Ahead of her talk at Aesthetic Medicine North this month, Tracey Jones asks, is registration with the Care Quality Commission right for your business?

Ahead of her CQC Workshop at Aesthetic Medicine North on Saturday June 29, Tracey Jones asks, should your business be CQC registered?

The discussion around regulation and governance in the area of aesthetic medicine has never been more debated. Medical practitioners in the United Kingdom are strongly arguing the need for more stringent governance, particularly when it comes to non-medical practitioners carrying out procedures that have the potential for risk.

Indeed, the debate has led many to question whether all procedures which carry a risk should be under the jurisdiction of the Care Quality Commission (CQC). However, identifying when these procedures cross the boundary, from cosmetic in the name of beauty to something that requires diagnosis and treatment, needs further clarity. 

This article aims to explore the question of regulation and the world of aesthetics to offer some transparency for those who are unsure of their position. 

The CQC was established in 2009 to regulate and inspect health and social care services in England. However it is only recently that a large proportion of the aesthetic world has focused its attention on the values and power of the CQC. Those working in the National Health Service are well versed in the bearing of a negative CQC inspection; however practitioners in the area of independent aesthetics have yet to experience the impact of this. 

Many businesses offering aesthetic procedures are managed by non-medical staff, with no previous exposure to the CQC or familiarity with its directive. But these clinics have visiting doctors and nurses carrying out regulated activities who are accountable for the care they provide. 

Since launching Inspire to Outstand Ltd, we have been overwhelmed by the number of questions put forward to us. There seems to be real confusion and misunderstanding around the topic of CQC registration and aesthetic practice, with practitioners unsure whether they should register with the CQC and uncertain if the procedure they are offering is a regulated activity. In the Cambridge English Dictionary, the term ‘regulation’ is defined as, ‘an official rule or the act of controlling something’.¹ However, in healthcare, practitioners often refer to regulation as the assurance that they are doing things correctly. 

Regulation must be separated from accreditation or reward; it is the law, and for practitioners registered with a governing body, such as as the Nursing & Midwifery Council (NMC), the General Dental Council (GDC) or the General Medical Council (GMC), there are penalties if they are found acting outside the realm of governance. In 2016, Sally Taber and Cheryl Barton wrote in the Journal of Aesthetic Nursing that there was a paucity of any enforcement action and even some who were ignoring the rules.² However, since this statement, the arena of regulation and aesthetic medicine has changed dramatically, with the list of activities regulated by the CQC ever increasing. 

The CQC describes cosmetic surgery as a range of procedures that involve what is deemed as an intervention that requires specific medical knowledge; these include any procedures where instruments or equipment are inserted into the body. A clear list of surgery types and further information can be found on the CQC website. However, confusion continues to prevail around the blurring of when a procedure moves from cosmetic in its nature to diagnosis 

and treatment. The information provided by the CQC can be difficult to navigate and many are often left with questions unanswered. At Inspire to Outstand Ltd, we offer a service to support businesses and practitioners through the CQC regulatory process. This service is not only offered to medical practitioners but also to those managing businesses where aesthetic procedures are delivered by medical professionals with practicing privileges. One procedure that is dominating discussion is PDO (Polydioxanone) thread lifting. This is a procedure which is increasing in popularity and was a key source of income generation for many aesthetic businesses throughout the United Kingdom. The changes in CQC regulation in England in 2019 has made this a regulated activity, requiring the clinic offering this procedure to be registered with the CQC. Treatments of skin condition that fall under the realms of disease, disorder or injury, such as rosacea, require regulation. Many practitioners are offering diagnosis and management of such conditions without recognising that this is a regulated activity.

There is no doubt that the number of patients undergoing appearance modifying procedures is intensifying, with the world of aesthetics being one of the highest income generating businesses of today. For some, the cosmetic procedure is elective, while for others it is untaken due to an underlying medical condition and this is when there appears to be confusion. Ambiguities have emerged that can exploit patients and jeopardise safety. The CQC can prosecute for a breach of regulation, therefore it is imperative that aesthetic practitioners seek clarity around the procedures they are offering and are directed when submitting their statement of purpose. One consideration that is clearly stated on 

the CQC website relates to the legal system and aesthetic practice. If a clinic is not registered with the CQC and is offering regulated procedures, it may be practicing illegally and its insurance may not cover the clinic or the patient if anything goes wrong. The team at Inspire to Outstand Ltd is offering free information workshops and one will be held at Aesthetic Medicine North in June. The aim of these workshops is to share information and formulate a bank of key questions posed by attending practitioners to be shared at a later date. Many are embarking on the CQC registration process with little or no understanding of the requirements or prerequisite evidence. Services like the one offered by Inspire to Outstand Ltd aim to reduce the uncertainty of regulation by supporting the practitioner or manager through the process. 

Finally, the area of regulation in the evolving arena of aesthetic medicine is one that requires further debate and clarity. There may never come a point of unanimous consensus around the area of regulation, accreditation or professional qualification. Clinicians practicing regulated procedures at this point in time are advised to seek further information if they are unclear. The risk of professional investigation and the appeal of lack of awareness or ignorance is no penitence for the law or the governing body with whom the practitioner is registered. 

Tracey Jones is a registered nurse and co-director of Inspire to Outstand Ltd, a company she and her business partner launched this year. Tracey’s career has been in senior nurse management and she has supported many organisations through the CQC process. She is also a senior lecturer and published author. 

 

Ahead of her CQC Workshop at Aesthetic Medicine North on Saturday June 29, Tracey Jones asks, should your business be CQC registered?

The discussion around regulation and governance in the area of aesthetic medicine has never been more debated. Medical practitioners in the United Kingdom are strongly arguing the need for more stringent governance, particularly when it comes to non-medical practitioners carrying out procedures that have the potential for risk.

Indeed, the debate has led many to question whether all procedures which carry a risk should be under the jurisdiction of the Care Quality Commission (CQC). However, identifying when these procedures cross the boundary, from cosmetic in the name of beauty to something that requires diagnosis and treatment, needs further clarity. 

This article aims to explore the question of regulation and the world of aesthetics to offer some transparency for those who are unsure of their position. 

The CQC was established in 2009 to regulate and inspect health and social care services in England. However it is only recently that a large proportion of the aesthetic world has focused its attention on the values and power of the CQC. Those working in the National Health Service are well versed in the bearing of a negative CQC inspection; however practitioners in the area of independent aesthetics have yet to experience the impact of this. 

Many businesses offering aesthetic procedures are managed by non-medical staff, with no previous exposure to the CQC or familiarity with its directive. But these clinics have visiting doctors and nurses carrying out regulated activities who are accountable for the care they provide. 

Since launching Inspire to Outstand Ltd, we have been overwhelmed by the number of questions put forward to us. There seems to be real confusion and misunderstanding around the topic of CQC registration and aesthetic practice, with practitioners unsure whether they should register with the CQC and uncertain if the procedure they are offering is a regulated activity. In the Cambridge English Dictionary, the term ‘regulation’ is defined as, ‘an official rule or the act of controlling something’.¹ However, in healthcare, practitioners often refer to regulation as the assurance that they are doing things correctly. 

Regulation must be separated from accreditation or reward; it is the law, and for practitioners registered with a governing body, such as as the Nursing & Midwifery Council (NMC), the General Dental Council (GDC) or the General Medical Council (GMC), there are penalties if they are found acting outside the realm of governance. In 2016, Sally Taber and Cheryl Barton wrote in the Journal of Aesthetic Nursing that there was a paucity of any enforcement action and even some who were ignoring the rules.² However, since this statement, the arena of regulation and aesthetic medicine has changed dramatically, with the list of activities regulated by the CQC ever increasing. 

The CQC describes cosmetic surgery as a range of procedures that involve what is deemed as an intervention that requires specific medical knowledge; these include any procedures where instruments or equipment are inserted into the body. A clear list of surgery types and further information can be found on the CQC website. However, confusion continues to prevail around the blurring of when a procedure moves from cosmetic in its nature to diagnosis 

and treatment. The information provided by the CQC can be difficult to navigate and many are often left with questions unanswered. At Inspire to Outstand Ltd, we offer a service to support businesses and practitioners through the CQC regulatory process. This service is not only offered to medical practitioners but also to those managing businesses where aesthetic procedures are delivered by medical professionals with practicing privileges. One procedure that is dominating discussion is PDO (Polydioxanone) thread lifting. This is a procedure which is increasing in popularity and was a key source of income generation for many aesthetic businesses throughout the United Kingdom. The changes in CQC regulation in England in 2019 has made this a regulated activity, requiring the clinic offering this procedure to be registered with the CQC. Treatments of skin condition that fall under the realms of disease, disorder or injury, such as rosacea, require regulation. Many practitioners are offering diagnosis and management of such conditions without recognising that this is a regulated activity.

There is no doubt that the number of patients undergoing appearance modifying procedures is intensifying, with the world of aesthetics being one of the highest income generating businesses of today. For some, the cosmetic procedure is elective, while for others it is untaken due to an underlying medical condition and this is when there appears to be confusion. Ambiguities have emerged that can exploit patients and jeopardise safety. The CQC can prosecute for a breach of regulation, therefore it is imperative that aesthetic practitioners seek clarity around the procedures they are offering and are directed when submitting their statement of purpose. One consideration that is clearly stated on 

the CQC website relates to the legal system and aesthetic practice. If a clinic is not registered with the CQC and is offering regulated procedures, it may be practicing illegally and its insurance may not cover the clinic or the patient if anything goes wrong. The team at Inspire to Outstand Ltd is offering free information workshops and one will be held at Aesthetic Medicine North in June. The aim of these workshops is to share information and formulate a bank of key questions posed by attending practitioners to be shared at a later date. Many are embarking on the CQC registration process with little or no understanding of the requirements or prerequisite evidence. Services like the one offered by Inspire to Outstand Ltd aim to reduce the uncertainty of regulation by supporting the practitioner or manager through the process. 

Finally, the area of regulation in the evolving arena of aesthetic medicine is one that requires further debate and clarity. There may never come a point of unanimous consensus around the area of regulation, accreditation or professional qualification. Clinicians practicing regulated procedures at this point in time are advised to seek further information if they are unclear. The risk of professional investigation and the appeal of lack of awareness or ignorance is no penitence for the law or the governing body with whom the practitioner is registered. 

Tracey Jones is a registered nurse and co-director of Inspire to Outstand Ltd, a company she and her business partner launched this year. Tracey’s career has been in senior nurse management and she has supported many organisations through the CQC process. She is also a senior lecturer and published author.