Tackling CQC registration
The discussion related to aesthetic medicine and regulation has been awarded substantial focus in recent months, with more literature being published exploring the subject. Medical practitioners are contending the necessity for more rigorous governance, specifically over non-medical practitioners.
When we hear the word ‘regulation’ we often think of red tape, but in the context of healthcare would we be content without it? Interestingly, those working in the remit of aesthetic medicine are one of the only groups of medical professionals who still appear to believe that they have the choice whether to register or not. In no other field of medicine is this the case.
Regulation is simply a way to make sure that healthcare professionals are safe to practice and deliver safe care to the patients they treat. The ongoing appraisal system and checks ensure that those offering the services are of good character, have the relevant training and experience and most importantly have the correct skills to carry out the procedure. This not only assures the public but also provides the registered manager with a guarantee that the health practitioner remains safe to practice.
In the grey area
There is a wide diversity of education provision within the field of aesthetic medicine, with academies offering courses over varying time periods, ranging from hours to days. It is not only the time scales for learning that vary but the qualifications of the trainers, which are not always transparent. Practitioners make assumptions that there are standards in place about safety, efficacy, and integrity, however, this is not always the case. Having worked in the area of higher education for many years, it is of concern to see the volume of training available within the industry with little or no external monitoring.
Many of the concerns raised by MPs related to aesthetic medicine have included the lack of formal, recognised training for administering procedures such as dermal fillers and botulinum toxin and the types of products used. So, one should ask, is this where the regulation should ultimately start? Should those administering the education be held accountable for leading the way in regulation? There has been a recent increase in aesthetic academies applying for healthcare registration, which will require their governance and practice to be examined by an external agency.
Recently Dr Julia Sevi from Aesthetic Health published a piece about how to approach the registration process having gained an outstanding rating from the CQC. This article led the reader through some of the key areas where the regulator will expect firm governance and evidence. So why is it that many practitioners are still avoiding the landscape of regulation and burying their head in the sand?
A question of choice
During our time as regulation consultants we have spoken with many clinicians and clinic owners to promote our services and have been met with a wide range of responses. We would like to explore what is it that embodies registration with the healthcare regulator and what puts it at the top of some practitioner lists, while others to avoid and run? Dr Cormac Convery stated that regulation has become an instrument to solve a problem of a community seen to be, or which perceives itself to be, at risk. With the continual increase in media coverage of poor practice, this is indeed an industry at risk if regulation is not embraced.
Reasons for avoidance can be vast and are often linked to the cost and the lack of understanding about regulation surrounding some aesthetic treatments. It is without doubt that the process of registration is costly, both in terms of money and effort. However, it is imperative that those who plan to lead the way in the world of aesthetics focus not on the costs but on the gains. The recognition of being awarded registration with the healthcare regulator should be celebrated and shouted from the highest platform. Still websites are adorned with marketing detail which often does not include the one thing that the public will recognise – a CQC approval.
At the last CCR Expo meeting in London, Professor David Sines, chair of the board of trustees for the JCCP, gave a presentation where he discussed the need for further regulation of all those offering cosmetic procedures and services. This is not an appeal that is new to this industry and one which has been requested many times, specifically in the field of non-healthcare practitioners. Why is it that all areas of healthcare provision are covered by such regulation, yet a procedure one enters voluntarily for often a cosmetic purpose is not deemed to require such scrutiny?
When we launched Inspire to Outstand we had a dearth of experience within healthcare regulation, predominantly within acute services. When exploring not only the world of aesthetics but that of counselling, psychotherapy, physiotherapy and more, it became clear that much is happening without any external monitoring or governance. Rooms are being rented to an array of practitioners selling their wares without any form of monitoring or process. This lack of governance questions how practitioners assure themselves that practice is safe and responsive.
The increase in claims for financial recompense has increased the demand for many of these services provided from rooms let within aesthetic clinics. This was one of the areas that caused us some alarm in relation to who is accountable for the service provision from such rooms. When a clinic is registered with the healthcare regulator a manager or owner must become the registered manager. This role is one which comes with both responsibility and accountability. The person must provide evidence that they are a “fit and proper person”, one who can account for the service provision being provided within the regulated environment. When this is explained it can cause some to become sceptical about the process and sometimes reconsider if registration is right for their service. It is without doubt that the arena of healthcare regulation is under a process of immense change. There is a strong need for wider benchmarking and sharing of information. There is no national framework for the auditing of mistakes or reactions in aesthetic medicine which would not only lend to offer some learning but would be another safety mechanism to protect the public.
In a Westminster debate back in early 2019, MP Alberto Costa was quoted as saying that, “A voluntary and independent register does not go far enough.” He continued, “I would like to ask the Government to at least consider setting up a cohesive and compressive plan to properly regulate the non-surgical cosmetics industry.”
Any aesthetic business owner making their plan for the New Year should include preparing for changes to regulation and examine what they need to do to get their business governance ready. This is not something that can be done at a later date – it can be detrimental to the service you provide if you are found to be performing regulated activities when not registered with the healthcare regulator. There have been cases where clinic managers have been prosecuted by the regulators and reported to the governing body. Many risk their professional registration by continuing to offer regulated procedures knowing that they are flaunting the rules.
We are mindful that registering with the healthcare regulator is a complicated and lengthy process but, when completed in small stages, the feeling of being overwhelmed with policies and processes can be avoided. Start to consider what would be your expectation if you were still working for the NHS. The healthcare regulator aligns much of the inspection process around what follows within a hospital inspection. Consider your mandatory training –this continues to be a requirement and demonstrates clear governance and process that align to safe practice. Above all, question what being registered will offer your patients. This is not only about a process or tick-box exercise, but an opportunity to learn and improve.
References
1. Department of Health. Review of the Regulation of Cosmetic Interventions. [Accessed 12/12/15].
2. Scottish Cosmetic Interventions Expert Group Report July 2015. Options for regulation. [accessed 3/12/15].
3. Arie S. Cosmetic industry regulation is only skin deep. BMJ2017;358:j3047. doi:10.1136/bmj.j3047 pmid:28652383.Google Scholar
4. Westminister Hall, Non-surgical Cosmetic Procedures: Regulation, February 12 2019.
