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Mote Prime > Politics

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

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]