Policy for none Prescribers

Delegation of Administration of Prescription-Only Medicines Policy

HAUS OF ÄSTHETIK

Policy Statement

This policy governs the delegation of the administration of Prescription-Only Medicines (POMs) for non-surgical cosmetic treatments, ensuring full compliance with statutory regulations, professional standards, and patient safety protocols. HAUS OF ÄSTHETIK upholds the highest clinical governance standards as per CQC, Save Face, GMC, NMC, GPhC, and NICE guidelines, ensuring that delegation is conducted lawfully, ethically, and with due consideration for patient safety.

All delegated treatments must align with the Medicines Management Policy, Record Keeping Policy, and Complications Management Policy. This policy must be read in conjunction with the Clinic’s Safeguarding Policy to ensure the highest levels of patient protection, particularly regarding vulnerable groups.

Statutory bodies (GMC, NMC, GPhC, GDC) require that a face-to-face consultation with a registered prescriber is conducted before any prescription-only medicine is delegated for administration to a non-prescribing practitioner. Delegation is permitted only where the practitioner is competent, appropriately trained, and under direct or indirect supervision of the prescriber. All prescriptions must be obtained via a registered aesthetic pharmacy. HAUS OF ÄSTHETIK prescribers will source prescription-only medicines exclusively from Church Pharmacy or Arce Pharmacy, ensuring regulatory compliance, traceability, and patient safety.

Responsibilities & Competency Assurance

Responsibilities of the Prescriber

The delegating prescriber bears full clinical and ethical responsibility for ensuring that the delegated practitioner is competent to perform the procedure safely and effectively. Before delegating a treatment, the prescriber must:

Verify the qualifications, registration, and competency of the non-prescribing practitioner, ensuring alignment with professional standards.

Ensure the practitioner has undertaken formal accredited training relevant to the procedure.

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

Develop and document a Clinical Management Plan (CMP) that outlines the treatment protocol, contraindications, emergency procedures, and aftercare.

Obtain fully informed consent from the patient, ensuring that risks, benefits, and alternative treatments have been discussed.

Provide comprehensive treatment instructions, emergency response guidelines, and follow-up care information to both the practitioner and the patient.

Maintain clear written documentation of the delegation process, ensuring that the prescribed treatment is administered in line with regulatory guidance.

Be readily available for consultation, supervision, and escalation support if any complications arise.

Responsibilities of the Clinic Director

The Clinic Director (Managing Director of HAUS OF ÄSTHETIK) holds overall responsibility for ensuring:

Prescribers engaged with the clinic are fully qualified, registered, and compliant with regulatory standards.

Non-prescribing practitioners operate strictly within their scope of practice, experience, and formal training.

All delegated treatments follow clear governance structures, ensuring safety, ethical compliance, and quality assurance.

Regular audits, competency reviews, and staff training are undertaken to maintain the highest professional standards.

A robust mechanism for reporting, investigating, and managing complications is in place and reviewed regularly.

Requirements for Delegation of Prescription-Only Treatments

Before a non-surgical cosmetic procedure using a Prescription-Only Medicine (POM) can be delegated, the prescriber must meet the following requirements:

1️⃣ Conduct a comprehensive medical, social, and psychological history assessment ensuring no contraindications.

2️⃣ Confirm there are no medical conditions, allergies, or medications that may interfere with treatment.

3️⃣ Perform a physical examination of the treatment area, assessing suitability.

4️⃣ Identify and document clear indications for treatment, ensuring it is appropriate for the patient’s needs.

5️⃣ Ensure alternative treatment options have been discussed and explained.

6️⃣ Ensure the None-Prescriber knows the Clinical Management Plan (CMP) detailing the procedure, emergency management, and aftercare.

7️⃣ Obtain fully informed, documented consent from the patient, ensuring understanding of risks and benefits.

8️⃣ Provide written emergency instructions, including immediate complication management and escalation pathways.

9️⃣ Maintain accurate, secure, and GDPR-compliant patient records for medico-legal purposes.

🔟 Ensure the delegated practitioner has demonstrated competency, completed formal training, and is supervised appropriately.

Once a patient has undergone full clinical assessment, a registered nurse or appropriately qualified aesthetic practitioner may administer the procedure under delegation, provided they work within their assessed competence.

Safeguarding, Under-18s & Legal Compliance

HAUS OF ÄSTHETIK enforces a zero-tolerance policy for the administration of prescription-only aesthetic treatments to minors, in compliance with the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021. No delegation or prescription of POMs will be considered for individuals under 18, even with parental consent.

Practitioners must refer to the Clinic’s Safeguarding Policy if there are concerns about a patient’s psychological well-being, coercion, or vulnerability, ensuring compliance with CQC and Save Face safeguarding regulations. Patients presenting with potential Body Dysmorphic Disorder (BDD) or undergoing treatments for emotionally reactive reasons (e.g., post-breakup, post-trauma) must be clinically screened, and treatment may be declined if deemed inappropriate.

Documentation & Record Keeping

All delegated treatments must be comprehensively documented in the patient’s medical records, including:

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

Clear rationale for treatment, including full medical history, contraindications, and psychological assessment.

Details of the delegated practitioner administering the treatment.

Signed patient consent form, outlining risks, benefits, and alternative treatments.

Prescribed pharmacy details (Church Pharmacy or Arce Pharmacy) and batch number of medications used.

Emergency and follow-up care instructions provided to the patient.

Clear documentation of complications, adverse reactions, and escalation pathways.

Emergency & Complications Management

All delegated practitioners must be fully trained in:

Recognising and managing medical emergencies, including anaphylaxis and vascular occlusions.

Emergency reversal protocols for prescription-only treatments (e.g., hyaluronidase administration for filler complications).

Incident escalation pathways, ensuring immediate access to a registered prescriber if required.

Clinic-wide adherence to the Complications Management Policy, ensuring robust governance in adverse event reporting.

Quality Assurance & Annual Competency Reviews

Prescribers and delegated practitioners must undergo annual competency assessments to maintain compliance with regulatory standards.

Regular clinic audits will be conducted to review delegation practices, safety standards, and complication management.

A structured quality assurance mechanism must be in place to ensure ongoing patient safety, staff accountability, and clinical governance.

References & Further Reading

Professional standards as per GMC, NMC, GPhC, GDC regulatory bodies.

A Competency Framework for All Prescribers (Royal Pharmaceutical Society, 2016).

CQC Regulation 12: Safe Care & Treatment – Ensuring patient safety in aesthetic practice.

Save Face Guidelines – Standards for ethical, safe, and regulated aesthetic procedures.

Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 – Legal framework for under-18s.

Conclusion

HAUS OF ÄSTHETIK maintains the highest standards of patient safety, ethical practice, and regulatory compliance in the delegation of prescription-only aesthetic treatments. By ensuring all prescribers operate within a structured governance framework, and that delegated practitioners are trained, competent, and supervised, this policy upholds the principles of clinical safety, professional accountability, and best practice in medical aesthetics.

All prescribers and practitioners must strictly adhere to this policy to maintain compliance with CQC, Save Face, NICE, and statutory regulations.