Prescribing and remote prescribing
This looks at first like a topic that does not apply. It applies at the edges, and the edges are where problems in this sector concentrate.
Polynucleotide products are generally medical devices rather than prescription only medicines, so the product itself does not require a prescription. Prescribing questions still arise around what is used alongside it: injectable local anaesthetics are prescription only medicines, and so are the medicines that a practitioner would need in order to manage certain complications.
The wider principle matters more than the technical detail. Professional guidance across the healthcare regulators is clear that a prescriber must assess the patient personally before prescribing injectable cosmetic medicines, and that remote prescribing for these purposes is not acceptable. A practice where an unseen prescriber signs for medicines used by someone else is a practice with a structural problem.
5.3.1Why this applies to a device
Because treatments do not arrive alone. A polynucleotide session may involve topical anaesthetic, which is often a pharmacy or general sale product, or injectable local anaesthetic, which is a prescription only medicine. More significantly, managing a complication may require medicines that must be prescribed, and the ability to obtain them quickly is part of what an emergency protocol consists of.
A practitioner who cannot prescribe and has no prescriber arrangement is a practitioner whose response to certain complications is to send you elsewhere. That may be perfectly appropriate, provided it is planned rather than improvised, and provided you were told.
5.3.2Who can prescribe
Prescribing in the United Kingdom is restricted to defined groups: doctors, dentists, and registered professionals who have completed prescribing qualifications, including many nurses, pharmacists and some allied health professionals. Each group is regulated by its own body and each of those bodies publishes standards on prescribing.
The relevant standard across the professions is consistent on one point: a prescriber must have an adequate assessment of the patient. For cosmetic injectable medicines the professional consensus has been firmly against remote prescribing, meaning prescribing for a patient the prescriber has not personally assessed.
5.3.3The remote prescribing arrangement, and why it is a problem
The arrangement that professional bodies have objected to works like this. A non prescribing practitioner sees the patient. A prescriber, who does not see the patient, prescribes the medicine, sometimes on the basis of a form or a photograph, sometimes on the basis of a telephone conversation, sometimes on the basis of nothing at all. The practitioner administers it.
The objections are not procedural fussiness. The prescriber is taking responsibility for a decision they are not in a position to make. Contraindications may be missed. The assessment that a prescription is supposed to represent has not occurred. And when something goes wrong, the person who assessed the patient could not prescribe and the person who prescribed had not assessed, which is a poor arrangement for the patient in every direction.
This matters here mainly through anaesthetics and complication management rather than through the polynucleotide product itself. It also matters as a signal: a practice with a remote prescribing arrangement for anything is a practice whose approach to responsibility is worth understanding before you consent to anything else.
| Element | Status | What to ask |
|---|---|---|
| The polynucleotide product itself | Generally a medical device, not prescribed | Which product, manufacturer, and marking |
| Topical anaesthetic | Varies by formulation and strength | What is being used and what its status is |
| Injectable local anaesthetic | Prescription only medicine | Who prescribed it and whether they assessed you |
| Medicines for managing complications | Prescription only | What is held, who is trained, and how you get them urgently |
| Antibiotics if infection develops | Prescription only | How a prescription is obtained after hours |
A framework written by this publication to organise a decision. It is not a measurement, it is not drawn from any study, and no figure in it should be quoted as a finding.
5.3.4Anaesthetic, specifically
Topical anaesthetic creams vary in status. Some are available without prescription; others are prescription only depending on the formulation and strength. Injectable local anaesthetics are prescription only medicines.
The questions worth asking are simple: what anaesthetic are you using, is it a prescription only medicine, and if so who prescribed it and did they assess me. Those are ordinary questions and a well organised practice answers them without difficulty.
5.3.5The emergency medicines question
A practitioner offering facial injectables should have a plan for the serious complications, and some elements of that plan involve medicines. For hyaluronic acid, hyaluronidase is central to managing a vascular event and is a prescription only medicine, which is why arrangements for obtaining it are a standard question to ask any filler practitioner.
For polynucleotides there is no equivalent reversal agent, which changes the emergency picture. What remains relevant is whether the practitioner can recognise a vascular event, what their immediate management is, whether they can access urgent medical support, and how they get you to definitive care. Ask what their protocol is. A practitioner with a written protocol will describe it. A practitioner without one will describe a general intention.
5.3.6Questions
- Are you a prescriber? If not, who prescribes any medicines used in my treatment, and will they assess me?
- What anaesthetic will be used and what is its status?
- What is your protocol for a vascular event, and can you describe it?
- What medicines do you hold on the premises for emergencies, and who is trained to use them?
- If I need a prescription medicine urgently after treatment, how does that happen?
The fifth question is the one that most often exposes a gap. The answer should be a route, not a hope.
5.3.7If you think prescribing has been done improperly
Prescribing is a regulated activity and each prescribing profession has a regulator with a route for raising concerns. Concerns about a doctor go to the General Medical Council, about a nurse or midwife to the Nursing and Midwifery Council, about a pharmacist to the General Pharmaceutical Council, and about a dentist to the General Dental Council. Each publishes guidance on what it can consider.
Improper prescribing is a serious professional matter and regulators treat it as such. If a prescriber has signed for a medicine used on you without ever having assessed you, that is precisely the kind of concern the regulators exist to consider.
Questions
Do I need a prescription for polynucleotide treatment?
Generally not, because these products are usually medical devices rather than prescription only medicines. Prescribing questions arise around anaesthetics and around managing complications, and it is worth checking the status of the specific product rather than assuming.
What is remote prescribing and why does it matter?
It is prescribing for a patient the prescriber has not personally assessed, often on the basis of a form or a photograph. Professional guidance across the prescribing regulators requires adequate assessment, and the consensus on cosmetic injectables has been against it. It is a signal about a practice's approach to responsibility.
My practitioner is not a prescriber. Is that a problem?
Not necessarily, since the product itself is generally not a prescription only medicine. It becomes a problem if prescription only medicines are being used without a prescriber who has assessed you, or if there is no route to obtain prescription medicines urgently after treatment.
What emergency medicines should a clinic have?
That depends on what they offer. What matters for you is whether there is a written protocol for a vascular event, whether the practitioner can describe it without hesitation, what is held on the premises, who is trained to use it, and how you obtain a prescription medicine urgently if you need one.
Who do I tell if prescribing has been done improperly?
The prescriber's regulator: the GMC for doctors, the NMC for nurses and midwives, the GPhC for pharmacists, the GDC for dentists. Improper prescribing is a serious professional matter and each regulator has a route for raising concerns.
- General Medical Council
- Nursing and Midwifery Council
- General Pharmaceutical Council
- General Dental Council
- The Human Medicines Regulations 2012
- British National Formulary
Links to regulators, professional bodies, legislation and research indexes. They are cited because they are public and checkable, not as endorsement of this publication. No source listed here has any commercial relationship with us.
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