Cosmetic Surgery Standards FAQ

• Is female genital cosmetic surgery (FGCS) covered?
• Is male genital cosmetic surgery (MGCS) covered?
• Is refractive surgery included within the scope of your work?
• Why are hair transplant procedures not included?
• Why are dental cosmetic surgical procedures not included?
• Who is leading on the Keogh recommendations relating to non-surgical cosmetic interventions? 

Is female genital cosmetic surgery (FGCS) covered?

Not at the current time, but procedures may be included in the future. We are aware of the ethical issues regarding FGCS, in particular the ambiguity around the legal status of some of these procedures. We appreciate that for some patients FGCS may benefit the physical and emotional well-being of the individual concerned, and may therefore be medically indicated. We recommend surgeons to consult The Royal College of Obstetricians and Gynaecologists (RCOG) web site before considering performing FGCS.

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Is male genital cosmetic surgery (MGCS) covered?

Not at the current time. Procedures may be included within the scope of our work in the future, subject to endorsement by the British Association of Urological Surgeons (BAUS).

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Is refractive surgery included within the scope of your work?

No. The Royal College of Ophthalmologists (RCOphth), as the professional body for setting the standards for this area of practice, is leading the work to improve standards in refractive surgery.

The RCOphth defines refractive surgery as an operation to reduce a person’s dependence on spectacles or contact lenses, or improve their quality of vision. It is intended to improve a patient’s quality of life so they can lead a healthy, active lifestyle.

Examples of procedures include:

• laser corneal reshaping (laser eye surgery)
• incisional corneal surgery (astigmatic and radial keratotomy)
• corneal implants (presbyopic inlays and ring segments)
• scleral expansion and laser surgery for correction of presbyopia
• refractive cataract surgery and lens exchange (multifocal, accommodating, toric and conventional intraocular lenses)
• secondary and piggyback intraocular lens implantation
• phakic intraocular lens implantation

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Why are hair transplant procedures not included?

We recognise that hair transplants are categorised as level 1b treatments under the definitions in RCS Professional Standards for Cosmetic Practice (January 2013). However, the majority of practitioners who currently perform these procedures come from a non-surgical background, and we cannot set standards for non-surgeons. For that reason, Health Education England (HEE) is covering these procedures within its programme of activity.

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Why are dental cosmetic surgical procedures not included?

Keogh’s review noted that there remain concerns about cosmetic dentistry and suggested that ministers may wish to consider a further review in this area. The three UK faculties of Dental Surgery and the Faculty of General Dental Practice (FGDP) support this recommendation, as does the College.

Therefore at the present time our remit does not extend to dental cosmetic surgical procedures. 

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Who is leading on the Keogh recommendations relating to non-surgical cosmetic interventions?

The scope of our work, as recommended in the Keogh Review and set by the government response, does not extend to non-surgical cosmetic procedures for example Botox, dermal fillers and chemical peels.

Health Education England (HEE) has been leading the programme of work related to non-surgical cosmetic procedures. You can find out more about HEE’s work on their website.

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• I have been performing cosmetic surgery for years, why should I apply to be certified?
• Do individuals performing cosmetic surgery in the NHS need to certify?
• Will surgeons from abroad be able to apply for certification?
• How does certification assess the quality of care provided?
• What if my appraiser does not perform cosmetic surgery?
• Why is there a requirement to provide evidence of professional behaviours?
• What will the masterclass cover?
• Who will deliver the masterclass?
• Why does certification include a requirement to have indemnity insurance which covers cosmetic practice in the UK? 
• How will general surgeons and ophthalmic surgeons provide evidence of a declared specialist interest?
• What will the case review involve?
• Will certification be underpinned by legislation/regulation?

I have been performing cosmetic surgery for years, why should I apply to be certified?

This new system of certification will make the cosmetic surgery industry safer for patients and enhance the reputation of the profession.

We urge all eligible surgeons who perform cosmetic surgery to apply to be certified so they can demonstrate high professional and clinical standards in their area of practice. This is an opportunity for surgeons to show the quality of the care they offer.

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Do individuals performing cosmetic surgery in the NHS need to certify?

We have set the standards required in order to perform cosmetic surgery independently in the private sector. It will be for each NHS Trust to decide whether they want to include this requirement when employing surgeons to perform cosmetic surgery.

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Will surgeons from abroad be able to apply for certification?

Yes. They will need to meet the same requirements as a UK based surgeon in order to certify.

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How does certification assess the quality of care provided?

Revalidation is the mechanism that the General Medical Council (GMC) uses to ascertain whether or not a doctor is up to date and fit to practice in their chosen field. In order to certify, a surgeon will need to demonstrate that their outcome results have been discussed as part of whole-practice appraisal and revalidation. In addition, surgeons will need to demonstrate they are compliant with Competition and Markets Authority's (CMA) requirements in relation to information about performance.

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What if my appraiser does not perform cosmetic surgery?

We recognise that in some cases revalidation is carried out by colleagues who do not practice in the same area of interest. To support the appraisal and revalidation process we will produce specific guidance for appraisers of surgeons undertaking cosmetic surgical procedures.

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Why is there a requirement to provide evidence of professional behaviours?

The Keogh review highlighted that the area of professional behaviours and communication is frequently the subject of concern and complaints from patients. There are complex issues for cosmetic surgery in the private sector, such as consent, patient selection, ethical marketing and continuity of care.

Therefore demonstration of knowledge and skills in this area is included as an integral part of the certification process.

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What does the masterclass cover?

Professional and ethical aspects of practice including the relationship with the patient are the most common reason for unsatisfactory outcomes in cosmetic surgery. The content of the masterclass focuses on these aspects of practice and reflects the GMC guidance for all doctors who offer cosmetic interventions and the RCS professional standards for cosmetic surgery

The course and identifies the specific points where there is risk of a poor outcome, the more common reasons for patient dissatisfaction and strategies to reduce risk. The masterclass also covers areas such as consent, management of patient expectations, ethical marketing, record keeping and revision surgery. It aims to encourage reflection on practice, shared learning and exchange of experience with other surgeons.

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Who will deliver the masterclass?

For details of upcoming courses, view the information on cosmetic surgery certification 

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Why does certification include a requirement to have indemnity insurance which covers cosmetic practice in the UK?

It is a legal requirement and a condition of holding a licence to practice that a doctor has appropriate indemnity cover so that their patients will not be disadvantaged if they make a claim about the clinical care they have received in the UK. In order to certify, surgeons are required to have professional indemnity insurance, which specifically covers their cosmetic practice.

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How will general surgeons and ophthalmic surgeons provide evidence of a declared specialist interest?

Surgeons will be asked to provide information on the full scope of work, including but not limited to their cosmetic practice, and to share their job plan which was valid during their most recent appraisal.

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What will the case review involve?

Surgeons will be asked to provide reviews of four complex cases in which they participated and the learning they achieved. Full details are available in the certification application guidelines  

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Is certification underpinned by legislation/regulation?

Certification is a voluntary process. Patients and services will be able to search for a certified surgeon on the RCS website. In time, we hope that certification will link to the GMC’s proposals for credentialing and we are lobbying the government to make this necessary legislative change.

We believe that the overwhelming reason for creating a credential is to protect patients. We support GMC credentials in areas of medicine which fall outside recognised medical specialties or in areas where there is a lack of existing regulation and patients are vulnerable, such as cosmetic surgery. To ensure alignment with current curricula requirements it is our view that credentials should only be developed by the relevant medical royal college or faculty, along with their associated Specialist Advisory Committees.

Serious or persistent failure to follow the GMC's guidance puts a doctor’s registration with the GMC at risk.

We want providers of cosmetic surgery to use certified surgeons. The Care Quality Commission (CQC) is the independent regulator of health and adult social care services in England. The CQC makes sure services provide people with safe, effective, compassionate, high-quality care and CQC will take our standards into account when inspecting and rating services.

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• Who is responsible for collecting these data?
• How do the Clinical Quality Indicators for Cosmetic Surgery link with the CMA requirements?
• Some of these data items are not in the CMA requirements; do I still need to collect them?
• What if I can’t collect some of the items within the RCS dataset?
• Will the College be collecting these data?
• Who will be analysing these data?
• Will I receive a report on these data items for my service?
• How have the data items listed in Clinical Quality Indicators for Cosmetic Surgery been developed?

Who is responsible for collecting these data?

All services that provide cosmetic surgical care within the UK should be working towards collecting these data items. These items relate to surgical procedures only, not procedures such as Botox injections or dermal fillers.

The mandatory data items are listed as Competition and Market's Authority (CMA) requirements, and in this case the responsibility lies with the service provider.

The RCS dataset includes additional items that have not been mandated by the CMA. These data items are recommended as best practice and both surgeons and providers of cosmetic surgery should work towards collecting these as soon as possible, to ensure that appropriate data are collected to support audit and quality improvement. These data should be used for personal appraisal and will also support monitoring as part of the CQC’s inspections.

Read more about the CMA's requirements and PHIN.

How do the Clinical Quality Indicators for Cosmetic Surgery link with the CMA requirements?

The Competition and Markets Authority (CMA) requirements for data collection for independent healthcare providers are more extensive than those listed in the RCS Clinical Quality Indicators for Cosmetic Surgery and are legally mandated.

There are additional items listed in the RCS dataset that have not been included within CMA requirements. These data items are recommended as best practice. If you or your service is not able to collect these data, you should be working towards doing this as soon as possible.

Where the items are the same as those within the CMA requirements this is noted within the document.

Some of these data items are not in the CMA requirements; do I still need to collect them?

You are not legally required to collect all the data items listed in the RCS dataset for cosmetic surgery, although this is recommended as best practice.

What if I can’t collect some of the items within the RCS dataset?

Data items that are also listed as CMA requirements are mandatory.

Others are considered best practice. If you or your service is not able to collect these data, you should be working towards doing this as soon as possible.

Will the College be collecting these data?

No. The Royal College of Surgeons, in collaboration with the relevant surgical specialty associations, has set the standard for data collection that will support quality improvement and reflect best practice in cosmetic surgical care, but we will not be collecting these data.

Who will be analysing these data?

The Clinical Quality Indicators for Cosmetic Surgery sets out how data collection is anticipated for each metric. Many of these items will be included in routine collection by service providers that will be submitted to PHIN. PHIN will then be publishing specific performance measures from mid 2018 at a service and consultant level.

Data items listed which state ‘local collection’ should be collected and analysed locally through audit.

Will I receive a report on these data items for my service?

Reports reflecting practice at service and clinician level will be available for those data items that are being collected by PHIN and this will be in the public domain. Those items listed as ‘local collection’ will have to be reported on locally.

For further information go to the PHIN website.

How have the data items listed in Clinical Quality Indicators for Cosmetic Surgery been developed?

The data items have been developed by consensus. Representatives from key surgical specialty groups and other stakeholders have been involved including patient representatives, the Care Quality Commission (CQC) and the Private Healthcare Information Network (PHIN).