First, do no harm; second, do some good!
The Ministerial Advisory Committee on Complementary and Alternative Health (MACCAH) called for submissions on how CAM can be introduced into the New Zealand health system.
The Committee was looking at such issues as:
- whether there is a need to regulate CAM practitioners to protect consumers
- what information consumers consider important to know about CAM benefits, risks and costs
- which areas should be given the highest priority in developing New Zealand research on the safety and effectiveness of specific CAM therapies
- if and how specified complementary and alternative health practitioners should be integrated into the mainstream health system
The Committee consisted primarily of CAM practitioners with people involved in iridology, naturopathy/natural medicines, traditional Chinese medicine/acupuncture, aromatherapy/massage therapy, counsellor/Steiner, sociologist, and two doctors representing Maori and Pacific Health….
The NZ Skeptics made a formal submission to the Committee, after a frantic week researching the issues and policies abroad with the assistance of a wide range of people nationally and internationally. (Read the submission here; see the summary here)
The main focus in our submission was on stressing the importance of determining not just the safety, but also the efficacy of any CAM modality or product. Safety alone is not adequate if one is to provide consumer protection against fraudulent or misleading claims.
And if something is found to be both safe and effective, then it should be recognised as such and adopted if it proves superior to current practices or products.
As Marcia Angell, editor of the New England Journal of Medicine, put it:
There cannot be two kinds of medicine — conventional and alternative. There is only medicine that has been adequately tested and medicine that has not, medicine that works and medicine that may or may not work. Once a treatment has been tested rigorously, it no longer matters whether it was considered alternative at the outset. If it is found to be reasonably safe and effective, it will be accepted. But assertions, speculation, and testimonials do not substitute for evidence.
The NZ Skeptics are grateful for the many experts who provided advice, assistance and information. A non-exhaustive list includes the following:
Dr Stephen Barrett, Chair of Quackwatch
Dr Wallace Sampson, Editor the Scientific Review of Alternative Medicine
Robert S. Baratz, MD, PhD, President of the National Council Against Health Fraud
Ruth Kava, Ph.D., R.D. Director of Nutrition, American Council on Science and Health
Peter Moran MB BS BSc(Med) FRCS(Eng) FRACS
Timothy Gorksi, MD, NCAHF board member
Rocky Mountain Skeptics
Paul Lee
Moshe Frenkel M.D.
Donald Marcus M.D.
Summary of Recommendations
The list below covers the general recommendations made in the NZ Skeptics submission. Each point is covered in detail in the full submissions document.
Problems of Basic Focus
- The basic question is whether CAM can help, not how
- MACCAH definition of CAM is too broad
- Better definitional analysis of CAM is required
- Categorisation and prioritisation necessary for evaluation, research and application
- Broader representation on MACCAH needs to be addressed for credibility of policy recommendations
Regulation
- Need to recognise public demand for regulation
- Does training imply competency? Disclosure and liability responsibilities must be enforced
- Regulations required against disproven and unsafe practices and products
- Need to ensure that apparent safeguards arising from regulation are not misleading to consumers
- Costs should be borne predominantly by CAM industry with independent monitoring
- Regulations need to recognise range of risks
- Lower standards for CAM harm its own credibility and should not be accepted
- Self-regulation is inadequate and inappropriate
- Issues of public accountability and enforcement have to be addressed
- Failure to regulate products leads to public harm
- Clear, consistent product regulation is vital and achievable
- Recommended response to ensure safety and efficacy
Consumer Information Needs
- Informed choice should be a primary requirement and must include totality of available evidence
- MOH database needs to be balanced, neutral to achieve credibility
- Vested sources can be inaccurate, misleading and potentially dangerous
- Publication bias has to be recognised and assessment provided
Research, Evidence and Efficacy
- Identify practices, products outside the scope of research
- CAM is big business and should contribute to research
- Credible research programmes can provide useful information
- Public research programmes need to prioritise promising approaches over questionable ones
- Public funding should be based on results and capped at appropriate levels
- All research programmes need to be robust and defensible
- Binding negotiated research protocols required
- Negative results need to be acknowledged, accepted and publicised
- Anecdotal evidence should be treated as an indicator for research, not a research result
Integration
- First, do no harm; second, do some good
- Education and training required; acknowledged where limited or conflicting
- Evidence of safety and efficacy vital prior to integration
- Integration efforts require monitoring and evaluation as current examples are inadequate
- Ethical standards necessary regarding declaration of commercial interests
- Cost-benefit analysis required prior to integration