JCCP issues end of year policy statement

The JCCP has released a policy statement outlining some of the changes to take place to the register as well as plans for 2019. The statement came following a meeting of its Board of Trustees to discuss a number of significant issues following the announcement by the Professional Standards Authority (PSA) that it had accepted a number of changes proposed by the JCCP to its Practitioner Register. These changes were proposed by the JCCP and agreed by the PSA following a major ‘listening’ exercise by the JCCP to many key stakeholders. 

The status of practitioners and the right to practise in the non-surgical and hair restoration surgery sector is a subject that is both emotive and in many cases is often misrepresented across the sector and on media channels. The reality is that at the present time in the UK there are no restrictions placed on those who can practise in these areas (with the exception of hair restoration surgery which is a restricted practice to GMC Registrants only). The JCCP has consistently campaigned and requested that the Government should introduce statutory regulation of the most ‘at risk’ treatments and seek these to be restricted to appropriately trained practitioners. 

At its November Trustee Board meeting the Council reiterated its current policy to restrict entry to its Practitioner Register for Level 7 Injectable Toxins and Fillers only to appropriately trained health care practitioners (as defined on the JCCP web site) who hold up to date registration with their Professional Statutory Regulatory Body (PSRB). It should be noted however that other treatments are included in the JCCP Competency Framework (which now replaces the HEE framework) for which non-healthcare practitioners are able to register as members of the JCCP Practitioner Register (e.g. lasers and light, skin rejuvenation etc.). 

The JCCP also submitted a request to the PSA to enable PSRB health care professional Registrants with at least three years’ experience of working in the modality for which they were seeking registration with the JCCP, to be admitted to the JCCP Practitioner Register as ‘Full Registrants’, even if they do not possess a ‘full’ JCCP Approved Qualification in their post-graduate area of aesthetic practice at the initial point of registration with the Council. In response to this request the PSA have now agreed that professional health care Registrants who are registered under this category (but who have not yet been assessed by the JCCP as having met the Council’s full educational qualification standards for aesthetic practice) can be admitted as full registrants on ‘Part A’ of the JCCP Practitioner Register (‘Category Two’) for a two-year time limited period only. Such Registrants who are registered under this category will have satisfied the JCCP that they are safe to practise as confirmed by their current registration with their relevant professional 

statutory regulatory body (e.g. the General Medical Council; The General Dental Council; The Nursing and Midwifery Council; The Health Care Professions Council and the General Pharmaceutical Council). In addition to meeting the requirements set down by the JCCP to join the Register, registered health care professionals are required also to meet the strict requirements of their professional governing bodies to confirm that their practice is up to date on an annual basis. This provides members of the public with additional assurance that registered health care professionals are considered to be safe and competent to practise and are held accountable for their practice by their professional regulator e.g. the GMC etc. 

This condition applies only to Registrants on ‘Part A’ of the JCCP Register who have confirmed that they are currently registered with one of the healthcare Professional Statutory Regulatory Bodies defined above (and are therefore considered to have meet the conditions set down for entry and continuing practice and with that profession). Such practitioners must also confirm that they have been practising in their declared area of practice and at the appropriate level of practice for a minimum of three years and have provided sufficient self-declared evidence that they meet the JCCP’s standards and competence requirements to be considered by the JCCP to be safe to practice in each, or all of the procedures/levels for which they are seeking registration. 

All Category Two Registrants will be required to demonstrate that they meet all of the JCCP Educational Qualification requirements within a two year period following their initial registration with the Council, after which time those persons who met such standards/competencies will be transferred to Category One status as ‘Fully Registered’. Those Registrants who are unable to demonstrate that they meet the JCCP’s Educational Standards/Competencies within this timescale will be removed from the Register. The ‘Part A’ ‘Category Two’ part of the JCCP Practitioner Register will operate from the 7th January, 2019 – the 31st January, 2020 only. 

The JCCP has also received a significantly high level of interest in its Education and Training Provider Register and has issued approvals for the first three entrants. A number of other Education and Training Providers are now working through the application process with the aim of being entered onto the JCCP Register of Approved Education and Training Organisations. Approval will only be offered following a rigorous assessment exercise that relates to the JCCP’s published ‘Education Standards’ and ‘Education Competence Framework’ (September, 2018). There has also been encouraging interest from a range of Ofqual and SQA approved ‘Awarding Organizations’ who are seeking to develop and offer new qualifications in aesthetics and who wish to sign Memoranda of Understanding with the JCCP. The JCCP Trustee Board regards the new Register of Approved Education and Training Organizations to represent a major step in reducing the alarming number of bogus training companies that offer unregulated and non-approved qualifications and training programmes. 

• This month the JCCP is also signed Memoranda of Understanding with the Nursing and Midwifery Council (NMC); the General Dental Council (GDC); the General Pharmaceutical Council (GPhC); the Royal Pharmaceutical Society (RPS) and with the Scottish Qualifications Authority (SQA), to add to its existing agreements with the General Medical Council (GMC), Ofqual (the vocational qualifications regulator in England) and the Advertising Standards Authority (ASA). 
• The JCCP now works closely with each of these bodies and is receiving regular notification of complaints about practitioners and education and training providers – all of which are reviewed and passed on to the relevant Body for consideration. Our agreements also include joint working on the development of enhanced public protection processes and qualifications as well as the identification and dissemination of best practice. 
• The JCCP is also engaged with other regulators and public sector interest groups in order to identify more effective ways to enable the sector to improve practitioner, education and product regulation with the overarching aim of reducing threats to public safety. Examples include the role of local authorities and in particular that of ‘Environmental Health Officers’ who inspect and license many premises. The JCCP is also working with the Scottish Government where major advances have been made on regulation. Active liaison has also commenced with the CQC. 
• The JCCP has also written to the newly appointed Parliamentary Under Secretary of State for Health and Social Care (who also has responsibility for Cosmetic Regulation), Jackie Doyle-Price, outlining the JCCP’s activities and affirming the JCCP’s commitment to patient safety and public protection. The JCCP looks forward to participating in a ‘roundtable’ discussion with key stakeholders and the Minister later this month with regard to regulatory issues. 
• The JCCP has been in a continual process of development since its initiation in January 2015, following the publication of the HEE report. There is no reason to doubt that this developmental process will continue as the sector adjusts to rapid change, new forms of regulation and growing awareness amongst the public of the risks involved in some treatments. 
• The JCCP is making a call to all interested groups and stakeholders to ‘get behind’ a coordinated campaign to raise public awareness of the risks involved in some aesthetic treatments and the need to only go to registered and appropriately trained practitioners where redress can be found if things go wrong. The JCCP will be making a number of announcements in early 2019 on its ‘Public Awareness Campaign’ and invites any interested parties to contact us should you wish to be involved. 

Professor David Sines commented, "My final comment as the ‘Independent Executive Chair’ of the JCCP is that the time has come for all parts of the industry to unite behind a coordinated approach to encourage the Government to introduce statutory regulation for all practitioners who are ‘legally’ entitled to practise in the aesthetics industry in the interests of public protection.