Friday, 14 December 2018

Non-compliant Society of Homeopaths members

A previous post discussed the condition placed on the reaccreditation of the Society of Homeopaths (SoH) by the Professional Standards Authority (PSA) regarding CEASE therapy.

In short, the SoH has until 31/12/2018 to ensure that members' websites comply with the (weaselly worded) SoH position statements on CEASE therapy, vaccination and homeoprophylaxis.

SoH Position Statements
This is reproduced in full.
Homeopathic prophylaxis
The Society of Homeopaths has a clear policy on ‘homeoprophylaxis’ – it does not endorse the use of homeopathic medicines as an alternative to vaccination for the prevention of serious infectious diseases. 
The Society recommends that members of the public seek the advice of their GP, and/or relevant Department of Health guidelines, concerning vaccination and protection against disease whilst travelling. 
Currently there is no homeopathic alternative to vaccination or anti-malarial drugs which has been proven beyond doubt to be clinically effective. It is therefore unethical for a homeopath to advise a patient against the use of conventional vaccines or anti-malarial drugs. 
The Society acknowledges that homeoprophylaxis is a controversial area of homeopathy which differs significantly from usual homeopathic practice and that the current level of scientific evidence on homeoprophylaxis (including historical clinical experience and contemporary research) is insufficient to make definitive claims of efficacy or effectiveness. 
There is sufficient research evidence to suggest that homeoprophylaxis may be effective in certain circumstances and the Society therefore supports further rigorous, ethical research to its use. 
The Society supports informed decision making in regard to vaccination. We recommend that patients seek advice from their GP, as well as organisations that specialise in providing information about this complex issue, so they can make an informed choice for themselves and their children. 
The Society of Homeopaths appreciates that its registered members use different methodologies and adjunctive approaches and embraces diversity within the homeopathic community. We consider diversity to be healthy and appropriate to the demands of an informed public. 
CEASE is a therapy designed by Dr Tinus Smits in the Netherlands. A number of Society members have been trained in CEASE and make reference to it in their marketing. While this is acceptable, members should be aware the title, meaning ‘Complete Elimination of Autistic Spectrum Expression’ is misleading. RSHoms must not suggest that they are capable of a complete cure of autism as this would be unethical and in breach of the Code of Ethics. 
The Society does not endorse any aspects of CEASE therapy contrary to NHS guidance and nor should RSHoms, in particular on vaccination, homeopathic prophylaxis, and the use of dietary supplements. It is beyond standard homeopathic practice to provide advice on the use of supplements and therefore any guidance given should be in line with the NHS Guidelines
As previously discussed, this falls far short of the position that a professional organisation with a commitment to public health and safeguarding would take.

List of non-compliant members
This list is of SoH members who have CEASE therapy or the related Homeopathic Detox Therapy (HDT). Whilst there may be other members who do not comply with either the homeoprophylaxis or vaccination statement, it is difficult to determine who they are.

It is likely that the SoH will attempt to take the softest position with compliance. Whether this will satisfy the PSA is another matter and if history is anything to go by, they will complain and attempt to drag things out.

This list obviously contains members who have been discussed in the past. It is worth pointing out that the SoH have been provided with versions of this list. It isn't perfect.

Explanation indicates a listing on that website. That website is likely still non-compliant with Dutch advertising regulation. It would appear that the SoH think that a listing is not a problem. This is odd. Whether the PSA will agree with them is unknown. It might be better if SoH members requested listing removal. entry - some SoH members have a more detailed entry, which suggests a great interest in touting for business.

HDT? refers to whether a practitioner is listed on this website.

CEASE Therapy Claims? Examples of where more than a passing mention is made of CEASE. The claims vary. Only one page is recorded but there could be others.

Links to The ASA ruling against Teddington Homeopathy makes clear that such links are not permitted and the SoH should be aware of this. So linking to the CEASE therapy website is bad but having it link to an SoH member website is OK? The potential effect on consumer thinking is the same - they will have been exposed to "vaccines cause autism" and "autism can be cured".

Complete Elimination of Autistic Spectrum Expression? Use of this phrase is expressly forbidden.

Vaccination cause autism etc? Even the mere implicitation of this is forbidden. Some SoH members have a tendency to ignore the clear guidance that has been given. Nor that the SoH has shown any signs of enforcement.

So what?
Placing details of (potentially) non-compliant member into the public domain is a deliberate attempt to force the SoH to get their members to comply and if they don't, start disciplinary action.

The list will be revisited in early January 2019 to see if compliance has occurred. 

UPDATE 26/01/2019
At the time of writing, the PSA have either not completed the re-accreditation process or are yet to publish it. It is quite possible the process is taking longer that it should because the SoH are arguing over the wording. But there has been a development.

A paper prepared for a PSA board meeting on 19/01/2019 tells us something interesting -
We recommend continuing our observance of the founding principles. In the light of our experience with considering the issues involved in CEASE therapy we would highlight one additional point. Whilst we addressed this primarily from a safety perspective, it also raised an ethical issue under the Equality Act in so far as the therapy seeks to ‘eliminate’ a characteristic that not everyone would think necessary or desirable to eliminate. Since we already consider observance with the Equality Act within our assessment process we do not think we need to amend the principles. 
We consider the safeguarding legislative gap to present an ongoing risk to the public and we will continue to raise this matter with the DHSC and Ministers. This year we will focus our assessment activity on accredited registers risk management procedures, which will include reviewing their safeguarding arrangements and if this continues to highlight a problem, we will present our findings to DHSC to strengthen our call for action.
Many posts on this blog have raised questions about the attitudes of CEASE practitioners towards autism. The PSA have confirmed that -
In applying our equality duties, we made the decision that therapies underpinned by a philosophy that a protected characteristic under the Equalities Act (e.g. autism, sexual orientation) is a negative characteristic to be eliminated, must not be provided by ARs.
Or rather members of an Accredited Register. This puts a slightly different complexion on things. It's no longer about claims made by practitioners. It goes without saying that the PSA would not accredit an AR whose members offered, say, gay conversion therapy (which is still legal - the Counsellors and Psychotherapists (Regulation) and Conversion Therapy Bill is yet to be passed)It's clear that CEASE is very wrong about autism in so many ways but does CEASE embody a philosophy that autism is something to be eliminated?

It is possible that Tinus Smits chose CEASE as a catchy acronym but at the very least "Complete Elimination of Autistic Spectrum Expression" displays a profound insensitivity towards autistic people. The reactions of autistic people to the phrase vary but are uniformly negative. This is far more important than what the SoH, individual homeopaths and their supporters think. It is also more important than that non-autistic critics of CEASE therapy think. The PSA should listen to autistic people first.

Safeguarding has been discussed previously. That the PSA do identify a gap in legislation is good but change to legislation is difficult to achieve (see this for other proposed changes). If changes do result, it will affect more than just the SoH. 

Examination of the above list of non-compliant SoH members reveal few substantive changes to any website (and readers are encouraged to look for themselves). It is assumed that the SoH must now have begun disciplinary proceedings against these members - it would be awkward if the SoH failed to carry out something that they have publicly committed to doing whilst the re-accreditation process was being carried out.

If CEASE is a philosophy of elimination, then the PSA have raised the bar considerably in terms of compliance. Short of getting rid of all mention of CEASE, getting rid of links to the CEASE website and listing on there too, it is difficult to see how SoH members could comply. This does not only apply to websites but also social media, email newsletters and so on. If CEASE is a philosophy of elimination, then practice could well be grounds for instant expulsion.

Things can move very slowly. It is necessary to wait for the outcome of the re-accreditation process to be publish. Perhaps non-compliant members will start to amend their websites?

CEASE therapy has had profound implications for naturopathy in British Columbia. The practice has been banned for naturopaths and likely had some impact on advertising policy enforcement too.

It does not seem as if CEASE therapy has much of a future in the UK.

UPDATE 03/03/2019
The PSA have not published their re-accreditation of the SoH. The SoH have made no mention of re-accreditation either. They are holding elections for director appointments as mentioned in this news story. It appears some members asked (on the SoH's members only forum) if the Society’s work to retain accredited register status with the Professional Standards Authority (PSA) has been worthwhile? Interestingly one of the candidates is Margaret Kincade who offers CEASE therapy and is listed on the website. It would be possible to read too much into this.

The SoH are publishing board minutes again but note that the public versions are redacted (there are also members only (likely) redacted versions too). It is what is not said that is of more interest that what is - i.e. what is going with the PSA, CEASE therapy and the potential initiation of disciplinary procedures. There was a board meeting on 11/02/2019 but the minutes have yet to be published. 

The SoH Conference is March 22-24. It is possible that the SoH are hoping that the re-accreditation isn't made public until after this given the upset that the Guardian reporting of CEASE therapy caused just before the last one. 

The PSA recently re-accredited the Federation of Holistic Therapists. Mention is made of CEASE therapy -
During the year the team raised the issue of Complete Elimination of Autistic Spectrum Expression (CEASE) therapy with FHT. FHT confirmed that it does not endorse the practice of CEASE therapy and that homeopaths practising this would not be accepted onto its register. FHT carried out an audit of its members who practise homeopathy and noted that all confirmed that they did not practise CEASE therapy. FHT informed its registrants that it does not accept, endorse or insure this practice and has added a statement on its homeopathy therapy descriptor page of its website.
It's easy for an organisation that has no members practicing a particular therapy to outlaw it. However, 

There do not seem to have been any changes to the above list of SoH members who (potentially) offer CEASE therapy or HDT. The SoH have been made aware of this.

The biggest problem for the SoH is Jennifer Hautman. Her website security certificate has expired and many potential customers will thus not look at it but Hautman has a long history of non-compliance with advertising and medicines regulation as well as consumer protection law, let alone compliance with the SoH Code of Ethics. 

Wednesday, 5 December 2018

Letter to UK politicians

An email has been sent to officers of the All-Party Parliamentary Group on Autism (APPGA) bringing CEASE therapy to their attention and asking them to look into why regulators have not acted. None have responded yet. It is possible that an email from a single individual is easily ignored. Hence, (some of) the text is being placed in the public domain in the hope that others will write to their MPs, local representatives and members of the House of Lords with an interest in autism. It might also be helpful if autism groups are made aware of this too.

Public reaction to CEASE therapy on social media, when its nature is explained, is overwhelmingly one of "it's child abuse!"

It's not suggested that the text be used verbatim. The text omits details of various recent developments, actions involving other jurisdictions.

A quote from the "inventor" of CEASE therapy -

... All kinds of detoxification reactions may occur. The most common are eliminative reactions with an increase of reactivity (fever). Fever should not be treated with medication, as it is a healthy reaction of the organism and not a disease! It helps greatly to overcome an acute disturbance, shortens the healing process, stimulates reactivity and avoids complications. Eliminations like diarrhea, flu, expectoration, and bad-smelling and cloudy urine should also be left alone, because they are a part of the healing process.
A case of diarrhea as a cleansing reaction
I remember an autistic child who got diarrhea during the detoxification of his vaccines. The diarrhea relieved his system so much, that his autism almost disappeared instantly. After ten days the mother started to worry and went to the family doctor because I was absent at that moment. He prescribed Immodium (Loperamide) to stop the diarrhea by paralyzing the peristaltic motions of the bowels. Almost immediately the child had a setback and became autistic as before. The diarrhea was a perfect detoxification for his bowels and brain. Neither the doctor not the mother understood this, and the medication interfered with the progress of the cure.
Chilling and obviously neglect.

CEASE therapy
  • Stands for "Complete Elimination of Autistic Spectrum Expression".
  • Claims 70% of cases of autism are caused by vaccines
  • Claims autism also caused by other medicines
  • Claims it can treat and even "reverse" autism
  • Uses doses of supplements/vitamins in excess of NHS guidelines
  • Claims homeopathic medicines made from vaccines/medicines "detox" the "damage" caused by them
  • Advocates against vaccination
  • Advocates "celebrating" and not treating symptoms of potential serious conditions. They are signs of "detox".
  • Advocates against medical treatment/very anti-doctor
A detailed examination of CEASE therapy can be found here.

  • Around 170 practitioners in the UK
  • Vast majority not medically qualified, have no autism awareness, safeguarding training.
  • Many are virulently anti-vaccination
  • Some practitioners claim to have treated "hundreds" of children. The exact numbers currently at risk of neglect is unknown but it is known one practitioner is attempting to recruit 400-500 families.
  • Much of the "diagnosis" and "treatment" is done online (esp via Skype)
  • "Detox" homeopathic medicines are unlicensed medicines. Supply to/by medically unqualified practitioners offence under Human Medicines Regulations 2012
  • Marketing claims in breach of consumer protection legislation
  • Marketing claims in breach of ASA advertising regulation
  • Illegal and/or unethical trials have been conducted
Media coverage
There was a story in the Guardian and a rehashed version in the Mail. There have been similar stories in Canada.

Actions taken
  • Concerns raised with Society of Homeopaths who initially ignored. SoH is accredited by Professional Standards Agency.
  • Concerns re SoH inaction raised with PSA. PSA concerned enough to impose conditions on SoH reacreditation.
  • Concerns raised with Alliance of Registered Homeopaths. Ignored.
  • List of practitioners and claims supplied to ASA. Known ASA have engaged in some action.
  • Concerns raised with Medicines and Healthcare Product Regulatory Agency (MHRA). Have previously forbidden online listing of "detox" remedies. Have powers to prevent supply but do.
  • Concerns raised with General Pharmaceutical Council (GPhC) re pharmacies supplying. Breach of professional standards. No action taken.
  • Attempts made to engage with various local Trading Standards but no response.
  • Concerns raised with local safeguarding board. Unable to act as children involved unknown.
Questions need to be raised with -
  • MHRA and why they will not act on illegal supply. This may need to be raised with the relevant minister at the Department of Health and Social Care as well.
  • GPhC as to why they do not deem the pharmacies that supply "detox" medicines as being in breach of professional standards.
  • PSA on why they reaccredited the SoH and what action they intend to take if SoH can not get its members to comply with agreed actions.
It is unlikely that the Society of Homeopaths et al would respond to any enquiry.