AHPRA’s incoming guidelines for registered health practitioners performing non-surgical cosmetic procedures mean little without specific, approved training requirements.
The health practitioner regulator has taken another step forward in bringing the cosmetic medicine industry to heel – but the newly-released guidelines offer little variation on the existing advice.
AHPRA dropped advance copies of two separate-but-related updates to cosmetic medicine guidelines earlier this month, both of which will come into effect on 2 September of this year.
The first document lays out guidelines for practitioners who perform non-surgical cosmetic procedures – i.e. injectables like filler or Botox – while the other lays out guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures.
Medical Board of Australia chair Dr Susan O’Dwyer said the guidelines ensured that all professions were “working from similar play books” for the safety of patients.
According to AHPRA, the new guidelines “highlight” that practitioners like registered nurses need more than just the foundational qualifications included in their initial training before they can safely perform cosmetic work, and that further training or education will be necessary for practitioners looking to extend their scope of practice.
The exact phrasing of the guidelines is that cosmetic practitioners should have “appropriate education, knowledge, training, competence, authorisations (where required) and experience to safely perform the specific cosmetic procedure” and manage any complications.
Practitioners are responsible for ensuring they are “sufficiently educated” and “competent” to perform any cosmetic procedure and that any training they do is “sufficient to enable competent and safe performance of the cosmetic procedure”.
While AHPRA stopped short of recommending a specific path of study, it did say that it considered adequate education included appropriate training in anatomy and physiology, training on the assessment of suitability for the procedure and both theoretical and hands-on training in the specific procedure being offered, including an assessment and demonstration of competence.
All registered health practitioners whose scope of practice includes cosmetic procedures will now also have to undertake CPD that includes activities related to cosmetic procedures.
The new guidelines also make it clear that doctors and nurse practitioners providing prescriptions for cosmetic injectables via “text, email or online” asynchronous consultations is “not acceptable practice”, and neither is the provision of one prescription for multiple people.
Video telehealth or in-person consultations to prescribe injectables, however, fall within the guidelines.
On the face of it, these changes seem dramatic.
But Cosmetic Nurses Association president Sheri-lee Knoop told Dermatology Republic that AHPRA’s language was open to interpretation.
“One of the things we were very concerned about was the lack of stipulated education, and these guidelines have now said that you need appropriate education of a robust nature – both the doctor doing the prescribing for the nurses as well as the nurse – and that everybody, therefore, would be required to work within their scope of practice,” Ms Knoop said.
“It might sound obvious, however, that’s not always the case.
“Now explicitly in the guidelines this is required, which is fabulous.
“The grey area around it, however, is they haven’t said what appropriate is. What I might think is appropriate might be very different to a colleague, dependent on what your exposure is.”
Basically, the new guidelines stop short of recognising non-surgical cosmetic treatments as a specialty or an area of endorsement for nurses to add to their registration.
Without that status, it’s harder for the regulator to dictate things like what a legitimate training pathway for cosmetic injectables should look like or even identify specific issues.
“Until you recognise something as a specialty … you can’t really gather data, so we don’t know how many people are involved in [cosmetic injectables in Australia],” Ms Knoop said.
“You can’t gather any data around concerns or complications or anything like that.”
Ms Knoop also pointed out that the original guidelines produced for nurses working in the cosmetics industry in 2023 already clarified that prescribers should see patients either in person or via video and that remote prescribing by phone or email was unacceptable.
“I think [some of the reporting this week] makes it sound like we’re going to have this whole new set of guidelines, and we can’t do what we’ve been doing, which is not the case,” she said.
“There’s a couple of minor points … but actually, there’s not a lot of there to actually discuss.”
Australasian Society of Aesthetic Plastic Surgeons president Dr Lily Vrtik told DR that the advertising reforms laid out in the second set of guidelines released this week would help shift the narrative that treatments like Botox were perceived as low risk.
“[People] think it’s like just going to beauty shop and getting a facial or a haircut, but what’s missing in all that social media advertising is that these are actually still medical procedures and they carry risks,” she said.
“And also, potentially, quite significant complications.”
Dr Vrtik also noted that there was a lack of clarity around the specific training that cosmetic injectable practitioners should receive.
“I think they’ve tried to address the standardisation of training by saying the specifics of what’s required, but what is interesting is that they haven’t specified who can provide that training,” she said.
“As you and I both know, a lot of that training is provided by the industry … I think it’s important for a standardised form of training and education.”
The requirement for cosmetic practitioners to do cosmetic CPD activities, she said, was positive.
