The Nitty Gritty of Online Registration for the IHAS Register

Having recently successfully completed the IHAS Quality Mark Assurance scheme online registration process and, following scrutiny by CHKS, the third party company who administer the scheme, received confirmation that our clinic has been accepted onto the register, I now know the detail and evidence of documentation required to show, in principle, that the business operates in accordance with the standards required.

For those clinics registered with the Care Quality Commission (as ours has been since 2005) – the format and documentation detail required was not a shock. However, as we are primarily registered for lasers, and have never been inspected or asked questions about injectable use in the clinic by CQC inspectors, there was still a reasonable amount of work to do to ensure that all policies and procedures required were up to date and in the correct format.

For those clinics or individuals who have not received any outside scrutiny over the “nitty-gritty” of how they run their business, the work required to prepare appropriate documentation for the IHAS register may be considered as all 60 questions also ask you to upload documentary evidence to support the answers that you have given.

Many of the questions regarding effective communication (both written and verbal), treatment protocols, complaints procedures and access for patients/clients to a clinician out of hours should all be fairly straightforward for all businesses. However, on closer examination, I found a few minor gaps in our policies that needed to be addressed, which proved to be a useful exercise as this is, in effect a risk management process to ensure that all documentation complies with current standards. This is vitally important from an insurance perspective and/or if practitioners are unfortunate enough to be reported to their respective medical bodies; be it GMC, NMC or GDC.

Having attended a few meetings in the past run by barristers exploring “medical negligence” cases, I noted that the commonest areas that practitioners fall down on are in the documentation of consultations and evidence of regularly updated (and dated) patient information/consent documentation and other written policies and procedures. 

For those practitioners running a “multi-site” business model, where they do not actually own the business or premises that they are injecting in; the following questions may prove more difficult to  answer:

Question 5.2
Staff receive training in handling complaints. Attendance at training is recorded.

 

In the event of a practitioner utilising another business to market their services and provide rooms, such as a beauty salon (currently common practice in our industry) – do the front line staff (i.e. reception) in these businesses need to be trained in handling complaints in the event of a patient/client contacting them when the practitioner is not there?

 

This also relates to another tricky legal issue as to who forms the contract with the client in these situations? The practitioner or the business owner of the physical premises where the person was injected? And who is legally responsible for the complaint, particularly if it isn’t handled well and solicitors get involved?

 

Question 10.2
All treatment facilities comply with the Health and Safety at Work Act 1974 Section 3 and associated regulations and the Disability Discrimination Act 2005.

 

Again,may be difficult to prove for those practitioners visiting multiple sites where they use other people’s business premises. Also injecting in people’s houses would not be acceptable.

 

Two other questions that would preclude practitioners from registering and also seem to draw a line, as far as registration for the IHAS scheme is concerned, under the current topical debate regarding PGD’s/practitioners who cannot prescribe medicines themselves:

 

Question 3.7
All patients must have a face to face consultation with the prescriber prior to the administration or subsequent issue of a prescription and/or a patient specific direction.

 

Telephone consultations with prescribers who are not present is deemed not to be acceptable under this current scheme.

Question 3.5
A Patient Group Direction (PGD) for the administration of prescription only medicines is only used in establishments registered by the Care Quality Commission (CQC).

Due to the proposed changes relating to the CQC coming in this Summer/Autumn, many clinics currently registered with this body may no longer need to be due to the de-regulation concerning the cosmetic use of lasers and IPL’s. Add to this the fact that injectable treatments are not covered by CQC legislation.

As pointed out in my previous blog on this topic, anyone who understands this industry still knows that providers who are registered under this Quality Assurance scheme may still not provide treatments that patients/clients are happy with. Training is still unregulated and there is no way of currently being able to technically evaluate the skill of injectors in performing cosmetic injectable procedures. Hence, I’m not sure how the inspectors assess the answer to the following question apart from seeing evidence of a certificate of attendance to some form of training?

 

Question 9.3
Patients are assured that clinicians have received appropriate training, that they are competent in the treatment procedure/s to be carried out and have regular updating of their skills.  Clinicians are able to demonstrate to patients’ that they are trained and competent to perform the procedures

To date, I can only see one clinic in the whole of London that has successfully completed the registration process and been accepted onto the register, so I think that this scheme will be somewhat of a “slow burn”, even for those clinics that can provide the evidence required and who run businesses that meet the standards.
 
For businesses run by sole practitioners using a multi-site business model, the registration process maybe even more difficult, and nigh on impossible for those who do not have prescribing status themselves.