CNHC Progress Reports for Q3 2009
I obtained the CNHC's progress reports to the Department of Health under the Freedom of Information Act. There are some interesting things inside...
Introduction
The Complementary and Natural Healthcare Council (CHNC) is a voluntary regulator of supplementary, complementary and alternative medicine in the UK. It has already received £900,000 of public money, with additional funding approved for next year.
Critics have been quick to point out that it will be difficult to live up to its remit of protecting the public since it imposes no standards of efficacy or safety on the treatments it certifies. Instead, it ensures a basic level of training and insurance among the registered practitioners.
Levels of registration have not been going to plan. The original proposal predicted 10,000 practitioners would be registered by the end of the year. This was then quietly revised downwards to 4,000, by editing the text of an already-published press release on their website. Independent estimates suggest that around 1250 to 1400 is a more realistic figure given the actual rates of registration.
Freedom of Information
At the beginning of November, the CNHC announced on its website that it had sent the latest 3 months of reports to the Department of Health. Since this is a government body, it comes under the Freedom of Information Act, and via the excellent website What Do They Know?, I submitted a request to see the reports.
(You can find it here).
The story they tell is even worse that we had suspected.
I Love It When A Plan Comes Together
Or not, as the case may be. The first thing that leaped out of the pages was the level of registration, when compared to the original plans.
The figures to the end of June have the forecasted application fees as £14,596. The actual figure was £1365, less than 10% of the forecast. Even taking into account registration fees of £605, this was still only £1965, or about one seventh of the forecasted amount.
This doesn't seem to be a glitch, either. The year to date figures show that total over the year is a little more than 20% of the plan. Either performance is dismal, or the plan was originally over-optimistic.
If we move on to the July figures, the results are even worse. Again, the planned application fee income was £14,596. The income? £775. That's not a typo - that's less than a thousand pounds, or to put it another way, just over 5% of the planned amount. Registration fees were double this at £1600 which acted as a bit of a safety net but still failed to reach 20% of plan.
In August, the planned figure was revised downwards by a factor of three, o just £4538. So, at least the percentages will be up this month. Or perhaps not, with a measly £430 coming in - still under 10%. Registration fees were £1545, so if we take these together we have a shortfall of about 50% in the revised plan.
At this point, we learn from a footnote that applications and registrations will in future be aggregated into a single figure. This is why I have included the registration figures above. Even when taken into account, they still fail to add up to anything near the plan.
Meet the New Plan
In July, if we ignore the initial £502,796 from the government, the planned total income for the year to date was £66,186. The actual value was £47,964 shy of that, at only £18,222.
But the same set of figures on the August sheet are distinctly odd. Initially, I had thought that the end of the accounting year had arrived, and thus the figures had been reset to zero. But this doesn't stand up, because there, proudly in the year-to-date was the same £502,796 from the Dept of Health.
It looks like the elimination of the Application Fee section has been applied. The plan in this area is now conveniently zero, not just for this month, but retrospectively applied to the whole year.
In July, the plan suggested that fees (of all stripes) up to that point should have been £65,884. Under the old plan, the August prediction would have been close to £80,000. The new plan has revised these downwards to £18,728. The actual year to date figures, once you correlate them to the old ones properly, are correct at £19,865.
So, it looks like the revised plan is a much more realistic estimate of the combined income, at around £50,000.
The closure of two other professional bodies, the General Council of Massage Therapy, and the Nutritional Therapy Council, were forecast to inject an additional 500 registrants as they transfer across to the CNHC. Registration rates have increased considerably since the start of September, so this may be a result of these transfers coming on line. If so, we should expect to see the curve flatten back closer to its previous rate in the new year as all 500 new applicants are processed.
Conduct and Accountability
The Profession Specific Boards (PSBs) met for a joint PSB meeting in July, where the main focus was on conduct and competence procedures. The CNHC's procedures for complaints have recently become a thorn in their side with Simon Perry's organized campaign of holding new applicants to account.
This does not act as an indicator of good conduct or competence within the CNHC itself. It should be weeding out unsuitable applicants, not leaving it to the motivated skeptical bloggers. Despite the CNHC's written thanks to Simon, this is still a thorn that could turn septic.
There were a large number of of new applicants in breach of the CNHC's guidelines and I doubt that the proportion will be significantly different among those already registered. If the CNHC is forced to re-examine all existing registrants, then they could be in the same situation as the General Chiropractic Council, where all its resources are tied up investigating complaints against its own members.
A possibly enlightening quote from Maggie Dunn, Chief Executive of CNHC, can be found in an interview in the Nursing Times. "It is not my job to say whether therapies work but to say that the people who deliver them are safe and competent."
Board minutes are, as promised, available on the CHNC web site.
Publicity
The CNHC's public relations company, Mandate, have also been contributing to the monthly reports. These are the usual roundups of the number of press mentions, with the usual mix of large press (The Times) and small (The Woodley and Earley Chronicle).
This may be standard jargon in the PR industry, but I was a bit bemused by the phrase "The press release has been sold into 35 regional titles" in the September report.
One thing I found rather chilling was the suggestion that the CNHC should target the Hospice movement. After a little reflection, I was less dismissive of the idea. It may be that certain interventions such as massage and other stress-relieving therapies may be useful to improve the patient's state of mind. And much of the work of the hospice movement is indeed improving the state of the mind when there is no longer any hope for the body.
However, if therapists are tempted to imply that their treatments have unproven effects on underlying terminal conditions, then I would be very uncomfortable. Using CNHC registration to imply any kind of effectiveness in this situation would, in my opinion, be a serious offense.
The drafted press release announcing the 1000th registrant failed to impinge on my consciousness, if indeed it materialized at all. Perhaps they feared the adverse publicity of those who would point out the difference between promising ten thousand members and delivering one.
Roundup
I am, despite my skeptical nature, beginning to feel sorry for the CNHC board. They are in the impossible position of having to regulate nonsense, and that is beginning to tell. I doubt they will get another round of funding, and just quietly fade away towards the end of 2010.