Complementary and Natural Healthcare Council

The Complementary and Natural Healthcare Council (CNHC) is an industry body which provides a voluntary register of alternative medicine therapists in the UK. The aim of the register is to "support the use of complementary and natural therapies as a uniquely positive, safe and effective experience." The CHNC was founded in 2008 and became fully operational in early 2009.^[1]

The CNHC has attracted criticism, mainly for its role in appearing to legitimize what critics regard as quackery and for its efforts to promote alternate therapies which are often of dubious or unproven efficacy.

Also, the fact that, four years after it was founded, it has failed to register more than a tiny proportion of the tens of thousands of CAM practitioners in the UK means that is not succeeding in its stated aim to protect the public against incompetence or malpractice in the disciplines it claims to regulate, let alone in those - homeopathy for example - whose practitioners have no interest in the CNHC and claim to regulate themselves.

Origins

The Need for Regulation

In November 2000, the House of Lords Select Committee on Science and Technology reported on complementary and alternative medicine and considered the public health policy needs and NHS provision of these treatments. In one of its many areas of consideration, the report considered the needs to provide public protection by regulating practitioners. It noted that those practices that could injure patients were either already statutorily regulated (chiropractic and osteopathy) or were soon to be (herbalism and acupuncture). The remaining largely placebo based therapies and those without a sound evidence base for their efficacy and robust regulatory systems (e.g. reiki, massage therapy, aromatherapy, yoga and homeopathy), suffered from having a large number of fragmented registration bodies with considerable diversity of standards. The House of Lords found this unacceptable and that "in the best interests of their patients such therapies must each strive to unite under a single voluntary regulatory body".^[2]

The House of Lords described the necessary features of an effective voluntary self-regulatory body. These included having a register of members, educational standards, a code of ethics and practice, a public complaints mechanism, and the capacity to represent the whole profession.^[3]

The Federal Working Group

Following publication of the report, the Department of Health asked The Prince's Foundation for Integrated Health (FIH), a not for profit organisation founded by HRH The Prince of Wales, to facilitate the development of a federal 'umbrella' regulator for these therapies. The Foundation promoted the inclusion of non-evidence based alternative therapies into public healthcare in the UK.^[4] but is now defunct. The process was funded by a Department of Health grant of £900,000 over a three-year period from 2005 to 2008.^[5]

On behalf of the FIH, Professor Dame Joan Higgins was asked to be Chair of a Federal Working Group which was to look into setting up what was to become the Complementary and Natural Healthcare Council. Therapies who participated in the Working Group were Alexander technique, aromatherapy, Bowen technique, cranial therapy, homeopathy, massage therapy, naturopathy, nutritional therapy, reflexology, reiki, shiatsu and yoga therapy. Other eligible therapies were aromatherapists, reflexologists and reiki practitioners, although these practices were not represented.^[5][6]

Structure

The Complementary and Natural Healthcare Council is a private limited company^[7] made up of four elements:

• Federal Regulatory Council
• Profession Specific Boards
• Functional Boards
• Practice Advisory Panel

Members of the Council and the functional boards will be laypeople, appointed independently; each Profession Specific Board (one for each profession) will have a lay Chair and four registrants from the appropriate profession. Each Profession Specific Board will select one of its practitioner members to sit on the Practice Advisory Panel which will provide a pool of expertise to support the Council.

CNHC Code of Practise supports evidence-based approach

While there has been considerable criticism of CNHC with regard to "quack" therapies their Code of Practise may support an evidence-based approach.

The CNHC’s Code of Conduct, Performance and Ethics states:

15. You must follow CNHC guidelines in relation to advertising your services
Any advertising you undertake in relation to your professional activities must be accurate. Advertisements must not be misleading, false, unfair or exaggerated. You must not claim that your personal skills, equipment or facilities are better than anyone else’s. If you are involved in advertising or promoting any other product or service, you must make sure that you use your knowledge, healthcare skills, qualifications and experience in an accurate and professionally responsible way. You must not make or support unjustifiable statements relating to particular products or services. Any potential financial rewards to you should be made explicit and play no part at all in your advice or recommendations of products and services that you give to patients, clients and users.^[8]

CNHC to tighten up on unjustified claims for which there is no evidence-base

Following complaints submitted by Simon Perry, a blogger and member of Leicester Sceptics in the Pub, regarding 14 reflexologists claiming to treat specific diseases without any credible evidence, Maggie Dunn, CEO of CNHC, has said that they will tighten up on therapists making unjustified claims for which they have no evidence. CNHC reviewed the claims made by the reflexologists against the Advertising Standards Authority (ASA) guidelines - and told the reflexologists to remove their claims. In a personal communication to Simon Perry from Maggie Dunn, the CNHC’s Chief Executive Officer, CNHC said that in the future:^[9]

• CNHC will tell practitioners to remove claims they cannot justify.
• CNHC will conduct a review of evidence base for regulated therapies.
• CNHC will contact all registrants to instruct them not to make claims without justification.
• CNHC will contact complementary health course providers and authors to instruct them not to make claims without justification.
• this is to cover all promotional materials and all interactions with the client.

However CNHC has made no public statement in this regard - possibly because many therapists will not want their public and private claims for efficacy to be regulated.

Criticism

"How does a regulator decide what is good practice and what is charlatanry when none of it has peer-reviewed, scientific evidence that it works?... Professor Michael Baum protested that 'this is like licensing a witches' brew as a medicine so long as the batwings are sterile'... It matters that Newsnight found homeopaths advising patients visiting malaria areas not to take anti-malarial drugs. And that patients are told not to give their children the MMR jab." Polly Toynbee, The Guardian.^[10][11]

Private Eye magazine argued that the council had a conflict of interests between promoting and regulating alternative medicine: "Everyone would say that propagandists cannot be regulators because they cannot be trusted to act in the public interest." It quoted Edzard Ernst, professor of complementary medicine at the University of Exeter, as saying: "This is ridiculous. It really is a farce. All they will need to prove is that [practitioners] are following an established technique they believe to be appropriate. It's a ludicrous system."

Private Eye and The Economist reported that critics have nicknamed the council 'OfQuack'. Private Eye quoted a joke slogan, 'OfQuack - making quacks look professional since 2008'.^[12][13]

In January 2009, an online petition was started at the UK Government Petition website, asking for stricter requirements on efficacy and safety as a condition of certification. An official response to this was posted, but simply reiterated the terms of the current requirements.^[14] However, in response to the point made by the petitioners and others, the CNHC has now amended its website, deleting its original statement that regulation by them gives a guarantee of the efficacy of the procedures carried out by their registrants.

In addition to the medical criticism, CNHC have also been censured by the British Standards Institute for use of their trademarked term "kitemark",^[15] and have also been criticised for poor openness^[16] and an inconsistent approach to data protection.^[17]

There is a twitter feed from OfQuack, an obvious parody as it has been described as "puerile and sarcastic", and occasionally refers to the CNHC separately from itself.

Progress since start-up

In December 2008, CNHC stated on their website that they hoped to have 10,000 practitioners registered with them by the end of 2009. This was later amended without comment to 4,000 by Spring 2010. However, by August 2009 a total of only about 500 registrations had been made in four disciplines: Massage Therapy, Nutritional Therapy, Aromatherapy and (from 24 August) Reflexology.

By February 2011 practioners in eleven disciplines were eligible, but according to the organisation's website the total number of registrants was still less than 4,000.

Lack of enthusiasm for the CNHC among practitioners may be partly ascribed to the fact that at present anyone may legally practise in the UK without qualifications as a reflexologist, aromatherapist, homeopath, naturopath, nutritional therapist, acupuncturist, etc., and that voluntary registration by the CHNC will make no difference to this.

Funding

Because so few registrations have been made, it is very unlikely that the CNHC will be self-supporting (from fees) in the near future. The major source of finance has been the Department of Health, and application has been made to them for further funds, However, this is dependent on adequate progress being made, which has not so far been the case.

Some of the 2009 reports from the CNHC to its parent organization, the Department of Health, have been made available under the Freedom of Information act.^[18] These largely confirm the view that income is much lower than originally planned and also show a major revision of planned income.

References

1. ^ The Complementary and Natural Healthcare Council
2. ^ Features of an Effective Voluntary Self-Regulatory Body, Science and Technology Sixth Report 21 November 2000 [1]
3. ^ Features of an Effective Voluntary Self-Regulatory Body, Features of an Effective Voluntary Self-Regulatory Body 21 November 2000 [2]
4. ^ http://www.fih.org.uk/ Prince's Foundation for Integrated Health
5. ^ ^{a b} Press Release from Prince's Foundation for Integrated Health
6. ^ Final Report of the Federal Working Group
7. ^ http://wck2.companieshouse.gov.uk/e26c10b4db895db39b7fd1426c7dfa74/compdetails CNHC Details at Companies House
8. ^ CNHC Code of Conduct, Performance and Ethics, www.cnhc.org.uk
9. ^ CNHC Wishes to Thank Simon Perry, http://adventuresinnonsense.blogspot.com, Friday, 27 November 2009
10. ^ Quackery and superstition - available soon on the NHS Polly Toynbee The Guardian January 8, 2008
11. ^ New laws to govern alternative medicine Nigel Hawkes The Times January 5, 2008
12. ^ Private Eye no. 1229 p.28, February 2009.
13. ^ Trust me, I've got a licence: Regulating the Quacks The Economist April 17, 2008
14. ^ CNHC Safety - epetition response Number 10 website June 19, 2009
15. ^ Ofquack's 'Kitemark' is Deflated Andy Lewis The Quackometer February 4, 2009
16. ^ Ofquack: "Minutes? We never posted any minutes!" Martin Robbins The Lay Scientists April 17, 2009
17. ^ Department of Health response to CNHC letter "Dr* T" Thinking is Dangerous blog March 12, 2009
18. ^ Progress Reports from the CNHC, WhatDoTheyKnow.com, 18 November 2009