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.
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 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 complianceNote 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.
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.
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?
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.
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.
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.
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.