The JCCP is delighted to confirm that the Nursing and Midwifery Council (NMC) has determined that ‘The NMC is updating its position on the remote prescribing of non-surgical cosmetic medicines, including certain anti-wrinkle injections and aesthetic emergency kit items.

From 1 June 2025, nursing and midwifery prescribers will be required to consult with people face-to-face before issuing prescriptions for these procedures.

We expect all nurse and midwife prescribers to deliver safe and effective prescribing practice every day, but inconsistent regulation of non-surgical cosmetic practice can present risks to people who use these services and the public. Face-to-face consultations support the mitigation of these risks, and adopting this position will better align the NMC with other health and care regulators.

The JCCP has persistently and consistently called upon the UK Government (since 2019) and the associated Government Professional Statutory Regulators responsible for the regulation of all Prescribers to prohibit the practice of remote prescribing for medicines used as part of any form of elective non-surgical cosmetic procedural process.

The JCCP published revised guidance on this subject in June 2022 and at that time advised that ‘The JCCP and the CPSA (The Cosmetic Practice Standards Authority) have set down their decision not to endorse or permit the remote prescribing of any injectable prescription medicine and medical device when used for non-surgical cosmetic procedures. When the prescriber delegates the procedure to other practitioners, then the JCCP reminds the prescriber that the duty of care for the patient remains with the prescriber and the decision to prescribe must be compliant with the MHRA regulations and the Professional Statutory Regulatory Body guidance on remote prescribing. For the avoidance of doubt this guidance applies to the routine/planned administration of medicines or medical devices which are used for non-surgical cosmetic procedures, such as but not limited to, botulinum toxins, injected local anaesthetic, dermal fillers, hyaluronidase, tissue stimulants, vitamin infusions and injections, and agents used for lipolysis. Prescribers must not therefore prescribe such injectable medicines and devices for non-surgical cosmetic use by telephone, video link, online, at the request of others, for patients whom they have not examined personally ‘face-to-face’.

The NMC confirmed that their position is ‘consistent with the requirements of the RPS Prescribing Competency Framework and the High level principles for good practice in remote consultations and prescribing which includes the requirement that healthcare professionals make patient safety their first priority and ensure that adequate clinical assessments are always undertaken’.

The JCCP advises that ‘adequate clinical assessments’ must be undertaken face-to-face with the patients and must include the assessment of the patient’s physical, emotional and psychosocial holistic presentation, needs and expectations.

 

The JCCP also reminds prescribers that we do not consider an initial face to face consultation to have met the requirement for all future prescribing decisions. A cornerstone of prescribing practice is the requirement for shared decision making. If treatment is ongoing there should be clear arrangements in place to review decisions regularly, allowing patients the opportunity to ask questions and discuss any concerns. A follow up face to face consultation is therefore required at the discretion of the prescriber, but at a minimum whenever:

 

•  A new medicine is prescribed
•  There is a change to the dose of a previously prescribed medication
•  There is a change to the medical history of the patient
• There is an adverse incident.
• More than 6 months have passed since the last consultation

 

When the prescriber is considering issuing a repeat prescription in the absence of a further face to face assessment of the patient, they must satisfy themselves that none of the above conditions apply and that mechanisms are in place to make an accurate assessment of these conditions.

Professor David Sines CBE and Andrew Rankin, Co-Chair of the JCCP’s Clinical Advisory Group (CAG) advised ‘The JCCP has campaigned rigorously for professional statutory regulators to embargo and sanction the use of remote prescribing for non-surgical elective procedures. We consider that the cessation of such practices is a central requirement to ensure patient safety and public protection within the context of any future scheme of statutory licensing and regulation for the aesthetics sector in the UK. We warmly welcome the NMC’s decision to require all their registered Independent Prescribers to undertake appropriate face-to-face clinical assessments before prescribing medicines associated with elective non-surgical cosmetic procedures’.

The NMC Press Release may be accessed here

The JCCP is a charitable organisation primarily concerned with public safety across the cosmetic sector. It is the recognised body responsible for oversight of the HEE cosmetic qualifications’ framework. The JCCP works through partnership agreements with a range of UK regulators, professional membership organisations and stakeholder groups and has significant experience in the application of diverse regulations and standards to the cosmetic sector.

29^th April 2025