This week the General Medical Council (GMC) will issue new rules to its members, UK Doctors, stating that the practice of remotely prescribing prescription only botulinum toxin products, such as the brands Botox, Vistabel, Azzalure, Dysport, Xeomin and Bocouture will no longer be permitted and Doctors must see a patient face-to-face before issuing a prescription for the drug; (although they may still delegate the administration of it to someone under their supervision, such as a nurse).

This means that the ongoing loop-hole of writing prescriptions for Botox following a telephone call, fax, email or voice over internet connection (i.e., Skype etc.) will from this week mean that a Doctor is practicing outside of the GMC rules and could face disciplinary charges in the form of a fitness to practice hearing.

“There are good reasons why these are prescription-only medicines and we believe doctors should assess any patient in person before issuing a prescription of this kind,” said Niall Dickson, chief executive of the GMC.

The story broke on the BBC London Evening News on 9th July which highlighted an investigation into the practice of remote prescribing services following concerns that were raised to the broadcaster. The BBC sent a researcher undercover to investigate operations by infiltrating training sessions with one of the UK’s largest purchasers of botulinum toxin products, Dr. Mark Harrison, who runs Harley Aesthetics a company which provides training courses and remote prescription services for registered nurses up and down the UK.

For £30 per call, nurses subscribed to his services are able to telephone Dr. Harrison on his mobile phone, whereupon he would speak to them and their patient and issue a prescription for the cosmetic injectable treatment without ever seeing the patient face-to-face.

Dr. Harrison was secretly filmed by the BBC candidly remarking to a room full of trainees on a variety of practices which leave many within the industry sharply inhaling, such as obtaining Botox via prescriptions made in the names of friends and family so that a stock of the drug could be obtained ready for injecting patients immediately – something which even Nurse Independent Prescribers (who can legally prescribe themselves as well as Doctors) are not able to do (i.e. stock must not be held, the practitioner must wait for the drug to be delivered in the name of the patient and treat on another day).

Dr. Harrison also pointed out that although ‘a little bit naughty’ if nurses were unable to reach him for a remote consultation, perhaps due to poor mobile phone signal, and wanted to treat a patient there and then, they could do so and he’d ring the patient after the treatment to conduct a retrospective consultation! This puts the nurse in a position whereby they would be injecting a patient with a prescription only medicine (POM) without any form of written prescription prior to treatment; a serious issue for patient safety.

The practice of remote prescribing has already been condemned by the Nursing and Midwifery Council (NMC) who state that nurses engaging in treating patients with botulinum toxins following a remote consultation will be going against the NMC standards and thus risk their registration (which could be withdrawn following a disciplinary hearing) if they operate via that business model.

Commenting to the BBC, Dr. Harrison said he had performed more than 50,000 remote consultations since 2005, with no adverse affects on patient health. He told them that the use of prescriptions in one person’s name for the treatment of others was “common, almost universal practice throughout the aesthetics industry” and concluded; “I can confirm that I take my professional and moral obligations to both the patients who have treatments and the nurses who use the service extremely seriously.”

Dr. Harrison is by no means alone in providing remote consultation services, this practice is widespread amongst individuals and smaller service providing companies,  also extending to dentists who have prescribing powers. As the Director of the biggest organisation offering remote prescribing services within our industry it must be no surprise to Dr. Harrison that he was targeted by an investigation such as this to highlight the issues and dangers surrounding remote prescribing of botulinum toxin products.

Consulting Room Director Ron Myers says:

“This unequivocal statement from the GMC would seem to be the final nail in the coffin for remote prescribing business models of Botox for cosmetic purposes. The NMC have been clear on this for a while, but the GMC now comes into line and should halt the march of non-prescribers of any speciality seeking to offer this treatment via a remote consultation business model.

This decision has become increasingly important as we have even seen these prescription medicines getting into the hands of people without any medical qualifications. The insurers and underwriters now need to look had at the people that they are covering with indemnity insurance and take appropriate action.

I’m hoping that we also see moves to restrict the use of (more dangerous) dermal fillers by beauty therapists as medical devices come under more scrutiny in the near future.”

Mai Bentley RGN NIP, Director of Training at Intraderm Limited told us;

“The GMC, NMC and MHRA have been totally aware of this situation for over two years but no significant action has been taken until now. We have tried hard to raise awareness amongst nurses about the many problems associated with some remote prescribing services but this was not welcomed by some doctors, nurses and companies within the aesthetic industry. We have always been concerned that many nurses have been misled as to the legalities of some remote prescribing services but with little support from the appropriate governing bodies and the aesthetic industry, this has been impossible to address in the correct manner.

We welcome the report from the BBC this evening which has highlighted unprofessional practises that have been allowed to continue, unchecked by the regulatory bodies, for years and has thrown the situation into the light of the general public arena. The immediate response and announcement from the GMC today will go some way towards helping to protect the patients seeking prescription only aesthetic treatments in the future. However, earlier intervention by the governing bodies would have prevented the dreadful confusion that exists within the industry on the subject of remote prescribing. The Council for Healthcare Regulatory Excellence (CHRE) must surely need to look more closely at the role of the governing bodies in this situation.

The way forward for those nurses who are not already independent nurse prescribers may be challenging. The V300 independent nurse prescribing course is not the answer for everyone for a variety of reasons and prescribing buddy systems require a lot of trust and organisation on both side of the equation.

Nurses are responsible for their own actions under the NMC Code of Conduct and listening to the incorrect advice of medical or other nursing colleagues and pleading ignorance to the true facts are no defence.  We continue to offer confidential support and advice to those who may require it.”

Dr. Samantha Gammell , President of The British College Of Aesthetic Medicine (formerly the British Association of Cosmetic Doctors) said in a statement;

“The aim of the British College Of Aesthetic Medicine is to advance the effective, safe and ethical practice of aesthetic medicine and we therefore welcome the new General Medical Council (GMC) guidelines on remote prescribing.

We understand that the new guidelines will make specific reference to injectable cosmetic medicines such as Botulinum Toxin and therefore there can be no further claims of ambiguity by any medical professional. As per our Articles of Association ALL BCAM  members are expected to understand and have a working knowledge of the Code of Practice as set out by GMC and must adhere to it in daily practice.”

Emma Davies RGN and founder member of the British Association of Cosmetic Nurses (BACN) stated;

“The BACN has had no communication from the NMC, except to reiterate its stance on remote prescribing in aesthetics, i.e., that this practise does not meet the Standards. 28/3/2012

The BACN requires its members to abide by the NMC Code of Conduct, and Standards. We ensure our members are well informed and have drawn attention to any advice or guidance from the NMC, relevant to aesthetics.

We have been concerned for some time with Doctors presenting convincing, but misleading reassurances to nurses, that remote prescribing was legal and met NMC standards. We are relieved that the practise has been exposed and we can move forward with absolute clarity.”

Yvonne Senior, Co-Founder of the Private Independent Aesthetic Practices Association (PIAPA) told us;

“I would hope that this now closes the door to Doctors who are prescribing remotely to Beauty Therapists and other non-medics.”

Sally Taber, Director of the Independent Healthcare Advisory Services (IHAS) and responsible for the management of the Standards and Training principles for www.TreatmentsYouCanTrust.org.uk, responded by saying;

“www.TreatmentsYouCanTrust.org.uk applauds the move from the General Medical Council (GMC) to ban Doctors from prescribing Botox®, a prescription only medicine, without conducting a prior face-to-face consultation.

The inappropriate practice of remote prescribing by Doctors has to date been one of the biggest issues within the cosmetic injectable industry. Following its launch nearly two years ago, the Department of Health backed register of regulated cosmetic injectable providers www.TreatmentsYouCanTrust.org.uk has campaigned for the GMC to review its remote prescribing guidance and close the loophole which had put patients at risk by providing unqualified providers without a clinical background with Botox®.

Botox®, a prescription only medicine, should only be prescribed to a patient following a face-to-face consultation and clinical assessment by a regulated Doctor, Dentist or an Independent Nurse Prescriber.

Relaxed attitudes to remote prescribing in the past has resulted in profit over patient safety and Botox® sold to unregulated and inappropriately qualified providers, including beauty therapists, who lack the necessary clinical background to administer injectable treatments safely. Whilst unsafe, the practice of remote prescribing in some cases is also illegal, breaking the Medicines Act 1968 for possession of a prescription only medicine in the name of an individual who is not the designated recipient of the drug.

The cosmetic injectable industry has for many years recognised remote prescribing as unsafe and totally inappropriate. The review of prescribing guidance by the GMC marks an important step in further stamping out bad practice in the industry and ensuring patient safety.”

Dr Andrew Vallance-Owen, Chairman of IHAS Cosmetic Surgery/Treatments Working Group added;

“As champions of best practice in the cosmetic injectable industry, and acting in the best interests of patients, www.TreatmentsYouCanTrust.org.uk  applaud the move by the GMC to dovetail their remote prescribing guidance with the other professional regulators in the UK, leaving remote prescribing behind and marking a promising future for further stamping out bad practice in the industry.”

Source: The Consulting Room