Consultant dermatologists leading safe aesthetic care

Is your practitioner qualified?

The regulation surrounding cosmetic interventions and who carries them out in the UK is currently being reviewed by Sir Bruce Keogh for the Department of Health.  

At present not only can some cosmetic procedures be legally carried out by people with no recognised qualification, but non-surgical cosmetic interventions, including the injection of subcutaneous substances, can be delivered in non-healthcare settings which do not require the premises to be registered with the Care Quality Commission. For example, beauticians or hairdressers administer dermal fillers or laser hair removal. Some have diplomas, but they may have received no training in relevant cosmetic treatments. They may belong to a relevant trade organisation, but such organisations are not regulated, for example by the Council for Healthcare Regulatory Excellence (soon to be renamed as the Professional Standards Authority for Health and Social Care).

In announcing the Keogh review, the Department of Health noted that a medical practitioner does not have to be a surgeon to carry out cosmetic surgery unsupervised outside the NHS, and that in any event there is no section of the Specialist Register that refers to cosmetic practice. The GMC’s guidance “Good Medical Practice” makes it clear that doctors are expected to practise only in the clinical fields in which they are competent, but competence is currently self-assessed.

The Keogh report has made the following recommendations


The Royal College of Surgeons (RCS) should establish a Cosmetic Surgery Interspecialty Committee. This should consist of representatives from all the relevant specialty associations and professional associations and societies, including plastic surgery, ENT surgery, maxillofacial surgery, ophthalmology, breast surgery and gynaecology. Its task should be to: • set standards for the training and practice of cosmetic surgery. • make arrangements for the formal certification of all surgeons regarded as competent to undertake cosmetic procedures, taking account of training and experience. • establish and oversee a clinical audit database for cosmetic surgery, working with the Healthcare Quality Improvement Partnership (HQIP). • work with the Parliamentary and Health Service Ombudsman (PHSO) on dispute resolution (see recommendations regarding accessible resolution and redress). • meet the General Medical Council (GMC), Care Quality Commission (CQC), and the Medicines and Healthcare products Regulatory Agency (MHRA) regularly and, when appropriate, with provider representatives, to discuss current issues and share information and intelligence on the quality of care being provided. • develop a specific code of ethical practice for cosmetic surgery, in collaboration with the GMC, to include guidance on advertising, insurance requirements and the psychological assessment for patients. 

The RCS Interspecialty Committee should work with the CQC and the new Chief Inspector of Hospitals to ensure that providers follow the standards developed. In the meantime, the Review Committee recommend that only doctors on a GMC Specialist Register should perform cosmetic surgery, and that those doctors should work within the scope of their Specialty specific training. 

The RCS Interspecialty Committee should be responsible for developing clear, credible outcome measures for cosmetic surgery that are published at individual surgeon and provider level on the NHS Choices website. 

All non-surgical procedures must be performed under the responsibility of a clinical professional who has gained the accredited qualification to prescribe, administer and supervise aesthetic procedures.

Non-healthcare practitioners who have achieved the required accredited qualification may perform these procedures under the supervision of an appropriate qualified clinical professional. 

The Government’s mandate for Health Education England (HEE) should include the development of appropriate accredited qualifications for providers of non-Review of the Regulation of Cosmetic Interventions 22surgical interventions and it should determine accreditation requirements for the various professional groups. This work should be completed in 2013.

All practitioners must be registered centrally. The register should be independent of particular professional groups or commercial bodies, and should be funded through registration fees. 

Entry to the register should be subject to: achievement of accredited qualification; premises meeting certain requirements ; adherence to a code of practice that covers handling complaints and redress, insurance requirements, responsible advertising practice and consent practices ; continued demonstration of competence through an annual appraisal. 

The full report entitled Final Report on the Review of Regulation on Cosmetic interventions is published by the Department of Health April 2013