Response to Charity Commission consultation on CAM
In April 2017, the Charity Commission opened a consultation on the rules that govern charities which promote complementary and alternative medicine. This is my response.
I have decided to publish it here both as a permanent record of my response, and as an explicit waiver of my right of anonymity in the survey.
If you want to get involved with the consultation, it's at www.gov.uk/government/consultations/setting-the-mandate-to-nhs-england-for-2016-to-2017 and is live until 23 November 2015, so you don't have much time.
Here's my response to the survey, shorn of all formatting:
Here are my responses to the questions posed in your consultation document " The use and promotion of complementary and alternative medicine: making decisions about charitable status":
Question 1: What level and nature of evidence should the Commission require to establish the beneficial impact of CAM therapies?
However we label something claiming to be a medical treatment (whether complementary, conventional, alternative, integrative, or anything else), the nature of acceptable evidence should be the same. We should have robust evidence that the treatment is beneficial and has a significant positive balance of benefit over risk. This should be based on good quality independent clinical trials. Where a treatment is new, there may be less evidence, so we should take that into account, but its proposed mechanism of action should have good prior plausibility.
Question 2: Can the benefit of the use or promotion of CAM therapies be established by general acceptance or recognition, without the need for further evidence of beneficial impact? If so, what level of recognition, and by whom, should the Commission consider as evidence?
No. Long-standing usage is no guarantee of effectiveness. Traditional treatments are no more likely to be effective than new ones, and must be held to the same standard of evidence. Interventions that have been around for a long time and yet still have no good evidence of effectiveness should be viewed with particular rigour.
Question 3: How should the Commission consider conflicting or inconsistent evidence of beneficial impact regarding CAM therapies?
The evidence for a therapy should show a clear positive balance of benefit over risk. Where the evidence is conflicting, this means that there is not sufficient evidence to recommend the treatment. The default assumption should be that an intervention is not beneficial unless positively shown to be so, rather than the other way around. In judging the balance between different sources of evidence, it is very important to consider the quality and independence of the source. A small trial conducted with poor methodology should be weighted less heavily than a large independently-run trial with good methodology.
Question 4: How, if at all, should the Commission’s approach be different in respect of CAM organisations which only use or promote therapies which are complementary, rather than alternative, to conventional treatments?
Even when applied alongside conventional, proven therapy, a complementary therapy must pass the same tests for effectiveness as a stand-alone therapy. In each case, medical claims are being made and good evidence must be provided.
Question 5: Is it appropriate to require a lesser degree of evidence of beneficial impact for CAM therapies which are claimed to relieve symptoms rather than to cure or diagnose conditions?
Again, the same standard of evidence should apply. Symptomatic relief is important, and if poor quality evidence is used, patients will not be getting the benefit claimed for the treatment.
Question 6: Do you have any other comments about the Commission’s approach to registering CAM organisations as charities?
This consultation is very welcome. It shows that the Commission is serious about ensuring that the reputational and financial benefits of being a registered charity should be granted only to those who can show a genuine societal benefit for their work. Good quality evidence is an important part of the vetting process, especially so for medical charities where poor treatments can cost lives. To repeat myself one more time, any application from an organization describing itself as a medical charity should be subject to the same standards of evidence. I think that the Commission needs to ensure that the required standards are codified, reviewed, and enforced impartially across the board. CAM medicines should not be allowed to bypass these requirements by special pleading. After all, the diseases themselves don't have special exemptions.
Many thanks in advance for your consideration.
Sean Ellis [Address redacted]