Clinical Management Plan (CMP) for the Administration of Botulinum Toxin

Clinical Management Plan (CMP) for the Administration of Botulinum Toxin (Botox, Bocouture, Xeomin, Azzalure, Letibo) by Non-Prescribers Under Delegation

HAUS OF ÄSTHETIK

1. Purpose & Scope

This Clinical Management Plan (CMP) provides a structured, legally compliant, and clinically safe framework for the delegation of Botulinum Toxin administration to non-prescribing practitioners under the supervision of a registered prescriber at HAUS OF ÄSTHETIK. The CMP ensures treatments adhere to all applicable statutory regulations, professional guidelines, and best practices in medical aesthetics, providing clear patient safety protocols, competency requirements, and escalation pathways for adverse events.

This CMP applies to all brands of Botulinum Toxin Type A, including Botox®, Bocouture®, Xeomin®, Azzalure®, and Letibo®, when used for non-surgical cosmetic indications. It does not extend to therapeutic uses of Botulinum Toxin, such as for migraine, bruxism, hyperhidrosis, or medical conditions, unless explicitly prescribed and delegated by the prescriber in a patient-specific treatment plan.

All Botulinum Toxin must be prescribed following a face-to-face consultation by a registered prescriber and sourced exclusively from a registered aesthetic pharmacy. HAUS OF ÄSTHETIK will only obtain prescriptions from Church Pharmacy or Arce Pharmacy, ensuring full regulatory compliance, medication traceability, and patient safety.

This policy must be read alongside:

• CQC Regulation 12 (Safe Care & Treatment) and Save Face Guidelines

• General Medical Council (GMC), Nursing and Midwifery Council (NMC), General Pharmaceutical Council (GPhC), and General Dental Council (GDC) prescribing standards

• Royal Pharmaceutical Society (RPS) Competency Framework for All Prescribers (2016)

• The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 – Prohibiting treatment of under-18s

• HAUS OF ÄSTHETIK’s Safeguarding Policy, governing patient suitability and psychological considerations

 

2. Responsibilities of the Prescriber

The delegating prescriber holds full accountability for patient safety, prescription accuracy, and treatment delegation. The prescriber must:

Conduct a comprehensive face-to-face patient consultation, including full medical, social, and psychological history, ensuring suitability for treatment.

Identify and document potential contraindications, allergies, and medication interactions before authorising treatment.

Perform a thorough facial assessment, considering muscle movement, symmetry, and aesthetic goals to develop a tailored treatment plan.

Prescribe the correct brand and dosage of Botulinum Toxin, ensuring product traceability and suitability for the patient.

Ensure the patient provides fully informed, written consent, covering risks, benefits, alternatives, and potential complications.

Provide the delegated non-prescriber with a structured clinical treatment protocol, detailing:

   • Approved injection sites and dosage limitations per treatment area

   • Dilution guidelines and product handling instructions

   • Guidance for post-treatment care, complication management, and escalation procedures

Confirm the delegated practitioner has completed accredited training in Botulinum Toxin administration and is clinically competent.

Be available for escalation or intervention if complications arise during or post-treatment

 

3. Responsibilities of the Non-Prescriber

Non-prescribing practitioners must operate strictly within their scope of practice and formal competency assessment, under the supervision of a registered prescriber. They must:

Follow the prescriber’s exact treatment plan and dilution protocols, with no deviations.

Use aseptic technique, ensuring a sterile procedure to minimise infection risk.

Document the batch number, expiry date, and dilution ratios in the patient’s medical records.

Ensure the patient is positioned correctly and comfortable during treatment.

Monitor for immediate post-injection reactions such as hypersensitivity, vascular compromise, or adverse responses.

Follow up on patients post-treatment and report any concerns to the prescriber.

Refer any adverse events to the prescriber immediately for clinical intervention.

Adhere to HAUS OF ÄSTHETIK’s Safeguarding Policy, refusing treatment to:

  • Patients under 18, as per The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021

  • Patients with known contraindications (e.g., pregnancy, neuromuscular disorders, hypersensitivity to Botox components)

  • Patients with psychological vulnerability or Body Dysmorphic Disorder (BDD)

 

4. Patient Assessment & Treatment Plan

Inclusion Criteria

Adults 18+ years, seeking non-surgical cosmetic treatment with Botulinum Toxin.

Suitable for treating:

   • Glabellar lines (frown lines)

   • Frontalis (forehead lines)

   • Periorbital lines (crow’s feet)

   • Bunny lines (nasal wrinkles)

   • Gummy smile (excessive gingival show)

   • Masseter hypertrophy (jaw slimming) – only under prescriber delegation

Exclusion Criteria (Contraindications)

   Under 18s – Strictly prohibited under UK law.

   Pregnant or breastfeeding individuals.

   History of neuromuscular disorders (e.g., Myasthenia Gravis, Lambert-Eaton Syndrome).

   Active skin infections or compromised injection sites.

   Use of aminoglycoside antibiotics, anticoagulants, or muscle relaxants.

Treatment Protocol

   Dilution must follow manufacturer’s guidance (e.g., Botox® reconstituted with 0.9% NaCl).

   Injection site guidance must be strictly followed, ensuring safety and efficacy.

   Aspiration technique should be used in high-risk areas to avoid vascular compromise.

 

5. Emergency & Complications Management

Non-prescribers must be fully trained in early recognition and management of complications.

Immediate Complications (Within 30 Minutes)

Anaphylaxis: Administer IM Adrenaline 0.5mg, call 999, monitor airway and provide oxygen if available.

Vascular Compromise: Cease treatment immediately, apply warm compresses and massages, and refer to the prescriber for further management.

Delayed Complications (Post 24 Hours - 14 Days)

Eyelid Ptosis or Brow Drop: Advise Iopidine (Apraclonidine) eye drops under prescriber guidance.

Asymmetry or Aesthetic Concern: Review at 14-day follow-up; the prescriber must prescribe corrective treatment

 

6. Documentation & Record Keeping

   Prescriber’s name, registration number, and treatment authorisation.

   Patient’s full medical history, consent form, and psychological assessment.

   Batch number, expiry date, dilution ratio, and administration details.

   Injection sites and technique used.

   Complications and post-treatment follow-up plan.

 

7. Quality Assurance & Ongoing Training

   All non-prescribers administering Botulinum Toxin must undergo annual competency reviews and refresher training.

   Quarterly audits will be conducted to ensure compliance with delegation standards.

   An incident reporting system will monitor adverse events and drive quality improvements.

 

Conclusion

This CMP ensures the safe, ethical, and legally compliant administration of Botulinum Toxin by non-prescribing practitioners under the supervision of a registered prescriber at HAUS OF ÄSTHETIK. By aligning with CQC, Save Face, GMC, and NICE guidelines, this framework prioritises patient safety, practitioner accountability, and clinical excellence.

Failure to adhere to this Clinical Management Plan will result in immediate suspension of Botulinum Toxin administration privileges and regulatory review.