The MP, the ASA and the Case of Alyssa Burns-Hill

The need for transparency in the use of the title Dr in Alternative Medicine.

25339_-_3_John_Glenn_MP_400x400Dr Alyssa Burns-Hill has advertised her medical services as “Harley Street Hormone Health”. With the Harley Street address and the title ‘Dr’ you might be forgiven for thinking that Alyssa Burns-Hill is a medically trained doctor. She is not. But she describes herself as a ‘practitioner of health in its broadest sense’, although not so broad as to be an actual qualified medical doctor.

Using the title ‘Dr’ is not protected in the UK. Its usage is usually associated with medical doctors or those who have obtained a PhD. The public is then not able to easily know what the ‘Dr’ means when you tag it to your name without further information. Perhaps we do not need to ask further questions of Dr Fox the DJ as we would not judge his ability to play songs on the radio according the the type and quality of his education. But if we are making informed health choices then we probably ought to understand what the title ‘Dr’ means when someone advertises themselves as a ‘practitioner of health’. Have they a sound medical training, a distinct specialism? Or do they lack appropriate qualifications in this area? No-one will mind too much if you use your title when checking into a hotel or using it to impress at the airport check-in in the vain hope of an upgrade. But using it in an advert carries responsibilities.

The Advertising Standards Authority (ASA) in the UK has seen this as an issue and has given very straightforward blanket advice to people advertising health services:

Advertisers wanting to refer to themselves as “Dr”, “a doctor” or similar, should take care not to imply that they hold a general medical qualification if they do not. The need for clarity is greatest when marketers are making health-related claims and the ASA has taken the tough line on marketers calling themselves ‘Dr’ in the context of health.. The safest and simplest way to avoid confusing consumers is that if they do not possess a general medical qualification, advertisers should not call themselves “Dr”.

Alyssa Burns-Hill has found herself the subject of an ASA complaint about such matters. A complaint was made about whether her claims on her website about saliva-based hormone testing could be substantiated and whether her use of ‘Dr’ was misleading. The ASA found that that Burns-Hill had failed to produce sufficient evidence to substantiate her claims and about saliva testing and that the papers she did submit had significant weaknesses. Such lack of evidence had ‘limited [saliva testing for hormonal imbalances] acceptance within the medical profession.’

On the use of the title, the ASA said, “we considered that most consumers would be likely to associate the reference to Harley Street with qualified medical doctors” and that by calling herself Dr Alyssa Burns-Hill PhD “consumers were likely to interpret the website as belonging to a medically-qualified doctor”. The ASA asked her to ‘ensure she stated that she was not a medically qualified doctor in a clear and prominent qualification’.

This much seems reasonable. Although obviously not to Dr Alyssa Burns-Hill PhD (not a medically qualified doctor). She has set up a campaign to try to expose the ASA as lacking transparency, legitimacy and the expertise to judge her. Her statement says,

I was pushed to the edge by the Advertising Standards Authority and I know that I am not alone with my frustrations at the seemingly arbitrary nature of its so-called adjudications.  Its procedures convey the action of one voice with an agenda that acts as prosecutor, judge and jury.  Evidence is selectively compiled and presented to its council by its staff alone without regard for integrity or even other Government department’s remits.  It can be held to account by no one as it is a Private Limited Company just like Boots or Tesco.  How can these activities be justified as an organisation that proposes to represent legality, decency, honesty and truthfulness and purports to be an Authority and official Regulator?

Dr Alyssa Burns-Hill PhD (not a medically qualified doctor) is not the only alternative health practitioner to want the ASA exposed. Homeopaths have seen the ASA as a bugbear and have been lobbying them to lower their standards of evidence for alternative medicine. Burns-Hill’s campaign website lists the support of other Alt Med organisations:

Burns-Hill latest move was to convince her MP, John Glen to hold a debate in the House of Commons about her case. Last Monday, Glen spoke in the Commons about her case saying,

Following the ruling, Dr Burns-Hill was told in an email from the ASA to change her website, business cards and publications to say only her name followed by “PhD” and then the phrase “doctorate in healthcare”, followed by the rest of her post-nominals, including her MSc and professional memberships. Dr Burns-Hill refused to comply as she felt it conveyed that she was the holder of two doctorates, a PhD and a doctorate in health. After being rebuffed by Lord Smith of Finsbury and Guy Parker, managing director of the ASA, she went through the extended process of an independent review at her request, while the original judgment was still published on the ASA website. After the independent review, the ASA partially admitted its mistake but still insisted that she had to qualify that she was not a medical doctor next to any listing of her qualifications.

Glen raised the complaints of the alternative medicine practitioners that the ASA was not legitimate (being a private company), it was not transparent and that it has no expertise to judge alternative therapies.  People like Burns-Hill object to the ASA expert reports not being made by people who practice alternative medicine.

What is going on here appears to be a plea for a double standard to be made for alternative medicine. Apparently, claims in advertising should be subjected to tests of truthfulness set only by those who advocate such therapies. As such, it is part of the whole programme of alternative medicine that seeks to set up a double standard in healthcare. There is medicine that is subjected to reason and objective scientific evidence and then there is alternative medicine that only wants to be judged on its own standards. And those standards are very low. The ASA applies a consistent evidential standard across all sectors of advertising. But for alternative medicine, they want to be a special case. The ASA simply asks advertisers to hold the evidence for their claims. If it is insufficient to convince the ASA then the adverts should not be made. Burns-Hill quite obviously failed to supply sufficiently robust evidence as explained by the ASA in their judgement.

Ed Vaizey, the responding minister, made a suitably robust defense of the ASA whilst making a few recommendations such as that expert reports should be published. The ASA is an efficient and sensible approach to regulating advertising. It pretty much ensures advertisers never have to defend their adverts in court and provides a low cost mechanism for managing issues. For this reason it is near universally accepted by the industry as the arbiter of fair advertising. It is of course incompatible with the philosophies of the cult-like world of alternative medicine who will never accept external authorities and their views on their beliefs and practices and their refusal to accept any evidential constraints on what they claim. Increasing transparency in the ASA will just allow alternative health advertisers to make ad hominem attacks against those who judge their claims.

It does appear though that Burns-Hill biggest gripe is over the use of her title. She says,

Did you know that the ASA says that you cannot use the title Dr in your professional context? the ASA sought no guidance from academia on the use of the title of Dr, which is bestowed on people who have reached advanced learning.  Instead they made an arbitrary decision …

The ASA did not make an arbitrary decision. They made it quite clear how they made their decision by considering how people might perceive the implications of its usage in the adverts.

There are several ways the use of Dr might mislead,

  • If you have a PhD and use the title in a medical context, consumers might be misled into thinking you are a medically qualified practitioner.
  • If you are selling a service and use a PhD title, but that title is in an unrelated subject, consumers might be misled as to your expertise and experience.
  • If you have a PhD from an unaccredited institution or degree mill then people might be misled as to the quality of your qualification. This has been best exemplified in the UK with the case of Gillian McKeith, or to give her full medical title… (As a side note, Dr Burns-Hill states she is a Hormone Health Specialist for the Complementary Medical Association. The President of the CMA claimed to have a Professorship from a burnt-down Nepalese University.)

It is not true what Burns-Hill claims that the ASA are stopping people from using the title Dr in their professional context. If that qualification is relevant, transparent and not likely to mislead in an advert then that is fine. The ASA have advised Burns-Hill how to achieve this. The ASA has no remit over how you use your title in your professional life apart from how you advertise your services.

What is missing from Burns-Hill’s argument is any meaningful details about her own PhD. We do not know the details of her qualifications. I have repeatedly asked her on her Facebook page and she has refused to say where she obtained her PhD. Her website merely gives the title of the thesis ‘Holistic healing from breast cancer through the lens of hormones: Synopsis and synthesis’. (The word ‘holistic’ should ring very loud alarm bells.) We do not know when or where this research took place or who awarded the qualification. I cannot find any reference to this thesis in an academic context online. This is quite remarkable. I cannot think of any meaningful reason why an academic would not make clear this information. Her LinkedIn page lists Bath Spa as her education but this could be for an undergraduate degree or for her MSc in ‘Health Promotion’ (although I cannot find any such programme listed.) I have asked Burns-Hill to explain why she is withholding this information and she replies,

when you have an understanding of the issue here I will be pleased to communicate further. Until you can do your research and gain that understanding I see no point in continuing. You really are trolling and to what end or agenda I do not know but can only guess.

Insisting that you can style yourself ‘Dr’ in order to promote your business whilst refusing to be transparent about the nature of that qualification strikes me as problematic. Burns-Hill and her helpful MP John Glen accuse the ASA of lacking transparency in their work. Perhaps we could take these concerns seriously if Burns-Hill herself was transparent in her own work so that we and her prospective clients can make informed decisions about whether or not her services were backed by good evidence, had good outcomes with low risks. This is central to medical ethics – informed decision making. And so, I would challenge Burns-Hill to be transparent now and give full disclosure about the nature of her qualifications.

This goes to the heart of what the ASA seeks to achieve. It wants consumers to not be misled. Claims should not be made that cannot be substantiated or are untrue. It does a pretty good job in holding advertisers to those standards. The world of alternative medicine has a problem with this. Only its own ‘truths’ count. Calling yourself Dr implies things about yourself: your expertise, your experience, the quality of your education. It should not be an advertising tool but a marker of trust. If that trust cannot be backed up then it using the term Dr has no place in healthcare. Dr Burns-Hill, can we trust you?

 

Updates

Dr Burns-Hill replies (via Facebook)

You deserve no reply to this. The title of your blog is well known to those in the know. You are nothing more than an internet troll, intent on disparaging more natural approaches to being healthy. As I am someone who has overcome cancer more naturally and regularly work with people who want a more natural approach to being healthy I have nothing to say to you. Someone who spends so much time putting an article of this size together has their own agenda and it’s certainly not based on truth and integrity.

I am not convinced this is an adequate reply from a health professional to the concerns raised.

Saturday 28th May 2016

It looks as if the well-trodden path of deleting material is now being followed. I am somewhat long in the tooth when it comes to investigating alternative medicine and so naturally anticipated this action being taken. So, for completeness I post screen-grabs of the facebook discussion where I and others asked for details of her PhD.

abh phd       abh phd 2       abh phd 3

 

On this theme…

22 Comments on The MP, the ASA and the Case of Alyssa Burns-Hill

  1. Miss Burns-Hill surely knows that presenting oneself as having a PhD, but declining to indicate the awarding authority, might raise suspicion in the minds of some that she is a quack – intending to deceive and defraud patients. I have no evidence that is the case, and make no such allegation, but how can the public be assured? If not by the ASA (for all its faults) then by whom?

    It really would be helpful, and more professional, if Miss Burns-Hill was more forthcoming about her academic attainments.
    Those who have nothing to hide have nothing to fear.

    I can also guess at the Andy Lewis’s agenda – to expose quackery and pseudoscience. Does Miss Burns-Hill have a converse agenda?

  2. I find her behaviour very odd. Why not be “transparent” about the source of the PhD that gives you credibility of the field in which you are marketing yourself?

  3. Indeed, Ms Burns-Hill’s reticence on the subject of the awarding body for her PhD does rather raise suspicions that she may hold a McKeith doctorate.

    Likewise, the limited information provided vis-a-vis her Harley Street practice rather suggests that far from actually having her own premises she’s one of numerous alt-med practitioners who rent consulting rooms on an ad hoc basis.

  4. You forgot to clarify in the good Dr’s response that she is not A medically trained doctor. Just in case anyone might be misled.

  5. I followed the link to her campaign page and read this from one of her supporters.;

    http://asa-the-truth.org.uk/what-people-say/

    It is truly shocking to hear about intimidation and business restriction actions purportedly carried out by the ASA upon complementary and natural health practitioners as outlined by Alyssa Burns PhD in her video ASA – the Truth. I applaud her campaign to reform advertising adjudication in the UK and encourage practitioners to lend their support.

    Sandra Goodman, PhD, Editor and Publisher Positive Health PH Online

    Am I alone in finding it ironic that Burns-Hill’s supporter refers to both herself and Burns–Hill in a way that would not offend the ASA?

  6. Miss Burns-Hill advises us “As I am someone who has overcome cancer more naturally…”

    Given this is a blog concerned with health and quackery, it would be helpful to know what form of cancer (many regress and remit spontaneously); what she means by ‘overcome’ (I presume, but cannot be certain she means she no longer suffers the effects of the cancer); and what she means by ‘more naturally’ (more naturally than what?)

    I am sorry to read that Miss Burns-Hill was “pushed to the edge by the Advertising Standards Authority…”

    I am obviously keen to help her if I can, and advise that an excellent guide with the title ‘Feeling on the Edge, is provided by the Royal College of Psychiatrists. This should be consulted if indicated.

    So many questions. So few answers.

    • Regarding Ms Burns-Hill brush with cancer, the limited information provided in her biography indicates a diagnosis of breast cancer in 2001 for which she declined to receive either chemotherapy or radiotherapy.

      She provides no information on staging or any other treatment she might have received, although as she’s still around some 15 years later it’s not unreasonable to presume either DCIS or stage one at worst, which was treated surgically. Regardless of that, a quick look at her business website circa 2005/6 via wayback machine (bio-vitality.com), shows that she was heavily in peddling “natural” oestrogen and progesterone supplements alongside the usual stuff (coenzyme Q10, weight loss products,etc).

      The PhD appears to be a relatively recent acquisition – there are a few promotional pdfs from her supplements business knocking around which date to September 2009 which show only the MSc.

      However, given that she was referred by the ASA to Trading Standards in January 2016, maybe they’ll have more luck in ascertaining where she obtained the PhD.

    • I suspect Glen has little idea of the issues involved whatsoever. Like most MPs, ignorant of the nature of alternative medicine.

  7. I always wonder if people similar to the lady mentioned in this article, genuinely believe in what they are doing and saying, or merely feel guilt and fear that they are about to be found out. I’m not sure which is more worrying.

  8. Goodman does at least have a verifiable PhD, which was awarded by McGill University (Canada) in 1981.

    Unfortunately, from a clinical standpoint, her field is agricultural biotechnology.

    This is, of course, far from uncommon when dealing with quackery and it’s advocates. Many who parade their academic qualifications tend to qualified in wholly unrelated and irrelevant fields.

  9. G. Leggatt’s reference is much appreciated. I note:

    “When I was diagnosed with breast cancer, my risk factors were practically zero (so, zero risks then) … I had the lump removed and the doctors diagnosed invasive carcinoma, stage one (stage 1 means non-invasive). The hospital recommended radiotherapy and chemotherapy (to improve risk of having invasion from 15% likihood down to c.5%. Depending on what stage at which it really was. As said – it could have been DICS.) When asked what I could do to aid my recovery, such as change my diet, they said, “Nothing” – leave it to the professionals. (Good advice. There is no plausible evidence that diet makes any identifiable difference to the progress or otherwise of breast cancer).

    I had four juices a day, 120 supplements (what??), homoeopathic injections (injections of what??) and four coffee enemas (cappuchino, latte, Ameicano…? Nice). I also did yoga, meditation, reiki – a holistic approach. (But did she try putting her head in the kitchen sink? Just as effective – and the evidence for that is as for the other ‘treatments’ tried.)

    …but it’s not about courage or being clever. Going through cancer is about doing what’s right for you.”

    I agree with the last sentiment, but how does any patient determine what is ‘right’? I would hope, by an evidence-based approach. Mrs Burns Hill prefers alternatives. Fair enough, but I remain concerned that she resents the ASA trying to protect the public by ensuring all advertising is honest, decent and claims are substantiated. A practitioner who claims to have a PhD but refuses to identify the awarding institution might be thought of as dishonest.

    I do hope all this blog theme is being read by John Glen MP (Conservative, Salisbury), a ‘committed Christian’ and no doubt a man with high moral principles, who felt this was an issue so important that he took up Parliamentary time on it – and the time and trouble for Minister Ed Vaizey to reply. (Mrs Burns-Hill used to live in Jersey. Has she and her husband and children moved?)

    I will ask my own Mr Glen for his response, and copy to my own MP, Dr Sarah Wollaston (Chairman of the Health Select Committee).

  10. To save other readers some effort I’ll give a one-sentence summary of that Telegraph article;

    Four women had conventional treatment and have survived so far.

    Well done, the doctors!

  11. Andy Lewis: “There is medicine that is subjected to reason and objective scientific evidence and then there is alternative medicine that only wants to be judged on its own standards.”

    Gosh, do you believe this? I think that you need to get out more.

    [Edit: please do not cut and paste large swathes of text. Make your own arguments, quote lightly, and reference to sources. AL]

  12. I see, back to censorship. I’ll leave you to that.

    I have to say, most of the anti-Steiner people here seem more fanatical and less connected to reality than I remember from when I was last here a couple of years ago. I expect that working from an inadequate, overly narrow worldview and claiming only others have a worldview problem undermines ones sanity.

    • Ah, the cry of censorship! Not censorship, just asking you to respect the format by not spammimg comments sections with huge cut and pastes. If you note I ask for your arguments and aI ask you to cite sources. That is strange form of censorship. But I am sure you prefer to play the victim.

  13. What I posted was not spam. It showed that the medical evidence linking cardio-vascular disease to high cholesterol is not there and nor is that for taking statins . It was a rebuttal of your comment that: ‘There is medicine that is subjected to reason and objective scientific evidence and then there is alternative medicine that only wants to be judged on its own standards.’ You have rejected my post. That’s censorship and, as I said, I don’t play that game.

    • Ted. Grow up. I have given very straightforward reasons why I trimmed your post. You are free to resubmit something in the style I have suggested. This is the end of the discussion about this.

  14. Ah, talk down to me. As I said on the other thread, my source is the book; books have to be quoted to be referenced, they are not web articles. You have said I cannot quote; that is censorship.

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