Recently, there have been growing concerns about oversight in cosmetic clinics, along with questions around the relevant responsibilities of clinic medical directors.

Across health care settings, the physician medical director (or physician clinical director) is responsible for appropriate oversight of clinical practice and patient safety. While the Medical Director Standards in CPSO’s OHP Standards specifically outline the core requirements for the operation of Out-of-Hospital premises (OHPs), they also set out important considerations for physician medical directors of clinics that are not OHPs. 

Below are some key principles, drawn from the Medical Director Standards and CPSO policies, for the awareness of physicians acting as the medical director of cosmetic clinics and other clinic settings. 

Medical directors have oversight of the clinic, including compliance with applicable legislation, regulations, and CPSO policies

Medical directors should ensure quality and safe patient care within their clinic oversight, particularly for any delegated controlled acts being performed. This includes the care provided by the staff practising in the clinic.   

In all cases, there should be a contract in place outlining the specific role and responsibility of the medical director within the practice setting.

Medical directors who delegate controlled acts are accountable for ensuring that delegation occurs safely and appropriately 

Delegation is intended to be a physician extender, not a physician replacement, and delegates should never be left to manage a practice or patient population independently. In accordance with CPSO’s Delegation of Controlled Acts policy, delegating physicians must: 

• clinically assess a new patient prior to delegating or within two business days, unless an exception applies; and
• be physically onsite to supervise delegates, unless an exception applies (e.g., the risk associated with the delegation is low).

Sufficient medical directives should also be in place to enable appropriate delegation.

Medical directors should ensure the competence of clinic staff providing patient care under their clinic oversight

Medical directors should ensure that staff have requisite knowledge, skill, and judgment to practice competently and safely and that they are practising within their scope of practice and using appropriate titles to introduce themselves to patients. 

Medical directors should also ensure that staff hold appropriate qualifications, including reviewing and verifying their training and credentials.

Medical directors are reminded that virtual care must meet the standard of care 

In accordance with CPSO policy, virtual care must meet the standard of care and the same legal obligations and professional expectations that apply in person – including those pertaining to prescribing drugs, medical record-keeping, consent to treatment, and continuity of care – also apply to virtual care.