctors considering reopening cosmetic clinics based on existing provisions within their guidance.
Regulations currently allow an exemption to closing for dental services, opticians, audiology services, chiropody, chiropractors, osteopaths and other medical or health services, including services relating to mental health. The GMC noted that regulations in Scotland, Wales and Northern Ireland include an identical provision.
The GMC said, “We expect doctors to use their professional judgment when interpreting what is meant by ‘other medical or health services’, and whether there is a genuine medical or health need for treatment which would permit their business to reopen. The standards we set continue to apply during the pandemic and we expect all doctors to act responsibly and reasonably in response to the circumstances they face.”
In Good Medical Practice guidance, the GMC sets out key ‘duties of a doctor’ and highlight the expectation that doctors will make the care of their patients their first concern and protect and promote the health of patients and the public. They say these duties are particularly important considerations when deciding whether to reopen aesthetic clinics during the lockdown.
The GMC also stressed the importance of patient safety, telling the JCCP, “As the primary objective of cosmetic treatment is not medical, it may be considered non-essential treatment. Given the continued progress of the pandemic in the UK, ensuring a safe environment in which to practice, with adequate infection control procedures in place is essential. Should a clinic wish to reopen, doctors need to be confident that they have assessed all risks and can operate safely in accordance with the PHE guidance on social distancing.”
The regulator added, “We know that many doctors have adapted their practice to include remote consultations in an attempt to minimise the spread of COVID-19. However our cosmetic guidance sets an expectation that doctors must carry out a physical examination of patients before prescribing any injectable cosmetic medicine and therefore must not prescribe these medicines by telephone, video-link, online or at the request of others for patients they have not examined.” The statement also stressed that doctors must have appropriate indemnity and should check with their insurance providers.
Executive chair of the JCCP, Professor David Sines, confirmed that the JCCP supports the GMC’s advice. “We would add that it is important for practitioners to understand that cosmetic procedures being performed by healthcare professionals are not automatically designated as being either ‘medical’ or ‘medically-related’ in nature; in fact, many such procedures fall out with this definition. Rather, there must be a clearly defined, discernible and intended ‘medical’ benefit for the patient.”
He added, “The JCCP is of the opinion that if the practitioner is able to determine that they have applied a full diagnostic physical and psychological/emotional assessment of the patient’s presenting condition (and if they are of the opinion that both they and the patient consider that the treatment is actually urgent) and can justify that the provision of the proposed treatment would assist the patient to prevent and/or reduce the physical, psychological and psychosocial symptoms and effects associated with that condition, then the JCCP is of the opinion that the practitioner could justify that the treatment is ‘medically related’.”
Professor Sines stated that the final decision on whether to proceed to provide an aesthetic service at this time of lockdown must be made by the practitioner themselves. He said, “They should be informed by the exercise of their clinical judgement following the provision of a clinical risk assessment, whilst mitigating the conflicts of interest between commercial and ethical practice and having thoroughly reviewed the advice provided by Government in its authorised statements. Healthcare professionals must also follow the advice provided by their professional statutory regulatory body.”