What Industry Leaders Think Of AHPRA’s Cosmetic Surgery Regulation Review

The Australian Health Practitioner Regulation Agency (AHPRA) are conducting a review of the regulation of cosmetic surgery. Here’s what the industry leaders have to say.

The Australian Health Practitioner Regulation Agency (AHPRA) and the Medical Board of Australia’s public have announced a review into the regulation of the cosmetic surgery sector to investigate what actions will better protect cosmetic surgery patients. The consultation process is now open until 14 April 2022 and the review is expected to be published by mid-2022.

Around half a million Australians undergo cosmetic surgery each year, totalling AU$1 billion, which is more per capita than in the United States. This huge growth also attracted practitioners from all areas of medical practice, many of whom are inadequately trained in cosmetic surgery and whose practice poses a risk to the public.

We reached out to several industry associations to hear what they think of AHPRA’s review; a spokesperson for the Australasian Society of Aesthetic Plastic Surgeons (ASAPS) says “AHPRA should be taking this as an opportunity for speedy and decisive action to protect patients, while the Ministerial Inquiry into titles to reform National Law occurs.”

“Meaningful legislative change will take longer to implement, and swift regulatory action should be taken now. It is too late to say that something bad “could happen” if this is not rectified sooner. Based on the recent flooding of media stories of poor patient outcomes, something bad has already happened and patients can’t wait.

AHPRA and the Medical Board of Australia need to act quickly, to amend the guidelines for cosmetic surgery. This includes advertising the requirement to use only approved titles, and for full disclosure of registered titles and qualifications to patients, thus enabling them to make informed decisions ahead of procedures. At all costs, AHPRA must avoid any future patient saying that if he or she had known that their practitioner was not a registered surgeon, that he or she would not have proceeded with their surgery. Patients deserve to be fully informed, and to make an informed decision before giving consent to an invasive, surgical procedure.” 

In an ideal world, AHPRA would function as a proactive regulator. Not one that sits on the sidelines and will only take action once the damage has been done. Once a patient has been harmed, it is too late.


The Australasian College of Cosmetic Surgery and Medicine (ACCSM) has welcomed the new review. ACCSM President Dr Patrick Tansley believes that the current system allows almost any doctor to call themselves a cosmetic surgeon and patients could not easily identify whether or not a doctor had the necessary specific training to be competent and safe.

“The ACCSM is calling for the introduction of a national accreditation standard in cosmetic surgery for all doctors who perform it. No such standard currently exists,” says Dr Tansley. “The new standard would sit alongside the creation of a public register of practitioners who have met and maintain the standard… All competent surgeons providing cosmetic surgery who are concerned about patient safety should welcome its introduction.”

Data published to the current Senate Inquiry in late 2021 showed that in the three years to June 2021, AHPRA received 313 complaints relating to cosmetic procedures. The complaints related to 183 practitioners, of whom more than half were surgeons holding Australian Medical Council-accredited specialist surgical registration. Of these specialist surgeons, the majority (71 per cent) were specialist plastic surgeons.

The Cosmetic Physicians College of Australasia (CPCA) also welcomes the review but has identified “several disappointing aspects”, according to CPCA President Dr Michael K Molton. It seems that the review is too little, too late for Dr Molton.

“The present  ‘Guidelines for medical practitioners who perform cosmetic medical and surgical procedures’ were published in October 2016. If you look at the bottom of the last page of the guidelines it says these guidelines will be reviewed at least every three years. It is now 2022,” he explains. “The excuse that COVID intervened does not apply here because the guidelines were announced to be reviewed at least before 2019, and this did not even begin to occur in 2019, prior to COVID. Secondly, the consultation period for the review, which contains more than 30 questions, is about 28 days, which is unreasonably short. In Australia right now the east coast is in a state of emergency … It is impossible for a quantitative, qualitative and referenced response to be prepared and finalised before April 14th 2022.”

Dr Molton says the CPCA is especially concerned about the lack of understanding of the difference between cosmetic medicine and cosmetic surgery, which AHPRA does not clearly distinguish, and believes this will cause confusion for patients.

“The most disturbing aspect of the present guidelines and the announcement of the review is that the regulator still does not know or sufficiently differentiate between cosmetic medicine and cosmetic surgery. The present title of the guidelines reflects a difference but the content and text only differentiate between ’Major’ and ‘Minor’ procedures, not ‘cometic surgery’ and ‘cosmetic medicine’ — which are entirely different practices.”

– Dr Molton, CPCA President.

The AHPRA hopes that the introduction of a register of medical practitioners endorsed in cosmetic surgery will allow patients to identify which of these doctors is actually trained, competent and safe to perform cosmetic procedures.

Dr Tansley and the ACCSM believe it will “result in a significant reduction in the number of botched cosmetic procedures taking place each year, as all practitioners wishing to practise in this field will be forced to undergo specific training and demonstrate specific competency before being endorsed to do so, thereafter being able to use the title ‘cosmetic surgeon’.”

The CPCA, however, is a little sceptical when it comes to the review. “Our College is not involved with cosmetic surgery, however, the unintended consequences of protecting a title appear not to be well thought out, and there is no evidence that protecting the title will make cosmetic surgery safer,” Dr Molton says. “Under the National Law protection of titles only applies to specialists’ titles, like General Surgeon, Plastic and Reconstructive Surgeon. Cosmetic surgery is not a recognised specialty, therefore the National Law in its present form cannot stop the use of non-specialist titles. But to legislate protection of any one particular title opens the door by legal precedent for competing professions to dominate and create monopolies of other practices when there is no evidence that one profession is any better or worse at protection of the public.”

For more information and to take part in the review, visit the AHPRA website.

We have reached out to more industry leaders and will keep updating this article accordingly.


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