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.
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.