Standing Orders in Cosmetic Medicine

A standing order is a written instruction from a medical doctor, dentist, nurse practitioner or optometrist that authorises a specific person who does not have prescribing rights to administer a prescription medicine, under specific conditions.

Used correctly, standing orders help provide timely care but must comply with legal and professional standards. These are outlined in legislation and regulator statements, including:

• Medicines (Standing Order) Regulations 2002
• Standing Order Guidelines (Ministry of Health 2016)
• Joint statement on professional responsibilities for prescribing and dispensing???
• Good Prescribing Practice - Medical Council Statement 2024

In cosmetic medicine, standing orders are primarily used by registered nurses to administer prescription-only medicines, such as botulinum toxin injections (Botox®, Dysport®, Xeomin®).

 Procedure that do not involve prescription medicines, such as chemical peels or IPL, do not require standing orders.  

Doctors who issue standing orders must be:

• Registered with the Medical Council
• Prescribing within their scope of practice, as outlined in the Medical Council’s Statement on Cosmetic Procedures. This sets out the requirements for the scope of practice for Category 2 non-surgical cosmetic procedures.

Many doctors are surprised by the responsibilities involved when issuing a standing order. A standing order issued by a doctor is not a directive to the nurse personally, but an authorisation for the nurse to treat patients on the doctor’s behalf under specified conditions. Therefore, the Ministry of Health states 'the issuing doctor is completely liable for all aspects of the use of the standing order.'

Anyone considering issuing standing orders for cosmetic treatment must read:

• NZSCM’s Statement on Standing Orders (2015)
• NZSCM’s Statement on Standing Orders (2022)

In summary, the doctor must:

• Write the standing order, outlining safe use of the medicine and setting supervision levels appropriate to the nurse’s training and experience
• Ensure the nurse’s competency to carry out the standing order correctly
• Personally countersign or audit treated patients’ clinical notes each month
• Ensure adverse events are recorded
• Ensure the standing order meets legal requirements

Yes. While standing order legislation sets a general legal framework, NZSCM has two extra requirements to improve safety standards.

1. Direct Observation of Nurse Competence

   • NZSCM requires doctors to personally observe the nurse performing the cosmetic procedure when assessing their competency. This includes:

     • Conducting the consultation

     • Obtaining informed consent (a critical part of cosmetic care)

     • Administering the treatment itself

2. Clinical notes must meet NZSCM standards

• • Nurses must follow NZSCM’s standards for clinical documentation. The issuing doctor can monitor this when reviewing patients’ clinical notes during monthly countersigning or audit.

To operate under a standing order, a nurse must:

• Be registered with the Nursing Council of New Zealand
• Be formally assessed as competent by the issuing doctor to carry out the treatment
• Hold a valid standing order issued by the doctor
• Facilitate the doctor to personally countersign or audit the clinical notes of treated patients each month (it is not legal to sign a list of patient names, or allocate this task to another person)
• Maintain a record of all adverse events
• Undergo an annual competency review with the issuing doctor

While the doctor is ultimately responsible for patient care under a standing order, the nurse must use their professional judgement to ensure they are administering the standing order correctly. If a nurse believes their competency or the doctor’s supervision is insufficient, they must notify the issuing doctor.

These requirements help ensure that the use of standing orders in cosmetic medicine remains safe, compliant, and within regulatory standards.

NZSCM is a professional body for doctors working in cosmetic medicine. Our members are highly trained and experienced, with a postgraduate diploma in cosmetic medicine. Many of our accredited doctors issue standing orders to nurses, providing oversight and support for safe, lawful treatment.

While NZSCM does not regulate nurses or define their scope of practice, we expect nurses working under an NZSCM-accredited doctor’s standing order to uphold the same standards of safety, professionalism, and ethical care as our members.

To maintain these standards, NZSCM recertifies its members every three years. As part of this process, we review whether standing orders are being used appropriately, and whether the issuing doctor is meeting their legal and professional obligations including competency assessment, countersigning or auditing of clinical notes, annual review and recording of adverse events. 

NZSCM supports a collaborative, high-standard approach to cosmetic medicine, where all practitioners involved in patient care are accountable, informed, and operating within their scope.

Regardless of their role, all practitioners must:

• Work within their professional scope of practice
• Be competent in the treatment they perform
• Follow applicable guidelines from their regulatory authority
  

Working outside these parameters risks breaching professional, legal, and ethical standards.

This information is provided as a general guide for doctors working in cosmetic medicine. It is based on publicly available guidance from the Ministry of Health, the Medical Council of New Zealand (MCNZ), the Dental Council of New Zealand (DCNZ), and the Nursing Council of New Zealand (NCNZ).
Practitioners are individually responsible for understanding and complying with the legal, regulatory, and professional requirements relevant to their own scope of practice. The New Zealand Society of Cosmetic Medicine (NZSCM) does not regulate practitioners and accepts no responsibility for individual compliance or interpretation of regulatory standards.

For any specific queries about your scope, prescribing responsibilities, or legal obligations, please contact your responsible authority directly.

References & Useful Links
1. Standing Order Guidelines – Ministry of Health (2016)
These guidelines provide guidance on the use of standing orders for medication administration.

2. Medicines Act 1981
Governs the classification, approval, and control of prescription medicines in New Zealand.

3. Health and Disability Services Standards NZS 8134:2021
Sets the minimum standards for safe and quality health and disability services, including clinical governance, risk management, and service delivery.
(Note: This is a paid standard available via Standards New Zealand.)

4. Health Practitioners Competence Assurance Act 2003 (HPCA Act)
Provides the legal framework for regulating health practitioners, including defining scopes of practice and protecting public safety. 

5. Good Prescribing Practice – Medical Council of New Zealand (2013)
This statement outlines the expectations for medical practitioners regarding prescribing practices.

6. Joint Statement on Prescribing – Medical Council, Nursing Council, Pharmacy Council (2024)

7. Registered Nurse Scope of Practice – Nursing Council of New Zealand (2023)
This document defines the scope of practice for registered nurses in New Zealand.

8. Standards of Competence for Registered Nurses – Nursing Council of New Zealand (2025)

9. Nurse Practitioner Scope – Nursing Council of New Zealand (2023)
This document outlines the scope of practice for nurse practitioners in New Zealand.

10. Principles for Quality and Safe Prescribing Practice – Dental Council (2024)
This document provides guidance on prescribing medicines for dentists.

11. Standards Framework - Dental Council

12. Medsafe Product/Medicine Classification Database (Updated regularly)
This database provides information on the classification of medicines in New Zealand.