In response to the increasing number of clinicians offering cosmetic interventions, the General Medical Council has released guidance ("the Guidance") which comes into force on 1 June 2016. The GMC acknowledge that cosmetic interventions are now very widely available and the Guidance has been drafted to respond to concerns about "patient safety and whether the sector operates in an ethical manner" which were identified by the Keogh Review in 2013. We set out a summary of the key points from the Guidance below.
Background – the Keogh Review
Concerns had been raised that the availability and prevalence of cosmetic treatments were rapidly increasing and the regulatory framework that was in place was no longer fit for purpose. The number of unregistered providers and the PIP scandal had also raised concerns about public safety and redress for when things go wrong. Sir Bruce Keogh chaired a review into cosmetic interventions in the UK and made a number of recommendations to safeguard the public and increase regulation of the sector. The Guidance has been introduced as a direct result of the Keogh Report's recommendations.
Definition of Cosmetic Interventions
The Guidance defines cosmetic intervention as "any intervention, procedure or treatment carried out with the primary objective of changing an aspect of a patient's physical appearance. This includes surgical and non-surgical procedures, both invasive and non-invasive". The Guidance is therefore drafted in very broad terms and is likely to cover the entire range of cosmetic treatments on offer ranging from breast augmentation to Botox.
The Guidance is underpinned by a number of key points which must be considered by those offering cosmetic intervention: The Guidance requires a Doctor to:
- seek your patient’s consent to the procedure yourself rather than delegate;
- make sure patients are given enough time and information before they decide whether to have an intervention;
- consider your patients’ psychological needs and whether referral to another experienced professional colleague is appropriate;
- recognise and work within the limits of your competence, seeking advice when necessary;
- make sure patients have the information they want or need, including written information that supports continuity of care and includes relevant information about the medicines or devices used;
- take particular care when considering requests for interventions on children and young people;
- market your services responsibly, without making unjustifiable claims about interventions, trivialising the risks involved, or using promotional tactics that might encourage people to make ill-considered decisions.
The Guidance goes on to develop each of the key points and provide further recommendations to those working in this sector. It is of particular interest that the Guidance goes into some detail in relation to the consenting of patients and ensuring that they are fully aware of the risks and benefits of a procedure. Any advertising of services must be clear, factual, and not use promotional tactics, such as ‘two-for-one’ offers to encourage patients.
The Guidance also requires the psychological needs of patients to be considered very carefully before proceeding. The Keogh Report identified the increasing pressure on young individuals and that "cultural changes have placed much greater emphasis on physical perfection". In response, the Guidance requires doctors to consider the vulnerabilities and psychological needs of their patients and must be satisfied that the treatment is voluntary before proceeding, and it is recommended that GPs are informed as to the proposed treatments.
All clinicians working in the cosmetic sector should review this Guidance before it comes into force on 1 June 2016 to ensure their practice is fully compliant.