A Visit to the CNHC
On 13 April 2010, I managed to attend the Complementary and Natural Healthcare Council's Board Meeting. This is my record of the meeting.
IMPORTANT NOTE - This record is a personal record of the meeting and has not been ratified. It is not an official minute of the meeting.
I was granted an observer seat at the open session of the Complementary and Natural Healthcare Council (CNHC), and would like to thank Maggy Wallace in particular for making me welcome.
Attending were Maggy Wallace (Chair), Maggie Dunn (Chief Exec and Registrar), Carol Jollie (Clerk), Kay Dixon, Anne Sultoon, Julian Weinberg, Dimitrios Varsamis, John Lant, and three observers.
There were two other observers, one nutritional therapist (whose name I am afraid I did not write down), and Veronica Boden of the Healing Trust.
It was nice (and a bit surprising) to be introduced by name at the start, and named as one of the people responsible for the open sessions happening in the first place. This was due to my badgering of the CNHC to act on its pledge of openness and transparency.
Most of the meeting was procedural, summing up the work of the various subcommittees and working groups.
Matters Arising from Previous Meeting
It was noted that David Tredinnick is standing again. You may recall him as the MP who claimed expenses for astrology software. His personal secretary apparently helped with some of the early setup of the CNHC and maintains close links. He is standing in his own right, so may not be as available as he was before.
They have appointed a new business manager who will start on April 26.
Anne Sultoon has written a journal article for the VCVT and given them leaflets,
Standards for Health has given them funding for a study into what length of qualification is appropriate for CNHC registation. At present, they are using the existing NOS qualifications which are being superceded and will be deprectated and eliminated in 2-3 years. Some of these qualifications were based on insufficient study. Their Profession Specific Boards (PSBs) will look at what length of training they see as appropriate.
Social Enterprise Investment Fund application for funds was not successful. They wanted to fund development work on accreditation. The reasons given were that the SEIF felt that this would not help grow their business, and the current grant program is oversubscribed. However, they invited re-application in the new financial year. This year, the theme of the scheme was "enabling growth", next year, it will be based on "community values" although what this means is unclear.
The first annual accounts were submitted to, and accepted by, the auditors. These cover July 08 to December 09. Details will be published on the website as part of the annual report.
Conduct and Competence
One of the more interesting sections was the Conduct and Competence Committee report. They took pains to reassure us that the FIH were a separate organization, despite being involved in the formation of the CNHC.
The FIH now oversees 12 sub-organizations and is hatching 3 more. These will then be immediately referred to the CNHC for their regulatory needs, although they will not be compelled to join. Informally, they seem interested.
The level of involvement of the FIH is declining due to a change of direction. New groups will in future apply to CNHC directly.
The 3 new groups are potentially large: up to 2000 for hypnotherapy, Professional Healers up to 40,000 (although many unlikely to both meet standards and decide to register). Miscrosystems Acupuncture has up to 1500.
Discussion turned to the complaints. Registrants complained about were found to be in breach of guidelines but does not impact fitness to practice. Registrants were givenn advice from section 15 of the Code of Practice. A report has been distributed to the individual PSB members, who expressed interest in being consulted on registrant guidance. All guidance should be given to new members. PSB members have their own guidelines based on the professional bodies in those disciplines.
John Dent is preparing a web-based resource for training which will be linked from the CNHC website. Training establishments often don't give enough guidance on this kind of matter, and text books need updating. The complained-of practitioners, for example, used language commonly found in textbooks to promote their services. It will take time to get this right - it will not change overnight.
Only individuals who have taken the appropriate training (CCC section 7) are allowed to sit on the boards. I would like to see how this is enforced - Dmitri, for example, said that he had not been on the training course yet.
The constitution of the panels was discussed, with the requirement that they consist of at least one lay person and one professional in the appropriate discipline. This is to avoid complaints over proper competence and oversight. Panels without expertise in specific areas may consult with appropriate experts.
There was discussion about attendance (with a booth) at the annual Trading Standards conference. This was deemed too expensive this year as it would be a last minute rush and only expensive booth spaces are still available. Will attend next year as part of the PR strategy. This seems odd to me. TS is a patient protection function, not a PR function.
Does advertising of services on websites count under trading standards or advertising standards? No firm answer on this one.
The Professional Standards Committee did not meet last time, as there was no business to transact, except for an external discussion on professional standards for new "aspirant" profession standards.
Standards for Health guidelines will be used as a basis for creating standards for new professions coming on line; what standard does the profession as a whole need to meet in order to be considered as a CNHC-supported discipline? One particular problem is to define what "Complementary and Natural Healthcare" actually means, for a start! It was interesting to see the CNHC acknowledge in as many words what its critics see as its greatest weakness.
A draft of the guidelines will go to the PSB in June, then to the PSBs for their comments, and finally it will be ratified at the board meeting in the Autumn.
The audit subgroup was highlighted as the group that was in charge of ensuring that the professional associations for each discipline were in fact adequately vetting their members. There needs to be a process of verification, and checks and balances applied.
Profession Specific Boards
There are now 11 Profession Specific Boards in place. The previous meeting had 3 separate sessions over 2 days. They will rotate the groups so that different modalities (note - not therapies) have the chance to talk to one another. They are considering bringin everyone together for a big session in June, with all 11 having space for their individual discussions before being brought into a large session all together. Two days hav been booked in September to accommodate the old format, but if the June experiment goes well they will use the new format instead on one day.
The register will open for Naturopaths on 5 July. First meeting of the Naturopathy PSB was on 30 March, at which were presented the Code of Conduct, Ethics policy, Roles and Responsibilities of the PSB officers, and previous agendas of the other PSBs to get them going.
Each PSB will have a single person to act as point of contact with the main board.
The Operations section started with an activities report. Visitors to the website are increasing - good easy-to-read report on activity. Good conversion rate from site visits to calls and emails. Yoga, Alexander, Sports Therapy and Bowen were all new and resulted in an uptick in emails and phone calls as they were introduced earlier this year.
The newsletter has a good response with good read rate (50%) and good conversion to website visits. (I wonder how they track this - will have to subscribe to the email.) There are also low numbers of invalid addresses and unsubscribe requests.
A nearly 100% increase in the number of recipients in the last 6 months reflects increase in registrants. If we could have started with a large number of groups open, we would have had more.
There are several external contacts lists - a full list as well as registrants, professional associations, professionals, and the general public. The newsletter goes to everyone - anyone can subscribe through the website.
PR activity coordinator could only attend this morning. Communication consultant Hazel Russo has been looking into CNHC's failure to reach public, registrants, etc. Her first target is those professional associations currently registered.
The Association of Reflexologists, for example, now has a CNHC link on its home page, as well as an article in their magazine and leaflets distributed with it.
Website admins liked her assistance with websites, especially those from smaller organizations who often have volunteer webmasters.
She is also looking at ways to bridge the "paper gap" that currently exists for registrants registering via Professional Association websites. Often, this involves downloading, printing and filling a paper form which is silly seeing as how everything else is electronic.
The other item of note was her contact with DoH Primary Care Trusts, which have already started adopting NICE guidelines on lower back pain. Has talked to the DoH about their website. She has also been in contact with BUPA, who do not currently recognise any therapies registered by the CNHC. They will review based on the evidence base for the therapy.
A spreadsheet of Performance Indicators was circulated, with the overarching priorities spelled out. PR in particular was singled out for discussion. The PR push was to contact practitioners not currently registered, with a questionnaire. The questions included why they were not currently registered, had they heard of the CNHC, and so on. It is, apparently, difficult to get to talk to people directly on the phone, so this campaign is moving to email.
The complementary sector is very poorly described and researched, and it was said that the CNHC was handed a lot of incredibly inaccurate information by its predecessor. This was used as a basis of initial policy, and contained lots of "anecdote" and "over-egging of numbers".
It was decided to move discussion of the risk register from the morning closed session to the open session, starting at the next meeting.
The committee structure has been changed to streamline communication and reduce costs. All new committee members have been through a public interview and recruitment process. One resignation from the CCC was accepted and it was decided not to fill the position vacated.
The balance of the committees between board members and non-board members has been addressed, with more non-board members in place. The committee meetings are scheduled quarterly but do not sit unless there is actual work to do. Attendance is good - all meetings so far have been quorate.
Kay Dixon pointed out that the finance committee was still unbalanced, and has some attendance problems. There should be more non-board members on the FC to balance this, and they will look at previous applicants to see if any of these are suitable to sit on an expanded committee. The Department of Health would be interested in clearing and approving this position. Any change to the makeup of the committees will be reflected in updates to the standing orders.
The Annual Report is nearly ready in draft. The long form will be in a convention form factor, but a summary will be delivered in a form that is a bit more interesting. Maggy Wallace showed a leaflet that illustrated her view of what the short form report should look like. (Graphically dense, colourful, fold-out glossy sheet. Possibly A3 folded to 1/3 A4.)
The Secretary of State made an announcement this month on Next Steps in Complementary Healthcare. The CNHC were pleased to have this endorsement by the Secretary of State. They have been asked to regulate herbal medicines and Traditional Chinese Medicine (TCM), and possibly acupuncture as well. There are a numnber of issues with this, but they look forward to working with colleagues in both herbal and TCM. Informal discussions are progressing with professional representatives in each of these sectors.
Discussion then turned to wider regulatory matters. There are nine statutory regulatory bodies, including the General Medical Council and the General Chiropractic Council. The current view is that there will be no new statutory bodies - white papers and other sources all point this way. This suggests that regulation of herbal and TCM will fall to the CNHC. The white paper highlights that voluntary regulation as gaining more teeth rather than less. CNHC therefore has a significant part to play.
The CHRE has released a revised performance review process, which sets out (as far as I can see) a framework for regulation that is the recommended model for each of the statutory agencies. It is suggested that the CHRE guidelines are adopted for the performance review process. Kay Dixon suggested that CNHC should approach the CHRE for a regulatory audit of CNHC procedures. Who else could do it?
The General Medical Council has produced a consultation on the process of Revalidation, as it is applied to those who are under the regulation of the statutory regulation bodies. GPs, for example, have to be revalidated as fit to practice at intervals. It also spells out requirements for continuing professional development. The Osteopaths will fall under this remit, with pilot projects early next year with view to wide deployment in 2012. As far as the CNHC is concerned, this does not apply since they are a voluntary regulator and cannot force people to re-register. This may become an issue if registration with the CNHC becomes compulsary.
Similarly, the Office of the Health Professions Adjudicator have been created as an independent investigator into disputes and complaints, separating the investigation and adjudication even further than they are at the moment. It is not yet understood what relationship, if any, this new regulator will have with the CNHC.
Internet and Media Report
Dimitrios presented a round-up of coverage of the CNHC on the internet.
There was an announcement of pilots of complementary therapy (acupuncture and manual therapy), and an accompanying article in GP's magazine Pals. The article was good but comments were not positive.
The complainant to the CCC has blogged about his experiences, which has been extensively linked and viewed. Dimitri will send links to these.
It was at this point that Maggy Wallace took pains to re-iterate the CNHC's policy of not responding to blogs. This would need an additional two members of staff. And it's not just blogs either. There are a number of web sites with "unhelpful" comments, of which we are aware but we do not respond.
Maggy described these as "inaccurate", they "rewrite history", "invent truth" and "pound on rumour", to general nods of agreement. There are "questions of accuracy", and although it is annoying to have to sit quietly while this is played out online, the policy stands.
Press cuttings are too expensive to obtain through an agency - it would be useful for everyone to send press clippings to Maggy for a central file. Please make sure scans are legible!
One negative example was a piece on an osteopath and reflexologist who had been reported to a local court over allegations of rape. It was an "arresting headline" and generated some calls. It was recognised that as the CNHC gets more registrants and a higher public profile, more complaints will come in. As it happens, the accused was not a member.
The informal session was an opportunity for the observers to ask questions.
The number of registrants is about 2000, with a plan for 5000 by the end of 2010. This target has been agreed with the Department of Health.
The initial 10,000 figure for the end of 2009 was an initial estimate based on the inaccurate business information received at the start. The CNHC requires 10,000 members to be completely self-financing. They never thought that they would get them all in the first year, and the inclusion of the figures in the original press release was "a genuine mistake".
This inaccurate information suggested that 150,000 practitioners was the size of the market. This is more accurately estimated to be 25,000. This eliminates those practitioners who are doing this in a volunteer or non-professional environment.
Some discussion was had over the use of complementary medicine in cancer and palliative care. This is often done on a voluntary basis and should be open to registration. This is an important consumer protection issue. (I agree!) Is the £45 fee a big deal for most volunteers? Possibly. It was suggested that the cancer networks should be talked with, and the idea that the £45 fee could be picked up by the hospices rather than the volunteers themselves.
Many CAM practitioners are taking only a second income, and are primarily female. Except, for some reason, in hypnotherapy.
The detailed figures showed that there are 2241 registants, totalling 3222 when you include those in the process of registration. There are 339 nutritional therapists waiting to complete registration. The Osteopathy council, for reference, has 4000 members.
None of the complaints were against nutritional therapists.
Grant funding ends in March 2011 for the initial tranche of money from the DoH, but if herbal and TCM are required to register, then the DoH will supply additional money.
Much of the meeting was procedural, with only occasional reminders of the complementary nature of the therapies being regulated.
Specific things that struck me were:
- The sector is poorly defined and researched.
- The internet report was almost completely negative, but the negativity was largely dismissed as inaccurate.
- The links to cancer treatment are important to keep an eye on.