My submission to the Professional Standards Authority asking them to rethink their accreditation of the Society of Homeopaths

This is what I sent to the Professional Standards Authority today about their re-accreditation of the Society of Homeopaths. If this doesn't mean much then you may want to skip to the end and read the 'background explanation' first.

This submission was one of a few sent in by skeptics (scientists, doctors, bloggers) as part of the PSA's open invitation to 'Share Your Experience' (of whatever register they're currently considering). This opportunity is available for a few weeks whenever an accredited register indicates that it would like to be considered for re-accreditation. 

This relates to the next round of re-accreditation, note that the Good Thinking Society have been given permission to have a Judicial Review of the PSA's earlier decision to re-accredit them last year, in light of significant concerns about autism treatments and advice on vaccination etc.

A. Letter to the PSA
B. Background explanation

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A. Letter to the PSA

Dear Accreditation team

Thank you for the opportunity to contribute to the ‘Share your experience’ consultation regarding the Society of Homeopaths and its interest in having its register re-accredited.

My direct experience of the Society is that everyone I’ve communicated with there has been courteous so I have no complaints about any personnel. I have been frustrated with the slow pace of getting websites I complained about changed(1) (though they have mostly been changed) however my wider experience of the Society in terms of its public statements and responses has been more frustrating. I am also unhappy that members are still offering CEASE therapy, regardless of any claims made about it.

1. Lay homeopaths are not healthcare professionals
Taking the second clause first - “We help to protect the public through our work with organisations that register and regulate people working in health and social care.”

Homeopaths are not qualified to give health advice and cannot meaningfully diagnose or treat any condition. This alone could have excluded the SoH’s register from accreditation by the PSA in the first place.

Homeopaths’ training seems to be based on a fundamental misunderstanding of health, physiology or pathology (and frequently chemistry and physics too) and they are not always giving good or sensible advice.

Given the concerns that CEASE is harmful to and discriminates against autistic children (and that marketing compliance would not necessarily stop the ‘treatment’ from being offered) I am surprised that accreditation has been continued. I do not think the Society of Homeopaths should be re-accredited.

2. CEASE is problematic whether or not it’s mention in marketing
• Autism is not curable and implying (through the use of the acronym, the full version, or other text) that it can be cured, eliminated or otherwise lessened through supplements and homeopathy is cruel to autistic people and to the parents of autistic kids.
• The treatment itself is potentially harmful; the source material (though I have not seen the current training manuals) have recommended very high doses of vitamin supplements, against NHS advice, and seems to celebrate diarrhoea as a way of ‘detoxing’. This is nonsense. The CEASE therapy website (to which several SoH members still link (2)) recommends odd dietary restrictions and a baffling avoidance of microwaves.
• The concept of CEASE is linked to anti-vaccination sentiment with an inherent suggestion that vaccines are one of several ‘toxins’ that can lead to a toxic imprint which might be reversed by giving homeopathic “anti-toxins” based on vaccines such as MMR, this promotes the wrongheaded notion that there is any link between MMR and autism.
• Even with full marketing compliance SoH members could still be offering CEASE. The treatment isn’t a treatment for autism, it’s not been properly tested and is potentially harmful. It’s also not clear how anyone offering Skype consultations is able to properly assess a child. Anyone offering CEASE to an autistic child is acting against the child and the family’s best interests. By comparison people are no longer permitted to offer ‘gay conversion therapy’.

3. The SoH’s responses around CEASE have not been helpful
• The SoH’s 2016 Annual Review highlighted CEASE as something that was “noted as (a) popular CPD topic among our membership” instead of stating that it should not be on the market.
• Their position statement on CEASE says that it is “acceptable” for members to market CEASE therapy but that they should not imply a complete cure as that “would be unethical and in breach of the Code of Ethics” - rather than simply “not possible”.
• Members were slow to amend their websites after I complained about the websites of five RSHoms offering CEASE. Changes took several months though change did happen.(1)

4. Their responses to criticisms of homeopathy are also not helpful
• The SoH’s response to the ASA sending a compliance letter to UK homeopaths in September 2016 was to “seek legal advice on the legitimacy of the ASA and the actions it is taking pursuing homeopaths”, though they did follow legal advice not to pursue that further.
• Rather than sanctioning a member for spending half an hour talking about homeopathy and vaccines (homeoprophylaxis) to what turned out to be a newspaper reporter the Society complained about the journalist to IPSO. Their position statement on homeoprophylaxis starts out strongly but ends disappointingly by suggesting there may be something in it.
• News that the Good Thinking Society intended to request a judicial review into your decision to re-accredit the SoH was described as “whipping up hysteria.”

5. Accrediting the SoH does not protect the public
“We help to protect the public through our work with organisations that register and regulate people working in health and social care” - I would argue that the public are not protected by accrediting the SoH’s register of members. What is the benefit of recommending that people “only choose practitioners who are regulated or on an Accredited Register” when those practitioners are likely to be offering unwise advice about vaccinations or non- and potentially harmful treatments like CEASE?

6. Comments on menopause are also likely to be misleading
A separate statement from the SoH on menopausal symptoms shows that women are not
being given good advice either. I think this advice is likely to be misleading (and may well be at odds with ASA / CAP recommendations).

“Homeopathic remedies which can help to ease the symptoms of menopause are being highlighted to help women who are currently unable to get their hands on HRT” - this is from a news story in Sep 2019 in which I suspect the evidence offered is unlikely to satisfy the ASA. Surely no-one should be implying that homeopathy can help symptoms of menopause. (The compliance letter sent to homeopaths in the UK in Sep 2016 said “homeopaths may not currently make either direct or implied claims to treat medical conditions”).

7. Footnotes
(1) Website marketing claims took a long time to be amended
I wrote to the SoH on 9 November 2017 with details of five of their (then) members about problematic claims on their websites. I blogged about this a month later - I did not expect many changes to have been made by then but in several cases it took more than six months for changes to be made (it seemed to happen between June and July 2018). One homeopath is no longer a member (as of December 2017) and the websites of the remaining four are much improved, for example removing the link to the cease-therapy dot com website or not writing out the acronym in full.

(2) Examples of homeopaths currently linking to the ‘cease-therapy dot com’ website
Linking to this website is a problem because misleading claims are plentiful there but are not being said ‘directly’ by the homeopath, nor is the website within the UK’s jurisdiction.

[I have redacted from this post the names of the homeopaths and the links to their websites]


B. Background explanation
The Professional Standards Authority (PSA) regulates the regulators in healthcare. As an example they oversee the General Medical Council (GMC) and the GMC regulates doctors by keeping a register of members, setting standards, checking that doctors' education is up to scratch (and revalidating their learning) and by investigating complaints made about doctors. The GMC's operation is also regulated by the law (specifically by the Medical Act 1983).

The PSA also provides a similar scheme for organisations "that register health and social care practitioners who are not regulated by law" and this is where the Society of Homeopaths comes into the equation. They also keep a register of homeopaths, set standards, require a minimum of study and investigate complaints about homeopaths. Because of this their register of members (who can use the term RSHom to indicate that they are registered members of the Society) was accredited by the PSA in 2014 and has been re-accredited every year since.

In 2017 several skeptics expressed concern to the PSA that a number of their members were offering CEASE therapy to families with autistic kids and implying that it could help them (some of them made stronger claims). The PSA took action and in their re-accreditation asked the SoH to address this, adding conditions to their re-accreditation in 2018. The PSA considered at the next round of re-accreditation that the SoH had satisfied these requirements - however members are still offering CEASE and continuing to make misleading statements about autism and vaccination. Many of them give harmful advice around vaccination and some of them have even implied to potential customers that such a thing as a homeopathic alternative to vaccination exists (it does not).

Accreditation by the PSA does not mean that it thinks homeopathy works - they don't consider the efficacy of any particular treatment, only that the organisation registered keeps records of members. This is probably fine where an organisation is providing a valuable service but perhaps less so where an organisation has some of its members offering harmful autism treatments.