Unscrupulous operators in aesthetics and other fields will game the new TGA restrictions while ethical practitioners vanish from view.
The TGA has finalised its guidelines about advertising non-surgical cosmetics, two months after advising the non-surgical cosmetic industry of changes passed in late December without consultation or warning.
Not much has changed since the initial publication on 15 January, though it does explain the reasoning.
As suspected, the indiscriminate online advertising of multiple classes of medications across various fields – including menopausal medication, vaping medication, weight-loss medication and medical cannabis – has led to the TGA curtailing access to and information about all classes of prescription medications to a consultation first.
The TGA says: “This material reinforces that the legislation itself regarding cosmetic injectables has not changed, and advertising the use or supply of prescription medicines, including most cosmetic injectable products (as opposed to services), has never been compliant with the therapeutic goods framework. This includes through use of testimonials, claims about the goods, before and after photos, or price lists.”
The industry is in shock again. Many comments and messages are flying around asking what the alternatives to the common generic terms “anti-wrinkle” and “dermal fillers” might be, since most cosmetic treatments are heavily advertised to the general public including using competitive price lists like any other retail service.
Others have posted about their deep disappointment around the curtailing of these means of educating the public; unlike menopausal medication (typically two classes of drugs), vaping (one class), weight loss (one class), aesthetic medicine has a vast range of medications, most of them prescription-only that can be baffling even for people who consider themselves savvy by perusing pages on the internet and come in to order treatments on demand.
There is a lot of time and education that is needed to help someone with a treatment plan, but equally, the ability to show before-and-afters is paramount to help people choose who to book an appointment with.
Would you choose a landscaper or a renovation expert who had no before/after photos of their work and aesthetic?
That’s the problem for someone like me who’s never advertised drugs nor prices, but rather a full-face holistic approach to ageing.
In aesthetics there are at least five classes of prescription-only medication, broken down into different brands, and the indications for the use of each are different, separately and in combination. Think of someone you see with angina or following a stroke: apart from assessment and correct diagnosis, there is the assessment and education of the classes of drugs they’ll now need to take for secondary prevention, a discussion of side effects and then a decision to plan the treatment and to then proceed. Being able to talk in general terms about this, in view of everthing the public is already exposed to via the US and UK, is essential so patients have some idea of what they’re looking at and for, before making an appointment for entirely discretionary treatment.
Aesthetic medicine, when not sold to beautiful young people who don’t need anything, is similar to other areas of medicine. It attracts a lot of stigma, but the Netherlands has recently recognised it as a specialty in its own right and it is only a matter of time before this happens globally. General practice was only recognised as a specialty relatively recently, with criteria for entry, a standardised training program, supervision and exams to qualify.
In the meantime, most of us in Australia find ourselves gagged due to the unscrupulous choices and actions of a group of people, led by corporates and telehealth platforms, who entice barely qualified healthcare workers into the field in exchange for an easier life than what the traditional path offers – specialty training, competition, long hours, exams and more, which most of us went through and accepted as normal.
Medical aesthetics is seen as the opportunity to have an easier life, and in my work training peers, I regularly meet people who chose to enter aesthetics directly often without even a year in hospital or general medicine/nursing. Similarly there is no shortage of doctors post MBBS/MD choosing to enter medical aesthetics bypassing other speciality training programs and FRACGPs disenchanted by general practice.
The problem is not that they choose to do this; it’s that the bar for entry at present is so low and so heavily promoted as being sexy, that many flock to it without much experience, or insight into their own lack of awareness of ethics (we are not retail salesmen), healthy boundaries or procedural skills. When you haven’t been drilled in base procedural or anatomical knowledge, a two-day or even two-week bootcamp simply won’t suffice – but that’s exactly what is happening before people set up solo.
The horse has long since bolted. Covid made the transition from continuity of care to convenience medicine so easy that the public thinks nothing of it.
The promotion of all these services by barely qualified professionals makes it look like no big deal. All it takes is a Google search and an online appointment – often not even live but via email or text – to get a script. A follower advised me her friend lied about her BMI, filled out an online questionnaire and had her script for weight-loss medication within minutes.
So what now?
Those of us who have stuck to medicine, will be affected by our lack of ability to educate prospective patients since just about everything we say or do will count as advertising. In the wake of the announcements, I see the usual rogue operators continuing with business as usual and freely using the terms anti-wrinkle, dermal fillers and more.
I have no doubt the online services who’ve set up lucrative business out of weight loss medications, vaping medications etc. will do likewise and hope not to get caught, or that the fines are piddling next to their profits. There’s likely too much cash on the line to pull back and do the right thing.
As to the rest of us, it’s going back to the drawing board – except that the problem was never us, it was always the unscrupulous operators, who will continue unchecked.
Dr Imaan Joshi is a Sydney GP whose practice includes aesthetics; she tweets @imaanjoshi.
