Understanding Regulatory Requirements for Cosmetic Procedures in Dentistry and Medicine

Key Takeaways

• Client Safety Is the Priority
  Regulatory requirements for cosmetic injectables in both medicine and dentistry are designed to ensure patient welfare and uphold professional standards of care.
• Strict Advertising Compliance
  Advertising for cosmetic injectables must follow TGA and AHPRA guidelines. Promotions cannot imply that ageing or natural features are flaws, and must avoid terms like “quick” or “painless.” Photos must be unedited, and results cannot be guaranteed.
• Adherence to Board Guidelines
  Dentists and doctors must comply with their professional codes of conduct. Patient well-being must always come before profit, and requests outside a practitioner’s scope should be referred to appropriate professionals.
• Informed Consent Is Mandatory
  Practitioners must clearly explain treatment costs, risks, qualifications, and possible follow-up care. Patients must sign and receive a copy of their informed consent before treatment begins.
• Schedule 4 Drug Regulations
  Cosmetic injectables are prescription-only medicines. Prescribing, storage, and administration are governed by state and territory laws. The prescriber remains responsible for the patient’s care even if another practitioner administers the treatment.
• Continuity of Care and Practitioner Responsibility
  Doctors and dentists must arrange follow-up care, manage complications, and ensure all assisting practitioners are appropriately qualified. Accountability remains with the prescriber unless the patient is formally transferred.
• Ongoing Education and Insurance Are Essential
  Practitioners must complete accredited injectables training before offering these services and maintain professional indemnity insurance to cover all aspects of their cosmetic practice.

There are many reasons a practising dentist or medical doctor might want to add a cosmetic injectables service to their clinic. Once the practitioner has deliberated and decided, researched what treatments they might want to specialise in and how to market this in their local areas, the next logical step is to undertake a course so their existing skills and scope can be broadened to incorporate these offerings. A part of this step is understanding the regulatory requirements for cosmetic procedures in dentistry and medicine; these requirements are designed to place the “client’s welfare first and foremost”.

Advertising requirements for cosmetic injectables

When advertising cosmetic injectables, it is crucial to comply with the guidelines that have been recently released. These guidelines have been created to protect the public and must be strictly observed. Guidelines include wording and presentation of advertisements. For example, it is not permitted to allude to, or state outright, that a natural body process is unflattering and should be erased by utilising cosmetic injectables. 

Advertisements must not include people singing or dancing; they should not minimise or trivialise a procedure by using words such as “fast”, “painless” or “easy”. Advertisements must be factual and present side effects and state clearly that individual results may vary from person to person. Photographs used must not be airbrushed, and before shots should be taken in as similar conditions as the after shots as possible. If one is working in a cosmetic injectables business, they are responsible for their advertising, adhering to the guidelines.

Dental and Medical Board Guidelines

It is expected that practising dentists and medical practitioners should already be complying with their relevant board’s codes of conduct, and as such, adhering to the new non-surgical cosmetic guidelines won’t be a huge stretch. For example, placing the patient before profits and ensuring procedures are not minimised or sexualised is already expected from dentists and doctors. For medical practitioners, especially, they are already expected to be aware of a patient’s mental state regarding requested treatments, and this also applies to cosmetic injectables. 

The medical practitioner must adequately assess the patient to ensure they are safe to undergo treatment, and review them each time the Schedule 4 medication is prescribed. This can be in person or via telehealth. The option to not have the procedure should be offered, as should the choice to have the procedure with another practitioner. A patient desiring cosmetic injectables will need to be referred by a General Practitioner. A dentist should only practice in keeping with their scope and be ready to decline a patient whose requests fall outside this scope – and refer them to a practitioner more appropriate. 

Informed Consent

A medical practitioner must obtain informed consent from each patient, and this includes explaining that cosmetic treatments are not covered by Medicare, as well as the exact costs of each treatment, the treating doctor’s training and qualifications, and the possibility of further treatment either in the short or long term (such as antibiotics or surgical removal of injectables). This informed consent must be understood by the patient and a signed copy provided to them. 

Prescribing and administering schedule 4 drugs

The dentist or medical practitioner must abide by their relevant state or territory legislation when it comes to prescribing, storing and administering the schedule 4 drugs that are used in the cosmetic injectables industry. The transportation and supply of these drugs are also closely regulated. As a practitioner, this knowledge should already be well known, and differences from state to state should be understood.

In Victoria, for example, a dentist is not permitted to prescribe or supply certain drugs used in cosmetic injectables unless it is for dental treatment specifically. If the prescribed drug is administered by another practitioner who does not have prescribing rights, for example, a Registered Nurse, the doctor or dentist is still responsible for the patient’s management, including post-procedure. 

Other professional responsibilities 

The medical practitioner is responsible for arranging care in the case of complications and is responsible for the patient until they are under the care of another practitioner or a hospital. Additionally, the doctor or dentist is responsible for ensuring that any other treating practitioner is appropriately trained, qualified and experienced, if caring for a patient. 

Unless a patient is formally referred to another registered health practitioner, the medical practitioner prescribing the injectables or performing the procedure retains responsibility if another party either assists the medical practitioner or completes a part of the procedure independently. If a doctor or dentist decides to begin offering cosmetic injectables in their facility, they must undertake the appropriate training before performing any procedures or prescribing any injectables. Of course, appropriate insurance is essential.

Part of studying cosmetic injectables is learning about what applies to your profession. It is essential to be aware of the regulations.