“Buddy prescribing” for Cosmetic Injectables

Have you been approached by an aesthetic nurse or beautician to act as their designated medical practitioner and prescribe cosmetic injections (eg, Botox^®)? What are the medicolegal issues relating to this?

Could being a ‘good buddy’ put you and your career at risk?

Botulinum toxin, although used to treat several medical conditions, is commonly used as a cosmetic treatment. Once injected, it relaxes the surrounding muscle and temporarily freezes it, having the effect of smoothing out lines and wrinkles in the skin caused by facial expressions. The most commonly used injectable is Botox^®.

Botulinum toxin is a prescription-only drug. It should only be prescribed after a careful and thorough assessment by a clinician who is qualified to treat a patient who develops any unexpected complications in an appropriate environment. If not administered correctly, it can lead to infections, drooping facial features, impaired vision and/or breathing difficulties.

Cosmetic injectables are frequently administered in cosmetic clinics by aesthetic nurses or beauticians who have received training in the process. If they are non-prescribers, they should work under the guidance of a prescriber who has experience in the treatments being offered.

The role of the designated medical practitioner in prescribing Botox^®

PMP is aware that some consultants are being asked to prescribe cosmetic injectables for colleagues to administer. Before accepting this role as the ‘buddy prescriber’, you should consider the following:

1. Is the person you delegate responsibility for the administration of the cosmetic injectable trained and competent to undertake this task? Ensure they have their own indemnity insurance.
2. Prior to prescribing the medication, you, as the ‘buddy prescriber’, must hold a face-to-face consultation with each patient (see point 3). During this consultation:
   • Undertake an in-depth discussion regarding past medical history, including medications, risk benefits and alternatives of the proposed treatment.
   • Give the patient time to ask any questions.
   • Provide supplementary information for the patient to read about the proposed treatment and record in the patient’s medical record the information you provided.
   • Inform the patient of any relevant arrangements for monitoring, follow-up and review, including a further consultation if necessary.
   As the designated medical prescriber, consider whether the information you have obtained is sufficient and reliable enough to enable you to prescribe safely. If you consider it is not safe to prescribe, you should inform the patient of the reasons and document this in the patient’s medical records. Please refer to GMC Decision making and consent Nov 2020.
3. You must comply with GMC guidance in Good practice in prescribing and managing medicines and devices April 21, particularly relating to paras 21 – 26.Para 26 states: “You must carry out a physical examination of patients before prescribing non-surgical cosmetic medicines, such as Botox, Dysport, Vistabel or other injectable cosmetic medicines. Therefore, you must not prescribe these medicines remotely.”Remember, you are responsible for any prescriptions you sign. You are also accountable for your decisions and actions when supplying or administering medicines and devices. This responsibility continues when authorising or instructing others to administer medicines.
4. Maintain clear, accurate and legible medical records of every consultation. These should include detailed notes relating to the discussions with patients and any medication prescribed. Please refer to GMC Good medical practice, paras 19 -21.The records for each patient should be stored securely in accordance with the UK General Data Protection Regulation (GDPR). Please refer to PMP factsheet Storage and Retention of Medical Records, May 2021.
5. Do not prescribe botulinum toxin as a cosmetic injectable for young people under the age of 18 years unless medically required.Under the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, which will come into force in Autumn 2021, it is an offence for a person to administer botulinum toxin to a patient under the age of 18 years unless medically required. For the latter, the Act requires that botulinum toxin is only administered to a patient under 18 years old by a registered medical practitioner or a health professional.