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Health Education England (HEE) held a consultation meeting for its report on ‘Non-surgical Cosmetic Interventions and Hair Restoration Surgery’, on 9 December.

HEE Stakeholder Summit The Stakeholder Summit, which took place at the Kia Oval, London, brought together again representatives from professional associations, royal colleges, regulatory bodies, education providers and insurers. Lead members of the Expert Reference Group (ERG) presented HEE’s Qualification Requirements and latest developments, before answering delegate questions. Most recommendations were well-received by stakeholders, particularly the Recognition of Prior Learning (RPL) and Accreditation of Prior Learning (APL). It was debated, however, how all of the recommendations would be regulated in practice. Dental surgeon and aesthetic practitioner Dr Souphiyeh Samizadeh asked, “What measures are going to be put in place to make sure non-health professionals are not providing level seven [advanced] treatments, especially prior the implementation of these recommendations?” Many agreed with this question, further supporting her query on public protection. Professor David Sines, chair of the ERG, acknowledged, although possibly difficult to regulate, this issue would be addressed post-consultation. Noel Griffin, team leader of the Department of Health (DoH) Public Health Policy and Strategy Unit, replied, “It’s good that work has already started and all we can try to do is ensure that work continues.” Dr Samizadeh argued this was insufficient. She said, “I am very glad that work towards regulating this industry has started, however it is not enough to leave patients and the public unprotected for another few years until training requirements and accreditation become mandatory.” Many stakeholders felt implementation of the recommendations would take too long. Whilst HEE’s final report will be sent to the DoH in April, a delay in publication is likely due to May’s General Election. Carol Jollie, HEE performance and delivery manager, explained, “The date of publication depends on whether there is a change in government and what their priorities are. She continued, “It would be beneficial if education providers supporting the proposals start adapting their courses, or create new ones that meet the requirements. Membership associations could also recommend that their members work towards HEE’s recommendations.” Mike Mulcahy, dentist and ERG member representing the Faculty of General Dental Practice UK (FGDP), noted that he was impressed with the the suggestion made by another ERG member that prescribers of Prescription Only Medicines should be within the building when they are used, and be available after the event to deal with any postoperative side effects. Other stakeholders, however, questioned the location of the supervising prescriber. Elizabeth Allen, trustee and principal tutor at the British Association of Skin Camouflage, felt that supervisors should be present in the same room, not just building. HEE recommend that practitioners should perform 150 procedures over the preceding three-year period to be classed as a supervisor for training or providing oversight of more complex 14

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cosmetic procedures. Where clinical oversight was recommended, the regulated health professional would remain accountable for complications. Stakeholders doubted whether this number was sufficient to be regarded as an ‘expert’. Mrs Sarah Pape, consultant plastic surgeon and ERG modality lead representing the British Association of Plastic Reconstructive and Aesthetic Surgeons (BAPRAS), said the ERG had difficulty choosing the number, explaining, “There’s some evidence to suggest that if you have acquired 50 repetitions of any practical skill you’ve climbed the steepest part of the learning curve.” She highlighted that despite performing numerous procedures, not all practitioners are flexible enough to adapt to unexpected situations. Providing supervisors can adapt their skills, consultant plastic surgeon Mr Dalvi Humzah agrees with the recommendation. He said, “The number may sound low but it does have some evidence base. Also, not everyone will want the responsibility of being accountable for other practitioners, and would not want to have to put themselves forward to be critical of practise when required.” Andrew Rankin, nurse and ERG modality lead representing the British Association of Cosmetic Nurses, presented the possibility of creating an industry standards body, the Joint Council of Cosmetic Medicine, which would encompass the current associations and statutory regulators, and aim to improve cross-communication. This suggestion received mixed reactions, with some stakeholders, such as independent nurse prescriber Emma Davies, supporting the idea: “We must rally support for a Joint Council”, whereas others like aesthetic practitioner, Dr Askari Townshend highlighted potential pitfalls: “The proposal was well intentioned but not something that I think is necessary or one that will contribute more than its cost in money and bureaucracy.” Moving forward, Mr Humzah said, “I think we’re starting to see a basic framework but it needs to have some proper teeth to enforce it.” He added, “We need to look very carefully at who’s providing training and who’s labelling themselves as an expert.” Although question time was limited, Carol Jollie emphasised that the consultation period, ending January 9, provides the opportunity for stakeholders to highlight concerns and share ideas. “It’s absolutely key that we get a good response from across the industry,” she said. “We want to fill our final report to the DoH with endorsements from practitioners, membership associations, insurance companies and training providers to ensure the recommendations have the support of everyone involved.” To conclude, Emma Davies said, “HEE has to be commended for achieving so much, working with so many stakeholders, to deliver on its remit in such a timeframe. I think the one positive that has come out of this is that we’ve all gained professional experience working together.” Email cosmetics@nwl.hee.nhs.uk to get a copy of HEE’s report and submit your views on the consultation.

Aesthetics | January 2015

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