In this exclusive coverage, Aesthetics explores a new framework for treating complications
A new governance framework has been launched to help eligible aesthetic practitioners access specified emergency medicines during time-critical complications. Called the Emergency Direction for Immediate Complication Treatment (EDICT), the pathway has been developed by complications group Aesthetics Complications Expert (ACE) Group World as a lawful mechanism for certain practitioners to obtain and administer emergency medicines in defined situations, without changing existing prescribing law.
The framework is intended for use in acute complications such as vascular occlusion, where treatment delays can have serious consequences. It aims to address a long-standing issue in aesthetics, particularly for nurses and other clinicians who may be trained to manage complications but are not legally permitted to hold emergency stock independently.
To explore what the framework means in practice, Aesthetics spoke to nurse prescriber and director of ACE Group World, Sharon King, as well as Sharon Bennett, nurse prescriber, former chair of the British Association of Medical Aesthetic Nurses (BAMAN) and lead of the Aesthetics Clinical Advisory Board.
The emergency medicines gap
According to King, EDICT will operate within existing medicines legislation and professional regulation, and incorporate prescribing oversight, Patient Specific Directions (PSDs), medicines governance, audit and accountability through a formal Service Level Agreement (SLA).
ACE Group World states that access to this emergency medicine framework is restricted to members whose professional regulators permit them to administer prescription-only medicines under a PSD. Practitioners whose regulatory framework does not allow PSD-based administration are not eligible to undertake this aspect of the SLA.
King says the pathway is intended to tackle what she sees as a major patient safety and governance gap affecting nurses and other healthcare practitioners who cannot legally hold stock. In her view, this gap exists because the Medicines Act 1968 and the Human Medicines Regulations 2012 have not kept pace with the increasingly autonomous role in modern clinical practice.¹˒²
Bennett adds that this has been a real and recognised tension for years. “A nurse could be fully competent but still be constrained by prescribing law rather than clinical ability. That gap has left nurses uncertain about liability, indemnity cover, and open to Nursing and Midwifery Council (NMC) scrutiny if they acted outside the current rules, even when acting in the patient’s best interest,” she says.
BAMAN had previously called for reform of the Human Medicines Regulations 2012, arguing that the inability for nurses to hold emergency stock undermines standards of care in emergencies and limits their ability to provide safe and effective treatment when it is needed most.³
King argues that while PSDs, Patient Group Directions and collaborative arrangements can support medicines use in planned care, they are often inadequate in emergencies because they depend on named patient authorisation and real-time prescriber access.
“While EDICT cannot change the Medicines Act or fix the wider problem immediately, it provides ACE Group World members with a lawful, governed mechanism to access and administer emergency medicines during genuine emergencies, addressing the most significant patient safety gap in current practice,” King says.
What EDICT changes in practice
The framework was developed to align with guidance from the Care Quality Commission (CQC) and the Medicines and Healthcare products Regulatory Agency (MHRA), alongside input from insurance provider Hamilton Fraser and aesthetic distributor ACRE. It is embedded within ACE Group World’s CQC-registered governance system, allowing practitioners to use the framework safely within their own clinical environments while ensuring emergency medicines are accessed and managed in line with medicines management requirements.
King notes, “Under the EDICT governance system, authorised prescribers complete the clinical assessment and generate the PSD electronically via the ACE Group World website or app. Both the prescriber and the practitioner must be signed up to the SLA. Prescribing members may issue PSDs whether treating their own patient or acting on behalf of a non-prescribing member, while non-prescribing members must obtain PSD authorisation from an ACE-approved prescriber or the ACE Group Clinical Helpline before any emergency medicine is administered.”
In an emergency such as vascular occlusion, eligible ACE Group members can invoke the EDICT pathway and access ACE Group-owned emergency medicines under ACE Group’s governance and indemnity to treat that specific complication. However, King is clear that if those medicines are used outside the defined emergency indications, for example elective dissolving, the practitioner would breach the framework, lose indemnity and potentially face regulatory consequences.
Bennett believes that EDICT will benefit both practitioners and patients. She continues, “For the practitioner, it will provide faster and lawful access to the right medicine at the point of need, with less dependence on reaching a prescriber mid-emergency, and a clearer governance trail, such as protocols, accountability and documentation if things go wrong and are later reviewed.”
Limits and future implications
King explains that EDICT does not create new prescribing rights or apply to routine practice, but instead sets out a governed route for emergency access to a limited number of medicines in specific circumstances. She emphasises that practitioners must continue to comply with the Human Medicines Regulations 2012, professional prescribing standards, scope of practice boundaries and all legal requirements governing the supply and administration of medicines.¹ “Fitness to practise expectations, duty of candour, documentation requirements and clinical governance obligations all remain the same. Practitioners remain fully accountable to their regulator,” she says.
Bennett notes that wider reform is still needed, including statutory regulation of the non-surgical aesthetics sector, which remains largely unregulated in the UK. “There needs to be consistency across different professional and membership bodies, rather than each operating its own model, and clearer national guidance from the NMC and MHRA so practitioners are not reliant on individual associations to fill a legislative gap,” she says.
Bennett concludes, “EDICT shows that patient safety and legal compliance don’t have to trade off against each other if the right clinical oversight is built in.”
References
- The Human Medicines Regulations 2012. SI 2012/1916. London: The Stationery Office.
- Medicines Act 1968. c.67. London: Her Majesty’s Stationery Office.
- British Association of Medical Aesthetic Nurses (BAMAN). BAMAN calls for urgent reform of Human Medicines Regulations 2012. Available at: https://www.baman.org/news/baman-calls-for-urgent-reform-of-human-medicines-regulations-2012 (Accessed: 31 July 2026).
- Care Quality Commission (CQC). GP mythbuster 19: Patient Group Directions (PGDs) / Patient Specific Directions (PSDs). Available at: https://www.cqc.org.uk/guidance-providers/gps/gp-mythbusters/gp-mythbuster-19-patient-group-directions-pgdspatient-specific-directions (Accessed: 31 July 2026).
- Specialist Pharmacy Service (SPS). Introduction to PGDs. Available at: https://www.sps.nhs.uk/articles/introduction-to-pgds/ (Accessed: 31 July 2026).