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Practicing Botox & Dermal Fillers: Am I required to register with the Care Quality Commission?

Question :

Hi Cosmetic Courses,
I’m not sure whether you can help with this?

I have been asked by someone I will be working for, giving Botox /dermal filler injections, whether I am
registered with the Healthcare Commission.

Apparently this is a Commission for places rather than people / things and I was wondering whether I had to register here or if there was a Loop-hole around it?

Many thanks for your advice.

Answer :

You are right that the Healthcare Commission monitor premises rather than individuals.

If your future employers are a Medical Practice then they should be registered with them.

As you may know, Mr Adrian Richards of Cosmetic Courses does regular podcasts on topics such as this with Ron Myers from the Consulting rooms.

Ron is extremely knowledgeable about topics such as this so we will ask Ron for his opinion on your query.

Ron what are your views on this?

Ron Myers:  “Care Quality Commission registration should only apply (currently) if you are offering cosmetic surgery procedures (you should be fine if you only offer laser/IPl & injectables).”

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Critics Slam New Crackdown on Cosmetic Surgeries

Surgeons across the UK are lining up to criticise a new government initiative, backed by medical regulators and the cosmetic industry, which seeks to clampdown on cosmetic surgeries such as Botox. The government is seeking to ensure that consumers have access to credible facilities to receive cosmetic procedures by listing clinics with qualified staff and appropriate facilities. Critics however have said that the measure does not do enough to stamp out “rogue” providers of cosmetic procedures.

Currently the Care Quality Commission, which oversees medical treatment in the UK, has no control over procedures like Botox injections. Roughly 5,000 facilities across the UK provide these cosmetic procedures to over 200,000 patients a year. As a result, the procedures can be provided in places like beauty salons where the staff have no formal training in medicine, dentistry, or nursing. If the procedures are wrongly-applied they can cause health problems and good hygiene is needed to reduce the risk of infection.

The new initiative seeks to provide qualified clinics and professionals with a “Quality Assurance Mark” that will be backed up by a timetable of regular inspections. The initiative would establish a list of clinics that have qualified staff and clean facilities for consumers to choose from to ensure they receive proper treatment.

Cosmetic injections are designed to reduce the appearance of wrinkles and the industry has experienced a 25% growth in the last year alone, making now the perfect time in the minds of many to tighten the regulation of the industry. Due to the growth of the industry, the government has recognised the need to regulate the procedures to safeguard patients. The programme has received an initial investment of 200,000 from the government to help launch the initiative.

Critics have slammed the new initiative though calling the plan an easy out for the government to wash its hands of industry regulation. A representative from Safer Cosmetic Surgery criticised the scheme stating that the only clinics likely to sign up for the programme are those that already meet the high safety requirements.

Supporters fired back though, believing that other measures contained within the initiative will serve to further prevent irresponsible providers from conducting cosmetic procedures. Supporters have said the “Quality Assurance Mark” will serve as an additional weapon for consumers against poor facilities and unqualified providers. The measure also seeks to make it harder for unqualified providers to get insurance coverage in hopes it will prevent places like nail bars and beauty salons from providing cosmetic injections.

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Quality Assurance Mark Guarantees Quality

Patients of injectable cosmetic treatments, such as wrinkle fillers and Botox, can finally rest easy. Up until now, cosmetic treatment facilities have been unregulated by the Care Quality Commission (CQC), and patients risked securing care from providers offering less-than-quality services. But a new provider registration and quality assurance mark offered by the Independent Healthcare Advisors Services (IHAS) and backed by the Government guarantees quality care from cosmetic treatment providers.

The IHAS Registration mark separates quality cosmetic treatment providers from the unqualified practitioners, offering a safeguard to patients seeking cosmetic services. Organisations and practitioners offering injectable cosmetic treatments must register through IHAS in order to legally display the IHAS Register of Injectable Cosmetic Providers mark. Registration requirements include completing self assessment forms and submitting supporting evidence, permitting random site visit inspections with only 24 hours’ notice, and paying a registration scheme fee to support the IHAS quality cosmetic treatment initiative. The providers must prove, through assessments, inspections, and supporting documentation, that they comply with good practice standards for the cosmetic treatment industry.

The industry led initiative is fully supported by Health Minister Mike O’Brien, who stated that the registration will “…help protect the public from unscrupulous operators. It will clearly mark those who uphold the highest standards the industry can provide.” The Minister has Government offered funding to support the regulation of cosmetic treatment providers in the United Kingdom.

Large cosmetic treatment providers in the industry have already offered their commitment to supporting the quality initiative. The Harley Medical Group, Transform, and Sk:n, who together own more than eighty clinics, plan to register all of their facilities. The initiative is also highly supported by suppliers to the cosmetic treatment industry, such as Q-MED UK Ltd, the manufacturer of Restylane dermal fillers, and Dental Protection, which offers professional support and advice to a majority of dentists in the United Kingdom. The British Association of Cosmetic Doctors also announced its support of the industry regulation.

Patients seeking quality care can search the Independent Healthcare Advisors Services registration for registered cosmetic treatment providers, or simply look for the “IHAS Register of Injectable Cosmetic Providers Quality Assurance Mark” at any provider of choice. Doctors, registered adult nurses, and dentists will be registered during the first year of implementation. If the launch is successful, IHAS will consider adding standards for dental hygienists, therapists, physiotherapists, and others during a second rollout of registration year two of implementation.

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