Keep Remote Prescribing for Aesthetic Procedures

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The Issue

It's essential that we safeguard access to remote video prescribing for aesthetic, non-surgical cosmetic, and healthcare treatments. This includes such elective treatments as Botox, Dermal Fillers (in case emergency products such as hyaluronidase or antibiotics are required), and medications for weight loss.

The Nursing and Midwifery Council (NMC) is proposing a requirement for nurse and midwife independent prescribers to have direct face-to-face contact with the person having an elective treatment before issuing a prescription. This action would significantly impact aesthetic practitioners and their clients, especially those in rural areas or with limited mobility.

Therefore, we are calling on the NMC, General Pharmaceutical Council (GPhC), Medicines and Healthcare products Regulatory Agency (MHRA), and the Department of Health and Social Care (DHSC) to preserve and protect safe access to remote video prescribing for such treatments.

Why are remote video prescriptions essential?

Clients deserve the freedom to choose their existing trusted aesthetic practitioner and maintain access to treatments through safe channels.

Complications with Botox are extremely rare and there have been no cases of botulism linked to cosmetic neurotoxin injections in the UK. In the case of dermal fillers (not prescription medicines), it's vital to have immediate access to reverse these products in case of complications. Delaying response time can cause a situation to escalate quickly, putting client safety at risk.

Without remote prescribing, the ability to provide fast, appropriate treatment for complications would likely result in unnecessary referrals to the NHS.

Members of the public in rural or underserved areas struggle to access face-to-face consultations due to geographical and transportation challenges. Trying to coordinate schedules between the aesthetic practitioner, prescriber, and client on the same day is a logistical nightmare.

Sometimes it requires driving long distances by the prescriber, whereas a simple video call would resolve the issue efficiently and save time and resources. Remote video prescribing provides a safe and secure way for clients to continue receiving aesthetic treatments, non-surgical cosmetic treatments, and medical treatments.

Weight loss treatments like Saxenda, Ozempic, and Wegovy are really important for many clients and are currently accessible through secure, regulated digital consultations. A ban or further restrictions on remote online prescribing for these treatments would force clients to turn to unsafe, unregulated sources, risking their health and well-being, especially when many fake medications are readily available online.

Current Context

Remote video prescribing is permitted under Section 214(2) of the Human Medicines Regulations 2012, which allows prescription-only medicines (POMs) to be administered under the supervision of a qualified prescriber without the need for their physical presence.

Doctors are able to diagnose clients over the phone and prescribe medication, so it stands to reason that prescribers should also be able to prescribe for elective treatments through video consultations. The same principles of client safety and oversight apply, with video providing even greater insight than a phone call.

During the COVID-19 pandemic, video consultations were widely accepted and used without issue. It seems contradictory that this method is now being questioned, despite its proven effectiveness during a global health crisis.

The accuracy of information provided by a potential client for treatment depends entirely on what the client discloses, whether the consultation is face-to-face or remote. Remote video prescribing does not affect the reliability of this information.

Face-to-face prescribing does not alter the administration of the treatment, as it is always the practitioner, not the prescriber, who administers it. The in-person interaction does not enhance safety; remote video consultations, when following proper guidelines, maintain the same level of client safety while offering greater efficiency.

Additionally, practitioners and prescribers typically do not have full access to clients' GP records, so the level of diligence in assessing suitability remains unchanged.

The NMC is currently facing scrutiny due to internal culture and management issues, with significant delays in case processing. These concerns should be addressed before considering any new restrictions on remote prescribing, which would only add further strain to an already overburdened system.

The Care Quality Commission (CQC) has faced severe criticism for its internal failings, including inspection delays and transparency issues. Given these concerns, introducing further restrictions without fixing these problems could endanger public safety in the aesthetic industry.

The Joint Council for Cosmetic Practitioners (JCCP) frequently advocates for the NMC to stop remote video prescribing.

It should be noted that while the JCCP is a charity and its guidelines are intended to prioritise public safety, their position may align with the interests of some medical companies, which could lead to restrictions that favour nurses and doctors, potentially reducing competition in the non-surgical cosmetic industry. This would, of course, result in a sharp rise in treatment prices, thereby limiting access to aesthetic treatments and non-surgical cosmetic treatments for many people.

Government Perspective

Health Secretary Wes Streeting has called for radical reform in the NHS and CQC to restore public confidence. Introducing restrictions on remote prescribing without first addressing these internal issues will exacerbate malpractice, compromise safety, and further burden the NHS.
Remote video prescribing aligns with the goals of NHS reform and the push for greater digital access, as outlined in the Health and Care Act 2022. The Electronic Prescription Service (EPS) already offers a safe, reliable, and regulated framework for remote prescribing, ensuring convenience and safety for both clients and practitioners alike.

Our Proposals

Rather than implementing restrictive new guidelines, we propose:

Strengthen the existing legal framework set out in Section 214(2) of the Human Medicines Regulations 2012 through regular audits and improved guidance for prescribers and practitioners.
Revise and improve the safety protocols for remote video prescribing, such as follow-up consultations, which will be more practical than mandating face-to-face consultations.
Ensure that all aesthetic practitioners, medics and non-medics, can continue working with prescribers to offer clients timely and safe treatments.
The aesthetics industry, predominantly led by women and non-medics, is a thriving sector that contributes significantly to the UK economy. Restricting remote prescribing risks undermining this industry, limiting treatment access, and driving up costs. Now is the time to make changes that will take us forward, not reverse and undermine the progress in women's empowerment in their work and providing for their lives and families.

Restrictions on remote prescribing will affect all parties involved—non-prescribing medic aesthetic practitioners and non-medics alike—but ultimately, client safety will suffer if restrictions are implemented.

Remote video prescribing is essential for safely providing elective treatments, and without it, the public may face significant risks, including the likelihood of turning to unsafe sources for treatments.

Support this petition to protect the accessibility and safety of care through remote video prescribing, online prescriptions, and the Electronic Prescription Service (EPS).

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Independent Aesthetic Practitioners RegisterPetition StarterWe protect independent practitioners, their livelihoods, and your freedom to choose who treats you. Please help us to stop unfair regulation of the UK Aesthetics Industry.

The Decision Makers

Nursing and Midwery Council

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