The Australasian College of Cosmetic Surgery
Raising Standards, Protecting Patients
31 August 2012
Australian Commission on Safety and Quality Health Care
Open Disclosure Program
GPO Box 5480
SYDNEY NSW 2001
Re: Australian Open Disclosure Framework – Consultation Draft
The Australasian College of Cosmetic Surgery welcomes the opportunity to provide
comment on the Australian Commission on Safety and Quality Health Care
(ACSQHC) Australian Open Disclosure Framework – Consultation Draft.
The ACCS believes in the goals and philosophy of the open disclosure program and
supports the draft guidelines, though the College wishes to suggest that it is
important to emphasise this philosophy particularly strongly in the context of elective
procedures, where there is a much higher ethical threshold for effective doctorpatient communication.
These concerns are particularly germane in the context of cosmetic medicine and
surgery, where, due to the elective and largely self-referral nature of these
procedures, there is a far greater need to ensure that patients seeking such services
have the necessary information in order to make informed decisions.
As the ACSQHC has noted,
Patients have expectations about their health care and about actions that
might follow patient harm. These expectations are not only about the medical
care patients receive, but about their entire experience during medical care.
All Correspondence To: PO Box 36, Parramatta, NSW 2124
Registered Office: Level 2, 96 Phillip Street, Parramatta, NSW 2150
Tel: 1800 804 781
Fax: 02 9687 1799
www.cosmeticsurgery.org.au admin@accs.org.au
ABN 890 863 834 31
ACCS response
ACSQHC Australian Open Disclosure Framework – Consultation Draft
31 August 2012
This is very relevant in the case of elective procedures such as cosmetic medicine or
surgery, where the harm caused to a patient may be that their expectations have not
been realised as result of the procedure they have had.
In this respect, the College has put a very strong emphasis on the importance of
patient communication and informed consent. The College’s Code of Practice
prescribes and prohibits a range of communications by its Fellows that are aimed at
improving patient communication and informed consent before treatment and
providing additional pathways for patient redress afterward should they have
concerns or feel that they have been harmed due to poor communication.
The College’s Code of Practice may be found on the College’s website, at:
http://www.accs.org.au/pdf/accs_code.pdf
Once again on behalf of the ACCS, I extend our appreciation to the ACSQHC for its
efforts in producing the Consultation Draft and for its invitation to the College to
provide comment and advice. Should you have any questions or require additional
information from the College, please do no hesitate to contact me or
Alan R.M. Jones, our director of regulatory affairs and government relations.
Yours sincerely
Dr Colin Moore FRCS FRACS FACCS
President
Attachments
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ACCS response
ACSQHC Australian Open Disclosure Framework – Consultation Draft
31 August 2012
Purpose of the College and background
The College’s goal is to ensure the safe provision of cosmetic surgery and cosmetic
medical procedures to the Australian community through the supply of appropriately
trained and certified medical practitioners.
Cosmetic Medical Practice, which encompasses the scope of practice of cosmetic
surgical and medical procedures, is a well defined and unique medical specialty,
practiced by medical practitioners from various specialties including dermatology,
general surgery, general practice, plastic and reconstructive surgery, oral and
maxillofacial surgery, ophthalmology, otolaryngology and gynaecology. The factor
which unifies this divergent group of practitioners is that they all need to obtain
additional specialised education, training and experience beyond their original area
of postgraduate specialisation before becoming competent in cosmetic medical
practice.
The ACCS defined Cosmetic Medical Practice as:
Operations, procedures and treatments that revise or change the appearance,
colour, texture, structure or position of normal bodily features with the sole
intention of improving the patient’s appearance or self-esteem.1
The proposed specialty is distinct from other specialty areas such as plastic and
reconstructive, dermatology or general practice – whose members may also perform
cosmetic procedures – in that no defined medical abnormality need be present. In
that sense, the proposed specialty is sui generis among all medical specialties.
Cosmetic Medical Practice uses non-invasive and invasive procedures to enhance
an individual’s appearance according to the patient’s own subjective criteria. The
success or otherwise of treatment is judged by whether the patient’s expectations
have been met. This is also different from all other areas of medicine, where
objective outcome criteria such as morbidity and mortality rates exist. Uniquely, the
majority of cosmetic patients, do not have any pathological condition or, as in
obstetrics, a condition which is potentially so. But they require careful physical and
psychological assessment by an appropriately trained and experienced practitioner
1 Adapted from definition adopted by the UK Department of Health. Expert group on the regulation of
cosmetic surgery: report to the Chief Medical Officer, January 2005, p. 3. And see e.g. Provision of
cosmetic surgery in England: Report to the Chief Medical Officer Sir Liam Donaldson, 2004.
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ACCS response
ACSQHC Australian Open Disclosure Framework – Consultation Draft
31 August 2012
in order to determine if they are likely or not to benefit from a proposed course of
treatment.
CMP is a well defined and unique medical discipline, practiced by doctors from
various specialties or specialty backgrounds. It continues to expand and the range of
new treatments is developing rapidly. As has been seen with the development of
other specialties, the provision of invasive treatments will increasingly be provided by
providers with a non-surgical background. Gastroenterology, radiology and
cardiology are all examples of this. In CMP, new techniques such as tissue
engineering, fat cell transfer, lipomodelling and the placement of permanent and
semi permanent filler materials are some current examples of a similar evolution.
CMP is expanding both within Australia and abroad. While there is a broad
spectrum of views about the value or merits of cosmetic procedures, the widespread
and continuing growth of the specialty throughout the Australian community is an
evident fact: men and women have and continue to exercise their consumer
sovereignty to obtain the services provided by cosmetic medical and surgical
practitioners and others. The key issue is how best to ensure high standards of care
and patient safety.
Initiatives by the College to improve standards and patient safety include:
The ACCS has implemented recommendations of the 1999 NSW Enquiry into
Cosmetic Surgery, specifically:
i)
Developed a standard for recognition of skill and competence in
Cosmetic Surgery; and
ii)
Established standards of training and practice benchmarks.
Additionally the College has:

Developed a formal training programme in Cosmetic Surgery which requires two
years of intense study and practical tuition and also requires a minimum of five
years post graduate experience, three of which must be in recognised surgery
positions before commencing the cosmetic surgery programme.

This is the only cosmetic surgery specific training programme in Australia and is
also the only programme that requires comprehensive written and oral
examinations in cosmetic surgery.
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ACCS response
ACSQHC Australian Open Disclosure Framework – Consultation Draft
31 August 2012

Has among its members and trainers some of the most experienced practitioners
of cosmetic surgery in Australia whose expertise is recognised internationally by
their peers and who are frequently invited to teach plastic and cosmetic surgeons
around the world.

Instituted mandatory continuing medical education and annual recertification,
specific to cosmetic surgery, which includes peer reviewed clinical audit.

Established a medical faculty and associated training and qualifications to cater
for cosmetic physicians (non surgical doctors) who specialise in less invasive
cosmetic procedures.

Developed new accreditation benchmarks for Fellows in special areas of
Lipoplasty (Diploma), Cosmetic Laser Medicine (Diploma).

Established Procedure Specific Registers to enable the public to be informed
accurately which doctors are experienced in different procedures. Only qualified
College Fellows can be listed on one of the registers and then only after having
performed the specific procedure at least 50 times (100 times for some registers).

Requires its members to disclose how many times they have performed an
invasive procedure before if this is less than 100 times.

Created education programmes for GPs, for example suture courses, workshops
at GPCE (RACGP conference) to deliver suture and wound management
education as well as introduction courses in laser practice and cosmetic
medicine.

Developed Diploma courses in Cosmetic Medicine and Diploma of Cosmetic
Nursing.

Instituted an Advertising Code which is specific to cosmetic practice and provided
a template for regulatory reform of advertising protocols in various Australian
jurisdictions including Victoria, NSW and Queensland.

Developed guidelines for informed consent which have a specific relevance to
cosmetic practice and which have also provided a template for regulatory bodies.

Instigated a series of stakeholder roundtable discussion groups and production of
white papers on a variety of topics of essential interest in the field of cosmetic
medical practice. The first Roundtable was attended by a representative from the
South Australian Health Department. The recommendations of the subsequent
white paper were reflected in the SA Health Minister’s memo to the Australian
Health Ministers’ Conference of which led to the current review process.
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ACCS response
ACSQHC Australian Open Disclosure Framework – Consultation Draft
31 August 2012

Established a track record of co-operative interaction with peer groups and other
agencies, for example the RACGP, Cosmetic Physicians Society of Australasia,
Australian Academy of Facial Plastic Surgeons, Facio Maxillary Surgeons
association. The College’s attempts engage the RACS and the ASPS to work cooperatively to advance standards have been rebuffed.

Provided expert advice and assistance to regulatory bodies, Therapeutic Goods
Administration (TGA), Health Departments, Medical Boards and Coroners in New
South Wales, Victoria and Queensland, Health Quality Care Commission (Qld),
state coroners and the ACCC.

Provided representation on the medical advisory panels of major indemnity
insurers and developed medical indemnity insurance categories to genuinely
reflect practice profiles and developed a cosmetic surgery specific risk reduction
programme with the insurer MIGA.

Introduced a Patient Satisfaction Survey instrument managed and monitored by
an independent organization UltraFeedback which also supplies services to the
Department of Health of Victoria. ACCS members were the first to introduce
external, independent audits of patient satisfaction in cosmetic surgery through
Roy Morgan Research

Inaugurated the ACCS Insights programme which is a College wide survey of
practice profile and demographics designed to give as accurate as possible
information as to the actual scale and variety of cosmetic practice in Australia.

Developed an effective mechanism for self regulation and disciplining of
members (in addition to the College’s Code of Practice) including Board of
Censors and Ethics Committee. Some members have been removed from
College registers and two removed from the College.

Established a conference programme and now hosts the biggest cosmetic
surgery and medicine conference in Australasia (more than 600 delegates and
over 1,000 attendees in 2010) and administers a series of wide ranging seminars
and workshops.

Established an International profile with a presence in Hong Kong, Singapore,
Indonesia, Korea, China and New Zealand. ACCS is a respected provider of
education and training in cosmetic surgery and cosmetic medicine throughout
Asia.

Launched a professional journal, The Australasian Journal of Cosmetic Surgery,
now in its sixth year of publication.
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