RCS Proposals on Cosmetic Surgery Regulation | Fieldfisher
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RCS Proposals on Cosmetic Surgery Regulation

31/03/2015
Earlier this month the Royal College of Surgeons ("RCS") consulted on proposals to improve standards and safety for patients undergoing cosmetic surgery. Cosmetic surgery procedures are now widely Earlier this month the Royal College of Surgeons ("RCS") consulted on proposals to improve standards and safety for patients undergoing cosmetic surgery. Cosmetic surgery procedures are now widely available but there have been concerns about the quality of service being provided for a long time, and the RCS is concerned that there is too great an incidence of procedures going wrong.

In 2013 Sir Bruce Keogh (Medical Director at NHS England and former cardiothoracic surgeon) led an independent review into cosmetic practice and made various recommendations to improve the quality of patient care. The Keogh review followed concerns about the quality of implants used in cosmetic breast surgery and found that "the existing regulatory framework has not kept pace with changes and it does not provide enough protection against many of the potential risks from cosmetic procedures". As a result, the RCS formed the 'Cosmetic Surgery Inter-specialty Committee' ("CSIC") containing representatives from the relevant specialties to oversee this project. CSIC aims to set standards for training and practice, develop a system for surgeons to demonstrate whether they meet these standards, improve data collection and the availability of outcome data about cosmetic surgery, and to ensure there is easily accessible, clear and unbiased information for patients.

The regulatory issues within the cosmetic surgery industry broadly fall under the training/qualifications of the practitioners, the safety of the products and standards set and maintained by providers. These areas are governed by various regulators including, the General Medical Council, the Medicines and Healthcare Products Regulatory Agency and the Care Quality Commission. This patchwork of regulatory frameworks presents a challenge to the effective regulation of cosmetic surgery and the extent to which the relevant organisations will work together effectively to effect improvements recommended by the RCS is yet to be determined.

Under the proposed changes, surgeons working in the private sector will need to demonstrate that they satisfy the required standards of training to be appropriately certified as well as being included on the GMC's specialist register. The GMC will be working to develop the new accreditation scheme and introduction of a new certification system for surgeons to demonstrate whether they meet the required standards to enable this proposal to take effect. In order to support this, the CSIC have categorised cosmetic surgical procedures into groups of closely related operations. One of the key announcements by the RCS is that patients should be able to make informed decisions before agreeing to cosmetic surgery or treatment. In particular, this should allow individuals to consider the options available and check to see if the surgeon is listed on an approved register. Many patients may be choosing to undergo surgery without proper consideration of the risks involved with the procedure and without any real information about the surgeon's training, qualification and experience to perform the procedure in their chosen field.

The CSIC consultation document sets out details of the proposals and in particular how a surgeon would be able to obtain and retain certification to perform surgery in a specific field. It also supports the publication of data about the outcomes of surgery by way of a national clinical audit. Further details can be viewed on the RCS website by clicking here. However, the plans for reform do not cover non-surgical procedures which have also increased in popularity over recent years such as Botox, dermal fillers or chemical peels. Neither the current regulatory framework nor the RCS proposals address how to offer increased protection to such patients, and this regulatory gap, for the moment at least, remains unfilled.

The recommendations and proposals will now be considered further in an attempt to improve the industry and strengthen patient protection. Whether the changes will be enough to make a real difference remains to be seen.

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