On the back of the new MBA Guidelines, Dr Gabrielle Caswell, President of the Australasian College of Aesthetic Medicine, highlights what is required for ‘good medical practice’.

The new regulations released in April 2023 by the Medical Board of Australia came into force on 1st July 2023. Medically registered practitioners who work in cosmetic surgery and those who conduct aesthetic procedures now have clear guidelines concerning the MBA expectations and standards in this area of medicine. It is also important to note the updating of Telehealth guidelines and their use in cosmetic medicine requires regular patient review and contemporaneous medication scripting by the treating doctor who is responsible for the patient’s treatment.

The NSW government had earlier changed their requirements for cosmetic services with regards to scripting, consultations, medication storage and practice requirements. If offering medical procedures then a medical environment is required, using the NSW Amendments to the Poisons and Therapeutic Goods Regulation 2008, effective 1st September 2021 as template for good practice:

  • it is important to note the refrigeration requirements for the storage and monitoring of those medications that need to be stored at a specific temperature;
  • And perhaps most importantly the requirement for resuscitation equipment as well as trained personal.

Review of your practice surroundings then brings into question what is required to provide a medical practice environment:

Patient confidentiality

Cosmetic patients, like all patients in Australia, are reserved the right of confidentiality. The MBA guidelines outline what are the board’s expectations concerning patient interactions. It is important that as a practitioner you review the following:

  • History taking – a comprehensive history should be composed and evaluated by the medical practitioner responsible for the procedure;
  • Included in a complete medical history taking should be a psychiatric assessment by the treating aesthetic medicine doctor. If the doctor has concerns for a condition such as Body Dysmorphic Disorder (BDD), the practitioner is required to refer the patient for a psychological/psychiatric referral and review before treatment;
  • All information concerning the consultation should be stored to a medically accepted standard and kept for seven years (for adults) as per Medical Board Requirements;
  • Finally, all medical consultations should be conducted in a medical setting, with the privacy that setting affords patients.

Patient treatments

Patients should be treated in a medical setting which meets the expected standard for a medical setting. Included in this requirement are: cleaning and maintenance of the medical setting and treatment room to a good standard; good infection prevention and control mechanisms in place; and appropriately skilled staffing;

This requirement also includes the provision of correct refrigerated storage as well as resuscitation equipment, and trained staff to administer resuscitation if required.

Treatment room standards may vary between states and territories. A starting point, however, would be with your local council.

Licences and laws

Each state and then each council have a variety of guidelines and licences needed to conduct medical procedures. Some individuals believe that a ‘piercing licence’ (for example, tattoo or piecing services) covers injectables. Injectables are for the most part scheduled medications or devices requiring a script to be written for their use; they are a medical procedure. Therefore, an appropriate DA (development application) or use of a room or building is required for medical rooms.

Other things to note, include:

  • A licence to conduct traditional beauty services, as in a beauty clinic or spa, is not the same as required to conduct medical procedures.
  • Access for ambulances may be an issue, particularly in co-located services sharing the space within a beauty salon.

Your local council is a good place to start for information on their requirements for medical practice approvals. The council regulations will generally default to state or territory legislation and guidelines, which can often be reviewed online.

You will also need to be mindful of specific additional acts such as the NSW Poisons and Therapeutic Goods Regulation 2008, effective 1st September 2021, specifically with the ‘what, where and who’ regarding the administration of scheduled medications (ie, what type of environment is acceptable to the licensing authorities). Safe storage of scheduled medicines and devices (such as dermal fillers) as well as sharps and medication disposal are also considerations.

Finally, review who has access to a locked store, who is responsible for fridge monitoring (both electronic and manual is required) and what is the recommended procedure for your particular state or territory.

Schemes which accredit general practices are available for review and it should be noted that a general practice would not be accredited without the correct equipment and medications, included resuscitation equipment and medications. Doctors are aided by the PBS in the provision of emergency medicine but it is the responsibility of the practice to provide the necessary equipment to respond to an emergency, including a defibrillator.

Individuals who are not used to working in accredited environments and rooms may find some of the guidelines difficult to navigate. Below are a list of resources that may help:

Ultimately, for aesthetic medicine, the new MBA guidelines are a step towards better patient care and professionalisation of the practice. AMP

Dr Gabrielle Caswell
Dr Gabrielle Caswell is the President of the Australasian College of Aesthetic Medicine and Medical Director of Eyra Medical and Skin Clinic.
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