THE HEE REPORT: THE IMPLICATIONS OF NEW GOVERNMENT QUALIFICATION STANDARDS FOR BEAUTY THERPISTS AND NON-MEDICAL AESTHETIC PRACTITONERS
On January 8th 2016 the Department of Health published the Health Education England Report outlining a new framework of qualifications from Levels 4 – 7 relevant to all beauty therapists working, or looking to work, in the clinical skin care sector. While many of you may find the recommendations of this publication unnerving in respect of your professional position, I would like first of all like to emphasise its importance, not just to the safety of clients but equally to the future status and reputation of advanced beauty therapists offering clinical grade skin rejuvenation treatments and light therapies.
Whether we like it or not, if we are to continue to work within the multi-disciplined medipsa sector, we have to evidence advanced knowledge and practical skills and show compliance in line with the new government guidelines. This is vital if we are to to secure the trust of the public and the respect of the medical aesthetic community in which we can play an important role.
Which treatments are covered in the HEE Report?
The treatments reviewed in the HEE report at therapist level include chemical peels, micro-needling, non-injectable mesotherapy, laser/IPL and LED while the provision of non-surgical treatments such as Botox and Fillers remains within the post graduate Level 7 and requires medical qualifications. Other treatments, referred to in the report as ‘orphan’ or ‘out of scope’ procedures, are implicated for future attention. This group implicates blemish removal by advanced electrology or cryotherapy, radio frequency, ultrasound, tattooing, micro-pigmentation and cryolipolysis.
Industry driven self-regulation
The new qualification framework sets out very clear recommendations for the standardisation of education and training at higher levels and, while this is not as yet a legal requirement, this marks the beginning of industry self regulation. This will rightly put pressure to on everyone providing advanced skin procedures to comply and become properly qualified in order to ultimately ensure the safety of clients or patients.
This is a vital move towards the regulation of our industry and no beauty therapist who wishes to continue to offer these advanced skin treatments can afford to ignore it.
It may well be that you may be thinking that if no law on this has yet been passed why should you be concerned? However, a better question you should ask yourself is, what will happen if you don’t comply? The answer really lies in the fact that the call for formal qualifications and regulation is strongly industry driven and not just a notion of a government minister. The HEE report has been compiled following intensive consultations with professional bodies, regulatory bodies, universities and private training providers, insurance companies awarding bodies and individual practitioners from the specialist fields of plastic and reconstructive surgery, aesthetic medicine, medical laser authorities, cosmetic nursing, dentistry, pharmaceuticals and higher education.
Supplier driven training is no longer enough
Many therapists who are already providing advanced skin treatments will have received considerable training from product or equipment suppliers and have extensive experience in the field. It is very natural to question why there is a need to do further training or embark on a formal education program. The answer here is that, while many companies do indeed provide excellent training, the standards are inconsistent and the content of such short courses cannot be measured against the rigour of an Ofqual accredited curriculum and the formalization of knowledge and competency assessment.
A message to the public
The publication of the HEE report emphasises the call for higher level qualifications and standardization of clinical practice to ensure client or patient safety. We can be sure that the media and the industry regulatory bodies will send a potent message to the public in respect of who they should go to for advanced clinical skin treatments and laser procedures. The potential for legislation is equally referred to in this quotation from the Department of Health in their review document:
“Throughout our meetings, discussions and correspondence with stakeholders from all groups, professions and experts, the call has been for a new legislative framework. Taken together, our recommendations provide that framework for both surgical and non-surgical interventions.”
So how will all of this affect you?
Whether you are an individual beauty therapist, a clinic owner, an educator/trainer or have any related clinical role in the sector, these new standards are, sooner or later, going to affect your career prospects or the future of your business. In terms of job opportunities, the demand for higher level qualifications is inevitably going to be a pre-requisite moving forwards. Equally, once employers, particularly the larger clinic groups, begin to shout about the fact that they only employ Level 4+ beauty therapists, smaller businesses will be under pressure to give their clients the same assurance. The message here is not to allow your competitors to get ahead of you. Be seen to be at the top of your game and representing the best practices of our industry.
Implications for Insurance
There is the further question relating to professional indemnity insurance – how will the insurers react? Having spoken to a number of insurance companies, the issue is all about their assessment of risk. Many of them are already saying that they will only insure laser practitioners with a Level 4 Qualification in Light Therapies as they knopw that they have the appropriate knowledge base and have been assessed to be clinically competent. We can only speculate, at present, on whether they will make the same exclusion for the provision of skin rejuvenation treatments. However, it is fair to presume that underwriters may indeed regard those without the government recommended level of qualifications in skin treatments to present a higher risk. This could well result in your premiums being higher or that you may not be covered for certain treatment provisions.
The qualification framework
The qualification framework itself is too large a study for us to examine in full here. However in brief the implications are:
- Provision of chemical peels from very superficial epidermal ( stratum corneum only) down to the Grenz Zone ( Dermal- Epidermal Junction) will be at Levels 4 – 6 depending on the depth of peel penetration, implicating the consideration of pH levels as well as peel agents and their percentage strength.
- For the application of manual dermal rollers, 5 mm needling sits at level 4, 1.00mm at Level 5 and, at Level 6 you will be qualified to provide needling at 1.5mm with a manual roller or stamp on the face or body and at 1.00mm with a mechanised micro-needling device.
- In terms of laser and IPL treatments, hair removal is at Level 4 together with non-ablative photo-rejuvenation treatment. Tattoo removal and the treatment of vascular lesions is at Level 5 and ablative fractional laser procedures together with the treatment of hyperpigmentation are at Level 6. All of these procedures exclude treatment with the peri-orbital rim.
- Level 7 is for postgraduate / medical professionals and includes procedures such as injectable treatments, phenol peels, fully ablative laser and laser treatment within the peri-orbital area.
Medical oversight at level 6
A further element of the requirements outlined in the report deals with the demand for clinical oversight of beauty therapists and other non-medically qualified practitioners who are delivering Level 6 treatments. I understand the concerns that some advanced therapists will have about this but again I would urge a positive viewpoint.
First of all, having asked to Carol Jollie of HEE how this oversight provision would look, I am advised that at the moment this will be open to individual interpretation and further debate. However the indication at the moment is it does not mean that you have to work directly with a doctor, nurse or other clinician on your premises but to ‘have access to and support from’ a medical professional. Therefore a skin care clinic without existing medical provision would need to affiliate themselves with a medically qualified practitioner to whom they can refer for advice and who can assist them in cases of complications or adverse reactions to treatment. It also provides the capability for prescription medication when required. Certainly this can only be reassuring to any practitioner, and their clients, in respect of the more invasive skin treatments and for any therapy based business this will undoubtedly give enhanced credibility.
The publication of the HEE report represents a positive way forward for our industry and for therapists around the UK who work ethically, knowledgably and skillfully and who wish to be fully valued and respected for the high quality services they provide. While we will no doubt never get rid of the ‘cowboys’ and ‘bargain basement’ mentality of some individuals, we can at least separate ourselves from their poor reputation and establish a higher echelon of professionalism that the public, and our peers in the aesthetics sector, will recognise.
URL Link to the HEE Reports Part One and Two:
You can view the full report by going to the following web link: https://hee.nhs.uk/news-events/news/new-qualifications-unveiled-improve-safety-non-surgical-cosmetic-procedures