New Guidelines have been published by the Royal College of Surgeons of England and the GMC with the aim of improving professional standards in the provision of cosmetic surgery and cosmetic interventions. The RCS guidelines do not cover the non-surgical procedures such as Botox injections but the GMC guidelines do.
The authority of the GMC is over registered medical practitioners and not over aesthetic practitioners, nurses or others who might provide non-surgical cosmetic interventions. However the guidelines provide that a doctor must physically examine a patient before prescribing a cosmetic medicine such as Botox. If you have Botox injections you should be examined by a registered medical practitioner, even if the injection is given by a non-doctor.
The Guidelines provide that there has to be active consideration of the patient's psychological vulnerability and their suitability for the proposed surgery or treatment. This will include making a referral to a mental health practitioner if the patient maintains unrealistic expectations of the surgery notwithstanding the provision of advice by the surgeon or if they have a history of "psychological disturbances". The two week "cooling off" period is now clearly set out as a requirement in the RCSEng guidelines.
Of considerable interest are the new guidelines to surgeons concerning financial arrangements
"Surgeons who perform cosmetic surgery should:
- Obtain adequate professional indemnity insurance that covers the procedures
That begs the question, "What is adequate?" I have previously commented on this blog on the adequacy of insurance that does not cover pre-operative advice, or which does not cover a claim made in a period after the insurance has lapsed, even if it is for negligent surgery performed during the period when the insurance was in place.
"Communicate clearly their relevant professional qualifications to patients, including
specialist registration on the GMC register and certification in the areas of cosmetic
surgery in which they practise."
This information must be given to patients. The surgeon cannot rely on the patient looking up the information on line, or asking questions.
" Make patients aware of fees and the full cost of treatment before seeking consent,
including fees relating to follow-up treatment or potential complications and revisions.
Information should include what is covered and what is not covered in the fees.
"Disclose any personal affiliation or other financial or commercial interest relating to
practice, including other private healthcare companies, pharmaceutical companies or
"Inform patients if any part of the fee goes to any other healthcare professional."
This is a welcome move towards transparency in relation to cosmetic surgery fees and costs. It seems to me that surgeons will have to disclose what their own fees are for the proposed surgery. At present patients often pay a fee to a clinic, unaware of the amount paid to the surgeon or the anaesthetist. Surgeons might be engaged on a contract to perform a certain number of procedures at a certain cost. Whilst the new guidance applies to surgeons and not the clinics, it seems evident that if a surgeon is to make a patient aware of "fees and the full cost of treatment" and whether any part goes to any other healthcare professional, it is a requirement to make the patient aware of the surgeon's fees, the aneaesthetist's fee and the total cost to the patient. It is the surgeon's personal obligation to provide the information.
"Ensure that any advertising is realistic and ethical. Advertising should be for the sole
purpose of conveying factual information. Surgeons should refrain from the use of
financial inducements that may influence the patient’s decision such as discounts, timelimited
or two-for-one offers."
Again, surgeons have to take personal responsibility for the advertising deployed by any clinic for whom they work.