HEE Guidelines 2016

HEE Guidelines 2016

Professional qualifications are not only beneficial to a person wishing to become proficient in a specific subject – they create consumer and industry confidence.  Government regulations might insist on certain qualifications before a professional person is entitled to work legally for paid or even unpaid services, and indemnity insurance will almost certainly insist on evidence of the appropriate qualification.


You might think there is no industry more regulated than the medical and healthcare profession but the aesthetics and cosmetics business has been lacking in robust education, training and qualifications for a long time.  The dramatically increasing consumer demand for treatments such as BOTOX® and Dermal Fillers means a career working with these procedures is becoming highly desirable.  These two factors combined with unregulated practices are likely to lead to disaster for all concerned.


It wasn’t until the PIP breast implant crisis that the government took action on all forms of cosmetic surgery including minor or semi-invasive procedures such as BOTOX®.   While it was the breast implant product that was at fault, rather than the practitioners, the catastrophic consequences in the PIP case has produced one positive outcome.  Health Education England (HEE) was mandated to work with regulators, Royal Colleges and industry stakeholders to conduct a full review of the qualifications required for non-surgical cosmetic interventions.   The report, undertaken by Professor Sir Bruce Keogh, was published in April 2013 (The Keogh Review).  As a result of this review the HEE produced guidelines in two parts.  The announcement in January 2016 draws attention to Part 2 of the report which discusses recommendations, qualification details and changes since Part 1 which are expected to come into regulatory effect in September 2018.

About the report and updates to the qualifications requirements

From the Keogh Review: 

“People undergoing non-surgical treatments should be confident that their practitioner has the required skills and expertise to undertake the procedure successfully and safely.  The training and accreditation process should ensure that practitioners are able to identify and manage complications of treatment.  The curriculum and training requirements should be regularly reviewed to ensure that all practitioners are adequately trained in emerging procedures, this will involve regular retraining for those who wish to perform the latest treatments”.

The guidelines are designed to support overall improvements in the quality and standards of patient care.  The requirements apply to all practitioners, regardless of previous training and professional background on the basis that patient safety can only be assured if delivery of cosmetic procedures is carried out by practitioners who have had specialist training in the application, operation and maintenance of the product being used.  Practitioners must be able to recognise the emotional needs of a patient/client to help them make informed choices and assess the suitability of procedures that patients/clients request and redirect for alternative referral if appropriate.

The significant change in these guidelines is the required qualification for treatments on BOTOX® and Dermal Fillers.  You will find the detail of the change on page 13 of the Report Part 2 but in essence this outlines the new requirement as follows:

To raise the qualification level for Botulinum Toxin (BT) treatments to the upper face and non-permanent Dermal Fillers (DF) treatments for lines and folds (precluding complex zones) so that no treatments are able to be delivered until practitioners have successfully completed a qualification at level 7 (postgraduate level), at which point they would only be able to practise with clinical oversight.  This change was made for the following reasons:

  • In recognition of the high risks and complexity associated with BT and DF treatments, possibilities of complications and the need for practitioners to be able to recognise and manage medical emergency situations and minimise the risk of complications
  • In recognition of the difference between administering injections for drug delivery, eg vaccinations or intramuscular injections, and administering injections into the face to modify appearance and, in the case of BTs, alter the function of a specific muscle.
  • Because it is important for practitioners to be able to deal holistically with a patient/client who may require a combination of treatments which require qualifications at level 6 and 7, with the benefit of continuity of care from the same practitioner
  • Because practitioners need to make complex decisions and risk assessments regarding their treatment plans which requires learning at level 7.

Further recommendations will be coming down the pipeline with the likely formation of an accredited function led by a single national body to provide reassurance to:

  1. those purchasing training courses

Indemnity Insurance companies expecting reliable high standards of practice.

In a nutshell

The review and reporting has been a lengthy process, but in a nutshell here is how it all came about:

2010 – PIP Breast Implant crisis 2010

2013 – Department of Health via Health Education England (HEE) commissions a review of The regulations of Cosmetic Intervention, produced by Sir Bruce Keogh KBE (known as the Keogh Report)

2014 & 2015 HEE Report Part 1 = Covers review process and early findings

2015 HEE Report Part 2 = Covers greater detail on the qualficiations; updates to those suggested in Part one;  more definitive recommendations such as governing bodies and implementation dates

2016 HEE Guidelines – Concise document drawing attention to updates in HEE Part 2

What does this mean for the industry?

The new guidelines and, indeed, the updates to qualifications have received overwhelming support from the industry.  When you consider the number and variety of stakeholders involved in the reviews and guidelines it is heartening that so much evidence, anecdotal input and feedback has been thoroughly evaluated to produce a comprehensive set of guidelines and recommendations.  The reassurance that the world of cosmetics and aesthetics will become a better industry should only serve to improve the reputation and increase more business opportunities.

What will this mean for training?

All practitioners must now ensure they stay ahead of government regulations and in particular on training requirements – especially if certified qualifications are mandated.   Spot checking on clinics and practitioners may come into force at some point and indemnity insurance will most definitely be seeking evidence of the latest appropriate qualifications.

This means some clinics and individuals will need to take action and quite soon.  The new guidelines are expected to be set for regulation by September 2018.  This will impact on training organisations as they must learn to re-market who and how they target existing professionals and those with aspirations for a career in aesthetics treatments.  For those who currently have a medical bachelor’s degree (Level 6) it is clear that “fast-tracking” to becoming qualified in this area is an appealing option.

It is recommended that you familiarise yourself with the latest requirements from the HEE reports.  Do you have the required qualification standards and are you in need of updating your skills for the treatments you offer?  Reputable training centres such as Medical and Aesthetics Training Academy (MATA), that offer the latest training courses in accordance with government requirements will be sure to keep you informed and legal.

What will this mean for the consumer?

It seems Britain is set to lead the way in regulating the way we deliver aesthetic procedures from – the very complex surgical operations to minor treatments such as chemical peels.  For now, practitioners with good business integrity, these guidelines offer a best-practice solution, but we will all soon be strictly regulated which is exactly what is needed for the patient or client. Regular customers and those considering aesthetic treatments do have a responsibility to check that the practitioner or clinic has all the necessary qualifications and updated ones where necessary.  This means a little research on their part, but a good business can help a client by proactively providing the training and regulation evidence, registration numbers with accreditation websites etc. at their premises or on the own business website.  If everyone does their bit, patient/client trust will be easy to achieve making the service a more successful one on both sides.


For large organisations, small clinics and individual practitioners these regulations will undoubtedly have a significant impact but in the long term it will benefit all of these businesses.  The protection, safety and ultimately the trust of patients will be assured which is the government’s overarching objective.  All in all, the new guidelines and stricter legal regulations will elevate Britain’s aesthetics industry to be world class – and one we can all be proud to work in.