Our health care regulators cannot differentiate between a health care profession and a pseudo-medical cargo cult.
The Professional Standards Authority has accredited the Society of Homeopaths as a holder of a approved voluntary register of health-care practitioners. The PSA have announced in a press release that,
Patients and the public can have confidence in the Society of Homeopaths’ voluntary register which has been vetted and approved by the Professional Standards Authority.
There are many reasons why the PSA should not have done this. The PSA is charged with overseeing the statutory and voluntary bodies that regulate health and social care professionals in the UK. It is supposed to give assurance to the public that high standards are met and they are being appropriately protected from the untrained, the unscrupulous and the incompetent. The PSA they “do this to promote the health, safety and well-being of users of health and social care services and the public.” By accrediting the Society of Homeopaths they have clearly demonstrated they are not fit for purpose and are incapable of protecting the public. If the PSA can give the rubber stamp of approval to an organisation that promotes one of the most egregious forms of quackery around, then it can accredit pretty much anyone.
See my previous blog post: Ten Reasons why the Society of Homeopaths Should not Receive PSA Accreditation
The PSA give lots of detail about their decision to accredit and it is worth looking at this in depth. The first hurdle the Society had to jump was to convince the PSA that they “held a register for people in health and/or social care occupations.” I had argued that it was not possible to consider homeopaths working in a health profession as members of the Society of Homeopaths have no knowledge, training or practices that can diagnose or successfully treat illness. Whilst their intention is to act as health care providers, their beliefs make them systematically incompetent and a threat to the well-being of those they practice on. The PSA stated,
The Panel noted Call for Information submissions arguing that homeopathy is without a basis in evidence and not a health care practice, therefore unable to meet this Standard. The Panel noted that it is not its role to determine the efficacy of a therapy but to decide whether the Accreditation Standards are met.
Whilst one might accept that their role is not to review the evidence base for any practices of the registrants, it is reasonable to expect the PSA to evaluate if the applicants are telling the truth. The PSA noted,
The Panel noted the basic definitions of homeopathy provided in the application and on the Society’s website: ‘a system of medicine which involves treating the individual with highly diluted substances, given mainly in tablet form, with the aim of triggering the body’s natural system of healing’. The Panel considered that these could satisfy the definition of healthcare.
It is not true that homeopaths use highly diluted substances – mainly because there are no active substances in the remedies they dish out. The remedies are ritualistically diluted such that the remaining product is free from any active ingredient. There is also no reason to believe that such ritualistic preparations trigger any sort of healing process. If the Society had claimed they shook bags of bones to improve a persons imuju it would have been just as meaningless and equally unworthy of acceptance of being a healthcare practice. Homeopaths are not healthcare professionals. They are practitioners of pseudo-medical beliefs – quackery. This is the consensus view of science and the PSA has no need to determine the efficacy of this nonsense therapy.
Is it merely sufficient for people on a register to claim they are healthcare professionals? Has the PSA no duty to test that claim?
The PSA noted that a director of the Society had been directly in partnership with Andrew Wakefield during the MMR scandal. They also noted that homeopaths were associated with anti-vaccine views. However, they accepted assurances from the Society that a statement on their website makes it clear they do not endorse homeopathic vaccines. I doubt the PSA have read the statement though as it gives mixed and misleading messages. It states that “Currently there is no homeopathic alternative to vaccination or anti-malarial drugs which has been proven beyond doubt to be clinically effective”. What it ought to say is that there is no reason whatsoever to believe that homeopathy could be alternative to vaccinations at all. It goes on to state misleadingly that “There is some research evidence to suggest that homeopathic medicines may be effective in preventing serious disease: therefore homeoprophylaxis can be an ethical option under certain special clinical circumstances”. These are dog whistles to committed antivaccinationists and homeopaths.
For further advice on homeoprophylaxis under special clinical circumstances, please contact your homeopath or homeopathic pharmacist.
The PSA go on to reject the idea that the Society should not be accredited because it practices pseudoscience. The PSA say,
The Panel noted that questions of efficacy are outside the remit of the AVR scheme. The Panel noted that the Society affirmed its commitment to public protection through its policies and activities, providing for the public to be safer through seeing a Society registrant than seeing a practitioner who did not sign up to its standards.
The idea that you can tell pseudoscience by examining “questions of efficacy” is a serious misunderstanding of pseudoscience. Standard medical treatments may not be effective and clinical trials will help resolve such questions. But homeopathy is based on nonsense. Clinical trials do not add to our understanding that magic cannot work. We can reject homeopathy simply by examining its basic claims. The Civil Aviation Authority will not wait to see if a alleged flying carpet can gain an airworthiness certificate before rejecting it for public transport operations.
Next the PSA looked at issues of risk and concluded the “Society had demonstrated understanding of risks relevant to the occupations it registers and was found to have appropriate controls in place.” They understood the biggest risk from homeopathy can from the divertinon conventional diagnosis and treatment away from patients. The PSA believed that “this risk is mitigated by the Society’s educational and conduct requirements”. Alarmingly, the PSA accepted that the training in Anatomy and Physiology, Pathology and Disease for a homeopath was sufficient for them to be able to diagnose and recognise their own competencies. This shows a staggering lack of insight into what homeopaths are: they believe and are trained in pre-scientific, vitalistic views of disease and health. Many reject germ theory and believe ‘miasms’ are the basis of disease and health. Homeopathic training is a systematic training in incompetency and to think they can diagnose illness to the extent that they can mitigate such risks is absurd. In addition, homeopathic principles reject the very notion of conventional diagnosis and believe that all they have to do is take a detailed case history of symptoms. The PSA have been ridiculously naive in this area. This naivety is enhanced because they acknowledge the Advertising Standards Authority have criticised the Society for “discourag[ing] essential treatment for conditions for which medical supervision should be sought”. The fact that the SoH have cleaned up their web site does not mean this is not a systematic problem within homeopathy.
The PSA looked at whether the Society could inspire public confidence in the running of its register. They noted,
The Panel considered a concern raised about a YouTube link posted by the Society’s former Chair on Twitter, entitled ‘Homeopathy for Health in Africa – HIV/AIDS – Finding the Genus Epidemicus’ and whether this could impact the public’s confidence in the Society’s ability to manage its register. The Panel noted that the AVR team as part of its due diligence had confirmed the former Chair had posted the link after stepping down from that position but was still a registrant of the Society. The team suggested that posting this link did not appear to be in breach of the Code of Ethics and Practice or the ASA’s adjudication decision.
So, let’s be clear. A registrant and former director is suggesting that magical pills can treat HIV in Africa but this should not be a cause for concern about the Society running a register with such people in it. Just what would it take for people to be concerned about such a register?
Next the PSA looked at the defined knowledge base for homeopathy. It again stated that “accreditation does not validate the efficacy of a particular therapy” but was happy to accept that “scientific research of homeopathy is an ‘active and growing field’”. It obviously does not concern the PSA that this evidence base is overwhelmingly negative for homeopathy. The PSA also showed both a lack of understanding of medicines regulation and homeopaths prescribing and manufacturing habits. Most homeopathic remedies are classed as unlicensed medicines. It is illegal for a homeopath to dispense such remedies. Many homeopaths manufacture their own remedies most often with magical electrical machines. To think that there is not a supply chain of these unlicensed remedies that goes through homeopaths is again a position of the utmost naivety.
I could go on.
It is worth noting that the Call for Information from the PSA on the accreditation of the Society gained 18 responses. Only two were positive. This is a set back for all those concerned about the public health impact of quackery such as homeopathy. The PSA have completely failed to ensure their fundamental purpose of public protection has been fulfilled. If the PSA were effective, the ability for quacks to influence public health would be diminished, but as the PSA itself acknowledges, “Accreditation should result in increased referrals to the Society’s registrants.” By rubber stamping the Society of Homeopaths, it is likely that more misleading health advice and pseudoscientific treatments will be carried out.
This failure has come about due to the near universal practice in healthcare regulation of failing to understand the nature of quackery and to ignore the risks that quacks pose. Indeed, Earl Howe made this position clear in the House of Lords,
My Lords, the Government have no plans to change the membership of the council of the Professional Standards Authority. The authority is required under the Health and Social Care Act 2012 to set standards for organisations holding voluntary registers for health and social care occupations, and accredits those which meet these standards. It is not required to make a judgment on the beliefs and practices of individuals registered with the organisations that it accredits.
It is not all bad news though. I know that at least one homeopath has already jumped ship from the Society to join an alternative non-accredited register after being dismayed buy the Society for not standing up to the regime imposed on them by the ASA where claims of efficacy cannot be made. Given that the Society has to renew its accreditation annually it might now have to be a lot better at enforcing its codes of practice. That is, if you spot a homeopath claiming something dodgy or selling something they should not be selling, you should make a complaint to the Society of Homeopaths. Before now, that would have been an utter waste of time.
The PSA report reveals that the Society of Homeopaths are down to a membership level of 1250 homeopaths. They have not been publishing this figure for quite some time. It is possible that this accreditation, although a battle I did not want them to win, may well end up being hubris after all.
And as for the PSA, it is now clear they are worse than a chocolate tea-pot and a direct danger to public health. If I was a doctor, or other health care worker, I would be furious at the PSA for undermining public health through incompetent oversight. The PSA will no doubt claim that their accreditation is just a test to see if membership bodies can run a register. How the public perceive what they do though is of vital importance. It is most important that this accreditation is not seen as an endorsement of effectiveness. The PSA might be justified in their activities if, and only if, they could be sure that their rubber stamps were not perceived by the public as endorsements of quackery.
UPDATE 16th September 2014
The story hits the Times.
Harry Cayton, who declared as a conflict of interest that he used to work in a Steiner community, appears to believe that the question of whether homeopathy is useless or not is matter of opinion. He also thinks that even if people want a ‘competent’ homeopath then the government should have a role in endorsing that competency.For quackery, competency is just a measure of how well versed you are in that quackery. It says nothing about how effective you are, whether your claims can be justified or whether you pose a risk to the public. Indeed a well trained homeopath may well pose a bigger risk to the public as they may have a more distorted view of their own capabilities.