Saturday, 3 March 2018

The Society of Homeopaths - Fruits of Hubris

The Society of Homeopaths (SoH) are in deep trouble. They were recently re-accredited by the Professional Standards Authority (PSA) but only conditionally. This has not be well publicised. At the time of writing, the SoH have made no mention of it. Whilst the PSA have published the decision, it's listed as "news".

This discussed the relationship between the PSA and SoH some time ago. The SoH is mentioned in several other posts as well. There are a considerable number of posts on this blog regarding CEASE therapy. There have been some behind the scenes activities that it has not been possible to discuss.

To quote -
The Accreditation Panel reviewed the accreditation of the register held by the Society. Panel members reviewed the annual review application form, an updated risk matrix, and a summary report from the Accreditation team. The Panel had to review the Society’s compliance with the Standards and decide whether or not to renew accreditation, renew accreditation with conditions, suspend accreditation or remove accreditation. The Panel could make recommendations in the form of:
  • Conditions – changes that must be made to maintain accreditation. If Conditions are not met within the timeframe specified, accreditation may be removed.
  • Instructions – actions that would improve practice but do not affect compliance with the Standards and that the Panel requires to be implemented and be satisfied of appropriate implementation within a given timeframe
  • Learning Points – actions that would benefit the operation of the register, the implementation of which would be verified during the annual review of accreditation. 
One condition was applied and note the time frames -
1. The Society must:  
a. Develop and submit to the Panel for review its position statement on the use of CEASE therapy by registrants, including advertising this. This must be submitted to the Panel for review and published within three months  
b. Develop mechanisms to ensure that registrants who use and advertise CEASE therapy follow the Society’s position and do not breach its Code of Ethics and Practice. An action plan outlining how this will be achieved must be submitted to the Panel within one month  
c. Review risks related to CEASE and other therapies additional to registrants’ regular scope of practice, as part of its ongoing risk assessments. This must be incorporated into the Society’s risk matrix within three months.
This may appear quite mild. The PSA did not remove or suspend accreditation. In reality, the SoH will find the Condition impossible to meet or, at best, only at a very high cost. This will be discussed in greater detail.

There were four instructions -

  1. The Society is to publish its exceptional circumstances policy regarding registrants who are not displayed on the public register, within six months.
  2. The Society is to submit the outcomes of its website audits, including websites checked and all actions taken.
  3. The Society is to provide clearer information to complainants on the actions it takes in relation to concerns raised when these are resolved outside of the formal complaints process.
  4. The Society is to develop and publish its persistent or vexatious complaints policy to make clear where it considers contact from people or organisations to be unreasonably persistent or vexatious and the approach it will take.
These are not particularly onerous. However, 2 and 3 do place a greater emphasis on ensuring that member websites comply with legislation and regulation and that the results of audits/complaints are communicated.

There were two learning points -
  1. The Society should consider making improvements to its openness and transparency by, for example, publishing its Board meeting minutes and other information previously available to the public on its website as soon as possible.
  2. The Society should consider submitting its web page on ‘The evidence base for homeopathy’ to the Advertising Standards Authority’s Copy Advice team for independent review.

The section on risk needs to understood in terms of the Standards that the PSA sets for Accredited Registers. 
Standard 3: Risks The organisation: 3a) Has a thorough understanding of the risks presented by their occupation(s) to service users and the public – and where appropriate, takes effective action to mitigate them. 3b) Is vigilant in identifying, monitoring, reviewing and acting upon risks associated with the practice of its registrants and actively uses this information in carrying out its voluntary register functions. Evidence provided should demonstrate how the organisation seeks, gathers and handles information, and provide examples of having acted to prevent or mitigate risk. The Professional Standards Authority will decide whether this Standard is met with reference to guidance provided in the Accreditation Guide (2016).
The risks identified by the SoH were pretty dull. However, the SoH have been aware of CEASE therapy for quite sometime but did not not classify it as a risk. The PSA thought differently -
The Panel noted that risks relating to registrants’ use of ‘CEASE therapy’ (discussed under Standard 5) had been identified as part of the team’s assessment, for example that practitioners could recommend treatments noted to be harmful by the NHS. As part of the Condition outlined within Standard 5, the Panel stated that: The Society must consider risks related to CEASE and other therapies additional to registrants’ regular scope of practice, as part of its ongoing risk assessments.
Capacity to Inspire Confidence
This is a strange concept to anyone familiar with the SoH. Previously available board minutes have mentioned that some members are disatisfied with the board.
Information about the Society’s directors may be found on the Society’s website. The team noted that Board meeting minutes had previously been made available to the public, but were now published in restricted, members’ only, sections of the website. The team discussed this with the Society, noting that previous Panel decisions had stated that publishing minutes or excerpts of discussions from Board meetings relevant to public protection and the public interest assist transparency and registers’ ability to inspire confidence. The Society responded that it would make these links available. 
It is questionable whether the SoH ever meant to make these documents public. They revealed things that the SoH may well not have wanted the public to see, in particular those that relate to the SoH's relationship with the Advertising Standards Authority. The PSA go on to say -
The Panel noted the Society had provided a timeframe for publishing Board meeting minutes, and other information on its website, to the team. The Panel issued the following Learning Point: The Society should consider making improvements to its openness and transparency by, for example, publishing its Board meeting minutes and other information previously available to the public on its website as soon as possible.
Even if the SoH did publish such documents, it is likely that they would edit them for public consumption. The next bit on CEASE therapy is reproduced in full.

CEASE Therapy The Authority received concerns about Society registrants practising ‘CEASE (Complete Elimination of Autistic Spectrum Expression) therapy’. CEASE Therapy (as per suggests that there is a direct link from vaccination, and other conventional medicine, to the causes of autism and other serious health conditions and that these can be treated using homeopathic remedies. CEASE therapy uses homoeopathically prepared solutions of ‘causative factors’, to ‘clear out the energetic field of the patient from the imprint of toxic substances or diseases’. Case studies on the site linked above make claims such as ‘the major part of the autism has been cured with the detoxification of the MMR shot.’ 
The team noted the Advertising Standards Authority (ASA)‘s Ruling on Teddington Homeopathy which found that CEASE therapy appears to imply an intention and ability to treat autism. CEASE’s supporters suggest that it is also being applied to treat other ‘modern chronic diseases’, for example: ‘In addition to offering this approach to my clients with Autism Spectrum Disorder, I have used it for patients with Asperger’s, ADHD, Polymyalgia and symptoms resulting from IVF treatment.’ The team noted examples of Society registrants making similar statements about CEASE therapy on their websites. 
The team noted that the CEASE website, which appears to be the primary source of information about CEASE, makes claims that conflict with the advice of the NHS and have potential to cause harm, if followed: 
• ‘One of the important factors in the development of autism is without a doubt the administration of many vaccines at a very early age.’ (the NHS, states that there is no evidence that the MMR vaccine causes autism’) 
• ‘Autistic children should never again be vaccinated!’ (against the advice of the NHS) 
• Children should be given 1000mg of Vitamin C per year of age daily (the NHS states that more than 1000mg of vitamin C per day can cause: stomach pain, diarrhoea or flatulence) 
• Children should be given 10-30mg of zinc per day depending on age (the NHS states that more than 25mg per day risks anaemia and weakening of the bones.)  
The CEASE therapy website is not operated by or associated with the Society, but lists Society registrants who have undertaken CEASE training and opted to appear on the CEASE therapy website’s public directory. The team noted many of those registrants highlighted the practice of CEASE therapy on their own websites. The Society had noted in its 2016 annual report that CEASE therapy is a ‘popular CPD topic’ among registrants and it had previously linked to CEASE training provided by a Society registrant. The team suggested that this could imply the Society’s endorsement for CEASE therapy. 
The team asked the Society whether CEASE therapy was in line with its stated positions on vaccinations: ‘It is therefore unethical for a homeopath to advise a patient against the use of conventional vaccines or anti-malarial drugs’. The Society stated that CEASE protocol is not ‘homeoprophylaxis’. This did not allay the team’s concerns that vaccination may be actively discouraged by CEASE practitioners, against the Society’s Advertising Guidance for registrants: 
‘You can state that homeopathy is safe to use alongside conventional treatments, whilst being careful not to suggest or imply that it is safe to use instead of essential conventional medical treatment’ 
and Section 41 of the Society’s Code of Ethics and Practice: 
‘Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion; all speculative theories will be stated as such and clearly distinguished.’ 
The Society stated that undertaking CEASE training does not imply that a practitioner will claim to completely ‘eliminate autistic spectrum expression’, apply the entirety of CEASE methods within their practice, or undertake any action that would breach the Society’s Codes. However, there did not appear to be any supporting evidence for this, such as mitigating statements, on registrants’ websites or on the Society’s website or other public materials. The team suggests that the main sources of information for CEASE therapy would inform the public that its purpose is to treat autism (and other disorders and diseases) and to steer clients away from conventional medicine. 
The team suggested that from the information available, the Society would need to provide significant assurance to the Panel that it continues to meet the Standards for Accredited Registers. The Society committed to developing public guidance outlining the scope of CEASE therapy that is acceptable to incorporate into registrants’ practice. The Society would then develop a mechanism to assure that registrants who do apply aspects of CEASE in their practice do not contravene relevant standards. The team suggested that the Society had an opportunity to enhance public protection by publishing an industry-leading resource highlighting risks associated with CEASE therapy and appropriate standards and advertising guidance for practitioners. 
Strong language from the PSA and weasel words from the SoH. It would seem unlikely that the SoH can develop guidelines. This will be discussed later.

Knowledge Base
The PSA observed that the SoH's webpage on the evidence for homeopathy might suggest it was scientifically proven. It suggested that the SoH should submit the page to the ASA!

Share Your Experience
There were three submissions to the PSA. All three of the submissions state that the SoH failed to engage appropriately when concerns were raised - whilst all of the concerns contained an element of challenging the SoH to do something about misleading advertising, the third one raised other additional issues. Yes, I submitted the third one.

Can the Society of Homeopaths meet the Condition?
One thing the SoH are likely to do is interpret the Condition purely in terms of CEASE therapy, ignoring the broader issues. They might think that, for example, getting members to remove mention of it would satisfy the PSA. This is unlikely. Whilst the PSA do not mention it, the concerns raised with them focussed on competence and safeguarding issues - and those concerns were raised when the SoH failed to acknowledge them. These are not trivial.

The key areas they should address are -

  • Autism awareness training. CEASE therapy presents a model of Autism that is completely at odds with current best practice. The training will almost certainly have to come from a recognised provider - PSA are unlikely to accept, say, homeopaths running their own.
  • Safeguarding policy. The SoH will have to update its current guidance quite radically.
  • Safeguarding training. Again, the PSA are likely to want this to come from a recognised provider. The training may need to customised to address Autism specific issues as well as the odd nature of homeopathy.
  • Disclosure and Barring Service - although self-employed persons can not apply for their own DBS checks, other voluntary registers have set up schemes where the register applies for the checks. The SoH could make DBS checks mandatory for members who work with children and vulnerable adults.
  • Competence frameworks and assessments - a previous post revealed that CEASE therapy often involves ignoring symptoms. Clearly, the decision to ignore symptoms of what are potentially dangerous conditions is beyond the competence of any lay homeopath. The SoH may have to set up list of compentencies expected and a way to test/measure them.
  • Working with professionals - in all cases, the child's GP and, if they have, social worker must be informed. Parents who refuse to inform GP etc should be refused. It could be that treatments will have to be approved. SoH members will have to defer to professionals absolutely.
  • Restrictions on non-homeopathic products - either dosage limits or total prohibition.
  • Update Code of Ethics and Practice - SoH members effectively sign a contract to abide by the Code, so some requirements/restrictions should be placed there.
Tackling the disinformation and bizarre beliefs associated with CEASE therapy is probably impossible. The SoH has largely failed to deal with anti-vaccination claims by its members despite have a policy advising vaccination.

One thing is very clear. There are members of the SoH that would take very badly to any of this. They will resent being told that they are not competent to treat autistic children. They will resent any attempt at what they are likely to construe as "thought control". It is likely that they will fight any attempts to impose any restrictions on them, which would be counter-productive given the very strict timeframes involved. The SoH are likely to have to force through changes without consulting members. 

Rock and a Hard Place
The SoH has large reserves but it has been running at a deficit. Costs have exceded income from membership fees and other sources. As membership fees account for the majority of the SoH and member numbers have been in decline, the SoH can't really afford to lose members.

Would purveyors of CEASE therapy leave the SoH if restricted in their activities? Unknown. Would the SoH expel those members to retain PSA accreditation? Again, unknown. But the SoH may well be faced with a bleak choice between its financial future and PSA accreditation.

Whilst voluntarily relinquishing PSA accreditation would be less damaging than the PSA removing accreditation, it would represent a massive loss of face for the SoH and particularly those most closely associated with the drive towards it. Current board members that the CEO would likely be damaged - they let this happen. Director elections are due soon. Conveniently, nominations closed before the accreditation was published.

Whether the PSA would be damaged by the SoH relinquishing or losing accreditation is difficult to answer. Arguably, the loss of a register that can't control its members would not be a bad thing. The loss of more than one register would be a different matter and would raise questions about the initial framing legislation and whether the PSA should even be in the business of accrediting quack registers. Yes, the Condition imposed on the SoH does set a precedent for other registers.

Whatever happens, the SoH are in for a very rough ride over the next three months.

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