The Chair of the AoNZ National Committee wrote to the Chair of Te Kaunihera Rata o Aotearoa - Medical Council of New Zealand (MCNZ) in response to a draft revised Statement on doctors performing cosmetic procedures and a draft Policy on the training and expertise necessary for doctors to safely perform cosmetic procedures.
RACS is generally supportive of the draft revised statement, which includes a requirement to ensure the doctor has the necessary training, expertise, and experience to safely perform the cosmetic procedures and manage any risk. However, we are concerned the draft Policy on the training and expertise necessary for doctors to safely perform cosmetic procedures, would not fulfil this requirement. For surgeons it references merely having FRACS without stating in an appropriate vocational scope, similarly for dermatologists. The Dermatology curriculum spans three years of advanced training after a period as a general medical registrar, which is not comparable to the average three to four year basic surgical training then a further minimum of five years of speciality advanced plastic surgical training (similar for other surgical scopes of practice), with a further one to two year sub-speciality fellowship undertaken by all Fellows of RACS.
We submitted strongly the procedures listed in Category 1 are invasive surgery which should only be undertaken by those with surgical training; the dermatology pathway does not include adequate training for such invasive procedures beneath the skin and of this complexity. Any procedure requiring anaesthetic involvement falls firmly in the camp of a complex surgical procedure which requires extensive training and assessment such as provided by RACS’ advanced training programmes and achievement of fellowship status within RACS in appropriate vocational scopes.
Further, not all surgeons should be able to perform all Category 1 procedures. These should only be undertaken by surgeons who are trained and accredited in the procedures themselves; identification of risk and management of complications; understanding surgical pathology in relevant organ systems; and the management of patient expectations including psycho-social assessment. Specifically, these should only be undertaken by:
- surgeons who have attained Fellowship in a relevant surgical scope with appropriate sub-specialty skills, post-graduate qualifications and experience, with ongoing Continuing Professional Development, feedback, and accreditation
- surgeons who are International Medical Graduates (IMGs) vocationally registered in Aotearoa New Zealand, with appropriate surgical sub-specialty skills, post-graduate qualifications and experience, ongoing Continuing Professional Development, feedback, and accreditation, and
- surgical vocational Trainees under supervision of a RACS Fellow or vocationally registered IMG, who is thus responsible for the procedure and its outcomes.
We agreed with consideration of a new category of lower complexity surgeries such as hair transplantation, varicose vein treatment, and dermal fillers which could be undertaken by dermatologists.
RACS endorses the submission from the New Zealand Association of Plastic Surgeons - Te Kāhui Whakamōhou Kiri.