Saturday, 25 February 2017

International Concerns about Indian Homeopathy

It may seem curious that a UK-based blog takes an interest in Indian regulation of homeopathy but there are some very good reasons for this. There are some concerns that not only apply to the UK but to many Anglophone countries.

Misrepresentation of Qualifications
Whilst India and a number of other countries recognise homeopathic qualifications, the vast majority do not. This means that in those countries, Indian homeopaths are not considered medically qualified in anyway. Depending on jurisdiction, they may not be permitted to practice at all (medical practice being restricted to those with a medical degree and registration). In some jurisdictions, such as the UK, anyone call practice but they are not allowed to imply that they have a medical qualification. They are treated the same as any other medically unqualified person. Any one can call themselves a "homeopath" without qualifications of any kind. In some of these jurisdictions, the title of "Doctor" or its equivalent is protected by law - only those with the appropriate qualifications can use it. Even if this is not the case, advertising regulators take a dim view of the use of "Doctor" in a healthcare setting as it has the potential to mislead the public.

There is a problem in the UK with Indian homeopaths either practicing here or visiting the UK from India to give lectures, etc, using the "Doctor" title. Some of them are obviously aware of the issue as they include disclaimers in their advertising stating that they are "Doctors of Homeopathy", usually in small print somewhere. It is also known that various Indian homeopaths have be told about restrictions on the use of the title but still go on using it.

There are questions relating to how Indian homeopaths end up practicing in countries that have eligibility criteria for immigration. Their qualifications are not recognised. It could be the case that they can immigrate on the basis of a spouse's qualification but then again, possibly not.

Some Indian homeopaths who appear to be largely resident in the UK seem to retain their registration with the Central Council of Homopathy (CCH) in India. This has the potential to cause problems.

Training and Courses
From the above, any advertising of training and courses that involve an Indian homeopath using the title "Doctor" would be as problematic as in the healthcare scenario. There have been problems with the naming of the qualifications handed out as a result. For example, in the UK only universities have the ability to award degrees. A course run by a listed college etc actually comes from a university.

Diploma mills have existed in the UK and still pop up from time to time but the Internet allows distance "learning" and it is true to say that some Indian homeopaths have been involved with such organisations.

For those Indian homeopaths that still maintain CCH registration, offering courses in the UK is problematic. The Homoeopathic Practitioners - (Professional Conduct, Etiquette & Code of Ethics) places many restrictions on what they can do. Firstly, it is considered professional misconduct if...
j) if issues certificates in Homoeopathy to unqualified or non-medical persons:
Provided that nothing contained in these regulations shall prevent or restrict the proper training and instruction of legitimate employees of doctors, midwives, dispensers, attendants or skilled mechanical and technical assistants under the personal supervision of practitioners of Homoeopathy.
This would apply to the Allen College of Homeopathy. "Dr" Banerjea still maintains his CCH registration. Quite likely, it would include any Indian homeopathy with CCH registration involved with any UK homeopathy course.

There is little point in setting up a homeopathy course aimed at potential "practitioners" unless the qualifications are recognised by one or more of the trade bodies in the UK. However the CCH Code of Ethics also states...
20 Association with Unregistered Persons
A practitioner shall not associate himself professionally with any body or society of unregistered practitioners of Homoeopathy.
Which is unfortunate.

It is also the case that some UK resident homeopaths have been involved in schemes to offer Indian resident homeopaths UK qualifications. This is problematic for the UK based ones if they still retain CCH registration (issuing certificates) and for the Indian residents if they do not (consorting with the unregistered). Perhaps the answer lies in this quote -

Q: What are the employment opportunities once we pursue the course??A: As mentioned above the degree will help you to practice in places like US,UK,CANADA,NEW ZEALAND and many such places where homoeopathy is slowly gaining ground. In addition if you don’t practice on the foreign land and decide to stay back in India, the degree will add a prestigious value to your current B.H.M.S OR MD DEGREE. Another important aspect of the same issue is that we will provide post course guidance once the entire course is over and also keep you informed of the possible vacancies owing to which newly passed out homoeopathic graduates can benefit a lot like MD. But MD course will not enable you to practice in US, UK OR EUROPE.
Absolutely not true on all counts. Fortunately, the associated website is dead. However, the organisation behind this still offers distance learning courses including one aimed at Indian homeopaths although it does not make any claims about allowing practice in other countries.

Trade Bodies
The three largest trade associations in the UK are the Society of Homeopaths (SoH), Alliance of Registered Homeopaths (ARH) and the Homeopathic Medical Association (HMA). The latter seems the most popular with Indian homeopaths in the UK. But any Indian homeopaths maintaining CCH registration would breach the Code of Ethics by doing so as would associating with any of these groups in any way.

Interestingly, India homeopaths in the UK have attempted to set up Trade Associations only to fail. The World Homeopathic Association - London is one example but there have been others. The Indian man in the photo is Shashi Mohan Singh who seems very entrepreneurial as well as appearing in a Bollywood film.

It works the other way around with Indian resident homeopaths. The International Homoeopathic Foundation would seem to be an all Indian affair although, again, Shashi Mohan Singh seems to be involved. Membership would appear to be open to non-Indian homeopaths but again this would be a breach of CCH Code of Ethics as are the foreign guests at their conference.

Trips to India
Some UK homeopaths proudly proclaim that they have been to India. This trip did not involve the UK homeopaths treating any patients but associating with members of the HMA would have put the Indian homeopaths in a tricky situation.

The Allen College of Homoeopathy is far more problematic as it offers a programme in India which involves "80+ hours of CPD & Clinical hours Certificate". Subrata Kumar Banerjea maintains his CCH registration. The website breaches multiple regulations and legislation both from a UK and Indian perspective. It would take a voluminous article to describe them all. He is also involved with Bengal Allen homeopathic medicines and has the Bengal Allen Medical Institute - readers of a sensitive nature may find some of the images disturbing.

Export of Homeopathic Medicines
Although as was explained in a previous post, there are no explicit regulations regarding export of homeopathic medicines, purchasers do need to be aware of importation regulations in their own country. This post covered the UK, this one Ireland and most draconian of all, this one covered Norway. What these jurisdictions have in common is the requirement for the manufacturer to have Good Manufacturing Practice (GMP) certification and for the homeopathic medicines to be registered with the medicines regulator. Norway pretty much forbids personal importation but the UK and Ireland do not. However, importing the medicines and placing them on the market in the UK does occur - one example is this and there are some others.

US regulation is different, and will be covered in a future post but the requirement for GMP is there. Also, only a limited number of ingredients are permitted - the ones in the Homoeopathic Pharmacopoeia of the United States and only indications for self-limiting conditions are permitted.

Test Complaints
The attitude towards these problems by regulators is largely unknown. The only way to determine this is by making test complaints. It is suspected that in many cases regulators will be indifferent. 

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