Cliff edge

What is going on with the Society of Homeopaths (SoH) and the Professional Standards Authority (PSA) has become a little clearer. Things have moved on since the last blog post. The SoH recently told the PSA that they do want to renew Accredited Register (AR) status.

But the SoH has a number of hurdles to overcome before the PSA will consider their application.

Conditions

The PSA have imposed various Conditions on the SoH. One Condition was imposed by the last Annual Review, three by an in year review in July 2020. 

The decision as to whether the SoH have met those Conditions will be made by an Accreditation Panel (composed of three senior PSA staff). If they haven't, Accreditation may be removed. If that happens, the SoH's application may be dead in the water.

Two were due on 21/10/2020. At the time of writing, the Panel was still yet to meet.

Condition 1: The Society must ensure that its recruitment processes include appropriate due diligence checks to assure itself that applicants are, and have been, in compliance with the Society’s Code of Ethics and position statements, including those relating to the use of social media. This should apply to all paid and voluntary positions within the Society including Board and staff members. The Society should also ensure that it has processes in place to assure itself that officials of the Society remain in compliance after appointment. The Society must report to the Authority on the steps it has taken to comply with this condition within three months of the date of this letter. (Deadline 21 October 2020)

It isn't known exactly what the SoH's policies are on social media (not visible to the public). Even so, this should not be too difficult to meet. Recently advertised positions mention compliance as a pre-condition for application and that the SoH will send a copy of the policy to the applicant. The more cynical might think that this would present an applicant with an opportunity to delete any problem content - although if the applicant is a member of the SoH they should already be compliant.

Condition 2: The Society must provide the Authority with its policy for the escalation of complaints against registrants, which are initially handled informally, into its formal processes and its procedures for handling persistent complainants. The Society must also provide a summary of complaints received since the publication of its new position statement on 10 June 2020 (including those handled through an informal route) and outcomes to the Authority. This should be completed within three months of the date of this letter. (Deadline 21 October 2020)

This is trickier. Historically, the SoH were averse to dealing with complaints/concerns from critics. This has not served them well in recent times as frustration with the SoH has lead to critics raising concerns with the PSA about the SoH's complaint/concern handling. Providing the PSA with a policy and procedures is one thing but the PSA want to see if that they are being applied.

The PSA have indicated that the Accreditation panel may take into account any issues that have raised in those concerns/complaints. Whilst none are likely to result in the Accreditation panel removing Accreditation, they could result in the imposition of further Conditions. On the other hand, given that renewal is getting closer, they may defer consideration of such matters until then.

Condition 3: The Society must: 

a) monitor its registrants’ use of social media to ensure that they are complying with its position statements. The Society should provide quarterly reports to the Authority. 

b) review and if necessary, update its social media policy for registrants, ensuring consistency of guidance to registrants on the content of their own websites, and their statements and actions on others’ websites and other social media. This should be completed within six months of the date of this letter. (Deadline 21 January 2021)

a) in effect broadens the scope of Condition c) discussed below. That deadline is getting very close and although some SoH problem members have amended social media content, more have done absolutely nothing. The SoH really needs to pick up the pace of getting members to comply if it intends to meet that condition.

b) potentially sets up a requirement for the SoH to look at all online activity by members. 

It's clear from some PSA reports that they have concerns about the tone of guidance that the SoH has produced in the past. They felt that the SoH has not taken public protection seriously. It looks as if the SoH issued some sort of social media guidance in April 2020 but there is no obvious sign of it being updated. It is impossible to know if it has been reviewed. There may be a gap between what the SoH thinks compliance looks like and what the PSA thinks. 

Some non-compliance is certainly down to intrasigence on the part of more difficult members. It is known that the SoH have spoken to some members about their social media yet they show no sign of amending it. The most clearly worded guidance would be unlikely to have any effect on them. Expulsion may be the only option. 

Also, there is a Condition set in February 2020 by the previous Annual Review. For convenience, this will be refered to as Condition 0.

a) Make its position statements clear that registrants must not practise or advertise adjunctive therapies that are incompatible with Society registration. Specific reference must be made to the Society’s position forbidding the 2 practice of CEASE, and dietary/nutritional supplements. This must be submitted to the Authority for review and published within three months. - met

b) Make its position statements clear that registrants’ scope of practice does not allow registrants, whether acting in a professional or public capacity, to provide advice on vaccination or offer or provide homeopathy as an alternative to vaccination for the prevention of serious infectious diseases. Registrants should direct service users to NHS and other public health sources, for example, their GP or public health departments. Revised statements must be submitted to the Authority for review and published within three months. - met

c) Provide quarterly reports of its monitoring to ensure that within the following 12 months all registrant websites comply with its updated position statements (as referred to in part a above) - deadline 13 February 2021

d) Complete and make available to the public its guidance on adjunctive/supplementary therapies and inform the Authority how it will promote compliance with that guidance - deadline 9 January 2021

c) is very tough. In short, all member websites must comply with the Position Statements by the deadline. If members do not voluntarily comply, the SoH will have to at the very least suspend them if not expel them. The SoH looks to have expelled one member over anti-vaccination content on their website. Kate Diamantopolou is very obviously anti-vaccination. Compared to some ARs, the SoH provide very little information on specific allegations but there is the hint of more than just her website being non-compliant.

It may be able to meet this Condition but there could be problems with the interpretation with the Position Statements. Given that there will be four reports in total, the PSA will know if progress is being made. It is known that the PSA will be doing their own checking.

d) has the potential to upset a lot of members. Many members use "therapies" other than homeopathy. If the SoH declares some of them incomptaible with membership, they could lose members. It doesn't set a deadline for compliance but there is the potential for the PSA to impose a Condition.

This is a problem that affects other Accredited Registers as well. Their attitudes vary. It is known that the PSA expects them to cooperate over some of the more problematic therapies that are offered.

Member consultation

The SoH ran a member consultation February 2020 to September/October 2020 regarding AR status. The results of the consultation are not available to the public nor is qualitative analysis that seems to have been carried out.

What it told members during the consultation is unknown but historically, the SoH has played up the supposed benefits of Accreditation most of which have not materialised and never mentioned the downsides. There is no indication of whether the SoH communicated to members that the price of retaining Accreditation is ever escalating restrictions on what they do and what they say. Nor is there any indication of communicating that the SoH would have to actually start to enforce restrictions at some point. It is doubted that the SoH would have been as blunt as telling members that support for Accreditation is support for expelling members who refuse to comply with standards.

Renewal Process

The renewal process guidance has changed. It is a lot clearer, especially in terms of timings. It may take a while for the timings to be achieved though. The PSA has had a backlog of Accreditation renewals which it is working its way through. Also, Conditions placed on ARs before prior to the new guidance was in place may have deadlines that don't align with the new timeline. For example, the guidance talks about the Accreditation decision being made four weeks before the renewal date but some Conditions have the renewal date as their deadline. This seems to be the case for some of the Conditions on the SoH and the decision of whether they have been met will be part of the renewal decision rather than seperately considered.

Fees guidance states - 

Once payment has been received and confirmed by the Authority’s Finance team, the Accreditation team will start their review.  

Fees are non-refundable. 

Warning signs

As well as consideration of the Conditions that have a deadline around the renewal date, the PSA stated in the August in year review - 

4.9 However, the Panel confirmed that there are clear public health reasons why it is wrong for practitioners to endorse the practice of CEASE, anti-vaccination messages or otherwise suggest that homeopathy should be used as an alternative to recognised medical interventions. The Authority expects all Accredited Registers to take a proactive leadership role in ensuring that its registrants are meeting its standards and considered that, if the Society does decide to continue to seek to be part of the register, it needs to demonstrate that its leadership fully supports both the spirit and the letter of its statements. The Authority can look at this question again as part of the next reaccreditation round.

This is strong stuff. One criticism of the SoH is that in the past it has done the minimum possible to satisfy the letter of Conditions, Recommendations, etc. For example, it only looked at websites of members and didn't look at Facebook accounts that were being used as websites. 

What the SoH should expect, if they manage to retain Accreditation, is another raft of Conditions and Recommendations (which as the in year reviews have demonstrated can turn into Conditions). It should also expect complaints to be raised.

At the moment it looks as if the SoH will fail to meet Condition 3. If the SoH fails to retain Accreditation as a result, it may appeal, likely on the grounds that the time scales were unreasonably short. The most that could achieve is re-Accreditation with an extended deadline of the Condition hanging over it.

It could try to argue that restrictions on members' personal social media are unreasonable but there are precedents for members of certain professions being sanctioned by their regulator over personal social media. If the SoH pursued that line would be effectively admitting a lesser status for its members than "professional". 

Complaint

Prior to the change in the renewal process, the only way for third parties to challenge an Accreditation decision was via judicial review. Now, third parties can complain about decisions. This is not the same as an appeal in that it can't overturn an Accreditation decision but one potential outcome is that the PSA could mount an in year review.

In theory, the PSA were always able to do this but never have until the SoH had their problems. 

In year review

The PSA suggests as reasons for in year review - 

a. Information that indicates a Standard has been breached.

b. Information that suggests the Accredited Register has not been transparent in a previous renewal of accreditation.

c. Information that suggests a previously met Condition may have been breached.

d. Events that have potential to bring the programme into disrepute.

A complaint about the renewal of the SoH's Accreditation would likely have to present new evidence that the PSA had not seen to trigger an in year review. It is known that the SoH has given incorrect/incomplete information in the past although the reasons are unknown.

Can the Society of Homeopaths retain Accreditation?

Possibly, if it can meet Conditions 0.c and 3.a. It should become clearer whether they stand any chance of this closer to the respective deadlines.

However, getting past the renewal stage is one thing. Something like the Sue Pilkington fiasco could happen again and trigger an in year review. Renewal is bound to come with Conditions and depending on deadlines, failure to meet them could result in removal of Accreditation before the next renewal.

There is also the strategic review of the AR programme. It will not deliver anything in time for this renewal but it certain will for the next and that could involves changes to the Standards that the SoH might be hard pressed to meet.

Game over for the Society of Homeopaths?

The in-year review of the Society of Homeopaths (SoH) Accreditation by the Professional Standards Authority (PSA) has completed. The PSA did not remove Accreditation. Instead it imposed addition Conditions on the SoH.

Whilst this may fall short of what some critics of the SoH were hoping for, it does not mean the SoH are out of the woods yet. It would be very difficult for them to meet the Conditions. They may choose to withdraw from the Accredited Registers scheme.

Parts
There is a news item.
It links to a Accreditation Panel report from July 2020. This was not published immediately.
Because of concerns raised, a further report was produced in August 2020. This was published a week after the Accreditation Panel met for the second time.
On the page about the SoH, there is a link to Q&A about the in-year review as well as the August report, as well as re-stating of the Conditions.


Background
Regular readers will be well aware of the multiple ongoing concerns about the SoH and its members. An in-year review can occur outside of the usual annual cycle if serious concerns are brought to the attention of the PSA.

It's clear that the appointment of Sue Pilkington initially triggered the in-year review. To quote from the July report.

3. Investigation of concerns raised in June 2020 

3.1 On 11 June 2020, the Authority received information through its Share Your Experience process that the recently appointed Safeguarding Lead of the Society (who is also a registrant) had apparently published social media posts that might contravene the Society’s position statements, and its wider standards and Code of Ethics. 

3.2 The Authority raised the concerns with the Society and began an investigation on 12 June 2020. The Authority undertook a social media audit and found material on the Safeguarding Lead’s social media, and the Society’s own social media accounts, which appeared to contravene its Code of Ethics and recently published position statements, and the Cancer Act 1939. Some of the posts were within the past six months and included material that could be considered anti-vaccination and promoting treatments for specified conditions, including cancer and Covid-19. In accordance with its processes, the Authority asked a Moderator to consider the evidence and decide whether further investigation or other action was warranted.

The Moderator believed that there were sufficient concerns for a Panel to consider the matter. The Panel were concerned by Pilkington's appointment.

4.3 The Panel expressed its serious concerns that, very soon after the Society’s accreditation had been renewed with conditions designed to ensure registrants’ compliance with core requirements of practice, the Society had appointed to a critical position a person who had recently published statements at clear variance with those requirements. This inevitably called into question the Society’s ability to comply with the Standards for accreditation.

The July 2020 report was not published but it would have been seen by the SoH. The SoH were well aware of concerns and Conditions before the public were.

Other concerns were raised which caused the Panel to consider things again.

3 Concerns raised July 2020  

3.1 On 30 July 2020 the Society reported to the Authority that its interim Chief Executive Officer (CEO) had resigned. The Authority was concerned that the fact that two senior posts were vacant might mean that the Society was unable to take the actions that would enable it to meet the new Conditions. 

3.2 In addition, the Authority became aware that a particular registrant appeared to still be advertising and practising CEASE, despite us bringing this registrant to the attention of Society in February 2020. On further investigation, we discovered that 32 Society registrants were listed as CEASE practitioners (around a third of the total listed for the UK) on the cease-therapy.com website. Although this website is not run by the Society or any of its members directly, the inclusion of Society registrants on the website raised concerns about the effectiveness of the actions being taken by the Society to ensure its registrants comply with its position statements. The Accreditation team looked at the websites of those individuals and noted concerns about the content of six of them.

Emily Buttrum was appointed CEO in October 2019. By March 2020, she had gone. Richard O'Quinn was interim CEO up until 30/07/2020. Apparently, the SoH have a new interim CEO but their identity is unknown. The SoH website still shows O'Quinn as interim CEO. There is a question about O'Quinn's involvement in the appointment of Pilkington.

There are a small number of SoH members who still mention CEASE on their websites despite the SoH's prohibition. These members have been known to both the PSA and SoH since the end of 2017. There are questions about the ability of the SoH to monitor and enforce member compliance.

Conditions
As the various documents make clear, the PSA think that the problems with the SoH can be dealt with by existing and new Conditions, rather than removing Accreditation, assuming the SoH are minded to implement the Conditions.

There are two Conditions from the Annual Review that still need to be fulfilled -

c) provide quarterly reports of its monitoring to ensure that within the following 12 months all registrant websites comply with its updated position statements (deadline 13 February 2021).

Monitoring is time consuming but achieving total compliance is more about persuasion and if it comes to it, expelling members.

d) complete and make available to the public its guidance on adjunctive/supplementary therapies and inform the Authority how it will promote compliance with that guidance. 

The PSA is asking the SoH come up with a policy on adjunctive therapies. It's not asking for compliance yet. It wants to know how the SoH will ensure compliance. As discussed here, the use of adjunctive therapies seems to be very prevalent. If the sampling is representative, more members other therapies in addition to homeopathy than don't. 

The new Conditions are -

Condition 1 – recruitment policies  

4.7 The Panel considered the Society’s proposals to change its recruitment policies. The Panel considered that it was essential that members of the Society’s staff team and its Board demonstrably uphold the Society’s standards. It is important that the Society undertakes due diligence about this through checks conducted during its recruitment processes and also on an ongoing basis to ensure that compliance is maintained. 

4.8 The Panel decided to issue Condition 1: The Society must ensure that its recruitment processes include appropriate due diligence checks to assure itself that applicants are, and have been, in compliance with the Society’s Code of Ethics and position statements, including those relating to the use of social media. This should apply to all paid and voluntary positions within the Society including Board and staff members. The Society should also ensure that it has processes in place to assure itself that officials of the Society remain in compliance after appointment. The Society must report to the Authority on the steps it has taken to comply with this condition within three months of the date of this letter. (Deadline 21 October 2020)

Appointing Pilkington was an unmitigated disaster for the SoH. This Condition is hardly surprising. On the face of it, it looks easy to comply with but it would effectively exclude a considerable proportion of SoH members from holding paid or voluntary positions with the SoH. It would exclude anti-vaccinationists for standing for Board elections and so. Not only that, but the SoH would have to continuously monitor appointees' activities. There are questions about the monitoring abilities of the SoH.

Condition 2 – complaints handling 

4.9 The Panel considered the Society’s processes for handling complaints about its registrants’ websites and social media content. The Panel noted that the Society had received twenty-one complaints about its registrants’ compliance with its new position statements. The Panel noted that it was not for the Panel to comment on how individual complaints were being handled as these cases were ongoing and it is the Authority’s policy not to get involved in ongoing complaints.

4.10 The Panel noted comments from the Society during verbal evidence that it was the Society’s policy to deal with such concerns in an informal way by, for example, contacting a registrant regarding advertising that is in breach of its Codes and working with them to put it right, before initiating its formal complaints procedures or referring to Trading Standards. The Society has previously stated that it will accept concerns from any source, all concerns are acknowledged and acted on, but outcomes are not provided to the party raising the concern if it has been handled through an informal process. It was unclear to the Panel, however, how the Society escalated concerns from an informal route to a formal route where that was justified, or how it handled persistent complainants. 

4.11 The Panel decided to issue Condition 2: The Society must provide the Authority with its policy for the escalation of complaints against registrants, which are initially handled informally, into its formal processes and its procedures for handling persistent complainants. The Society must also provide a summary of complaints received since the publication of its new position statement on 10 June 2020 (including those handled through an informal route) and outcomes to the Authority. This should be completed within three months of the date of this letter. (Deadline 21 October 2020)

This requires some explanation. Whilst the PSA may not want to comment on individual complaints/concerns, they do want to know what the SoH are doing about them. The PSA is not confident that the SoH is dealing effectively with them. There have long been concerns about how the SoH deals with concerns. Historically, it has tended to brush off public health concerns.

The SoH has had multiple opportunities to deal with some concerns such as CEASE and anti-vaccination. Generally, it hasn't and when it has reluctantly acted it is because the PSA has put pressure on it. It rarely engages with those raising concerns, which sometimes results in the PSA getting involved.

Condition 3 – social media policy 

4.12 The Panel noted the Society’s proposals to update its social media policy to give it more of a public protection focus and noted that this had been issued as a Recommendation to the Society at its last annual review in February 2020. The Panel agreed that the concerns raised about the Safeguarding Lead and the Society’s handling of this process, could give rise to concerns about its ability to inspire public confidence in its management and governance of the register. This placed further importance on the need for clear guidelines to its registrants. 

The Panel decided to replace the previously issued Recommendation with a new Condition 3: The Society must: 

a) monitor its registrants’ use of social media to ensure that they are complying with its position statements. The Society should provide quarterly reports to the Authority. 

b) review and if necessary, update its social media policy for registrants, ensuring consistency of guidance to registrants on the content of their own websites, and their statements and actions on others’ websites and other social media. This should be completed within six months of the date of this letter. (Deadline 21 January 2021)

The PSA are being very clear here that the SoH's Position Statement applies to members' social media and marketing on third party websites. Formulating a social media policy was originally a Recommendation in the Annual Review -

5.15 The Authority had received concerns regarding a sample of registrants’ public social media posts, that appeared to discourage vaccination and drew this to the Society’s attention. The Authority considered an initial response from the Society which appeared to apply different standards between registrants’ professional, and personal behaviours on social media. The response suggested the possibility that outside of their homeopathic practice, registrants may act contrary to the Society’s standards without risk ofdisciplinary action. 

5.16 The Authority did not agree with the Society’s position that personal beliefs, stated in public spaces, could be distinguished from registrants’ professional practice. The Authority noted many practitioners were self-employed or otherwise represented their own practices on social media, and that promoting ‘anti-vaccination’ messages may conflict with the Society’s position statements. The Authority asked if the Society had considered issuing its policy on the use of social media (further to existing statements regarding treatment of cancer) in its position statements (or other guidance) or within its Code of Ethics. 

5.17 The Society, having further reviewed the social media pages provided, considered they were part of the registrants’ practice due to the content and nature of the materials ‘posted’. The Society stated it accepted that if registrants’ personal social media pages are publicly accessible, members of the public looking for information about homeopaths or homeopathy may be informed or influenced by what they read there. 

5.18 The Society affirmed that the use of social media blurred boundaries between registrants’ personal and professional lives. The Society stated it would develop guidance on the use of social media by registrants and its Board. The Society would draw from existing examples of best practice and engage its membership in development of the guidance. Once issued the Society would check registrants’ engagement with the guidance and include social media pages where possible within its regular audit of registrants. 

5.19 The Society advised that those registrants already highlighted to the Society would be prioritised under its audit schedule. Where necessary the Society would consider disciplinary procedures, applying relevant sections of its Code of Ethics, and its previous communication to registrants requiring them to review all social media pages, websites, and other material. 

5.20 The Authority noted the Society’s recognition that registrants’ social media may impact on their professional life and their compliance with the Society’s standards. The Authority also noted that the Society had confirmed it could take action regarding registrants’ use of social media and considered theSociety’s approach appeared proportionate. As part of the Condition issued under Standard 2, the Authority required the Society to provide a copy of its guidance to the Accreditation team and set out how it would monitor compliance with that guidance. (Recommendation 3)

If the SoH has a social media policy, it's not been made public. Even if it does exist, the SoH will likely have made a mess of it. There are concepts that homeopaths struggle with such as professional boundaries which would have to be addressed as part of such a policy.

Worse
From the August report -

1 Outcome 

1.1 The Panel met on 13 August 2020 to consider the information provided as part of an in-year review of the Society of Homeopaths (the Society). The Panel recognised the concerns raised, however felt that they could be addressed through the previously issued Conditions. The Panel decided that it would not be proportionate to take further action at this time. However, the Panel wished to make clear that the Authority expected that the Society had a leadership role in demonstrating whole-hearted endorsement of the Authority’s view that advertising or undertaking Completed Elimination of Autistic Spectrum Expression (CEASE) therapy or putting across anti-vaccination messages posed a risk to public health and were not compatible with membership of an Accredited Register. The Authority would be assessing the Society’s approach to this in the event that the Society sought reaccreditation.

 Before the Panel considered the matter -

3.6 The Moderator considered the messaging provided by the Society to its registrants about its new position statements and noted that there appeared to be inconsistencies between the messages the Society was giving to its members and the content of its position statements. This raised the question about whether the Society has made an effective distinction between professional and public interest, and properly prioritised the latter. The Authority expects public protection to be the main focus for its registers.  

3.7 There was concern that materials provided to members by the Society failed to adequately recognise the concerns raised about CEASE and anti-vaccination as valid risks to public protection. This, combined with a further change in leadership, could undermine confidence in the ability of the Society to ensure compliance with the position statements.

The putting members' interests first and failing to recognise CEASE and anti-vaccination as risks are long standing criticisms of the SoH. It's not known what was in that messaging that caused some much concern but the SoH saying one thing publicly and something else to members is nothing new. It maybe the case that the PSA had to ask to see the communications with members. 

Also -

4.8 The Panel noted the communications by the Society to its members. It was concerned that the tone of these communications may indicate that the Society did not see the issues raised as a significant as the Authority does. However, it also recognised that there were significant differences of opinion within the Society’s membership and that it was open to the Society to have a debate about whether it wished to be part of the Accredited Registers scheme or not. While the Panel was disappointed that the leadership of the Society was not more emphatic in endorsing the Conditions, it recognised that there was a spectrum of reasonable ways to put the message across and it did not consider that the Society’s communications went so far as to undermine its position statement. 

4.9 However, the Panel confirmed that there are clear public health reasons why it is wrong for practitioners to endorse the practice of CEASE, anti-vaccination messages or otherwise suggest that homeopathy should be used as an alternative to recognised medical interventions. The Authority expects all Accredited Registers to take a proactive leadership role in ensuring that its registrants are meeting its standards and considered that, if the Society does decide to continue to seek to be part of the register, it needs to demonstrate that its leadership fully supports both the spirit and the letter of its statements. The Authority can look at this question again as part of the next reaccreditation round.

The clear unambiguous message from the PSA is that anti-vaccination and CEASE therapy are incompatible with membership of an Accredited Register.

The criticism of the SoH's leadership is also very clear. There have long been concerns about its leadership but compared to what was said in Accreditation report back in February, either the PSA's position has hardened or the SoH have gone backwards. To quote -

5.21 The Authority noted the breadth of actions undertaken by the Society’s leadership in response to the issues highlighted, within the period of assessment and considered that these would inspire confidence in the Society’s ability to manage its register effectively. The Authority found that this Standard continued to be met, noting the link to the issues identified and Conditions set within Standard 2.

Whilst it is known that the SoH is/was consulting with members over PSA Accreditation, there is no indication of how far this has got, let alone any outcome.

Game over?
This blog has made the point that the SoH may be better off withdrawing from the Accredited Registers scheme. In short, the scheme has delivered no obvious benefits to SoH members and the increasing compliance requirements have lead to the loss of members.

Because of varying deadlines of the Conditions, there are several points at which the PSA could remove Accreditation. Even if they can get through those, the PSA have clearly signalled that they would long and hard at the SoH's leadership at the next Accreditation. There is also the possibility that events could trigger yet another in-year review if the SoH does something as spectacularly stupid as appoint Sue Pilkington.

The in-year review took a narrow focus. There are a number of issues that it did not deal with. For example, it did not consider the business of the effective re-branding of CEASE therapy as "Homeopathic Detox Therapy". Or the problem of certain members spreading COVID-19 misinformation and being against masks.

The PSA has started a consultation on the future of the Accredited Registers scheme. Whilst it is unlikely to result in any direct changes to Standards in the short term, responses may influence the PSA's interpretation of the current Standards and this would be in addition to the change in emphasis seen above.

It is not at all clear which way the SoH are leaning on Accreditation at the moment. It has made no real public mention of it since February 2020. Its members likewise have had nothing much to say since then, which suggests indifference.

It needs to decide very soon what it is going to do. Doing nothing is pretty much guaranteed to end in removal of Accreditation and extensive negative media coverage.

A Simple Question

The last post mentioned that the Society of Homeopaths (SoH) was attempting to engage with its members. The timining of this engagement was highly suggestive of it having something to do with the Professional Standards Authority (PSA) decision to conduct an in-year review of the SoH's Accreditation.

Admittedly, at the time of writing it is about two weeks since the engagement was concluded. The SoH has said nothing publicly yet about the outcome of this engagement. Neither have any of its members. In fact, there seems to have zero publication reaction from any UK homeopaths to Telegraph story that revealed that the SoH had appointed an anti-vaccinationist as Professional Standards and Safeguarding Lead and that an in-year Review had been initiated.

As far as can be determined, the in-year Review process is still ongoing but it is unknown what stage it is at.

Process
The Annual Review process has been discussed at great length in various posts. However, something that has not been mentioned is that at two separate stages, the PSA will share drafts of the Accreditation report -

Step 1: The Accreditation team will carry out a review of the evidence gathered during the year and supplied by the Accredited Register in the annual review form. The Accreditation team will produce a report based on this review which will be shared with the Accredited Register to check for factual accuracy and to answer any questions that the Accreditation team may have.

And

Step 5 (if applicable): Once the team has completed its targeted review, it will update the summary report. This will be shared with the Accredited Register to check for factual accuracy. The team will then convene an Accreditation Panel made up of three members of the Authority’s staff. The Moderator will not be eligible to sit as one of the three members of the Panel for a register they have reviewed in Step 3. 

As in-year review is supposed to be quicker, the first step might not happen. There is no way of directly knowing if Step 5 has been reached. But the SoH will get an indication of the PSA's thinking before anything is published.

It is clear from prior Accreditation reports that the SoH's fact-checking was deficient. There are also concerns about disclosure, non-cooperation and a tendency to spin things out. The SoH need to bear in mind that they need to provide evidence that they meet the Standards for Accredited Registers. There is evidence that suggests that they do not. Non-cooperation, non-disclosure and providing factually incorrect information is not going to help them in the slightest.

Once the Accreditation Panel has made its decision, the SoH will have 10 working days to appeal. 

Anti-vaccination? Not a problem
Looking back at prior Accreditation reports, it's clear that initially anti-vaccination among SoH members was not considered a major risk by the SoH and that the PSA didn't think so either. There is mention of anti-vaccination in the first Accreditation report -

The Panel considered a Call for Information response alleging that members of the Society had been associated with the ‘Andrew Wakefield / MMR vaccine’ controversy and related public health risks, such as ‘Steiner schools as unvaccinated communities’ leading to increased occurrences of disease outbreaks. The Panel noted the damage to public confidence in the Society that such allegations could cause. The Panel noted relevant actions carried out by the Society such as introducing guidelines for registrants and placing a public position statement on its website stating that it does not endorse the use of homeopathic medicines as an alternative to vaccination for the prevention of serious infectious diseases.

The link to Wakefield is former SoH Director Richard Barr. Steiner schools have in the past been linked to measles outbreaks. Some lay homeopaths send their children to Steiner schools and actively try to use other parents as a client base. But this is really about being linked to anti-vaccination activities of others. The "guidelines" are mostly a reaction to various reports by BBC Newsnight and were weak and the subject of much criticism. "Does not endorse" isn't an absolute prohibition and it took several years to get the SoH to issue a prohibition (which has been ignored by some).

Anti-vaccination among members has always been a very real risk to public health, the SoH's reputation and Accreditation. It is almost certainly the risk that poses greatest danger to Accreditation. Looking at later Accreditation reports -

• 2015 - no mention of anti-vaccination
• 2016 - no mention of anti-vaccination
• 2018 - mention of risk of anti-vaccination misinformation from CEASE therapy practitioners
• 2019 - mention of risk of anti-vaccination misinformation from CEASE therapy and Homeopathic Detox Therapy practitioners
• 2020 - mention of risk of anti-vaccination misinformation overall

There was no 2017 report as the Accreditation date changed from September to January.

To be clear, the risk of anti-vaccination misinformation was not something that the SoH identified itself. Evidence came from third parties and the PSA raised it with the SoH. Note the incremental increase in the effective prevalence of the risk as different groups are identified.

The point has been made before that the PSA is dependent on Accredited Registers disclosing risk to them. They may be more aware of the generic risks posed by the various types of registers now compared to a few years ago but they are not experts in various therapies, they offer quality assurance of how registers operate. In the case of the SoH, their inability to either recognise or acknowledge the risks posed by their members anti-vaccination activities is astonishing. It should not be down to third parties to quantify and qualify that kind of risk.

Good Thinking Society
The GTS response to media reporting is well worth reading but in short -

“In our opinion, the PSA has a simple choice to make: remove the Society of Homeopaths and their uninformed vaccination paranoia from the register, or continue to allow homeopaths to make these dangerous claims with the tacit approval of the PSA.” said Michael Marshall, Projector Director of the Good Thinking Society.

But there have been pressures on the PSA before to remove Accreditation and they did not. The grounds for removal of Accreditation are -

Accreditation removed – the Accreditation Panel finds that the organisation does not and cannot continue to meet one or more of the Standards. The outcome will be communicated to the organisation with the Panel’s reasons. The organisation will then have 10 working days from receipt of the outcome to inform the Authority whether it will accept or appeal the Panel’s decision (see section 9). The outcome will be published on the Authority’s website after conclusion of the annual review process, including any appeal.

The PSA would need to be convinced that the SoH is not capable of meeting the Standards. 

Run out of chances?
The PSA have given the SoH multiple chances to improve compliance with standards. The 2020 Accreditation report is full of promises from the SoH. Whatever the reasons for Sue Pilkington's appointment (and subsequent removal) as Professional Standards and Safeguarding Lead, it does look like a regressive move. What few messages come out of the SoH suggest that is now far less committed to Accreditation. Other developments also suggest that the SoH has gone backwards since February 2020. Difficulties with losing a CEO, COVID-19 and so on might explain making slower progress than might have been anticipated but not a reversal.

The SoH managed to scrape through the 2020 Accreditation with Conditions. They may gamble that they can do so again. But...

A simple question
Nearly a month ago, the SoH were asked directly if they supported the UK vaccination programme. Their response?

Thank you for your email below. We will consider your question alongside your other emails. 

We will reply in due course.

A non-answer to a very direct and simple question.

Can the PSA accredit a register which purportedly regulates "healthcare professionals" that does not support one of the most effective public health measures? It might be acceptable for a register whose members have a narrow scope of practice such as psychological therapies not to have an explicit policy on vaccination but much less so for a register with members who think they have a much wider scope of practice and even position themselves as primary care practitioners?

Probably not.

Crunch time?

The last post talked about the Society of Homeopaths (SoH) and media reporting of its problems. It also discussed the Professional Standards Authority (PSA) calling an emergency in-year review of the SoH. It must be stressed that an in-year review only happens if very serious concerns have been raised about an Accredited Register.

So far, the SoH have only said things like it would be inappropriate to comment whilst the review is ongoing. But it seems to have reacted.

Members' Disccusion sessions
The SoH are having three of these over two days, each an hour long. They are being conducted using Zoom. This is odd in itself. No indication of whether they are seperate or linked.

This is highly unusual.

Members' Discussions are usually part of the SoH's Annual Conference. This years conference was cancelled and replaced by a Zoom session. The Members' Discussion was part of a later online Zoom session along with the Annual General Meeting. It is not known what was discussed during it - the SoH no longer report publicly on that sort of thing.

The SoH has made no mention of it on its Facebook page which seems to be its primary public medium at the moment. Nor has it put up a news item on its website. Just an entry on the Events section of its website. Even more unusual. The SoH would normally make a bit of a song and dance about member engagement.

Presumably, the SoH has informed members via (a) different route(s)? It has a private online forum. There's also email. It has the mobile numbers of a lot of members so text might be a way to alert some. It could always resort to calling or mailing members.

Timing
Although it is difficult to certain of the exact date that these sessions became a thing, there was no mention of them on 13/07/2020. This is after the PSA announcement of an in-year review and also after the Telegraph reporting.

Given the gravity of the SoH's current situation it is difficult not to believe that these sessions have nothing to do with PSA Accreditation and the in-year review.

Although the SoH's words aren't to be trusted at face value (they can mean very different things from the common sense meaning), if the supporting papers for the online AGM/Members' discussion back in May are to be believed, the SoH were already running a consultation on PSA Accreditation.

About what though?
It is impossible to know exactly what these sessions are about. It's unreasonable to expect rationality from the SoH - its leadership are predominantly homeopaths and their sympathisers. But whatever the sessions are about, it must be very important and something that the SoH doesn't want the public to know about (yet).

It would not be a total surprise if it turns out that the SoH are asking members to vote on whether to withdraw from the Accreditation scheme but on the other hand, such decisive action would be out of character. But there are other possibilities.

Delay and inaction are more usual but things may have reached a point where the PSA are moving very quickly and if the SoH wants to limit the damage that the in-year review could cause, it has to act quickly. That applies whether the SoH withdraws or wants to continue with Accreditation.

Mandate
If the SoH are wanting members to vote or otherwise participate in an important decision on the future of the SoH, it really needs to get as many UK based members involved as possible. Using Zoom may exclude some of the more technophobic or those with no/poor quality internet connections. It's unknown whether members pay a lot of attention to emails.

Like many membership organisations, the SoH likely has a considerable number of members who don't feel very strongly about most issues, who tend not to get involved and don't make their voices heard (very often). Debates on issues can be dominated by small groups with very strong opinions. That can be offputting for many, especially when one of those groups is divisive and destructive re the organisation's goals and cohesion. When there are questions as to whether the organisation really wants that group as members.

From the outside, it looks as if the SoH leadership never had a proper mandate to pursue Accreditation in the first place. 

Outcomes
Because of the largely unknown nature of the sessions, it's difficult to predict what will come out of them. However, the SoH would be well advised to make a public statement reasonably quickly, especially if has made any concrete decisions. Damage limitation is a compelling reason to. The SoH needs to avoid the situation where third parties have worked out what is going on before it informs its members and the public.

But it is largely now a matter of waiting to see what happens.

Big trouble for the Society of Homeopaths

It was always going to be the case that the Society of Homeopaths (SoH) would find it very difficult to deal with the problem of anti-vaccination sentiment. It's a problem that is endemic to UK homeopathy. The potential impact of anti-vaccination on UK homeopathy has been discussed multiple time on this blog (this article is recommended reading).

Things have got much worse for the SoH and its largely of their own making with the Sunday Telegraph's Society of Homeopaths under review amid claims standards chief promoted anti-vaccine propaganda.

Some explanation is required as this has unfolded over a period of time.

New Appointment
Apparently, the SoH lost their Professional Standards Manager at some point in 2019. Curiously, nothing was said at the time. Generally, when staff leave for pastures new there will be a little news item wishing them well. It is even more curious in the context that nothing was said by the SoH about the departure of CEO Emily Buttrum.

There was an advert for a "Professional Standards and Safeguarding Lead". The use of "lead" as opposed to "manager" is somewhat like NHS language. It tends to be used to indicate responsibility for practice standards rather than line management.

You will be responsible for governance and risk management in relation to professional standards, promotion of professional standards and safeguarding matters and you will lead the Society’s annual application to the Professional Standards Authority accredited registers scheme and oversee delivery of work associated with the accreditation.

The SoH had a problem in that it wanted to recruit a homeopath with relevant professional experience. In reality, those candidates don't exist. 

On 04/06/2020 Sue Pilkington was announced as the Professional Standards and Safeguarding Lead. To quote from a now removed new item -

Sue Pilkington said “I am passionate that homeopaths are confident in their practice in these difficult times. This role encompasses guiding the membership with a coherent professional standards and safeguarding strategy. I will also liaise with the Professional Standards Authority regarding accreditation of our register and managing the audits and reports required for this. 

I hope to be able to clarify regulations for our members. Going forward, I firmly believe that increasing professional standards is not about standardising the profession, it is about raising the quality of the professional standards”.

Note again the implication that the SoH wish to carry on with Professional Standards Authority (PSA) Accredited Register status.

But there were problems with Pilkington.

Anti-vaccination and other bad things
Pilkington has shared anti-vaccination propaganda on social media. This is not the first time that a person associated with the corporate function of the SoH has been caught out. The Daily Mail reported on Linda Wicks, Chair of the SoH doing the same and Pilkington shared some of the same problematic material. 

But it's not just anti-vaccination propaganda. Pilkington also promotes thermography as an alternative to mammography for breast screening. This is bad.

Pilkington also has some questionable ideas about the role of homeopathy in cancer treatment.


Some of the testimonials on her website were problematic.

"I'm utterly amazed. I woke this morning without the pain in my lungs. In fact I felt it lifting yesterday evening after I texted you. I was utterly exhausted yesterday which is understandable. By 9pm I was in bed and couldn't keep my eyes open but already by then, I'd felt a lifting in my right lung and it is all but gone. There is a little tightness left which some self-care will sort out and I imagine my muscles are tense from fear and lifting myself to breathe properly. Tears of joy this morning rather than tears of grief.
Thank you so, so much for your care. x" 

“My situation at the time Sue was recommended to me (by a G.P./close family friend) was an extremely complex one and my first experience of any physical/emotional health issues. I was suffering from clinical depression, chronic anxiety disorder and PTSD due to a series of life events and physical health problems, an extremely dark period for a mid-twenties, outgoing, ´high flying career girl´ with a lust for life to endure. I was terrified, desperate and trusted no-one least of all myself. The remedy Sue recommended certainly had an impact. It was gentle but the change was definite and unlike coming to terms with the (possible) side-effects of a prescribed medication (not that they don´t have their place), the only effects I noticed were positive ones and my symptoms eased. Sue was warm, approachable, communicative and clearly very knowledgeable, qualities that were vital to me at that time as I had lost faith in ´normal´ medicine. I trusted her and it was a wise choice. Homeopathy gave me glimmer of hope when I felt absolutely devoid of anything else and I highly recommend Sue to anyone considering an alternative treatment. “ 

"The side effects of my cancer medication are spikes of high blood pressure and hot flushes - homeopathy helps me to control these side effects. This helps me to stay on the maximum dose of medication, avoid additional medication and it helps me to feel more in control of my health at a difficult time. Learning about Homeopathy from Sue has enabled me to become confident in prescribing for myself during these episodes and, although initially cautious, I have been amazed at how quickly the remedies can work."

There were other questionable claims such as "It [homeopathy] can be used alongside pharmaceutical medication and to promote detoxification and restore balance in health." Detoxification claims are widespread.

It is known that in the past Pilkington has offered hypnotherapy, neuro-linguistic programming and reiki. Whilst she may no longer advertise them, it is unclear if she still practices them. 

Concerns raised
Concerns were raised with the SoH. The PSA were made aware of these concerns. As might be expected, the concerns revolved around the problem claims but points were made about how the PSA might regard Pilkington's appointment.

The irony of the "Professional Standards and Safeguarding Lead" being the subject of a complaint about potential breaches of professional standards days after being appointed is probably lost on the SoH and Pilkington.

A formal complaint had also been raised about the SoH's recruitment policies and processes. Pilkington very quickly removed the problem content but no explanation was forthcoming from her or the SoH.

One defence that might have been used is that the SoH did not have specific social media guidance in place. Pilkington may have been compliant with what existed prior to her appointment but that is a very weak argument.

The PSA was also requested by some parties to carry out an in-year Targeted Review.

Social media guidance
The PSA issued a Recommendation to the SoH at the last Accreditation.

3. The Society should provide its social media guidance to the Authority and advise how it will promote compliance with that guidance (paragraph 5.20)

It had become clear that the SoH was saying one thing about anti-vaccination content from its members whilst its members were spreading pretty extreme anti-vaccination propaganda on social media. Concerns were raised with the SoH but as the below demonstrates, initially the SoH did not seem to accept there was a problem.

5.15 The Authority had received concerns regarding a sample of registrants’ public social media posts, that appeared to discourage vaccination and drew this to the Society’s attention. The Authority considered an initial response from the Society which appeared to apply different standards between registrants’ professional, and personal behaviours on social media. The response suggested the possibility that outside of their homeopathic practice, registrants may act contrary to the Society’s standards without risk of disciplinary action.  

5.16 The Authority did not agree with the Society’s position that personal beliefs, stated in public spaces, could be distinguished from registrants’ professional practice. The Authority noted many practitioners were self-employed or otherwise represented their own practices on social media, and that promoting ‘anti-vaccination’ messages may conflict with the Society’s position statements. The Authority asked if the Society had considered issuing its policy on the use of social media (further to existing statements regarding treatment of cancer) in its position statements (or other guidance) or within its Code of Ethics.  

5.17 The Society, having further reviewed the social media pages provided, considered they were part of the registrants’ practice due to the content and nature of the materials ‘posted’. The Society stated it accepted that if registrants’ personal social media pages are publicly accessible, members of the public looking for information about homeopaths or homeopathy may be informed or influenced by what they read there. 

5.18 The Society affirmed that the use of social media blurred boundaries between registrants’ personal and professional lives. The Society stated it would develop guidance on the use of social media by registrants and its Board. The Society would draw from existing examples of best practice and engage its membership in development of the guidance. Once issued the Society would check registrants’ engagement with the guidance and include social media pages where possible within its regular audit of registrants.  

5.19 The Society advised that those registrants already highlighted to the Society would be prioritised under its audit schedule. Where necessary the Society would consider disciplinary procedures, applying relevant sections of its Code of Ethics, and its previous communication to registrants requiring them to review all social media pages, websites, and other material.  

5.20 The Authority noted the Society’s recognition that registrants’ social media may impact on their professional life and their compliance with the Society’s standards. The Authority also noted that the Society had confirmed it could take action regarding registrants’ use of social media and considered the Society’s approach appeared proportionate. As part of the Condition issued under Standard 2, the Authority required the Society to provide a copy of its guidance to the Accreditation team and set out how it would monitor compliance with that guidance. (Recommendation 3)

Bear in mind that the SoH were responding after the Linda Wicks story after several concerns being raised with them over problem social media content.

However, circumstantial evidence does point towards the SoH communicating with members on the issue of social media. What exactly is said is unknown, likewise how many members bothered to read it and if so, whether they took it on board.

With regard to CEASE therapy -

5.5 The Authority asked the Society how it would monitor compliance with its updated position statements. In order to ensure that registrants comply both with the revised policy positions reported under Standard 2, and the revised position on the use of the term ‘CEASE’, the Society advised that it has: 

• Issued guidance to registrants instructing them to review all social media pages, websites and other promotional material and remove 16 references to the ‘cure of named conditions’ and protocols such as CEASE 

• Issued guidance on how registrants may promote their interests and expertise in a transparent way, including specific training undertaken 

• Begun speaking individually to known registrants who were known to have received training or offered CEASE in the past, to assist understanding of the new position statements 

• Undertaken to ensure that within the following 12 months all registrant websites would be checked for compliance

Note that it mentions "social media pages". It does not take a genius to work out that what applies to CEASE therapy may well end up applying to anti-vaccination.

Blunder
As discussed in a previous post, the SoH recently updated their Position Statement which makes it clear that members must not go anywhere near vaccination matters. It makes reference to a Scope of Practice document. That document was released to members back in February 2020. It does not mention that discussion of vaccination is outside of the scope of practice of members. 

If it had, assuming that Pilkington read it, understood it and got that it also applied to social media, this business may never have occurred. It is possible the SoH did communicate the effect of the Position Statement prior to it being released. That would be worse for Pilkington and the SoH.

Message
By appointing Pilkington, the SoH sent out the message that it does not take the issue of members spreading anti-vaccination propaganda seriously. That it puts members before public health. It doesn't matter whether her appointment was a genuine error or a deliberate ploy. All the potential reasons are bad.

It should be pointed out that the PSA made its decision that the SoH had met some parts of the Condition on Accreditation before they were aware of the Pilkington problem. What they privately make of it is unknown. They wer unlikely to be enthused by the idea of dealing with Pilkington. 

In the past, when required to do "audits" and the like, the PSA and others found that the SoH failed to spot very obvious non-compliances. Was Pilkington going to be any better at it?

Media coverage
The SoH should not have been surprised that the media would take an interest in Pilkington's appointment, that they approached various bodies and individuals for their views and so on.

The article speaks for itself but this is interesting -

The policing of anti-vaxx propaganda was one of several strict conditions placed upon the SoH to enable them to gain accreditation, a move that averted a Judicial Review late last year. 

The Sunday Telegraph understands that the Good Thinking Society (GTS), the charity who had instigated proceedings, is now actively considering the legal implications of decisions pending by the PSA. 

The government regulator has since posted a statement on their website stating that a review was being undertaken. 

“In our opinion, the PSA has a simple choice to make: remove the SoH and their uninformed vaccination paranoia from the register, or continue to allow homeopaths to make these dangerous claims with the tacit approval of the PSA.” said Michael Marshall, projector director of the GTS.

This story has taken a while to be published but the SoH and PSA have known it is coming for quite some time. 

Outcomes
Pilkington is no longer in post. The SoH have removed the news item that announced her appointment, removed the Facebook post that pointed to it and also she is no longer listed on the People page. 

At the time of writing, the reason for her no longer being in post is unknown. The SoH say "appropriate action" has been take but that it is part of a wider review and it would be inappropriate to comment further. This raises awkward questions about Linda Wicks. Why should Pilkington have action taken 

The PSA has acted. It has initiated a Targeted Review of the SoH. 

Targeted Review
From the Annual Review Process Guide -

3.2 Any concerns raised with the Accreditation team by stakeholders, or areas of concern that the Accreditation team discovers during the accreditation year, will be raised with the register during the year. We will not wait for the annual review to raise issues that suggest a public protection concern, bring the programme into disrepute or that suggest an Accredited Register may not be compliant with our Standards. 

3.3 If the Accreditation team’s in-year monitoring raises sufficient concerns, or if information is shared with us that raises concerns, a targeted review may beinitiated. The process and possible outcomes of this targeted review are thesame as for a targeted review initiated at annual review. An in-year targeted review will not negate the need for an annual review. 

It must be stressed that the PSA do not lightly carry out an in year Targeted Review. For one thing, they get no income from it. They must be very concerned by the SoH's recent antics. It is suspected that there might also be pressure from the NHS and the Department of Health and Social Care. 

A Targeted Review is quicker than an Annual Review. It skips the "Share your Experience" stage. How long it will take is not clear. 

In terms of the Standards for Accredited Registers, Pilkington's appointment raises questions about SoH compliance with -

Standard 2: the organisation demonstrates that it is committed to protecting the public and promoting public confidence in the occupation it registers. 

The organisation will need to demonstrate that its purpose and directives arefocused on public protection. Additionally, the organisation will need to show thatin carrying out its voluntary register functions public interest is paramount andthat professional interests do not dominate or unintentionally subvert thatinterest. 

Evidence of this might include board or committee discussions where issueshave been debated and conflicts of interest identified or the ethical interests ofparties weighed in the balance; decisions made about admittance to the registerwhere the documented rationale shows due consideration of public protection;outcomes of complaints; particularities of governance arrangements. 

And -

Standard 5: the organisation demonstrates that it has the capacity to inspire confidence in its ability to manage the register effectively. 

Factors the Professional Standards Authority will take into account include the organisation’s leadership, its reputation within and outside its field, the skills and experience of those involved in its voluntary register functions, its operational efficiency and its openness.  

There are a whole series of other concerns the PSA will also take into account but its problems with anti-vaccination among its members will feature heavy.

There are only two likely outcomes of the Targeted Review but difficult to say which one is more probable.

The PSA could strip the SoH of Accreditation. The PSA would been be convinced that the SoH can not or has no intention of meeting the Standards.

The PSA could Accredit with Condition(s) in addition to the existing ones. That recommendation to come up with social media guidance might well be one. If the PSA can not stomach the idea of stripping the SoH of Accreditation it could set Conditions that are very difficult for the SoH to meet. It could set very tight time scales that the SoH would struggle with.

Whatever the outcome, the PSA will deliver an Accreditation Report that is unlikely to make for comfortable reading for the SoH.

The SoH can appeal a decision. It probably would not be a good idea and they would likely need to seek outside legal advice. 

As discussed in a previous post the SoH may do better to withdraw from the Accredited Registers scheme. They can do this at any point. If they withdrew now whilst the targeted review is going on, the PSA may continue with the Review. What factors they would take into account isn't known but there may well be a public interest argument. Of course, if the SoH does withdraw, it doesn't have to cooperate with the PSA.

What next?
If the SoH manages to retain Accreditation, it still has to face its next Annual Review in January 2021. There is also the question of whether the likes of the GTS would seek judicial review of the PSA's decision (although given the timescales, that would be difficult).

If the SoH is stripped of its Accreditation, it will attract more negative media attention. The SoH likes to position itself as the most important UK homeopathy organisation. Whether any of the bad publicity rubs off on the rest of UK homeopathy is another matter.

The SoH will probably survive. It may end up losing members, it may encounter greater financial difficulties. It will be hurting and weakened though.