THIS STORY WAS UPDATED ON 16/12/22. The regulator for independent healthcare services in Scotland, Healthcare Improvement Scotland (HIS), has announced that non-prescribing medical aesthetic practitioners can no longer perform dermal filler injections without a prescriber present on-site.
The announcement, which appeared to be released with no warning, has caused upset for many non-prescribing aesthetic nurses in Scotland as it will change how they are able to operate their businesses.
In an informational release emailed to all HIS registrants working in aesthetics on December 6, the HIS states it has made this decision following increased applications for new aesthetic clinics by people with limited healthcare experience an increase in training providers accepting non-medic applicants and an increase in remote prescribing of prescription-only medications.
Originally, this change was to be implemented with immediate effect, but HIS has now announced that the decision is being reviewed, and non-prescribing practitioners can continue to inject for the time being as long as they can prove they have plans in place to implement prescribing into their practice. A timescale for this has not be disclosed.
Whilst this step is designed to protect patient safety, many non-prescribing nurses who currently practise in premises without a prescriber now feel their business will be limited, or even blockaded altogether, by the changes.
In an official statement, an HIS spokesperson said, “It is vital that the people of Scotland who opt to use private healthcare services receive the best quality and standard of care, and that they can be assured that procedures are carried out in safe and regulated environments. For these reasons, registered clinics are required to demonstrate that they take the safety of their clients seriously, that they operate to the highest standards and are committed to continually improving the service they provide for clients.
“Recently we decided it was necessary to clarify the definition of ‘suitably qualified’ and ‘competent’ healthcare professionals. This was due to an increase in applications for registration from newly-qualified healthcare professionals, where healthcare experience is very limited, and a recent increase in service providers offering training to healthcare and non-healthcare professionals in non-surgical aesthetic treatments and procedures. We engaged with a number of stakeholders while we were writing the guidance including the British College of Aesthetic Medicine and British Association of Aesthetic Nurse, as well as the Scottish Independent Healthcare Providers Network.
“We understand that in some situations services may require time to implement the updated guidance on meeting requirements in relation to ‘suitably qualified’ and ‘competent’ healthcare professionals. Therefore, for existing services regulated by us, we would expect to see plans in place to for how they will implement this guidance in a timely way that mitigates potential risks to service users. Any providers that lodge a new application to register will be asked to show that they have adequate numbers of skilled and competent staff as a part of the registration process.”
Aesthetic nurse prescriber and founder of the HIS Support Group Jill Smith has commented, “I am shocked and saddened for my friends and colleagues whom this regulation will affect. Livelihoods are at stake, and an immediate action to stop injecting dermal fillers if you don’t have a prescriber ‘onsite’ is unacceptable. Medically qualified injectors all have to provide evidence of prescribing management in any event and is part of their registration policies already approved.”
Aesthetic nurse prescriber Frances Turner Traill, who practises in Scotland and is an honorary board member of the British Association of Cosmetic Nurses, has said, “I think there are a few shock waves amongst some junior colleagues who aren’t yet prescribers, but the path to independent nurse prescribing is now a well-trodden one, and regulatory changes such as this have been discussed by the HIS for some time. I feel this is a positive move, and I hope HIS brings more medical personnel under their jurisdiction to tighten other loopholes.”
As beauty therapists and other non-medics are not required to register with HIS, they will not be affected by this development.
Aesthetics will be reporting further on this story in due course.
