JCCP and CPSA issue a statement outlining their position on remote prescribing
In line with several Professional Statutory Regulators (the General Medical Council and the General Dental Council and in accordance with guidance set down by the Royal Pharmaceutical Society) the JCCP and the CPSA have set down their decision not to endorse or permit the remote prescribing of any prescription medicine when used for specifically for non-surgical cosmetic treatments. In such circumstances when a prescriber delegates treatment to other practitioners, then the JCCP would remind the prescriber that the patient remains under the oversight of the prescriber, requiring that the prescriber must be familiar with the patient through an initial face to face consultation and diagnostic assessment of the patient’s suitability for treatment. This applies to the routine/planned 1 2 administration of medicines that are used specifically for cosmetic purposes, such as botulinum toxins, injected local anaesthetic or topical adrenaline, and the emergency use of medicines such as hyaluronidase.
Furthermore, the JCCP would advise that whenever a designated Prescriber prescribes medicines or treatments, they must exercise their professional and clinical judgement, have adequate knowledge of the patient’s physical and psychological health status and be satisfied the medication serves the person’s needs. This applies to all medicines used specifically for cosmetic purposes that are ‘Prescription Only Medicines’ (POM) whether they be injectable, topical or oral.
The JCCP does not therefore endorse or permit the use of remote prescribing of injectable, topical or oral prescription medication for non-surgical cosmetic treatments in any circumstances. Examples of this include the off-label use of adrenaline when applied topically, to enhance pain control and limit bleeding. The JCCP reminds all prescribers of the need to carry out a physical examination of patients before prescribing injectable prescription only cosmetic medicines. The JCCP advises that prescribers should not therefore prescribe such medicines by telephone, video link, online or at the request of others for patients whom they have not examined personally.
The JCCP recognises the important role that technology will play increasingly in the effective and efficient delivery of effective and productive prescribing and is cognisant of the need to ensure that the JCCP and the Professional Statutory Healthcare Regulators work together (wherever possible) to make sure that our approaches to regulation do not become barriers to innovation.
The JCCP has shared this statement with the General Medical Council and the General Dental Council who have both reviewed this Guidance Statement and advised that it is consistent with their own guidance. The Royal Pharmaceutical Society has also advised that ‘In our view as the professional body for pharmacy, the JCCP statement is consistent with the approach of the professional regulators and will be useful for the RPS to signpost to”. The General Pharmaceutical Council is currently concluding its consultation on the ‘Prescribing Guidance’ issued by the GPhC and have been apprised of the JCCP’s position in this matter.
The JCCP Statement on ‘Responsible Prescribing for Cosmetic Procedures’ can be viewed on the JCCP website.
Professor David Sines CBE – Executive Chair of the JCCP said,
“The JCCP recognises the important role that professional prescribers make to public protection and of the contribution that they make to the development and maintenance of a robust and effective patient safety culture in the aesthetic sector. The JCCP (and the CPSA) continue to strive to promote and develop standards and best practice across the whole of the non-surgical and hair restoration surgery sector and to promote and publicise the same to the public. The JCCP’s primary purpose is to raise public awareness and improve patient safety. The publication of our guidance on ‘Responsible Prescribing for Cosmetic Practitioners’ demonstrates our commitment to signposting and promoting safe and effective practice within the aesthetic sector. We commend the adoption and application of this Guidance Statement in accordance with our shared aim of protecting the public”.
The Honourable Alberto Costa (Member of Parliament - South Leicestershire) and Chair of the All Party Parliamentary Group on Beauty, Wellbeing and Aesthetics said:
“I very much welcome this step made by the JCCP, remote prescribing for non-surgical cosmetic procedures can be unsafe and harmful and should not be used under any circumstances. This is a great first step to further protect consumers who choose to undergo non-surgical cosmetic procedures. This will help to close the ‘loopholes’ that currently exist in which injectables, which are prescribed by health care professionals, can be remotely prescribed and delegated to anyone without first assuring that professional face-to-face patient assessment and clinical oversight is provided in all circumstances”.
