Botulinum toxin prescription

Can a GP prescribe botulinum toxin treatments on behalf of a healthcare assistant? One member called the MDU to find out...

The scene

A salaried GP rang the MDU advice line to ask for advice about prescribing. A healthcare assistant (HCA) at the practice had attended an aesthetics course and wanted to set up a clinic to administer botulinum toxin treatments to private patients.

The HCA had asked the GP if he would prescribe the botulinum toxin, because the HCA herself was not able to prescribe. The GP wanted advice on whether he should agree to his colleague's request.

MDU advice

The MDU adviser agreed that it could be difficult to decline requests from colleagues, but that the GP also needed to consider the relevant GMC guidance when making his decision.

The GMC's prescribing guidance explains that doctors are responsible for the prescriptions they sign, and should only prescribe drugs when they have adequate knowledge of the patient's health and are satisfied the drug serves the patient's needs.

While the GP himself was not carrying out the cosmetic procedure, he was reminded about the GMC's cosmetic interventions guidance. Paragraph 11 of the guidance makes clear that a doctor "must carry out a physical examination of patients before prescribing injectable cosmetic medicines. You must not therefore prescribe these medicines by telephone, video link, online or at the request of others for patients you have not examined."

This meant that the GP would be in breach of GMC guidance if he prescribed the botulinum toxin without first examining the patient himself.


After considering his professional obligations, the GP concluded that he was unable to prescribe botulinum toxin for the HCA to administer to private patients. He spoke to his colleague and sensitively explained his decision and reasoning, which the HCA accepted.

This dilemma is fictional but based on members' experiences and the types of calls we receive to our advice line.

This page was correct at publication on 30/01/2024. Any guidance is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.