Questions asked by insurers and their brokers

Are they practising legally?

Have any prescription only medicines been obtained lawfully in accordance with the Medicines Act and Human Medicines Regulations?
Is the service provider CQC registered if this is required?
Does the practitioner practise in accordance with national Equality, Inclusivity and Diversity legally defined requirements?
How does the practitioner conform with safeguarding standards?

Premise

Do they operate from a designated clinic or treatment centre that is appropriately registered either with the CQC and/or with the responsible Local Authority within the context of local licencing laws?
Have you inspected relevant certificates to confirm the same? Do the premises accord with published advised environmental health or CQC standards?
Have you advised practitioners that you will not insure them for ‘mobile working’?

Has the practitioner published (in plain English format):

a summary of the procedures that they provide
the risks associated with such treatments
the cost of such procedures
a summary of their practitioner qualifications,
insurance certificate
details of their redress scheme

This is required to ensure that members of the public are appropriately informed and able to make risk-assessed choices about ‘safe and effective’ treatment options.

Professional scope of practice or competence

Have you reminded all practitioners, who are all regulated by a professional statutory regulatory body that they are at risk of removal from their professional register if they provide any procedure that falls outside their professional scope of practice or competence or fail to possess suitably indemnifiable insurance cover if complications/averse events cause adverse consequences for the patient?

Health and Safety

Have they self-declared and provided evidence that the services they provide accord with health protection and health and safety and infection control safe practice standards (such as those relate that to preventative designed measures to restrict the transition of the Covid-19 virus or any other viral or bacterial infection)?

Products, devices and medicines

Are they able to confirm that the products, devices, and medicines that they use are ethically and legally sourced, procured and administered?
Are they able to confirm that the products, devices, and medicines that they use confirm to UK regulatory standards and requirements (e.g. such as those set down by the MHRA)?

Education and training

Has the practitioner undertaken appropriate initial education and training as specified and independently verified by national advisory bodies, such as Ofqual (and their associated Awarding Organisations, Higher Education Institutions?

At the present time non-statutory verification of appropriate education and practice competence standards has been provided by the JCCP/CPSA, Health Education England and National Occupational Standards to enable them to provide evidence to members of the public that they possess the requisite knowledge, skills and competencies to perform the commissioned treatments/procedures safety and effectively to an appropriately defined standard of competence and academic level of qualification (e.g. as defined by the JCCP/CPSA (2018).

In the future new DHSC regulations for the award of a Practitioner License will supersede current education and training standards. Independent verification of recognised initial training courses/training providers in the aesthetics sector against the new (and yet to be determined) DHSC Licensing standards will be a fundamental requirement in order to assist insurers to make reasonable judgements over a practitioner’s competence and ability to ensure patient safety.

Prescription only medicines

Where prescription only medicines are provided as part of the treatment process (or remedial use in the event of complications that arise from the procedure), has the practitioner provided evidence that they are either a registered and approved prescriber or have access to an appointed registered, approved prescriber who has undertaken a face-to-face assessment of each patient for whom they seek to administer prescription only medicines as part of the commissioned treatment process?
Is the name and contact details of the designated prescriber declared at the point of application for insurance?
Do the regulated prescribers that you insure possess adequate levels of insurance to cover the additional costs associated with complications/adverse events that cause consequences for members of the public as the result of their practices (including third party prescribing practices)?

Continuing professional development

Is the practitioner able to provide evidence that they have undertaken and engaged in procedure relevant and appropriate annual continuing professional development training and experience to perform the aesthetic activity safely and effectively to the standards outlined in the next section of this charter?

Cosmetic Redress

Does the practitioner provide members of the public who use their services with access to a ‘complaints handling’ or redress service?

Patient safety

Is the practitioner able to establish informed consent?
Has the practitioner recorded basic patient demographic data, and captured a detailed medical / healthcare history for confidential record keeping?
Has the practitioner explored the patient’s motivations / expectations for the procedural outcome and completed an holistic physical, emotional and psycho-social health check?
Has the practitioner provided a description and agreement of benefits and risks associated with any proposed treatment plan, including the option of no intervention?
Has the practitioner provided details of post-treatment / follow up care provisions with associated costs and contact details?
Has the practitioner provided the patient with given sufficient time allowance for any treatment decision – ‘a cooling off period’ - (48hrs)?

Advertising

Does the practitioner advertise their services in accordance with legally endorsed standards as defined by the Advertising Standards Authority (the ASA)?