The MYRO Briefing
Independent Healthcare Intelligence
Who checks the checker? What the Save Face review means for designated bodies
On 19 June 2026, the Professional Standards Authority published the outcome of its targeted review of Save Face, a prominent accredited register for doctors, nurses and dentists providing non-surgical cosmetic treatments. The review considered Standards Two, Six and Nine of the Accredited Registers scheme. The PSA found Standard Two met with one condition, Standard Six met, and Standard Nine met with two conditions.
The conditions require Save Face to strengthen public verification of practitioners' statutory registration within six months, publish Equality Act 2010 compliance and equality, diversity and inclusion information within three months, and implement arrangements to collect and use demographic information, or an equivalent method of assurance, by its next full renewal assessment.
This is not a story about a single clinic or a single doctor. It is a story about assurance infrastructure: the layer of accreditation and register membership that designated bodies, patients and commissioners may rely on as evidence of individual regulatory good standing. The PSA has now found that part of that public-facing assurance needs strengthening.
Accredited-register membership is not a static assurance
The Accredited Registers scheme, operated by the PSA under section 25(3) of the National Health Service Reform and Health Care Professions Act 2002, is designed to give patients and employers confidence in unregulated professions and to hold register operators to defined governance standards. Accreditation is renewable, not permanent. The PSA can — and does — impose Conditions where a register fails to meet the standards on renewal, and it can conduct targeted reviews where concerns arise between renewals. The Save Face review is precisely such a targeted intervention.
The practical implication for designated bodies is that a register logo on a practitioner's profile page is a statement about the register at a moment in time. It is not, in itself, evidence that the individual practitioner is currently on the medical register with a licence to practise, holds the indemnity claimed, or is engaged in appraisal with a responsible officer.
What designated bodies should independently verify
The GMC register is the primary source of truth for any doctor's registration and licence status, and is publicly searchable at gmc-uk.org. A designated body engaging a connected doctor — whether directly, through a practising-privileges arrangement, or via a locum agency — should verify each connected doctor's status directly against the GMC register at engagement and at appraisal, not rely on the individual's own attestation or on an accredited-register listing.
The GMC register discloses the doctor's licence to practise, any warnings, undertakings, conditions or suspensions currently in force, and the doctor's specialist and general practitioner register entries. It does not disclose closed complaints, ongoing investigations at the pre-tribunal stage, or matters concluded without an adverse finding — those must be established from the doctor's own declarations, and independently corroborated where necessary.
The wider point about assurance
Every layer of assurance — accredited register, professional body membership, mandatory training certificate, insurance certificate — is a statement about compliance at a moment in time. The value of the assurance is only as strong as the discipline of periodic re-verification. The PSA's finding on Save Face is a reminder that assurance infrastructure needs its own scrutiny, and that responsible officers, when checking the position of their connected doctors, should be looking through the badges to the underlying primary sources.
Appraisal & Revalidation
Practical Tips & Guidance
Don't just check the badge — verify the registration directly
The PSA's targeted review of Save Face highlights something responsible officers should already be doing: independently confirming a connected doctor's current statutory registration against the GMC register, rather than relying on an accredited-register logo or self-report. A short, disciplined verification routine at each engagement and each appraisal cycle can be assembled from primary sources.
GMC register. Search the public register at gmc-uk.org/registration-and-licensing/the-medical-register for the doctor's current status. Confirm: full registration; licence to practise; any warnings, undertakings, conditions or suspensions in force; specialist and GP register entries where relevant. Capture a dated screenshot or export for the doctor's file.
Prescribed connection. Confirm the doctor's prescribed connection to the designated body via GMC Connect. Where a connected doctor has multiple sessions or roles, the prescribed connection should reflect the setting in which the largest proportion of clinical work is undertaken, and any change should be recorded promptly.
Appraisal declarations. At each appraisal, the doctor should declare all complaints, incidents, investigations, warnings and cautions since the previous appraisal — including matters that did not result in an adverse finding. The declaration is the doctor's; the verification is the designated body's.
Indemnity or insurance. Confirm that the doctor holds cover appropriate to the full scope of their practice, and that any employer or clinic policy relied on does not carry a condition precedent requiring the doctor to hold their own additional cover.
Accredited-register status (where relied on). If the clinic or practitioner relies on Accredited Registers membership as an additional assurance layer, verify current membership directly on the register's own live listing, and note any current PSA Conditions or reviews affecting that register.
None of this is onerous. Documented periodically, it is straightforward evidence for the responsible officer's own board reporting and the periodic quality assurance framework.
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GMC Watch
Regulatory Updates
GMC publishes its response to the DHSC consultation on the GMC Order 2026
The GMC published its formal response to the DHSC's consultation on the draft General Medical Council Order 2026 on 23 June 2026. The regulator states it has "long called for" many of the proposed measures and describes the current legislation as "outdated" and "overly complex." The response is the GMC's institutional position on the reform process, distinct from the DHSC consultation's own status, and is available in full on the GMC's news page.
Read the GMC response →GMC publishes Public Confidence Research 2026
The GMC has published independent research — a 2,000-person survey and 12 discussion groups — on when off-duty conduct should trigger regulatory action. 85% of respondents agreed off-duty conduct should reflect professional standards. Findings will feed into the GMC's review of fitness-to-practise thresholds ahead of legislative reform. Directly relevant to cosmetic, aesthetic and hair transplant practitioners, where social media conduct and advertising attract particular regulatory scrutiny.
Read the research →GMC Chief Executive: primary care designated bodies show higher rates of disproportionate employer referrals
Speaking at Pulse LIVE Cardiff on 2 July, GMC Chief Executive Charlie Massey acknowledged that fear of complaints is driving "defensive medicine" among GPs, while citing faster provisional-enquiry closure — an average of nine weeks — and low hearing incidence. Massey said GMC data show primary care designated bodies have higher rates of disproportionate employer referrals than other settings. Private GP designated bodies should note the direct governance signal on referral thresholds and proportionality.
Read the GMC coverage →
MPTS Cases — Cautions & Warnings
Fitness to Practise Outcomes
Dr Elliot Burns — Erasure, immediate order
Outcome: ERASURE
The tribunal found that Dr Burns, a GP, had pursued an emotional and sexual relationship with a vulnerable patient he had treated for mental-health difficulties, exchanging explicit images and messages and engaging in sexual activity on more than one occasion — including once at the surgery. He subsequently worked as a remote and locum GP, including for a private practice, before safeguarding disclosures brought the earlier conduct to light. The tribunal directed erasure with an immediate order.
For designated bodies, the case is a hard illustration of a soft point: boundary violations with vulnerable patients can surface years after the conduct itself, brought to light by safeguarding disclosures rather than contemporaneous complaint. Appraisal and revalidation processes for connected doctors — particularly locum and remote-working doctors — should actively probe patient-contact history and safeguarding awareness, not rely on a clean employment record as evidence of unblemished practice.
Read the MPTS decision →Dr Richard Bowley ERASURE
A GP who had worked in Jersey's private healthcare sector dishonestly claimed on income-protection insurance forms that he was medically unable to work, while in fact undertaking regular locum GP shifts. Erasure was directed in his absence. Non-clinical financial dishonesty is treated as core fitness-to-practise misconduct — and, as this case illustrates, is a legitimate and recurring trigger for GMC referral.
Read the MPTS decision →Dr Salah-ud-Din Taj ERASURE
The doctor was convicted in Australia of stalking, breaching protective orders and threats to kill against a former partner, and dishonestly failed to declare the conviction on both GMC registration and an NHS job application. The tribunal directed erasure with an immediate order. Pre-employment and revalidation checks should include international criminal-record verification where a connected doctor has practised or resided overseas — a clean UK DBS check alone is not sufficient assurance.
Read the MPTS decision →Dr Alaaeldin Kamel ERASURE
A locum consultant radiologist fabricated medical reports and submitted them to the GMC to deceive Interim Orders Tribunal and Medical Practitioners Tribunal hearings, breaching existing IOT conditions. The tribunal directed erasure with an immediate order. Designated bodies onboarding a doctor with live GMC proceedings should independently verify supporting medical and occupational-health evidence rather than accept documentation supplied by the doctor.
Read the MPTS decision →Industry Intelligence
Independent Healthcare Sector
MHRA — The Medispa Clinic amends advertising following POM complaint
MHRA confirmed on 7 July 2026 that The Medispa Clinic Ltd, trading as The Medispa, amended its advertising following complaints that it had promoted Prescription-Only Medicines to the public contrary to the Advertising Regulations. A recurring compliance exposure for injectables-prescribing clinics — every clinic's advertising, including its website and social media, should be reviewed against Blue Guide standards.
Read the MHRA update →
ASA rules against Phlo Technologies / Morrisons Clinic — the funnel is the ad
A Facebook ad for a weight-loss service was upheld as breaching the CAP Code on 15 July. Although the ad itself referenced only price and clinical support, its click-through journey led to pages naming POMs (Mounjaro, Wegovy) without shielding the casual browser, contrary to MHRA Blue Guide standards. The ruling establishes that ASA scrutiny extends to the full landing-page and prescribing journey, not just ad copy — a material tightening of the compliance perimeter for any clinic advertising a weight-loss or hormone service digitally.
Read the ASA ruling →
"Keep your ads a cut above the rest" — CAP guidance for hair loss advertising
CAP guidance published on 9 July distinguishes medicinal from non-medicinal hair loss claims for clinics prescribing Finasteride or Minoxidil. POM references must stay off homepages, "consultation for Finasteride" advertising is not permitted, and before-and-after imagery rules are restated. Directly actionable compliance guidance for hair transplant and hair restoration clinics.
Read the guidance →
HFEA warns of the risks of unregulated sperm donation
On 8 June 2026 the HFEA warned of exploitative or serial sperm donors operating outside licensed clinics via apps and social media. The regulator's statement reinforces the governance case for licensed provision — useful patient-safety context for fertility designated bodies and a reminder for connected practitioners of the regulator's oversight of the licensed pathway.
Read the HFEA statement →
Sakura Aesthetics Clinic, Glasgow — three requirements, seven recommendations
HIS published the report of its 20 April 2026 announced inspection of Sakura Aesthetics Clinic on 1 July 2026. Three requirements and seven recommendations were issued, with an action plan published alongside — the highest finding count in the Scottish independent-clinic batch this cycle. The Sakura report is worth reading in full for its findings on documentation and governance in practising-privileges arrangements.
Read the report →Subscribe to The MYRO Briefing
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