Tracey Jones, a registered nurse and regulation consultant providing support for healthcare professionals related to
CQC registration and inspection, gives her views on enhancing regulation in the sector.
The topic of enhancing regulation in the field of aesthetic medicine has been a longstanding focus of discussion within the medical and nursing community. With the recent initiation of public consultations regarding the licensing of non-surgical cosmetic procedures, it appears that change may finally be on the horizon. While this sector is often referred to as an “industry,” we could argue that it should be viewed as a domain of medicine rather than a facet of beauty.
As a nurse running my own CQC-registered clinic, I have observed the proliferation of services provided by individuals with no medical training or education, offering treatments that are essentially medical procedures. We hope that the limited timeframe for the consultation did not deter responses and that it will ultimately lead to a genuine understanding of the public’s perspective.
Different groups have undertaken various initiatives to promote involvement, targeting both healthcare professionals and those in the beauty industry. However, we will not see the impact of this until the response is published. We anticipate that this is unlikely to be a swift process; there are indications that the final framework will not be enforced until 2026. This provides professionals with ample time to prepare for the aspects outlined in the consultation.
I would implore those operating in this field to exercise caution before embarking on costly alterations or educational programs, as the final enforcement is yet to be confirmed. While registration with the Care Quality Commission is outlined in the consultation document, professionals must recognise that the regulation of registered services will remain consistent. If you, as a medical practitioner, are offering services falling within the scope of registration, this applies now and will continue to do so. What may change is the inclusion of additional services under the scope of registration, while the requirements for achieving registration will remain unchanged.
Some have argued that the license may potentially lead to more regulation for those who are already subject to stringent oversight by their respective governing bodies.
Nevertheless, viewing this as a step toward a more regulated domain rather than an impediment is important. As regulatory consultants with years of experience in this sector, we have witnessed and worked with many professionals who have faced the threat of prosecution from the healthcare regulator. As healthcare professionals, we must enhance our understanding of which services fall within the purview of this regulatory scope to mitigate the distress and risk associated with such threats. We must ensure that we adhere to the regulatory scope and lead by example for the public.
It is noteworthy that we have seen an uptake in professionals seeking support for CQC registration since the launch of the consultation, indicating that practitioners are preparing for the impending changes. The three-tiered sections outlined in the proposal, referred to as the “rag rating,” within the proposed licensing scheme may not be novel information for those who have been following this initiative over the past few years. However, the specific treatments listed within those categories may be new. Some question whether all treatments with potential patient risks should indeed be classified in the “red” category, which necessitates registration with the Care Quality Commission in addition to being a medical practitioner. This may account for the rise in inquiries we are experiencing.
It is evident that there will be shifts within these categories, with Professor David Sines of the JCCP suggesting that certain dermal filler procedures, such as rhinoplasty, should be viewed differently due to the risk and classified in the “red” category. One crucial aspect not clarified in the proposal is the requirement for healthcare regulation or medical registration for many treatments, which causes the biggest concern, such as all dermal fillers. This remains a concern as many lacking medical accountability are offering such procedures.
The Keogh Report 2013 emphasised the need for enhanced regulation in what the media called the “Wild West of medicine.” It is disheartening that it has taken a decade to raise public awareness and Government action, primarily in response to a significant number of instances of substandard practice and injuries to the public. Amendments to the Health and Social Care Act have paved the way for change. The
JCCP has been at the forefront of this effort, providing detailed information in the licensing proposal that underscores the necessity for a license for the facilities offering treatments and the individuals administering them. However, it does not specify how this will apply to clinics with medical and nursing teams already striving to establish robust governance structures and safety measures in line with CQC requirements and registration. We are left uncertain whether this license will be required for premises that are already CQC registered. As the consultation implies, we will await the response. I anticipate this will be a slow process, with indications that final decisions may not be implemented until 2026, allowing for an extended period to implement these changes. Thus, professionals have ample time to prepare, whether by ensuring their facilities are appropriately equipped, pursuing further education, or seeking registration with the CQC. Like many others, I will closely monitor developments and submit my responses, as this is the only means by which we can facilitate meaningful change.
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