Health regulators do an important thing: protect the public from the potential risks that health care providers and their practices pose to their clients.
Risks cannot be avoided in health care. For any treatment that will have effects, there is the risk that there will be detrimental effects which may outweigh any benefit. If a patient is informed of these risks and benefits, good decisions can be made.
Alternative medicine poses specific problems for regulators. Superstitious and pseudoscientific health practices do not in general have specific beneficial effects, and the belief systems associated with them can serious mislead people into making ill-informed decisions. Therefore, the normal methods of ensuring there are appropriate levels of risk fail. Insisting on good training and technical competence simply ensures practitioners are well trained and effective in delivering ineffective health care advice and treatments. Patients may be misled into taking a course of action that will fail or will harm then when other evidence-based options exists that can be shown to have benefits.
It is then rather shocking to see that the Society of Homeopaths has announced policy to seek official, accredited voluntary register status from the Professional Standards Authority. In their Annual Review, the Society announce that “We have embarked on a policy of seeking accreditation of the Professional Standards Authority (PSA) and our objective remains to be at the heart of the homeopathic community.”
Do they stand any chance of gaining accreditation?
Unfortunately, yes. And to do so will demonstrate that the PSA is incapable of protecting the public from harm. And worse, the PSA exacerbate risks by giving the impression that quack claims have received official approval.
The PSA make no distinction between evidence based practices and pseudoscientific and superstitious practices. Indeed, in their standards for accreditation they make this quite clear,
Standard 6: the organisation demonstrates that there is a defined knowledge base underpinning the health and social care occupations covered by its register or, alternatively, how it is actively developing one. The organisation makes the defined knowledge base or its development explicit to the public.
The Professional Standards Authority recognises that not all disciplines are underpinned by evidence of proven therapeutic value. Some disciplines are subject to controlled randomized trials, others are based on qualitative evidence. Some rely on anecdotes. Nevertheless, these disciplines are legal and the public choose to use them. The Authority requires organisations to make this clear to the public so that they may make informed decisions
In other words, they appear to accept organisation that base their practice on nothing more than anecdote, regardless of how flimsy that may be. The PSA then expect the public to be aware just how inadequate such an evidence base may be.
The Society do present a ‘knowledge base’ to the public. However, it is absurdly selective, uncritical and cherry picked. Independent reviews of the scientific credibility of homeopathy find it laughable, with the new Chief Scientific Advisor to the government calling it ‘nonsense’. The PSA do not appear to demand that the applicant therapies demonstrate any sort of rationale or plausibility to underpin whatever evidence they may have, anecdotal or not.
Box ticking that the Society of Homeopaths have a notion of a knowledge base does nothing to assess whether or not that set of beliefs pose a risk to the public. That is the fundamental weakness in the approach of the PSA. And a failure to put risks at the heart of their decision making and instead accept mindless form filling as an alternative.
The behaviour of the Society ought to raise many red flags to any accreditor, but I see no box that needs ticking that might raise them.
For example, in the same Chairman’s statement that sets out their desire to be accredited, the Society also discuss how they are happy that their lobbying efforts appear to have resulted in assurances that their member’s law breaking activities will not be prosecuted by the MHRA. They state that,
During the year the Society embarked on a major lobbying campaign in response to the Medicines and Healthcare products Regulatory Agency (MHRA) consultation, which saw most MPs get a visit or a letter about the importance of homeopathic treatment. The campaign, in which The Society of Homeopaths’ involvement has been pivotal, involved hundreds of people both writing to, and meeting with their MPs, to highlight our concerns that unlicensed remedies would only be available from pharmacies face to face. Representatives from the Society and the profession met with Ministers from the Department of Health to talk about the possible repercussions and although homeopathic remedies were not made exempt, the profession did receive an assurance that the level of enforcement of the act would remain as it has for the last 40 years with regards to homeopathic remedies.
This lobbying was as a result of the MHRA consolidating the medicines regulations. There was much panic that such consolidation would make most homeopathic products illegal. The truth was that most of them were already illegal and that homeopaths were prescribing and selling them in contravention of the law. By the MHRA stating that nothing would change, the Society of homeopaths chose to interpret this as that it was Business As Usual.
How could the PSA possibly accredit an organisation that appears to tacitly endorse the widespread illegal use of unregistered medical products by its members?
The risks of such unregsitered products directly put at risk children and other users of homeopathy. BBC South West uncovered how homeopaths offer sugar pills as treatments and as alternative vaccinations for dangerous diseases such as measles. Such “treatments” exist within the anecdotal ‘knowledge base’ of homeopaths as so no doubt will receive a tick in the box from the PSA. Should they do so, the regulator will move from the role of protecting the public to one of endosring those who put the public at direct risk from life threatening illnesses.
The Society of Homeopaths is not the only quack body to seek accreditation. The Complementary and Natural Healthcare Council (http://www.ofquack.org.uk/), set up by the Prince of Wales and the Department of Health, has now been running for five years and has completely failed to remove any practitioner from the market for making dangerous and misleading claims, despite the fact that all members implicitly or explicitly do so. Indeed, the Council has admitted that it will not take action against their members making misleading claims if that is how they were trained. To accredit the CNHC as a responsible register that could protect the public would indeed be utter folly.
The PSA risks undermining the regulation of the entire medical field. If the PSA is happy to see registers with members flogging sugar pills as vaccines or Ofquack rubber stamping reflexologists with batty beliefs, how can I be confident they are properly overseeing the regulation of real medical practitioners?
And the answer to that is we can’t.
We have effective regulation to protect the public from alternative medicine. The problem is not one of lack of proper ‘professional’ regulating bodies, but of lack of enforcement of laws. The MHRA need to shut down the pharmacies that make unregistered homeopathic products just as they would any other manufacturer of illegal medicines, and Trading Standards need to prosecute those who make unsubstantiated medical claims, just as they would in any other product category.
But by accrediting quack regulators we do worse than taking no action against those that pose risks. The government gives the impression that the issue has been tackled and solved by the addition of accredited voluntary registers, whereas in fact, they do nothing but give undue credibility to dangerous beliefs.
Updates
9/5/2013
With the annual updates to the Society of Homeopaths web page after their AGM we see that Richard Barr is no longer listed on the Board of Directors web page although he is listed on their review of 2012. As such his status is unclear. His removal from the list might be favourable to their application as Barr was Wakefield’s machinator and partner in the MMR debacle that led to the BMJ exposing the study that Barr paid for as a fraud.
“…can serious mislead people”?
Ta Fixed.
No ‘taint. Par 3.
INFECTIVE health care advice?
Looks like this was done in a rush while changing nappies.
While there is a tone of resignation to this piece, and I do not say so as a criticism given the lack of regulatory action against (S)CAM to date, I do see an opportunity here for the Medical profession and skeptical community to fight back.
1. We should organise a large petition to the PSA, MHRA and Government to push for proper regulation and control of SCAM, and opposing recognition of SCAM to show that there is a more cohesive and informed opposition, than the SCAMMERS can mobilise in their favour.
2. If above is too much to ask in the short term, then it appears from the PSA Standard 6 as quoted above that there is scope to put pressure on the PSA to ensure that any SCAM that they do achieve accredited status are required to preface any material on which that accreditation is displayed or stated with a prominent ‘health warning’.
Here is the PSA wording which I think can be used to insist upon this:
“The Authority requires organisations to make this clear to the public so that they may make informed decisions”
It is self evident that some sort of small print disclaimer at the end of any published material is not sufficient to make “CLEAR”
I propose that we get behind a ‘health warning’ that must be in bold print and upfront, along the following lines:
“Homeopathy (or whatever the appropriate SCAM in question) has not been able to demonstrate effectiveness under controlled testing. Homeopathy should NEVER be used to the exclusion of evidence based medical treatment.”
Or words to that effect as I am sure someone can come up with a better or more pithy version. My only warning is to make it short and easily understood.
So, my call to action. Anyone fancy getting together to promote these ideas?
I endorse whole heartedly.
We hear about ‘professional criminals’. Will they be able to be acredited by the PSA? If not, why not?
In ‘SCAM’ does ‘S’ stand for ‘Supplementary’? If that is too challenging, how about ‘Suposedly’? ‘Suposedly Complementary and Alternative Medicine’.
Supplements, Complimentary & Alternative Medicine. Or so I always thought from Mark Crislip’s “Quackcast”.
Peter
There are several ‘advantages’ to being PSA-accredited – it imposes conditions like the one you mentioned. There are others and homeopaths and their ilk aren’t going to like being held to them either!
So, they may well think they will gain legitimacy from being on the AVR, but it opens up all sorts of avenues for skeptics. 🙂
Hm.. So far, many acronyms and typos. Is this due to a lack of care? 🙂
David
I read the post again and I can see no acronyms.Could you point them out.
There are a number of abbreviations, all of which are referenced prior to usage. This is perfectly acceptable.
There is a single unreferenced abbreviation – BBC. For a post in the UK I would have thought it was hardly necessary to explain what BBC stood for, especially when used in context.
PSA is an abbreviation. Calling it “PISSER” would be an acronym.
So. They make no distinction in terms of pseudoscientific and superstitious practices.
As far as I can see if your regular contributor Simon Baker wanted to set up an Institute For Unicorn Contemporary Knowledge (I-FUCK) he would be able to do so and get accreditation.
He is a qualified vet. Probably a member of various professional bodies. Almost certainly scrupulous in his adherence to the relevant rules, regulations and procedures. Committed to animal welfare and education. Track record in promulgating common sense and science. Could probably develop a viable unicorn practise based on his equine veterinary knowledge (after all a unicorn is mostly horse, isn’t it? – he could brush up on the horn bit by studying rhinos or narwhals).
What is to stop him?
Seemingly not the PSA.
And to pre-empt the claim that “that is ridiculous” (from the likes of Fractious Feline) how is it any more ridiculous than sugarpillery.
Hi Pedant. Thanks.
The gullibility and ignorance of the general public are boundless. If idiots want to drink buggered water, costing serious money, in the belief that they will gain benefit from so doing, who are we to stop them?
David Amies
I would have thought that Andy would be rejoicing at the idea of homeopaths joining the PSA and being subjected to more controls.
If joining the PSA meant homeopaths were forced to be upfront about the utter implausibility and lack of evidence, as suggested by Peter Robinson above, then I wouldn’t complain.
However, there is a very real risk that accreditation with the PSA will bring an unwarranted respectability to this form of fraud. Inevitably, accreditation will be used to sprinkle some stardust on homeopaths’ delusions of grandeur.
I really like the description of Homeopathy in the Daily Mash today where they refer to it as “a ÂŁ20 bottle of ghosts”.
Why pay ÂŁ20 for a bottle of ghosts when you can get a bottle for only ÂŁ5.50. What you lot forget is that no one is forced to spend their money on it.
Bring on the PSA. So it will be homeopaths verses a motley collection of IT experts like Andy and full timers like Alan. There will be no more than a handful of Drs and good old BSM talking for the vets. I look forward to it. Great fun.
Watch it though that the 0.004% budget for homeopathy does not become 0.04% then 0.4%. Keep an eye on your blood pressure guys as accreditation comes. Belladonna 10M 3 times daily for the rest of your lives may help. xxxxx
Grumpycat, perhaps you could give us your opinion as to what proportion of the NHS budget should be spent, knowingly, on fraud.
You mean the handful of doctors represented by the BMA, of course.
Have you evidence that the BMA are against homeopaths joining the PSA Mojo? Tell me if you have.
The NHS is run for the public Dr Bollocks. Drs are obviously key in providing the service. If some Drs want to provide a homeopathic service then they will do so and you will have to just report any alleged fraudulant activity to the police who may have other things to do..
In the context of the above thought some of you might appreciate this:
http://explosivedetectorfrauds.blogspot.co.uk/2013/05/cheer-up-jim-i-was-going-to-say-it-may.html
The following URL offers good quotes to describe acceptance of homeopathy:
http://www.goodreads.com/quotes/tag/willful-ignorance
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