Saturday, 10 November 2018

Homeopathy International

A new homeopathy organisation recently appeared. It is called Homeopathy International (HINT). It is very odd to say the least.

Not a Limited Company
HINT describes itself as -
Homeopathy International is a non-profit profession body administered by a Steering Group and governed by its membership.
There a number of ways that a non-profit organisation can be set up. But most of these require registration with Companies House and/or the Charity Commission. It's possible that it is an unincorporated association but this tends to be associated with only very small voluntary organisations but there are legal risks. It's possible that someone is operating HINT as a sole trader but this would leave that person liable for any debts that might result. Some sort of limited company would seem the most sensible option but there is no sign of one.

It's entirely possible that there is an associated limited company with a very different name but none of the "steering group" are directors of any relevant company. It's possible that a limited company is registered in a different jurisdiction such as Ireland but that has complications as well.

But being governed by it's members suggests something like a cooperative but this is not borne out by any of the content on the website.

UPDATE: HINT confirmed that they are not a limited company and not VAT registered. If what HINT says is true, its income is above the VAT threshold and it is not exempt.

It's difficult to know when HINT came into being. The domain was registered in December 2017, some of the website content appeared in February 2018. There is a Twitter account that was created in April 2018 but does not seem to have done anything until July. It isn't very active and mostly seems to tweet things involving US homeopath Joette Calabrese.

There is correspondence on the website that predates all of this but it makes no mention of HINT.

HINT is a voluntary register. It seems to offer a public liability insurance scheme to members but there is nothing to stop homeopaths obtaining their own insurance. In theory, a register can negotiate a discount for members but the costs of running a register are very likely to outweigh that.
Homeopathy International differs from other bodies in that whilst we also provide referral and education support, legal support, preferential-rate insurance, and a range of other services, we are pro-active and robust in both defending and promoting homeopathy. 
So essentially, they do what other registers do but are more aggressive. Anyone familiar with some of the pronouncements that come out of the Alliance of Registered Homeopaths would not think this a difference.
We know of many homeopaths who have wished other organisations to have taken a stronger line with denigrators. Perhaps not all homeopaths think in that way, and organisations have needed to embrace everyone’s viewpoint. Homeopathy International exists for the benefit of those wishing to take the most robust line with denigrators and government alike.
This is likely a criticism of the Society of Homeopaths (SoH). Homeopaths do have problems with quantity. 

Who are Homeopathy International
The "steering group" consists of. 

  • Simon Taffler – Chair
  • Paul Burnett – Communication Lead
  • Carol Boyce – Education Lead
  • Dr Noel Thomas – Practitioner Representative
  • Karyse Day – Lay Representative
  • Barry Tanner – Regulatory Adviser

Simon Taffler is a homeopath, member of the SoH and seems to head up the Homeopathy Action Trust which is a charity that is very closely associated with the SoH. Taffler is mentioned in a previous post due his claims to treat autism with homeopathy - which may include CEASE therapy. What the SoH will make a member being involved with a rival organisation is unknown. It is difficult to see how HINT can gain members without poaching them from other trade associations. 

Paul Burnett is also a member of SoH. Burnett is known to be virulently opposed to the Advertising Standards Authority (ASA) see the Quackometer blog. Burnett was once Chairman of Homeopathy: Medicine for the 21st Century (H:MC21) - which was the subject of an ASA ruling. From the HINT website, it would appear that Burnett also has a thing about Trading Standards.

Carol Boyce has also been mentioned on this website before advocating CEASE therapy. Boyce turns up in other places too. It is strongly suspected that she is involved with CAM4Animals. It's not clear if Boyce is a practicing homeopath.

Dr Noel Thomas is registered as a GP but would appear to appear to work as a locum and run free homeopathy clinics if not completely retired now. 

Karyse Day is a not a homeopath but certainly is a supporter of homeopathy and spreads anti-vaccination propaganda via social media.

Barry Tanner's occupation is unclear. What is know is that he is also involved with the General Regulatory Council for Complementary Therapies (GRCCT) which will be the subject of a future post. In short, it is extremely dubious.

Some of the claims made on the HINT website are extraordinary.
We are the fastest growing profession body for homeopathy in the world today. Membership of Homeopathy International has exceeded 2000 practitioners in our first year and we are on target to be the largest body for homeopaths in Europe in 2019.
There is a search facility on the website. Various combinations of search criteria return no results. Apparently members can use the suffix "R.Hom.Int" (apparently "one of the most sought-after designations in the field"). Internet searches reveal no homeopaths using that suffix, not even those on the steering group.

There are also claims of "referral support" - whatever that means. It could mean as little as providing a list of practitioners see -

Free listing on the Homeopathy International Register of Members for full UK and international practising members. The searchable Register is used by Commissioning bodies and the public.
Commissioning bodies? If they are referring to Clinical Commissioning Groups in England and Health Boards in the rest of the UK, absolutely not. For one thing, that register currently contains ZERO entries and also commissioning works via tender.

There is also mention of "education support" but this be as little as just a list of course providers. Oh, HINT do have lists of "approved" course providers yet strangely none of them make mention of HINT. Very odd. Nor is it clear whether these course providers had to go through any approval process.
Our Support Teams have an exceptional track record in defending practitioners against the claims made by the Advertising Standards Authority.
Given that HINT has not been existence for very long and there have been a number of adverse rulings against advertisers that involve homeopaths/homeopathy, this is difficult to credit. A complaint has been made to the ASA on this very matter.
Our Communications Team leads on a number of high-profile actions including submission of evidence to the Commons Health and Social Care Committee and engagements with National Trading Standards Board, NHS England, The Department of Health, and the Department of Business Enterprise and Industrial Strategy.
Errant nonsense. From the website, the "leading" on "high profile actions" seems to consist of Paul Burnett sending bizarre letters/emails. Anyone can submit evidence to public consultations - there is nothing special in doing so.
Homeopathy International represents its membership at the highest levels and on a wide range of bodies and groups in relation to the education, provision and regulation of homeopathy. These include as a guidance contributor to The National Institute for Health and Care Excellence (NICE), a number of Parliamentary Groups and as Evidence Provider to the House of Commons Health and Social Care Committee.
"Guidance contributor"? What does that mean? NICE guidance on homeopathy is various but none is recent, predates HINT coming into existence and is very clear that homeopathy is not a treatment. NICE have been approached about these claims. What bodies/groups HINT belongs to is not mentioned.
Based in the UK, Homeopathy International has direct engagement with governmental processes in China, Europe and the USA as well as profession body engagements in Australia, the Middle East, and Russia. 
Oh. Strange that professional bodies make any mention of HINT. And the search facility says -
This facility does not permit searches for members in China, India or Indonesia. If you are seeking a homeopath in these countries please contact our support teams by email.
None of this adds up.

Regulatory Expertise?
The Code of Professional Conduct makes for amusing reading. The "regulatory expertise" of HINT seems to be lacking -
HINT members must never claim to ‘cure’. The possible therapeutic benefits may be described following a face to face consultation (for the UK this is found under S12(1) of the Medicines Act 1968); ‘recovery’ must never be guaranteed. Homeopaths are not permitted to countermand instructions or prescriptions given by a doctor.
The Medicines Act 1968, with the exception of Section 10 has been repealed by the Human Medicines Regulations 2012.
Except in cases of sudden or urgent necessity, it is an offence in the UK for anyone other than a certified midwife to attend a woman in childbirth without medical supervision or for anyone other than a registered nurse to attend for reward as nurse on a woman in childbirth or during a period of 10 days thereafter.
The 10 day went sometime ago and basically legislation says a midwife or a doctor must supervise delivery. Doulas etc are allowed.
Practitioners shall not practise in circumstances in which a person who is not properly qualified takes decisions with regard to the treatment of the patient/client, unless that person is the medical practitioner for that patient/client.

What? The section on "Publicity" makes reference to the Medicines Act 1968 again and avoids any mention of the ASA, CAP Code or consumer protection legislation.
Unless reference to a specialist qualification has been entered on the HINT Register of Members, no claim shall be made by a practitioner that the practitioner is a specialist, or an expert in a particular field. Nevertheless, a practitioner may indicate that a practice is wholly or mainly devoted to particular types of treatment.
The register with no-one on it. This raises questions about validation of quaifications as well.
In cases where an HINT Member holds money on behalf of another person or body they shall do so in such a way that it is kept separately from their own money, and that they account to the other party for any interest earned by such money.
Are the steering group HINT members?

Financials and Viability
Starting up a trade association such as HINT isn't cheap, done properly.

The website talks of "Support Teams" and a "Communications Team". This implies employees. They will need to be paid and when HINT started up it would have had no members and it isn't clear if it has any members even now. And -
The Steering Group is supported in its work by team specialists in the areas of Administration, Insurance, Legal, and Education.
HINT may avoid the need to rent office space by being mostly "virtual". Some small organisations can get away with holding meetings in people's homes, coffeeshops, etc but this is not ideal. And these venues aren't ideal for meeting backers or customers. Trade associations generate a lot of administrative work. It is generally more efficient to site day to day admin staff together.

Websites don't come for free - at the very least there are domain name registration and website hosting fees. Bargain basement offerings generally have restricted bandwidth and can't handle a lot of traffic. Building a website is more than just a collection of text, that actually has functionality beyond that is a skilled job. Yes, there are off the shelf open source software packages that provide a lot of the functionality that HINT might need but they require configuration. There may also be integration work required eg with accounts packages. These kind of projects have a habit of over running on both time scales and budgets as well as not delivering on functionality. The SoH found this out with the redevelopment of their website.

Gaining members requires making potential members aware than a trade association exists. Publicity and marketing is key. Whilst it is possible to run effective low cost marketing campaigns, HINT has almost zero visibility. It may be using direct emails - but there are problems with this. Firstly, not all homeopaths are online. Secondly, there is no comprehensive list of all homeopaths in the UK and it's unlikely that other trade associations would be happy with their membership lists being used not to mention GDPR issues. 

HINT pitches its membership fees below those of other trade associations. Variations in fee structures, whether insurance is included or not make direct comparisons impossible. It's unknown whether HINT prices include insurance and if not what the cost of their insurance scheme is. HINT offers full membership for £230 a years, the SoH (from Year 3 of membership onwards) £470 (includes insurance), the ARH £310 (plus £44 for insurance) and the Homeopathic Medical Association (HMA) £285 (plus £51.53 for insurance).

Unless HINT has a source of funds that is not mentioned on its website, its financial viability looks less that certain. Attempts to set up other homeopathic trade associations have failed. It's known that membership numbers aren't growing and if anything are in decline. The number of practicing homeopaths in the UK is difficult to estimate - slightly less than 3,000 at a guess. Most will be members of an existing trade association. It's been suggested that most homeopaths don't make a lot of money. It seems unlikely that they would want to belong to two homeopathic trade associations. Therefore, it is probable that HINT could only grow membership numbers at the expense of other trade associations. 

Of course, there is the possibility that there is no intention to actually deliver on any of the promises made on the website. That it exists purely as a vanity exercise.

Homeopaths and other groups would be well advised to have nothing to do with HINT whatsoever. They should probably warn others about it.

UPDATE 18/12/2018
It appears that this blogpost upset HINT. It's an odd document. Who wrote it is unknown.
With one email he created mayhem and division in our community. It has been Peter’s Christmas gift come early. It is what he lives for.
To be clear, there wasn't just one email sent but most importantly the SoH were advised that Taffler and Burnett seemed to be involved in a rival membership organisation with aggressive expansion plans among other things (it is worth noting that Taffler no longer seems to have anything to do with HINT). "Mayhem and division" is likely an overstatement and it is suggested that if there was, it was created by HINT's statements. And whilst UK homeopaths do not like to speak of it, plenty of divisions exist.

Apparently, HINT has not launched yet. Which is odd given the claims made above regarding number of members in the first year. These claims have now disappeared as has the search facility but many other problematic claims remain. Strange that no mention is made of this. Setting a website live before an organisation has launched with that kind of content is not a bright idea.

HINT feel the need to "clarify the confusion" -
Homeopathy needs a robust political voice and urgently. Not cap in hand hoping against hope to be invited, but stepping up and declaring ourselves a necessary partner, equipped to address the most serious challenges facing healthcare today.

We are radical in our approach and suggest the need for internal revolution, if homeopathy is to take its rightful place at the table of healthcare solutions. We respectfully suggest that individually, and collectively, there needs to be a mind shift. HINT exists for those in the homeopathic community who wish to take the most robust line in protecting homeopathy and in ensuring that we are part of the decision-making process in the future of healthcare.
Our community needs to go through a rapid culture change and time is not on our side. We need to sharpen up our professionalism. We need to work together to restore academic status and increase the number of well trained practitioners. We need to unify our profession from within and we need to each do what we are best at. The promotion of homeopathy to the public is at this point in our communal history, perhaps a secondary focus of HINT.
Professionalism? A more professional approach is notionally what 4Homeopathy is about. This is more like left-wing student politics. Rise up Homeopaths of the UK, you have nothing to lose except your customers! The inward focus when the existential threats to homeopathy are (mostly) external is symptomatic of that.

The implicit (and even explicit) criticism of other homeopathy bodies, of the various training providers is hardly going to endear HINT to them. UK lay homeopathy needs another splinter group like it needs a hole in the head.

CodaI am a very private person. I blog anonymously to protect my own and my family's privacy. Many regulatory and trade bodies know who I am and have respected my privacy. Many of my activist activities are not spoken of. Media stories with my involvement never mention me.

I am not happy.

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