Tuesday 5 March 2019

Faculty of Homeopathy developments

The Faculty of Homeopathy (FoH) has recently changed its entrance criteria. Or at least it says it has.
The Faculty is now pleased to be able to accept membership applications from medical, nursing, pharmacy, veterinary and other medical professionals eligible for statutory registration in their own jurisdictions, who have completed a course of homeopathic study. This makes the Faculty a supportive home for BHMS / DHMS colleagues plus those practicing in fields such as naturopathy, functional medicine, environmental medicine, integrated medicine and the range of complementary therapies.
The FoH believes -
The Faculty of Homeopathy is the preeminent global association for healthcare professionals who are trained to use homeopathy alongside conventional medicine. To date the majority of the Faculty’s members have been doctors practicing in the United Kingdom or European Union plus international members from India, Japan and Australasia. Today the Faculty moves to embrace further its international mission as it moves into its 175th Anniversary celebrations in 2019. 
It is a bit wider ranging than the headline and FoH website suggest -
Therefore Faculty membership will in future be also open to: 
• those who have relinquished their licence to practise medicine but continue to work as homeopaths, upholding the standards of the Faculty of Homeopathy and eligible for statutory registration 
• members of similar organisations of similar standing who do not have Faculty awarded recognition of training in homeopathy but who are qualified for statutory registration 
• healthcare professionals who have undertaken a recognised degree in homeopathy 
• healthcare professionals trained overseas who are not eligible to be International Members, and UK citizens undertaking suitable healthcare training overseas.
The first category is confusing and is discussed below. 

Why?
Because the FoH is a statutory corporation and because of the way that the Faculty of Homeopathy Act 1950 was written, there is no duty to report its accounts and membership numbers to anyone except its members. It is not accountable to any public or private organisation.
As we know homeopathy has been under pressure from detractors for some years, and consequently membership of the Faculty has fallen. With this in mind, it has been particularly difficult to correspond with a number of members who are reluctantly being forced to leave the Faculty because of our historical interpretation of the membership eligibility criteria in the Faculty of Homeopathy Act.
Information is difficult to find. Membership has dropped because members retire and recruitment has fallen dramatically. In 2008, they claimed to have more than 1,400 members. Now they say they have "over 500". It is moot whether "detractors" have had any direct effect on this. Lay homeopathy associations have also seen falls in membership but nowhere near as steep.

The FoH has also experienced a sharp decline in income particularly from training courses (yet associated cost have increased). Membership income has declined less steeply. It is very likely the FoH has a deficit. 

Eligibility
The UK professions that can join the FoH are -
  • Doctors
  • Dentists
  • Veterinary surgeons
  • Pharmacists
  • Nurses
  • Midwives
  • Veterinary Nurses
  • Osteopaths
  • Chiropractors
  • Opticians
There are also the professions looked after by the Health and Care Professions Council (HCPC).
  • Arts therapists
  • Biomedical scientists
  • Chiropodists/podiatrists
  • Clinical scientists
  • Hearing aid dispensers
  • Occupational therapists
  • Operating department practitioners
  • Orthoptists
  • Paramedics
  • Physiotherapists
  • Practitioner psychologists
  • Prosthetists/orthotists
  • Radiographers
  • Social Workers in England
  • Speech and language therapists
It seems extremely unlikely that social workers would want to practice homeopathy or that the FoH would regard them as "healthcare professionals".

From 2012 -
Along with revalidation and appraisal, a major concern that we are hearing is what happens when members retire from their statutorily registered profession. The Faculty constitution is very clear. Faculty membership is for members of statutorily registered professions. If a member is no longer fulfilling the requirements of registration with his or her statutory body, then they are no longer active members of the Faculty and considered retired and no longer practising. Being a designated body requires that we uphold these standards.
From 2017
Another key theme going forward is broadening the Faculty’s appeal by reviewing our membership eligibility criteria. We must become more user-friendly for Faculty members who are relinquishing their licence to practice one of the conventional medical disciplines, but still practising as homeopaths. Broadening our community’s appeal is of course an important element in ensuring the Faculty’s long-term future. The Faculty receives requests for membership from credible, like-minded supporters including psychologists, psychiatrists, dieticians, overseas clinicians and homeopaths, academics, researchers, etc., and we must consider supporting their joining aspirations.
The Faculty of Homeopathy Act 1950 says -
4. (1) The objects of the Faculty shall be to continue the work hitherto carried on by the existing Faculty for the advancement of the principles and the extension of the practice of homœopathy and to do all such other things as are incidental or the Faculty may deem conducive to the attainment of those objects. 
(2) Without prejudice to the generality of subsection (1) of this section the objects of the Faculty are - 
(a) to advance and extend the principles and practice of homœopathy; 
(b) to establish the status of fellowship of the Faculty and to admit to such status members of the Faculty who are judged by the Faculty to be qualified for such status; 
(c) to admit to the membership of the Faculty such persons as shall be eligible in accordance with the regulations thereof and shall conform thereto; 
(d) to grant to medical practitioners registered in the countries in which they practise diplomas certificates or other equivalent recognition of special knowledge in homœopathy either alone or in co-operation with teaching or examining bodies authorised to grant recognition as aforesaid:

Membership
There are various levels of membership -
  • Affiliate
  • Associate
  • Licenced Associate (which requires LFHom qualification)
  • Full Member (which requires MFHom qualification)
  • Fellow
  • Student
  • Retired
Only Licensed and Full members are allowed to use qualifications after their name and to be listed in FoH online directory (and the FindAHomeopath website - although they can be listed there if they belong to either Society of Homeopaths or the Alliance of Registered Homeopaths).

Qualifications
There are introduction to homeopathy type courses run but the qualifications the FoH validate are -
  • LFHom Vet (Licentiate of the Faculty of Homeopathy)/Primary Health Care Examination (PHCE)
  • MFHom
  • Specialist Registration
Note that "specialist registration" doesn't mean a specialism as far as the General Medical Council (GMC) or NHS are concerned. There used to be a Diploma of the Faculty of Homeopathy but that was abandoned at some point and those with the qualification were "grandfathered" to MFHom status. 

The FoH doesn't offer courses itself, it accredits others to offer them. There are a number of organisations that offer them but most interesting are -
The LFHom qualification is not particularly demanding. One example of the course suggests 150 private study and 30 hours tuition, although this may be spread out over several years (the taught elements of the course happen infrequently over weekends).

Much is made of how demanding the MFHom course is but even the Fast Track course pales into insignificance to the training to become a veterinary or medical specialist. It is unsurprising that homeopathy is not recognised as a speciality. It seems very unlikely the Fast Track course will ever be run again given that NHS homeopathy has ended there.

The Specialist qualification does not involve training per se but the writing of a dissertation.

Prescribing Rights
This is a huge problem for the FoH. As have often been stated on this blog, the majority of homeopathic remedies have the status of unlicensed medicines. This provides a good overview of prescribing rights by profession. 

Regulation and Ethics
The FoH don't have a Code of Ethics per se - because members are statutorily regulated, the FoH defer to the statutory regulator. They do have conditions of membership (which at the time of writing have been removed - archived). A future post will discuss non-compliant members.

One thing that it makes clear is -
Faculty members are also bound to act within the defined level of competence of their Faculty accredited training and qualification in homeopathy. Members may practise homeopathy beyond the limits of their Faculty accredited qualification only under supervision and as part of a Faculty of Homeopathy accredited training programme.
European Committee for Homeopathy
The ECH was mentioned in a previous post along with its strong links to the BHA. The ECH claims to represent "approximately 6,500 homeopathic doctors across Europe". The FoH is a member of the ECH, however, it is unclear whether the FoH fulfils the criteria for membership.

Admission of new members is governed by the following conditions:
  • full members: individuals or organisations which, at the same time, fulfil the following criteria:
    • 1º they are, or they represent, doctors of medicine who are entitled to work in their country of residence.
    • 2º they are recognised as, or are comprised of, medical doctors who have acquired an adequate knowledge of homoeopathic medicine – the level of knowledge required being defined by the education subcommittee of the E.C.H.
  • individuals or organisations, which the Council considers necessary to accomplish its aims.
  • associate members:
    • individuals or organisations which do not meet the criteria for full membership but nevertheless espouse the aims of the association.

The ECH does offer individual associated membership.

What is interesting that the ECH do not recognise any of the FoH accredited training centres.

Liga Medicorum Homoeopathica Internationalis
The LMHI is an international association of trade associations that represent doctor homeopaths plus dentists, veterinary surgeons and pharmacists. The FoH is a member. The LHMI also allows individuals in countries that do not have an association to join directly. It seems to allow DHMS/BHMS graduates as well as medical doctors et al to join but as individuals as no trade association in the sub-continent is a member. The LMHI also offer associate membership to other statutorily regulated professions.

Joining the FoH means that such persons would automatically be members of LMHI via its corporate membership. 

BHMS
This standards for Batchelor of Homeopathy Medicine and Surgery. DHMS is a Diploma. DHMS/BHMS are found on the Indian Sub-continent. Pakistan, India, Bangladesh and Sri-Lanka. The DHMS is 4 years long including 6 month internship, BHMS 5.5 years including 1 year internship. These are undergraduate courses. The entry standards are lower than for medical degree. The teaching standards are lower too.

DHMS/BHMS are not recognised outside of the Indian sub-continent. It is impossible to get a work visa for most countries with one. Whilst in the sub-continent, the use of "Doctor" is permitted and graduates are legally recognised as medical practitioners, elsewhere they are not permitted the title and are regarded as no more medically qualified than an ordinary lay person.

Depending on jurisdiction, DHMS/BHMS might face criminal charges if applying for a work visa and stating they have a medical degree. If they get into another country, they could face prosecution for practicing - in most civil law jurisdictions like France, only registered medical professionals can practice medicine. This is also true in some common law jurisdictions. There are US cases where BHMS graduates have been prosecuted for practicing medicine without a license. In the UK, assuming they have residence status, as long as they do not use the title doctor, do not engage in certain activities, they can practice but they can not join the FoH even if still registered in their home country.

The MFHom is recognised in Indian law. It permits medical doctors to practice homeopathy and call themselves homeopaths. This has caused some upset in the past.

Other
In some jurisdictions, other medical professions are statutorily regulated that aren't in the UK. South Africa regulates homeopathy.  In some US states and Canadian provinces naturopathy is recognised (and homeopathy is in Ontario). Physician assistants are regulated in some jurisdictions.

But...
The FoH's attempts to broaden its membership are problematic.

There no absolute definition of "healthcare professional" in UK legislation but it is generally understood to mean those in professions that are statutorily regulated. The likes of the Society of Homeopaths may like to describe members as "healthcare professionals" but from a legal standpoint, they are medically unqualified members of the public with no special knowledge.

So healthcare professionals who have undertaken a recognised degree in homeopathy does not mean that lay homeopaths with BSc Homeopathy can join the FoH. If the FoH accepted such persons they could be in breach of the Faculty of Homeopathy Act. Even if they weren't arguably admitting them would cause the FoH to loose some of its distinctiveness.

The FoH has an existing membership category for retired practitioners but the conditions for that is that members do not practice. But it seems that the FoH wants to allow membership of those who have given up being a doctor, nurse etc but who carry on practicing homeopathy. To be clear, when someone gives up their profession, they give up the prescribing rights associated with the profession.



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