Here is a model that operates widely. An injector who is not a prescriber wants to offer botulinum toxin. A prescriber, often a doctor, dentist, nurse or pharmacist, agrees to write prescriptions for that injector's clients. The prescriber may never meet the client. In some arrangements they receive a list. In others they hold a brief video call. In the worst, they simply sign.
The prescriptions are for named patients, so the paperwork can look correct. The problem is not paperwork. The problem is that the assessment which the prescription is supposed to record never happened.
What the guidance says
UK prescribing guidance has converged on this point. The GMC's prescribing guidance addresses remote prescribing and requires prescribers to satisfy themselves that they have an adequate assessment, access to relevant information and the ability to provide safe follow up. It states that injectable cosmetic medicines should not be prescribed by telephone, video link, online or at the request of others without a physical examination of the patient.
The Nursing and Midwifery Council's standards for prescribing, the General Pharmaceutical Council's guidance for pharmacist prescribers providing services at a distance, and guidance from prescribing bodies all point the same way. The Joint Council for Cosmetic Practitioners has taken the same position in its standards.
The consistency matters. This is not one regulator's preference. It is a settled professional position across the bodies that regulate everybody who can prescribe.
Why the assessment cannot be done remotely
The reasoning is practical rather than procedural. A prescriber prescribing botulinum toxin needs to examine facial muscle activity and asymmetry, to assess anatomy, to identify contraindications, to check for previous treatment and its effects, to assess whether the patient's expectations are realistic, and to consider psychological factors including body dysmorphic disorder. Several of those cannot be done through a screen or from a form.
There is also a responsibility problem. The prescriber remains responsible for the prescription they write. If they have not assessed the patient, they have taken on responsibility for a decision they were not in a position to make, and they have done so in exchange for a fee.
What you are entitled to at this stage
- To be assessed in person by the prescriber before an injectable prescription only medicine is prescribed for you.
- To know the prescriber's name and registration.
- To a copy of your records including the prescription, under a subject access request.
- To raise a concern with the prescriber's regulator about prescribing practice, whether or not you were harmed.
- To decline treatment where no prescriber has assessed you.
The prescriber remains professionally responsible for the prescription, whoever administers it.
What it means for you
If the prescriber never assessed you, three things follow.
The clinical decision was made on someone else's account of you. A contraindication you did not know to mention was never elicited, because nobody with the training to elicit it was in the room.
Accountability is diffused. When something goes wrong, the injector says they administered what was prescribed and the prescriber says they relied on the information given. Both positions are arguable, which is exactly the problem. See who is liable.
Insurance becomes uncertain. Indemnity for a prescriber may be conditional on prescribing in accordance with professional guidance. Prescribing contrary to it can put cover in question at exactly the point it is needed, which is covered in our guide to indemnity.
A consultation with the injector only, followed by treatment on the same day, with a prescriber mentioned only in the abstract or not at all. The absence of a named, present prescriber is the single clearest structural warning available in this sector.
How to find out what happened in your case
Ask directly, before treatment: who will prescribe, and will they assess me in person. If the answer is that a prescriber will review the paperwork, or that the clinic works with a prescriber remotely, you have your answer.
After the fact, make a subject access request for your records. The prescription, the prescriber's name and the record of any assessment should be there. If the records show a prescription issued on a day when nobody saw you, that is documented.
What a compliant arrangement looks like
It is not complicated. Either the person injecting you is a prescriber who assessed you, which is the simplest arrangement, or a prescriber assesses you in person, writes the prescription and directs the administration by a named person whose competence they are satisfied with. In both cases someone who could prescribe has looked at your face, taken your history and made a decision.
Clinics that operate this way say so plainly, because it is a genuine point of difference and it costs them money to maintain.
If it has already happened
Remote prescribing for injectables is a matter for the prescriber's regulator. A complaint to the GMC, NMC, GDC or GPhC about a prescriber who wrote a prescription for a patient they never assessed is a complaint about prescribing practice, and those regulators have taken action in such cases. You do not need to prove harm to raise a concern about prescribing practice, and the route is set out in how to complain.
Where the treatment also caused injury, the prescribing failure is often the most legally significant fact in the case, because it goes to whether the treatment should have been given at all.