Preparing for AHPRA’s Cooling‑Off Periods & Consultation Requirements

Key Takeaways

• A mandatory 7-day cooling-off period applies to clients under 18 between consultation and treatment.
• No treatment (and limited payment) can occur until this period has passed, ensuring informed and considered decisions.
• All clients must have a doctor consultation (in-person or telehealth) before any Schedule 4 medications are prescribed.
• Practitioners must assess a client’s capacity to consent and ensure treatments are appropriate and in their best interests.
• Parental or guardian involvement is required for minors, and their views must be considered.
• Comprehensive information must be provided to support informed consent, including risks, outcomes, costs, and practitioner qualifications.
• Clinics should streamline processes with structured intake forms, documentation, and scheduling systems.
• Practitioners are responsible for identifying psychological concerns and referring clients when necessary.
• Understanding and integrating these requirements into workflows is essential for legal compliance and patient safety.

There has been significant discussion around new regulatory requirements in the cosmetic injectables industry. Practitioners who have completed cosmetic training courses in Australia must ensure they remain up to date with these changes.

Cooling-off periods are mandatory

If a potential client is under 18 years of age, there is now a mandatory cooling-off period of at least seven days between their initial consultation and any treatment. This protects minors from unnecessary procedures that could be influenced by outside factors such as peers or social media. It also gives businesses a chance to ensure that their minor clients understand all the risks and possible alternative treatments, and that they are suitable for treatment. It is the business’s responsibility to ensure that clients are psychologically well before undertaking any cosmetic injectables and refer them on to an appropriate independent health professional (a doctor or psychologist, not related to the business prescribing or conducting the cosmetic injectables) if there are any concerns. Any information provided to the client can be read through during this period and understood properly before they sign their consent. No payment should be taken before the cooling-off period has expired, unless it is for the initial consultation. Additionally, clients under 18 should discuss with their doctor why they wish to have any aesthetic medical treatment during this cooling-off period. By explaining this to a client and encouraging them to keep any appointments with other practitioners, the process can carry on uninterrupted.  

Consultations with the client

Any prospective client must have an in-person or telehealth consultation with a doctor prior to being prescribed any Schedule 4 medications. When treating a client under 18 years of age, the doctor prescribing the medications or the treating practitioner must be happy that the client has the capacity to consent to the treatment. Information about any treatment should be discussed during the consultation so the client has the necessary information for informed consent. The opinion of the parent or guardian must be taken into consideration, including whether they agree with the treatment being sought. A thorough holistic assessment would be made prior to any medications (cosmetic injectables, Schedule 4 Drugs) prescribed. If a procedure or treatment is not in the client’s best interests, the doctor should explain why and decline to perform it. Additionally, minors should not be treated with certain Schedule 4 Drugs, so if this is the case, it should be explained to the client and their parents or guardians. Knowing what these medications are is crucial. The client’s expectations also need to be discussed to confirm their realism. 

Streamlining scheduling

To make the process as smooth as possible while remaining compliant with guidelines and legislation, information that would support informed consent should be provided in writing during the initial consultation, discussed with the client and, if appropriate, their parent or guardian. 

This information should include: 

•     what the procedure involves, including pain management
•     the medications used and how much
•     risks, side effects, complications
•     expected results, both short- and long- term
•     the time frame to achieve these results (and/or how long the results should last)
•     financial expectations (including that treatments are not covered by Medicare)
•     post-treatment and follow-up care (including any further treatments and their costs)
•     the registration, training and qualifications of all practitioners involved in the treatment
•     how to make a complaint in a language that the client can understand. 

Intake paperwork should be completed prior to the initial consultation and include the client’s medications, conditions/illnesses, psychological and surgical history. Payment can be taken for this initial consultation, and the appointment can be booked. At the consultation, consent forms can be provided; they should include the information listed above to further simplify the process. The cooling-off period should be explained, and any referrals recommended and made. After the mandatory minimum seven-day cooling-off period, a second appointment can be made if the prescribing doctor is satisfied that all criteria have been met and the client has kept their appointments.

The mandated AHPRA cooling-off period is just one factor to consider when dealing with clients under 18. It is imperative that practitioners are fully aware of their obligations to both minor and adult clients. These include, but aren’t limited to, essential face-to-face or telehealth appointments prior to prescribing any Schedule 4 Drug, informed consent, ensuring the client is capable of consenting, and ensuring the treatment is appropriate. 

Conclusion

Understanding AHPRA requirements is essential for compliance and patient safety. Ongoing education ensures practitioners remain aligned with evolving regulations.

For guidance on training and compliance, contact the team.