In a time when the professional bodies are clarifying and amending their guidance on how their registrants should conduct consultations for patients receiving cosmetic treatments, the pharmacies are also now clarifying legislation.

A major pharmacy has released a statement to all of their customers highlighting the importance of only prescribing items suitable and appropriate for that one patient. They brought attention to off label prescribing suggesting that Botox 50 would be more appropriate considering its licensed indication.

Another large pharmacy is now only accepting scripts for cosmetic medicine that stipulates that a face to face consultation has taken place. If they receive a script that does not specify this, they will not dispense against it.

The industry is under strict scrutiny at present according to the pharmacy and as always, if a HCP works against legislation or their professional guidance, their insurance will be invalidated.

Following the BBC report of July 9^th in which he was secretly filmed admitting to the remote prescribing of Botox, Harley Street doctor Mark Harrison has been suspended by the GMC, it was announced yesterday. Dr Harrison is awaiting the news as to whether he will face a fitness to practice panel and remains unable to practice as a doctor for up to 18 months in the meantime.

This news serves to reinforce the message that GMC are serious about enforcing their latest guidelines for the prescription of Botox: doctors must only prescribe following a face-to-face consultation with the patient.

While the NMC guidance to nurses has not changed, it is a timely reminder to nurses to comply with appropriate guidelines – Botox may only be administered after a nurse prescriber, dentist or doctor has issued a prescription following a face-to-face consultation.

Here at Cosmetica we will continue to monitor developments for the benefit of all the medical professionals who are our customers. Our training courses will include the latest advice on compliance with professional guidance, and our Prescribing Service is available to help nurses continue to administer Botox while protecting their NMC registration.

We have received a number of enquiries from nurses concerned by the expected changes to GMC guidelines.

Please note that changes to GMC guidelines DO NOT affect nurses in their ability to administer Botox.

All the GMC have done is brought their standards in line with the other professional bodies; NMC and GDC.

All patients wishing to undergo a Botox treatment have to be assessed by one of the following:

•  Doctor
• Dentist
• Nurse prescriber

The guidelines for all professionals now mirror each other in that:

Botox cannot be remotely prescribed

There appears to be some confusion as to what a remote prescription is and I would like to take the opportunity to clarify this.  A remote prescription is one that is written in another location to that of the patient, typically without an assessment.   Some doctors, such as Dr Harrison in the BBC undercover report, have allegedly been using the telephone to prescribe for nurses’ patients.  This has not been allowed by the NMC for some time and now the GMC have stated telephones should not be used to prescribe Botox for patients.  This is because the patient needs to be seen face-to-face by the prescriber who is working with the nurse.

What does this mean for nurses who are not prescribers?

There is absolutely no difference to nurses. This is because the NMC have stated nurses can only administer Botox once a face-to-face consultation has taken place with the prescriber

I don’t have a prescriber who can undertake face-to-face consultations. Can I still administer Botox?

Yes you can: Cosmetica Training offers face-to-face consultations for nurses. We have a database of prescribers throughout the UK and we continue to recruit new prescribers each month.

I am due to take a training course. Will I be able to administer Botox after training?

Yes you will. We will provide detailed advice during the courses including an analysis of different scenarios that you may encounter and how they can be integrated into your practice in compliance with professional guidelines.   Please rest assured that you will be able to administer Botox following successful completion of your course and this will pose no difficulty for you.

It was inevitable: an undercover reporter attending a training course based in London to expose the “illegal and unethical” side of Botox administration.  The nurse secretly filmed Dr Harrison undertaking Botox training to a group of other nurses and revealed, what Sally Taber described as “wrong and unacceptable” practice.

This case highlighted the GMC’s need to clamp down on how doctors prescribe Botox, now mirroring the guidance by the NMC and GDC.  In short it means that before a doctor prescribes Botox or any other cosmetic medicine they need to physically see the patient, this cannot be done via Skype or 3G telephone calls.  So what does this mean for medical professionals who administer Botox?

Doctors – are now unable to prescribe Botox remotely, even for their own patients.  To be able to inject patients the first time they see them is now impossible unless they order wholesale Botox from Allergan direct, as the prescription will then be written from the wholesale stock.  If a pharmacy has dispensed the product against a prescription this is NOT wholesale and can legally only be used on the patient for whom it has been dispensed.  If they prescribe for nurses they need to undertake a face-to-face consultation before they write the prescription.

Dentists – the GDC stated last year that their registrants should not remote-prescribe Botox.  They should follow the same recommendations for how doctors prescribe as dentists can also purchase wholesale Botox.

Nurses –  can only administer botox once a face-to-face consultation has taken place.  Their prescriber can be either a doctor, dentist or independent nurse prescriber (who has completed a Botox training course).  Nurses cannot hold stock of toxins and they can only receive wholesale Botox if they are employed by or employ a doctor in their Botox practice/business.  If the nurse is not in the same physical legal entity as the doctor he/she cannot obtain such stock.    All nurses must ensure their patient has a face-to-face consultation with the prescriber and once they receive the product they can administer it as per the direction to administer.  Botox is like any other POM and needs to be prescribed before it is administered.

Paramedics – the HPC has not as yet stipulated any guidance for paramedics who inject Botox, however, they will have to in future ensure their patients have a face-to-face consultation as their prescriber can no longer issue a prescription for Botox remotely.

How does this change Botox training courses?  With reference to how we work at Cosmetica Training, it doesn’t really change a thing.  We have, since the NMC clarified their guidance, ensured we advise all doctors who work with nurses to comply with their regulations as we have with GDC registrants.  Whilst previously, it has been acceptable for doctors to remotely prescribe Botox, this has not been advisable when prescribing for nurses and this is our advice for their own clients.  Our guidance to doctors now will mirror the stance for nurses and dentists.

What does this mean for Botox administration?    Patients may have an initial delay in receiving treatment, however, nurses are still able to administer Botox, nurse prescribers, doctors and dentists can continue to prescribe and administer Botox as long as the prescription is not written remotely.

The news report below shows undercover footage from the BBC.