Scottish Cosmetic Interventions Expert Group Report July 2015
Report on usage and numbers of cosmetic interventions being conducted in Scotland and recommendation on regulation of Independent Healthcare Providers.
3. Purpose and operation of the SCIEG
Following the publication of the Keogh Review in England, the Chief Medical Officer of Scotland asked Mr Andrew Malyon in his role as expert advisor on plastic surgery to consider the report's implications for Scotland. This request recognised that not all of the recommendations could be implemented in the same manner as for England, given the different legislative system, regulatory mechanisms and political institutions.
After an initial scoping meeting in December 2013, the SCIEG was established as a short-life working group on 4th March 2014. Following this, it met on a further three occasions, with its final meeting in February 2015. Members of the SCIEG were invited as representatives of their speciality and are listed in Annex 1. The secretariat to support the working group was provided by the Scottish Government.
Purpose of the SCIEG
At the first meeting, the purpose of the SCIEG was agreed as follows:
1. To provide advice in early 2015 on options to assure safe, effective and quality care for users of cosmetic interventions in Scotland.
2. It is envisaged that advice will include options on:
a. Legislation to regulate independent clinics providing cosmetic intervention services
b. New competency-based training modules for health professionals and health practitioners
c. A social marketing programme to empower the public to make informed choices about use of a service
d. Mechanisms to facilitate adherence to the Advertising Standards Authority guidance on marketing of cosmetic intervention services
e. Improvements to cosmetic surgery training and accreditation
f. Monitoring the impact of changes, potentially with process and outcome indicators
3. Subject to Ministers' views, implementation is expected to begin late 2015, with a commencement order for existing legislation in 2016 and a social marketing programme proposed to commence in late 2015.
Structure and function of the SCIEG
The membership of the SCIEG agreed the establishment of two subgroups, with a focus on two areas of recommendations in the Keogh Review. Each of the subgroups met on three occasions between their establishment and February 2015.
High Quality Care subgroup
This subgroup was established with a remit to make recommendations to SCIEG on high quality care of cosmetic interventions in Scotland. In particular, its tasks included defining which procedures should be considered by the SCIEG, clarifying options for improved quality of care, liaising with the CSIC of the Royal College of Surgeons and making recommendations to SCIEG for a framework to ensure safe access to appropriate services.
The composition of the High Quality Care (HQC) subgroup is detailed in Annex 1. At the SCIEG's first meeting, there was agreement that Mr Andrew Malyon should also chair this subgroup. The HQC subgroup defined the following list of non-surgical procedures as being under the remit of the SCIEG:
- Injection of botulinum toxin (there are several brands and an example is 'botox®')
- Dermal fillers
- Chemical peels and skin rejuvenation
- Lasers, Intense Pulsed Light (IPL) & Light Emitting Diode (LED)
- Hair transplantation
These procedures were defined on the basis of the Keogh Report, with the addition of hair transplantation occurring in reflection of recent market changes and to ensure consistency with the work of other UK administrations.
Informed and Empowered Public subgroup
The remit for the Informed and Empowered Public (IEP) subgroup was to make recommendations to SCIEG on improving the methods for informing and empowering the public on cosmetic interventions in Scotland. The IEP's tasks included exploring the understanding and information requirements consumers and the public have of cosmetic procedures, establishing good practice for consent, exploring options for increasing public understanding about cosmetic procedures and considering how appropriate protection (including indemnity) for consumers could be achieved.
A lay chair, Ms Christine Jess, a Public Partner with Healthcare Improvement Scotland was identified through the Scottish Health Council representative to SCIEG, and agreed to take on this work. The composition of the membership is stated in Annex 1.
A set of principles to guide the SCIEG's work were developed by the SCIEG and its subgroups. These were:
1. People have a right to safe, effective and high quality care delivered by trained personnel competent and up to date in their field.
2. Cosmetic procedures are offered as a service and can be provided as such as part of the commercial/independent health care sector and should be subject to at least the same standards as the NHS.
3. People should decide what clinically appropriate services to purchase with full and frank information and discussion on the expected benefits and risks and with all necessary follow-up arrangements in place.
4. The governance procedures are in place with a risk assessment conducted and recorded which should be subject to inspection.
5. Services must abide by all relevant legislation and best practice with regard to health and safety of their workforce and clients.
6. Continuous provider development and on-going training appropriate to the activity areas is an essential prerequisite and as new procedures come into force, providers must be appropriately trained and risk assessed for these procedures prior to any provision.
7. Complaint and redress systems must be in place and easily communicated to all potential and actual service clients.
8. Where problems occur service providers must take responsibility for rectifying these problems.
9. The NHS is the provider of last resort, but cannot be responsible for unreasonable financial burden, and will consider whether cost recovery is an option.
10. Providers should comply with published guidelines and not make unsubstantiated claims with regard to the services they provide.
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