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regulation
As I have often said, you don’t need to be a scientist to see that most alternative medicine is bunk, though it is bunk that is supported and propagated by an enormously wealthy industry..
There were two good examples this week, John Sutherland, who was until recently professor of English literature at UCL, understands it very well. And so does political columnist, Polly Toynbee.
“Complementary and Natural Healthcare Council”
Polly Toynbee’s column, “Quackery and superstition – available soon on the NHS“, was prompted by the announcement in The Times that the government was to set up a “Natural Healthcare Council”. It was soon renamed the “Complementary and Natural Healthcare Council” (CNHC) It was instantly dubbed ‘OfQuack’ in an admirable analysis by quackometer.a>
The very name is tendentious and offensive to any thinking person. What is “natural” about sticking needles in yourself, or taking homeopathic polonium?
Toynbee comments
“Put not your trust in princes, especially not princes who talk to plants. But that’s what the government has decided to do. The Department of Health has funded the Prince of Wales Foundation for Integrated Healthcare to set up the Natural Healthcare Council to regulate 12 alternative therapies, such as aromatherapy, reflexology and homeopathy. Modelled on the General Medical Council, it has the power to strike therapists off for malpractice.”
There was only one thing wrong in this article. Toynbee says
“The alternative lobby replies that conventional medicine can also do more harm than good. They chortle with glee at an article in the Lancet suggesting there is no scientific evidence for the efficacy of 46% of conventional NHS treatments. But that’s no reason to encourage more of it.”
Professor John Garrow has pointed out (see, also Healthwatch )
“It is true they chortle, but they have got their facts wrong. The 46% of treatments which are not proven to be effective is 46% of all treatments for 240 common conditions – and very few are used in the NHS. The great majority are treatments used by alternative practitioners. “
The unconstitutional interference by the Prince of Wales in public affairs has been noted often before, and it seems that it’s happening again.
For example, there is the TV programme, “Charles, the Meddling Prince”, or, for a US view, see “Homeopathy: Holmes, Hogwarts, and the Prince of Wales“. And then there’s Michael Baum’s superb “An open letter to the Prince of Wales: with respect, your highness, you’ve got it wrong“.
It isn’t that regulation isn’t needed, but that the sort of regulation being proposed won’t do the trick. The framework for the “Natural Healthcare Council” has been set up by Professor Dame Joan Higgins, and it seems to be very much along the lines proposed by the Prince of Wales. Here’s what’s wrong.
| Professor Dame Joan Higgins (Jan 10th) says “Complementary therapists have been in practice for many years” and “If complementary therapy is not to be banned, is it not, therefore, wise to regulate it and offer the public some measure of protection”. That’s fine, but I think the sort of regulation that she, and the Prince of Wales, are proposing won’t do the trick. We don’t need new laws, or new quangos, just the even-handed application of existing laws. Homeopathic arnica 30C contains no arnica, and one would expect that the Office of Fair Trading would have banned it. It is no different from selling strawberry jam that contains no strawberries. But absurd legal loopholes make homeopaths immune to prosecution for this obvious mislabeling, whereas jam fraudsters would be in deep trouble. The Advertising Standards Authority, likewise, is prevented from doing its job by legal loopholes, and by the fact that it has no jurisdiction over web advertising, which is now the main source of untrue claims. If alternative medicine advocates had to obey the same laws as the rest of us, the public would be better protected from fraud and delusion. What won’t work is to insist that homeopaths are “properly trained”. If one takes the view that medicines that contain no medicine can’t work, then years of being trained to say that they do work, and years spent memorizing the early 19th century mumbo-jumbo of homeopathy, does not protect the public, it imperils them. |
The “Natural Healthcare Council” isn’t the only example either. Try Skills for Health.
Skills for Health
This appears to be a vast bureaucratic enterprise devoted to HR-style box-ticking. Just in case you don’t know about this latest bit of HR jargon, there is a flash movie that explains all.
“Competences are descriptors of the performance criteria, knowledge and understanding that are required to undertake work activities. They describe what individuals need to do, and to know, to carry out the activity -regardless of who performs it.”
That sounds OK until you realise that no attention whatsoever is paid to the little problem of whether the “knowledge and understanding” are pure gobbledygook or not. It’s rather like the HR form that ensures UCLH that you are a fully-qualified spiritual healer “Laying on of hands: just tick the box“.
It is an invidious insult to human intelligence to suppose that exercises like this are an appropriate way to select people for jobs. They have precisely the opposite effect to that intended.
An indication of the level of their critical thinking is provided what is written about the 62 items listed under “Complementary Medicine” These include “CHH5 Provide Healing”.
“This workforce competence is applicable to:
- healing in the presence of the client
- distant healing in contact with the client
- distant healing not in contact with the client
Both healing in the presence of the client and distant healing use exactly the same mental and spiritual processes. Clearly, however, distant healing does not involve many of the physical aspects of healing in the presence of the client. The performance criteria have been written so as to be able to be interpreted for use in any healing situation.
The workforce competence links to CHH6 which is about evaluating the effectiveness of the healing.”
It also includes homeopathy, for example “HM_2: Plan, prescribe and review homeopathic treatment“.
I sent an email to Skills for Health to ask who wrote this stuff. A reply from their Technical Development Director failed to elicit any names.
| We develop competences to fit sector needs and demands. When that need is moved into a competence project we establish a number of groups from the specific area to work with us to develop the competences. One of these groups is a “reference” group which is made up of experts from the field. In effect these experts give us the content of the competences, we write them in our format. So I guess the answer as to who is the author is Skills For Health, but with more complexity behind statement.Please do not hesitate to get in touch with me for further clarity. |
A conversation with Skills for Health
I did want more clarity, so I phoned Skills for Health. Here are some extracts from what I was told.
“It’s not quite as simple as that”
“the competencies on our data base are written by “experts in the field”
DC. Yes and it is their names that I was asking for
“I’m not sure I can give you the names . . . We’re starting to review them in the New Year. Those competencies are around six years old. ”
“We are working with the Prince’s Foundation for Integrated Health [FIH] via Ian Cambray-Smith to review these competencies, all the complementary therapy competences on our web site”
“They are written as a consensus decision across a wide number of stakeholders across that area of …”
DC. Written by whom though?
“written by a member of Skills for Health staff or a contractor that we employ simply to write them, and the writing is a collation of information rather than their original thoughts, if you like”
DC yes, I still think the sources can and should be given.
“FIH didn’t spend any money with us on this project. This project was funded by the Education act regulatory bodies, QCA, the Qualifications and Curriculum Authority . . . ”
“They [FIH] may well have put in and supported members of their professions or groups to do part of this . . they were there as experts on that particular area of complementary therapy ”
DC it’s their names that I was after
“There may well have been members [of FIH] on the reference groups that I’ve referreed to who are members of the FiH . . .they were there as experts from that area of complementary therapies.”
DC Oh, and are the names of [the people on] these reference groups published?
“No they are not published”
DC ah, why not?
“We do not consider it necessary”
DC Well, I consider it very necessary myself
“Tell me why”
DC It’s a question of public accountability
“I guess the accountability lies with us as the owners of those competencies”
DC Uh I’m afraid your bureaucratic jargon is a bit much for me there. “The owners of those competencies”? I’m not sure what that means
“Why do you want the information?”
DC haha, well if you want me to be entirely blunt, it’s because I’m appalled that this black magic is appearing on a government web site
“. . . can I say that as an organisation funded by a number of sources, one being Department of Health England, none of our work condones the practice you’ve just suggested. Our work supports best practice in areas that are evidence- and research-based”
DC Ah would you mind pointing me to the evidence for homeopathy and distant healing?
“Uh [pause] there is [pause]”
DC Yes, go on
“Well homeopathy is a contentious issue, because every newspaper article I read seems to suggest that homeopathy, in itself, is not an appropriate, uh, not an, uhm, appropriate, uh, therapy.”
DC Yes so why are you laying down standards in it?. You know I’m curious. I’m genuinely curious about this
“The areas involved in them have asked us to, including the Prince’s Trust hence the reason we are doing . . .”
DC But the Prince’s Trust is not part of government. Ha, it behaves as though it was , I agree, sometimes but it is surely for the Department of Health to ask you to do these things, not the Prince of Wales.
“We cover the whole health sector.. We don’t purely work for, or are an organisation of, the Department of Health.”
DC. I’m very baffled by the fact that you say, you very accurately the research on homeopathy, namely that it doesn’t work, but you are still setting standards for it. It’s quite baffling to me.
“Working with the Foundation for Integrated Health, as we are doing, homeopathy is one of the 10 areas that is listed for regulation by FIH ”
DC. Well yes the Prince of Wales would like that. His views on medicine are well known, and they are nothing if not bizarre. Haha are you going to have competencies in talking to trees perhaps?
“You’d have to talk to LANTRA, the land-based organisation for that.”
DC. I’m sorry, I have to talk to whom?
“LANTRA which is the sector council for the land-based industries uh, sector, not with us sorry . . . areas such as horticulture etc.”
DC. We are talking about medicine aren’t we? Not horticulture.
“You just gave me an example of talking to trees, that’s outside our remit ”
After explaining that talking to trees was a joke, the conversation continued
DC So can I clarify then? Who is it that said you must include these fairly bizarre things like distance healing and homeopathy? Who decides whether it goes in?
“We did”
“We are going to do a major review. We are doing that review in partnership with the FiH and the awarding bodies that award the qualifications that are developed from these competencies”
“When that need is moved into a competence project we establish a number of groups from the specific area to work with us to develop the competences. One of these groups is a “reference” group which is made up of experts from the field. In effect these experts give us the content of the competences, we write them in our format.”
Conclusions from this dialogue
We still don’t know the names of the people who wrote the stuff, but a Freedom of Information Act request has been submitted to find out
The Skills for Health spokesperson seems to a a bit short of a sense of humour when it comes to talking to trees.
The statement that “Our work supports best practice in areas that are evidence- and research-based” is not true, and when pressed the spokesperson more or less admitted as much.
Most importantly, though, we do now know that the revision of this gobbledygook will be carried out entirely by the Prince’s Foundation for Integrated Health and the people who set exams in the relevant form of gobbledygook. No critical voice will have an input, so don’t expect much improvement. “We are working with the Prince’s Foundation for Integrated Health [FIH] via Ian Cambray-Smith to review these competencies”. And in case you don’t know about the medical expertise of Ian Cambray-Smith, it is described on the FIH web site. He is the FIH’s Health Professionals Manager.
 |
Ian Cambray-Smith acts as the focus for FIH’s involvement with healthcare professionals. He works collaboratively to develop a range of work programmes, policies and initiatives to support healthcare professionals and help them to deliver a truly integrated approach to health. Ian’s background is in plastics research, project management and business development; he has an MSc in polymer technology. He joined the Foundation in 2006. |