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CT & OR: Oppose Scope Expansions

Across the nation, ASPS continues to carry out aggressive advocacy campaigns to respond to inappropriate scope of practice expansions by medical professionals and non-physicians. Most recently, the Society has engaged in Connecticut and Oregon to uphold patient safety and protect the future of the specialty.

Each year, the Connecticut Department of Health carries out an official scope of practice review for any entity that wishes to alter their profession's medical scope of practice. Upon learning of submissions on dental and esthetician scope of practice expansions, ASPS partnered with the Connecticut Society of Plastic Surgeons (CSPS) to submit impact statements to the Department articulating our concerns with each of these respective submissions. In response to the dental scope of practice request, ASPS and CSPS clarified serious concerns with allowing dentists to administer botulinum neurotoxin and dermal fillers on patients in the state. The societies jointly argued that patient convenience and broader, immediate access to cosmetic procedures facilitated by dentist should not override patient safety, especially when dentists do not have the necessary medical training to perform cosmetic surgery in the maxillofacial region.

ASPS and CSPS also articulated their concerns regarding an esthetician scope of practice proposal that would allow estheticians to independently perform significant procedures, such as the administration of chemical peels of 30% with a pH of 3 or more and the use of energy--based devices for skin resurfacing. Unfortunately, these were not the first attempts by dentists and estheticians in the state to expand their scope of practice. Earlier this year, ASPS and CSPS worked together to thwart similar attempts made during the legislative process outside the state's traditional scope of practice process.

In September, ASPS was also on the record in support of a proposed rule in Oregon that would tighten existing esthetician scope of practice guidelines in the state. The Society submitted comments in support of the rule because it would prohibit all estheticians from performing medium and deep chemical peels on patients. Under current Oregon law, advanced practice estheticians (APE) – who have more training than general estheticians – can still perform chemical peels under physician supervision. ASPS does not support the administration of these procedures by any esthetician, regardless of training, as they do not have the requisite education and training to penetrate layers of the skin. While the September proposal does not prevent APEs from performing this more invasive chemical peel, the Society supports efforts to ban the procedure by general estheticians.

The proposal is still in the rulemaking process, but the Oregon Health Authority is expected to finalize the rules in January 2020.

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