Thursday, 6 August 2020

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.

Tuesday, 21 July 2020

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.















Saturday, 11 July 2020

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.

Tuesday, 7 July 2020

Society of Homeopaths - Withdraw from Accreditation scheme?

The Society of Homeopaths' (SoH) ongoing problems with anti-vaccination make it difficult to continue with Professional Standards Authority (PSA) Accreditation. The SoH seems unwilling and/or incapable of dealing with it. Anti-vaccination beliefs are endemic among homeopaths and long established.

Anti-vaccination beliefs among SoH members has caused the PSA to come under pressure from NHS England (NHSE) and others to remove the Accreditation of the SoH. That pressure is not going to go away nor is the media reporting. 

The SoH has very reluctantly moved towards a prohibition on its members saying anything on the matter of vaccination. It still hasn't managed this. Whilst the SoH can police its members' public pronouncements, it is resource intensive. It isn't possible to police what is said face to face to parents of children, what goes on in closed groups. Whatever the SoH does, those anti-vaccination beliefs are not going away in a hurry.

Anti-vaccination isn't the only problem. It is currently the most visible but there are others that have the potential to cause the SoH even more headache.

The SoH is in a difficult position because if acts strongly, it loses members. It may be better off withdrawing from the Accredited Registers scheme.

Decision time
The Accreditation process and its timings have been discussed multiple times on this blog. In short, the SoH need to indicate in Month 8 that they intend to carry on with Accreditation. That would be 10/09/2020 to 09/10/2020. Things don't always happen precisely on time re the Accreditation process. COVID-19 might have an impact.

The SoH likely have a Board meeting in September if dates of past board meetings are anything to go by. It really needs to make the decision whether to carry on with Accreditation or not in that meeting.

Although the SoH may tell its members of its decision shortly after the meeting, the first that the public will know is when and if the PSA invites stakeholders to "Share Your Experience". The last round of that was a painful experience for the SoH.

Calculation
There are various factors that the SoH need to take into account in making their decision but the most important are:-
  1. Can it can retain Accreditation in 2021?
  2. What actions would it have to take to retain Accreditation?
  3. How many members would it lose as a result?
It also needs to consider 2022. There's little point in retaining Accreditation in 2021 if it loses it in 2022, especially if it causes significant loss of members. 

What it needs to do to retain Accreditation will be discussed in a future post.

Benefits of withdrawal
There could be cost savings beyond the £10k+ renewal fee for Accreditation. It is suspected that the SoH has a CEO is due to Accreditation. The role is understood to be quite part time but even so it probably pays more than £24k a year. The SoH managed with a CEO for many years and probably can do so again.

The SoH could immediately dump all the difficult and resource intensive tasks that the PSA has imposed on it. It can stop auditing member websites, it can stop ringing up members to persuade them to comply with its Position statements etc. It could stop dealing with what it regards as "vexatious complaints". It almost certainly doesn't enjoy dealing with concerns raised by critics but PSA Accreditation forces it to.

They might be able to retain members who are currently thinking of leaving because of increasing regulation. It might also be able to tempt some who have left back.

Resources and money free up could be used to retain/recruit members. They could be used to promote the SoH and its members. 

Humiliation
Withdrawal would be humiliating but less humiliating than the PSA removing Accreditation. It is virtually guaranteed to generate media headlines in a way that voluntary withdrawal might not. It would be depicted as a massive failure on the part of the SoH. Its pretensions of professionalism exposed as such. A triumph for reason, common sense and so forth. It might well provide positive publicity for the PSA, being seen to do the right thing.

Removal would hurt the Board, past and present. Anyone particularly associated with Accreditation could be hurt more. It seems unlikely that the Board would collectively accept responsibility. Finger pointing is likely to go on.

Back to the Good/Bad Old Days?
Whilst the SoH could roll back some of the changes it's had to make, it would be very foolish to roll back others. Allowing members to practice CEASE therapy again would be a really bad move (although arguably it does as long they call it Homeopathic Detox Therapy). It would be a provocation to say the least. 

What it does with anti-vaccination is another matter. 

Of course, the SoH could maintain its current position statements and simply not enforce them, which is what it used to do.

Managing the Media
One strategy might be to withdraw and issue a clear statement. Something the lines of - 
  • The supposed benefits of Accreditation have not materialised
  • It costs money that could be more usefully employed on other things
  • It diverts resourses from the core activities of the SoH
  • Members (and their clients) do not value Accreditation
  • Accreditation has placed unacceptable restrictions on what members can say and do
The SoH need to avoid attempting to put the blame on others for their withdrawal. The decision has to look like one made in its and its members best interests rather than the result of external pressures.

Playing the victim is not a good idea. It looks weak and the SoH has brought a lot of its problems on itself, largely due to inaction or half-hearted action. It's also very easy to pick apart. Invoking conspiracy theories looks silly at best, deluded at worst. 

Making an announcement when a lot is going on news-wise might mean that it never makes it into the media. Whilst withdrawal might cause a lot of excitement among critics, they have a limited audience.

The SoH doesn't have to justify itself to the media. It can make its statement and not engage further. The SoH's key audiences are its members, prospective members and their (potential) clients. 

Negative Media coverage
This isn't going to go away but the SoH will become less of a media target in terms of no longer having special status. It may attract greater attention than some of the other UK homeopathy associations because it is the largest but on the other hand, individual homeopaths who belong to the Alliance of Registered Homeopaths (ARH) or no association at all tend to gain more media attention because they are often more extreme in their beliefs.

Saturday, 4 July 2020

Minor developments

Things are not looking good for the Society of Homeopaths (SoH), especially regarding their Professional Standards Authority (PSA) Accreditation.

There are expected to be some major developments on that front in the near future, but it is worth looking at some more minor things.

Annual General Meeting
Normally, this happens as part of the SoH's annual Conference. This year's Annual Conference in London was cancelled because of COVID-19 and instead took place online. Likewise, the AGM but on a separate date.

The SoH has made much previously publicly accessible material such as board meeting minutes, certain guidance documents and even news/opinion articles members only. This also applies to AGM minutes (the previous year's are approved at the AGM). As has been mentioned before it isn't clear what the SoH expects to achieve by this. It's not exactly in the spirit of the PSA Standards for Accredited Registers.

Previous years' Annual Reviews are still available but curiously whilst the 2019 review exists as members only content, it has not been made public. Nor has their been any news items or social media posts about it. Compare this to coverage of the previous AGM
Homeopaths have reasons to be cheerful about the future despite suffering a very difficult 2018, Society chair Judith Kiely told members at the AGM in Oxford.
It turns out that they did not. 2019 was another bad year, 2020 isn't going so well for them either. 

There was also a Members' Disccusion session...

Accreditation consultation
Whilst the SoH try to screw down access to documents, it failed to restrict access to this document associated with the AGM. It contains this pearl of information -
During this [question and answer] session the Board will provide an update on its consultation with members on the PSA accreditation.
As this blog has pointed out, the SoH board never had a mandate (it is worth reading that post) to pursue PSA Accreditation. It is possible that this refers to something else - there was talk of consulting with members over professional standards. If this is something new and separate from that the SoH have managed to keep it very quiet.

If there is a genuine consultation on Accreditation going on, it is doubtful the SoH will have provided members with accurate information. It has consistently overplayed the benefits of Accreditation (some of which have not appeared at all) and ignored the downsides. What was said in that update is a mystery. As is whether there were any questions raised by members on Accreditation as a result or submitted before hand.

If a consultation is going on, it needs to reach a conclusion before the SoH Board decides whether or not to reapply for Accreditation. It needs to tell the PSA of its decision by some point in September. Historically, the SoH has Board meetings in July and September, with some variation.

Supervision
There are hints that the SoH sees supervision as part of its strategy for overcoming its current problems with Scope of Practice, especially with anti-vaccination. There are some problems with this.

A supervisor is normally a senior and experienced practitioner (but not necessarily to senior to the practitioner being supervised - otherwise who supervises the supervisor). Generally, they will have specific training in supervision. Their role is to help the supervisee learn from their experiences. It differs from coaching/mentoring in that it is evaluative. There is an element of quality control but it is not exactly policing of compliance with standards.  

It is understood that the SoH is at least putting together a list of supervisors. From what is known of those homeopaths who openly offer supervision, they are as much, if not more of a problem re compliance with standards. Some of them have a long history of anti-vaccination for example. Also, given that the standards of other organisations are different, will it be permissable to have a supervisor who is not a member of the SoH.

Making supervision mandatory would be difficult for various practical reasons but some homeopaths are highly individualistic and would probably resent supervision. 

Tacit admission?
It is speculated that the PSA came to the decision on Accreditation that they did to avoid the Judicial Review instigated by the Good Thinking Society (GTS). It would have been very difficult for the PSA to defend the 2019 Accreditation in Court. However, it has come to light is that the PSA changed their processes in the light of the Judicial Review. From the updated  Risk Register that was part of the documents considered at the last PSA board meeting -


This is strongly suggestive of the PSA recognising that the 2019 Accreditation process was flawed. The PSA and the SoH probably dodged a bullet in terms of the Judicial Review not being heard before Accreditation took place.


Fringe
Homeopathy International (HINT) has been discussed before on this blog. It is tiny. It has one member and a Steering Committee of seven. From what can be worked out, most of its pronouncements are written by ex-SoH member Paul Burnett. HINT recently released a statement about the PSA. It fails to understand the function of the PSA (it is not a regulator - it is a quality assurer of organisations). To quote -


Because it is simply a list of registers the PSA AR process has no powers of enforcement outside those listed on its registers. Aside from the limited numbers on its accredited lists the PSA AR has no power to stop bad practitioners working and it cannot restrict employment to those who are part of its completely voluntary process. 
What it can do is apply Conditions of Accreditation. If an organisation wants to stay on the list of accredited registers it must obey the instruction of the PSA. These conditions of course are only applicable to the members of the accredited organisation and do not restrict members of other bodies. The extent of the applied conditions is almost without limit. The Society of Homeopaths was recently instructed that in must ‘…not allow registrants, whether acting in a professional or public capacity, to provide advice on vaccination…’ but instead ‘Registrants should direct service users to NHS and other public health sources, for example, their GP or public health department’. In one simple requirement the capacity of the practitioner to practice homeopathy is removed. HINT would view the gagging of homeopaths in this manner as unacceptable and for this reason if no other would not join the PSA’s AR list.
Whilst Burnett is no longer a member of the SoH, it is likely that his views are shared by some SoH members. Burnett was one of the number of SoH members who pressurised the SoH into seeking legal advice on the legitimacy of the Advertising Standards Authority a few years ago.

The SoH are unlikely to have to worry about HINT making a concerted effort to poach their members though.

Discontent
As the SoH said in the Accreditation Report, some members were so upset by moves towards greater regulation that they resigned. To quote -
2.21 The Society noted that some practitioners were ‘not comfortable with [the] increasing degree of regulation’ apparent from recent policy directives (relating to its actions on CEASE therapy and similar) and identified a risk that ‘more homeopaths are opting to practise without formal registration’ accordingly. Although the Authority recognised that a goal of the Accredited Register programme was to bring practitioners within the regulatory assurance of an accredited register, the fact that some practitioners might leave a register rather than accept the requirements was not a reason to reduce necessary safeguards.
Membership numbers have clearly declined recently but it is not clear if it is entirely down to the above. The SoH has a problem recruiting new members. Many existing members are close to retiring, student numbers are down and it looks as if there has been a contraction in consumer demand.

Recruitment drive
Supposedly this is the time of year when students "graduate" from the homeopathy colleges. The SoH has made a fair few mentions of this on their Facebook account. 

This news item on the SoH website is more interesting in what it doesn't say. It makes no mention of being the only dedicated homeopathy register Accredited by the PSA. Which is very odd given that it has used this to differentiate itself from other homeopathy registers. Even more odd given this student survey that the SoH carried out in 2019. 59% thought PSA Accreditation was extremely important? 

Caveat
It's possible to read too much into what the SoH says. It's communications often lack clarity and can be highly ambiguous.

It is difficult to guage what the SoH are thinking about Accreditation. It is sending out very mixed messages. But it needs to make some tough decisions in the next couple of months.