A Simple Question

The last post mentioned that the Society of Homeopaths (SoH) was attempting to engage with its members. The timining of this engagement was highly suggestive of it having something to do with the Professional Standards Authority (PSA) decision to conduct an in-year review of the SoH's Accreditation.

Admittedly, at the time of writing it is about two weeks since the engagement was concluded. The SoH has said nothing publicly yet about the outcome of this engagement. Neither have any of its members. In fact, there seems to have zero publication reaction from any UK homeopaths to Telegraph story that revealed that the SoH had appointed an anti-vaccinationist as Professional Standards and Safeguarding Lead and that an in-year Review had been initiated.

As far as can be determined, the in-year Review process is still ongoing but it is unknown what stage it is at.

Process
The Annual Review process has been discussed at great length in various posts. However, something that has not been mentioned is that at two separate stages, the PSA will share drafts of the Accreditation report -

Step 1: The Accreditation team will carry out a review of the evidence gathered during the year and supplied by the Accredited Register in the annual review form. The Accreditation team will produce a report based on this review which will be shared with the Accredited Register to check for factual accuracy and to answer any questions that the Accreditation team may have.

And

Step 5 (if applicable): Once the team has completed its targeted review, it will update the summary report. This will be shared with the Accredited Register to check for factual accuracy. The team will then convene an Accreditation Panel made up of three members of the Authority’s staff. The Moderator will not be eligible to sit as one of the three members of the Panel for a register they have reviewed in Step 3. 

As in-year review is supposed to be quicker, the first step might not happen. There is no way of directly knowing if Step 5 has been reached. But the SoH will get an indication of the PSA's thinking before anything is published.

It is clear from prior Accreditation reports that the SoH's fact-checking was deficient. There are also concerns about disclosure, non-cooperation and a tendency to spin things out. The SoH need to bear in mind that they need to provide evidence that they meet the Standards for Accredited Registers. There is evidence that suggests that they do not. Non-cooperation, non-disclosure and providing factually incorrect information is not going to help them in the slightest.

Once the Accreditation Panel has made its decision, the SoH will have 10 working days to appeal. 

Anti-vaccination? Not a problem
Looking back at prior Accreditation reports, it's clear that initially anti-vaccination among SoH members was not considered a major risk by the SoH and that the PSA didn't think so either. There is mention of anti-vaccination in the first Accreditation report -

The Panel considered a Call for Information response alleging that members of the Society had been associated with the ‘Andrew Wakefield / MMR vaccine’ controversy and related public health risks, such as ‘Steiner schools as unvaccinated communities’ leading to increased occurrences of disease outbreaks. The Panel noted the damage to public confidence in the Society that such allegations could cause. The Panel noted relevant actions carried out by the Society such as introducing guidelines for registrants and placing a public position statement on its website stating that it does not endorse the use of homeopathic medicines as an alternative to vaccination for the prevention of serious infectious diseases.

The link to Wakefield is former SoH Director Richard Barr. Steiner schools have in the past been linked to measles outbreaks. Some lay homeopaths send their children to Steiner schools and actively try to use other parents as a client base. But this is really about being linked to anti-vaccination activities of others. The "guidelines" are mostly a reaction to various reports by BBC Newsnight and were weak and the subject of much criticism. "Does not endorse" isn't an absolute prohibition and it took several years to get the SoH to issue a prohibition (which has been ignored by some).

Anti-vaccination among members has always been a very real risk to public health, the SoH's reputation and Accreditation. It is almost certainly the risk that poses greatest danger to Accreditation. Looking at later Accreditation reports -

• 2015 - no mention of anti-vaccination
• 2016 - no mention of anti-vaccination
• 2018 - mention of risk of anti-vaccination misinformation from CEASE therapy practitioners
• 2019 - mention of risk of anti-vaccination misinformation from CEASE therapy and Homeopathic Detox Therapy practitioners
• 2020 - mention of risk of anti-vaccination misinformation overall

There was no 2017 report as the Accreditation date changed from September to January.

To be clear, the risk of anti-vaccination misinformation was not something that the SoH identified itself. Evidence came from third parties and the PSA raised it with the SoH. Note the incremental increase in the effective prevalence of the risk as different groups are identified.

The point has been made before that the PSA is dependent on Accredited Registers disclosing risk to them. They may be more aware of the generic risks posed by the various types of registers now compared to a few years ago but they are not experts in various therapies, they offer quality assurance of how registers operate. In the case of the SoH, their inability to either recognise or acknowledge the risks posed by their members anti-vaccination activities is astonishing. It should not be down to third parties to quantify and qualify that kind of risk.

Good Thinking Society
The GTS response to media reporting is well worth reading but in short -

“In our opinion, the PSA has a simple choice to make: remove the Society of Homeopaths 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 Good Thinking Society.

But there have been pressures on the PSA before to remove Accreditation and they did not. The grounds for removal of Accreditation are -

Accreditation removed – the Accreditation Panel finds that the organisation does not and cannot continue to meet one or more of the Standards. The outcome will be communicated to the organisation with the Panel’s reasons. The organisation will then have 10 working days from receipt of the outcome to inform the Authority whether it will accept or appeal the Panel’s decision (see section 9). The outcome will be published on the Authority’s website after conclusion of the annual review process, including any appeal.

The PSA would need to be convinced that the SoH is not capable of meeting the Standards. 

Run out of chances?
The PSA have given the SoH multiple chances to improve compliance with standards. The 2020 Accreditation report is full of promises from the SoH. Whatever the reasons for Sue Pilkington's appointment (and subsequent removal) as Professional Standards and Safeguarding Lead, it does look like a regressive move. What few messages come out of the SoH suggest that is now far less committed to Accreditation. Other developments also suggest that the SoH has gone backwards since February 2020. Difficulties with losing a CEO, COVID-19 and so on might explain making slower progress than might have been anticipated but not a reversal.

The SoH managed to scrape through the 2020 Accreditation with Conditions. They may gamble that they can do so again. But...

A simple question
Nearly a month ago, the SoH were asked directly if they supported the UK vaccination programme. Their response?

Thank you for your email below. We will consider your question alongside your other emails. 

We will reply in due course.

A non-answer to a very direct and simple question.

Can the PSA accredit a register which purportedly regulates "healthcare professionals" that does not support one of the most effective public health measures? It might be acceptable for a register whose members have a narrow scope of practice such as psychological therapies not to have an explicit policy on vaccination but much less so for a register with members who think they have a much wider scope of practice and even position themselves as primary care practitioners?

Probably not.