CONTINUING THE PHILOSOPHY OF REGINALD O. KAPP

9.51 IMPROVING PUBLIC HEALTH BY INTELLIGENT COMMISSIONING OF NICE-RECOMMENDED COMPLEMENTARY THERAPY AND DECOMMISSIONING OF HARMFUL DRUGS


Paper for commissioners of Health and Social Services                                         1.7.10
By John Kapp, Local Involvement Network (LINk) member for Sussex on the National Association of LINk Members (NALM)
johnkapp@btinternet.com           01273 417997


Contents

1 Summary of conclusions - NHS should decommission non-evidenced-based drugs, and commission NICE-recommended complementary therapy
2 Recommendations that can be implemented by intelligent commissioners on their own authority straight away, with the law behind them
3 Recommendations that government should do to improve patient safety
4 Recommendations that Department of Health (DH) should do to improve patient safety
5 Removing health inequalities by integrating complementary therapy
6 Obstacle 1 The vested interest of the drug companies.
7 Obstacle 2 Smear campaign against complementary therapy by the drug lobby.
8 Obstacle 3 The body is a ‘chemical machine which needs fixing with drugs’.
9 Obstacle 4 Politicians buy magic bullets (indulgencies) on our behalf for our own good with our taxes.
10 Obstacle 5 The drug lobby denies the harm that drugs are doing.
11 Obstacle 6 Complementary therapy is holistic, not mechanistic.
12 Obstacle 7 NICE recommendations for complementary treatments are advisory, not mandatory.
13 Obstacle 8 Paying the complementary therapists for providing these treatments.
14 Obstacle 9 Clinical Governance arrangements.
15 Obstacle 9 Lack of NICE-recommendations for other complementary therapies.
16 Conclusion – all these obstacles can be removed or bypassed.
17 References

1 Summary of conclusions – NHS should decommission non-evidenced-based drugs, and commission NICE-recommended complementary therapy

In a historic debate at its annual conference on 29.6.10, the British Medical Association (BMA) overwhelmingly endorsed the principle of evidence-based medicine, namely that if treatments have been shown scientifically to be no more effective than placebo they should not be publicly funded. They recommended the decommissioning of homeopathy, thereby saving the taxpayer £152,000 pa.

That decision is a good example of ‘intelligent’ commissioning, and this paper recommends the extension of the principle of intelligent commissioning to drugs (such as antidepressants) and NICE-recommended complementary treatments. These include spinal manipulation by chiropractic, osteopathy, and acupuncture and Alexander technique for low back pain, and the Mindfulness Based Cognitive Therapy (MBCT) course for depression. Low back pain and depression take up two thirds of GP consultations.

All the necessary legislation is already in place for intelligent commission to be implemented by commissioners on their own authority without delay. This was blocked during the last Labour government before 6.5.10 by the top-down bureaucracy of the Strategic Health Authorities (SHAa) and Primary Care Trusts (PCTs) They contained officers named Mr Ivor Snagge, the Abominable No-Man of Parkinson’s law, who obstructed progress in favour of business as usual and jobs for the boys, under a trade union led government.

The new Health Secretary (Andrew Lansley) has announced that all this bureaucracy is to go, to allow GP and Patient Based Commissioning (GPPBC) to create a progressive patient-centred NHS. This paper shows how intelligent commissioners can improve the public health of their communities dramatically, halving the present appalling statistics at half the cost to the taxpayer by 2020. It is now up to them to just do it.

2 Recommendations that can be implemented by intelligent commissioners on their own authority straight away, with the law behind them

a) Commissioners should decommission treatments that have been scientifically shown not to work better than placebo, and which have harmful side effects making them iatrogenic (doctor-induced sickness) such as anti-depressant drugs like Prozac (1) unsafe anti-psychotic drugs (2) and futile end-of-life interventions (3)

b) Commissioners should commission National Institute for Clinical Excellence (NICE) recommended complementary therapy.

c) Commissioners should fund (or justify refusal for) existing NICE-recommended complementary treatments for low back pain (spinal manipulation by chiropractic, osteopathy) acupuncture and Alexander Technique, and Mindfulness Based Cognitive Therapy (MBCT) courses for depression. (4)

d) Commissioners should contract with complementary therapy providers such as Social Enterprise Complementary Therapy Company (SECTC) to provide these treatments. (5)

e) GPs and therapists offering NICE- recommended treatments in Brighton and Hove should register with SECTC for vouchers with which to pay for these complementary treatments. (6) Other towns should replicate this scheme.

3 Recommendations that government should do to improve patient safety

a) Government should fill the ‘democratic deficit’ in health by making NHS commissioners responsible and accountable to elected Local Authority councillors (in common with Social Care and Education) This has already been pledged, and should be enacted as soon as possible.

b) Government should label all drugs (prescription and over-the-counter) ‘This is a drug which could seriously damage your health. You take it at your own risk. Read the Patient Information Leaflet before taking, and minimize your dependence on it.’

c) Government should make NHS commissioners part of the regulatory system for health, and remove their present financial conflicts of interest, by separating them as ‘gamekeepers’ to ‘arms length’ from healthcare providers, (poachers) such as hospitals, on the model of OFTEL, OFGAS, OFGEM etc (5)

d) Government should adopt a target by 2020 of halving the national sickness from work rate from 3.3% to 1.7% by promoting the holistic, systemic model of health promotion and sickness prevention advocated in this paper.

e) Government should promote good nutrition to improve staff health in hospitals and clinics, and all public service institutions. This can be done by setting up community wellness clubs in all departments. These could be lunch clubs to ensure that staff have a break and a nutritious lunch, so that they do not run out of steam in the afternoon. (7)

4 Recommendations that Department of Health (DH) should do to improve patient safety

a) Department of Health (DH) should adopt a target by 2020 of reducing the NHS sickness rate to 50% below the national average rather than its present 50% above. (namely to 1%, which is a 5 fold decrease) by promoting the holistic, systemic model of health promotion and sickness prevention advocated below. (8) If the NHS cannot keep its staff healthy, what chance have patients?

b) DH should redefine the job of NHS commissioners as: ‘to specify in detail in their Annual Operating Plans (AOP) and Strategic Commissioning Plans (SCPs) a detailed list of which and how many treatments, at what tariff price, they commit to pay for out of taxation in the coming years.’ This will enable providers (existing and potential) to plan to provide those treatments in the most cost-effective way. (9)

c) DH should require all members of all publicly funded regulatory bodies, research institutes, trust hospital boards, advisory bodies, commissioners, and other such bodies to hold their meetings in public, abide by the Nolan principles, and declare their financial conflicts of interest, including their association with drug companies, at every meeting.

d) DH should set a target of reducing the numbers dying in hospital (bedblocking) by a factor of 3, by 2012 by promoting Advance Decision forms (formerly advance directives, living wills) for terminally ill patients to indicate their end-of-life wishes (rescusitation, antibiotics, ventilation, drip feeding, dying at home) (3)

e) DH should remove the GPs per capita payment for vaccinating children, which pays doctors at taxpayers expense to risk harming children with conditions such as autism and asthma, and breaking their Hippocratic oath.

f) DH should require parents who want doctors to vaccinate their children to sign a consent form which warns: ‘This vaccination could seriously damage your child’s health. You take it on behalf of your child at your risk, and the risk to your child’s future health.’

g) The DH should clarify the difference between treatments ‘recommended’ by the National Institute for Clinical Excellence (NICE) by a Technical Appraisal Guidance (TAG) which are mandatory for being commissioned, and a Clinical Guidance (CG) which are advisory for commissioners to take into account when deciding which treatments to commission. This clarification should state that decisions not to provide NICE-recommended treatments by CGs: ‘have to be made rationally following a proper consideration of the evidence. If the commissioner decides not to fund a treatment, then it should explain that decision in a public document.’ (10)

h) NICE should evaluate traditional Chinese medicine (shiatsu, Chinese herbs, acupuncture, etc) and traditional Indian medicine (Ayurveda) and other complementary therapies, so that those which are found to be cost-effective and recommended can be commissioned and funded by the NHS to the benefit of patients. (24)

5 Removing health inequalities by integrating complementary therapy

In his speeches in early June, the Health Secretary (Andrew Lansley) has effectively said that the new coalition government will make the NHS patient-centred and give it to its patients and GPs jointly under GP/Patient Based Commissioning. The middle layers of bureaucratic management (commissioners) in Primary Care Trusts (PCTs) and Strategic Health Authorities (SHAs) are to be abolished, and with them the top-down control of public funding of treatments which resulted in patients and GPs having Hobson’s choice of drugs or drugs. (one poison or another)

Complementary therapy prevents as well as cures sickness, because it addresses the root cause in the mind and emotions. The Darzi/Boorman recommendations were endorsed by the last government, and require the NHS to prevent sickness in their patients and staff, as well as treat it. (8)

Half of all GPs now recommend their patients to have complementary therapy (9) but the patient has to pay for it. Most patients cannot afford it, which is the cause of health inequalities. The Marmot inquiry (published Feb 2010) said that deprived people suffer from long term conditions on average 18 years earlier, and die 9 years before affluent people. (12) All political parties pledged to remove health inequalities in their election manifestos, and this can be done by integrating complementary therapy into the NHS.

Polls say that 3 out of 4 patients want complementary therapy free on the NHS. (11) As patients pay for the NHS in their taxes, they should be given that choice. GPs should be able to prescribe it for their patients as they do with drugs and surgery, and the treatment should be free at the point of use to the patient.

The NHS constitution came into law last January, and gives patients the right to treatments that have been recommended by the National Institute for Clinical Excellence (NICE) if their doctor says it is clinically appropriate. The implication of this new patient right is that NICE-recommended treatments will be free at the point of use, and that the therapist will be paid for providing it, as if they are therapists providing conventional treatment. The following complementary treatments are recommended by NICE:

a) Spinal manipulation by chiropractic, osteopathy, and acupuncture and Alexander Technique, for low back pain, under Clinical Guidance (CG) 88 (dated May 09)

b) The Mindfulness Based Cognitive Therapy (MBCT) course of 8 weeks for depression, under CG 23 (Dec 2004) and CG90 (April 09)

It should be simple to achieve provision of these treatments to patients free on the NHS, since the law is in place to do this. However, there are many perceived obstacles in the way, as described below. However, obstacles are there to be overcome or bypassed, and none of them should stop intelligent commissioners from implementing them right away.

6 Obstacle 1 The vested interest of the drug companies.

Up until now, the drug companies have had a monopoly of public funding for NHS treatments, and patients have had Hobson’s choice of drugs or drugs. The top 10 Fortuna 500 companies are drug companies which make a combined profit ($35bnpa) exceeding the combined profit of all the other 490 companies. (13) Where did these profits come from? Taxpayers, because the governments of the world allow drugs a monopoly in public health provision, to the exclusion of its competitor - complementary therapy.

The drug lobby uses its wealth to buy the corridors of power throughout the world, including the medical profession, the public health services (such as the NHS) the health insurance companies, the scientific and medical research institutions, the health regulatory bodies, and the media. (13) Its vested interests maintain its monopoly with propaganda. As Goebells said, a lie repeated often enough is believed.

Big Pharma maintains its monopoly by:

a) Smearing its competitor (complementary therapy)
b) Pretending that the human body is a chemical machine which needs fixing with drugs.
c) Persuading politicians to spend our taxes on drugs to make us healthy for our own good without our consent, like indulgencies of old.
d) Denying the harm that drugs are doing to our health.

Do drugs work to improve public health? No. Overall they do more harm than good. The more a nation spends on drugs (poisons) the sicker its citizens become. Iatrogenesis (doctor-induced disease) has become the largest killer in the USA, (14) and the third largest killer (after heart disease and cancer) in the UK (15) Vaccination has been linked to 1 in 10 children now being asthmatic, and 1 in 100 being autistic. (16) No wonder the western world has run up the largest financial deficit in history.

However, the drug lobby’s lies are gradually being rumbled, and the evidence that they produce in support of their claims is looking increasingly shaky. For example Pfitzer was fined $2.3 bn in Oct 2009 for deceipt. There is suspicion that the swine flu epidemic of the summer of 2009 was a fabrication of the drug lobby to sell vaccines. Governments were persuaded to buy vaccines and mandatorily vaccinate all their public sector workers. However, many workers complained of being harmed, and half refused it. Governments were left with millions of unused doses, and big bills. The German government raised the issue in the European parliament under the banner: ‘schweinerei mit der Grippe’ (swinish scandal with the flu) A EU public inquiry into it was announced on 10.1.10 which could impose bad press and a punitive fine.

Dr Andrew Wakefield is a scientific researcher who has being investigating vaccinations for 2 decades. His article in the Lancet in 1998 reported a possible link between autism and the MMR vaccine. After a 3.5 years hearing he was struck off the register by the General Medical Council on 24.5.10. He has since said publicly (17) that this is a smoke screen to cover up the UK government licensing an unsafe MMR vaccine in 1998 which had to be withdrawn in 2002 after children got meningitis. He has published a book called ‘Callous disregard.’ It is also said (17) that 1 in 40 boys and 1 in 125 girls suffer adverse reactions from vaccinations. 1 in 100 children vaccinated since 2005 are said to have autism, and 1 in 10 have asthma. (16)

It is time to consign the non-evidenced –based part of the 20th century drug industry to the bin of history, where it can join 19th century blood letting.

7 Obstacle 2 Smear campaign against complementary therapy by the drug lobby.

Over the last few years there has been an attack on complementary therapy, saying that there is no evidence that works, so it should not receive any public funding. It is thought to be orchestrated by the drug lobby, as they have a vested interest in smearing their only competitor.

Prof Edzard Ernst is chair of complementary therapy at Exeter University. Together with Simon Singh, they wrote a book in 2008 called: ‘Trick or Treatment – Alternative Therapy on Trial’. It is a damning condemnation of virtually every complementary therapy, see my reviews of it. (18). In it they say ‘There is no evidence whatsoever for a life force’ (p104) There are none so blind as won’t see. For the last 2 years Simon Singh has been involved in a libel case against the General Chiropratic Council concerning claims about what chiropractic treatment can cure. He won, but it has cost him £200,000 in costs.

Homeopathy has been accepted as a healing modality in UK for the last 150 years. There are 5 homeopathic hospitals in the UK which have co-existed peacefully within the NHS since it was founded in 1948. However, as a result of the recent attack on homeopathy, the Tunbridge Wells hospital has been forced to close last year. The Parliamentary Select committee considered homeopathy and reported in April 2010 that there is no evidence that the remedies work better than placebo.

Until 29.6.10 the British Medical Association (BMA) had no official policy on homeopathy. On that day their annual conference debated whether the NHS should spend taxpayers money on it. The remedies (unlike drugs) are not provided free on the NHS. Doctors are not allowed to prescribe them, but they are allowed to suggest that their patients try it under the acronym: ‘TEETH’, (Tried Everything Else Try Homeopathy) However, the patient has to pay for the remedy themselves at the chemist. DH said that the total NHS spending on homeopathic medicines is £152,000pa.

After an hour-long emotional debate, with many who wanted to speak against the motion not being called, the following resolution was adopted as official BMA policy by a majority of about 3 to 1 in favour by electronic voting:
'This Meeting believes that, in the absence of valid scientific evidence of benefit:

1 There should be no further commissioning of, nor funding for, homeopathic remedies or homeopathic hospitals in the UK
2 No UK training posts should include a placement in homeopathy.
3 Pharmacists and chemists should remove homeopathic remedies from shelves indicating they are 'medicines' of any description, and place them on shelves clearly labelled 'placebos'.'

The BMA made history at that debate by standing up for the principle that only evidenced-based treatments should be funded by the taxpayer. That principle should of course also be applied to conventional treatments, such as anti-depressants. These too have been shown in meta-studies to be no better than placebo. (1) Sauce for the goose (homeopathy) should be sauce for the gander (antidepressants) which have the added detriment of having harmful side effects from which homeopathy is free. Anti-depressants should not be funded by the taxpayer, so should therefore be decommissioned.

The same principle should apply to all drugs and interventions which do more harm than good, (ie iatrogenic, doctor-induced sickness) which is thought to be about half of conventional treatments, including vaccinations. Throughout the 20th century these have been strongly suspected of being linked to harming children, such as autism affecting 1:100, and asthma affecting 1:10 children vaccinated since 2005. (16)

If all iatrogenic interventions were de-commissioned, there would be a double benefit to society. Iatrogenic harm would be prevented, removing the biggest cause of sickness, and halving the cost to the taxpayer. Public health would be doubled at half the cost, but it might take until 2020 to fully manifest this.

8 Obstacle 3 The body is a ‘chemical machine which needs fixing with drugs’

Why should homeopathy be such an emotional subject that doctors threatened to resign if the BMA passed the above motion? The reason is that all complementary therapies challenge the 3 century old Descartian medical model of the person as a machine. Machines cannot fix themselves, but have to be fixed by doctors, who are superior, indispensable, up on a pedestal. Patients have tended to go along with this belief because it lets them off the hook of having to take responsibility for their own health, and it gives them someone to blame when things go wrong, which they frequently do.

The justification for the efficacy of drugs rests on the paradigm (unspoken, underlying belief system idea) that our body is a chemical machine, and the cause of sickness is our body’s chemistry being wrong. Aspirin was the first manufactured drug, just before 1900, and the 20th century became the century for drugs throughout the western world. The industry now sells pills and vaccines in vast quantities to most of the entire world.

9 Obstacle 4 Politicians buy magic bullets (indulgencies) on our behalf for our own good with our taxes

Looked at rationally that paradigm is absurd. The human race survived for millions of years without drugs before 1900. Animals in the wild are healthy without drugs. The healthiest year of the British nation was 1944 when the civilian population got practically no healthcare. (20) To explain how the western world could be conned into believing this lie, we have to look at the 19th century, when the paradigm preached from almost every pulpit was: ‘we are all original sinners, who have done those things which we ought not to have done, and left undone those things which we ought to have done, and there is no health in us.’

Drugs were (and still are) marketed as magic bullets which make us healthy by taking away our sickness (caused by our sins). If the first drug makes us sick with side effects, doctors have a second drug to remedy them, and a third drug to remedy the side effects of the second, and so on. Half the UK adult population are now taking a cocktail of drugs for the rest of our lives. The USA used to be called the ‘Prozac nation’, and the label has spread to the UK. (21) This is great for medical businesses, but not for the patients who take the drugs, or the taxpayers who pay for them.

Why do politicians fund these drugs out of the taxes that we pay? The drug company lobbyists tell them that they are thereby improving the health of the nation. Unfortunately the nation is not obliging, but getting ever sicker. The lobbyists have an explanation. Patients are not taking the right pills, or not enough of them, and the industry needs to develop better pills. Slogans such as ‘we will not stop until we beat cancer’ are presently on hoardings in the London Underground. This idea flatters the ego of the people with the comforting idea that cancer can be beaten, and creates a populist lobby to persuade politicians to vote more public money in one last heave to find the magic bullet to beat cancer.

Sub-consciously, politicians are using our (taxpayers) money for our own good to buy indulgencies to make us healthy by taking away our sickness (sins) This was the issue that Martin Luther was protesting about over 5 centuries ago, and led to the breaking away of the Protestants from the Catholic Church. It was also the source of the wealth of the monasteries which Henry VIII dissolved. What goes around, comes around.

10 Obstacle 5 The drug lobby denies the harm that drugs are doing.

Doctors sign a Hippocratic oath ‘do no harm’, but all drugs have side effects which harm some people, so by prescribing drugs and vaccinating children doctors are breaking their oath. The drug lobby pontificate to absolve this sin by saying that it is a ‘peccadillo’ a little sin that doesn’t matter. It is only a minority of people who are harmed, and that harm is more than outweighed by the good that drugs are doing to the majority of users.

Take for example, vaccination, which the drug lobby tells us has eradicated many horrible diseases. However, there is another possible explanation. Sanitation, sewerage, potable water supplies, refrigeration, came in at the same time as vaccinations, and the improvement in public health could be due to that, not vaccination. There is now increasing evidence that vaccination is iatrogenic, and does more harm than good. (16)

However, to imply that doctors sometimes harm patients (iatrogenesis, doctor-induced disease) is not politically correct, but taboo. It is like implying that Catholic priests sometimes abuse children. Both are skeletons in the cupboard, which people do not want to admit has been happening. Many people have been blowing the whistle against vaccination for decades, such as Dr Andrew Wakefield, (see paragraph 6 above). The media seem to have imposed a conspiracy of silence about iatrogenesis. However, no-one can silence the internet, and the truth eventually reveals itself despite the wealth and power of the Catholic church and the drug companies.

11 Obstacle 6 Complementary therapy is holistic, not mechanistic

Complementary therapy is holistic, which is a different paradigm to the chemical machine. It recognises people as comprising, not just of a body, but also a mind which controls the body, and a spirit, which gives life (incarnate) to both mind and body. This is the paradigm underlying all religions, and is believed by practically everybody, Profs Richard Dawkins, and Edzard Ernst excepted, who doesn’t even believe in life.

To understand what is meant by holism, we need to expand the machine metaphor to a computer system. The body is the hardware, the mind is the software, the soul is the operator and the spirit is the internet. Other words for spirit are life force, (the motivator, ‘as the spirit moves us’ in Quaker meetings) chi in traditional Chinese medicine, prana in Sanscrit (the basis for yoga and the Ayurvedic (meaning ‘science of life’) Indian system of medicine, and the ‘innate intelligence’ in chiropractic. Science recognises life in the word ‘biology’ meaning ‘word of life’, from ‘bio’ (life) and ‘logos’( word) in greek.

Patients generally do not care about paradigms, as long as the treatments that they get on the NHS work to cure their conditions. Unfortunately, drugs do not do this, but only mask their symptoms. The National Institute for Clinical Excellence (NICE) is the government appointed body to decide which treatments are both evidence-based and cost-effective, so that they are authorised by the government to be publicly funded for use in the NHS by commissioners. The 5 complementary treatments listed in paragraph 3 above are NICE- recommended, but unfortunately not recommended enough.

12 Obstacle 7 NICE recommendations for complementary treatments are advisory, not mandatory.

The above 5 complementary treatments are hardly ever provided free to patients on the NHS, despite being authorised by the NHS constitution and DH via NICE. This is because of a technical loophole that the NICE recommendations are only advisory, not mandatory.

A footnote in the NHS constitution says: ‘Recommended’ means recommended by a NICE technology appraisal. Primary care trusts are normally obliged to fund NICE technology appraisals from a date no later than three months from the publication of the appraisal.’ The above NICE-recommended treatments are recommended by a Clinical Guideline, (CG) not a Technological Appraisal Guideline (TAG) so they are advisory, not mandatory (10)

Because they are not mandated to commission these treatments, the commissioners ignore the fact that they are advisory, and treat these NICE guidelines as if they did not exist. However, the DH say that NICE-recommendations ‘should be taken into account by healthcare professionals when planning care for individual patients.'(10) Furthermore decisions not to provide NICE-recommended treatments have 'to be made rationally following a proper consideration of the evidence. If the local PCT decides not to fund a treatment, then it should explain that decision.’ (10)

These treatments are hardly ever provided free to patients in Brighton and Hove. This proves that the PCT have not taken these NICE-recommended treatments into account when planning care for individual patients. For example, the MBCT course for up to 20 patients is said (22) to have been provided up to 4 times pa (total up to 80 places pa) by the sole provider (Sussex Partnership Foundation Trust SPFT) of mental health services for the whole of Sussex with a population of 1.5 million. Furthermore, the commissioners have not published any explanation of their decision not to fund these treatments, in spite of nearly 2 years of continuous requests by the writer.

While the SHA and PCTs commissioners remain in post, the Department of Health should instruct them to follow the above NICE rules, and make a proper rational consideration of the evidence for those treatments, and either decide to fund them, or publish their explanation justifying why they are not funding them. When GPs take over commissioning jointly with their patients, these treatments will have to be funded because some of their patients will request them.

13 Obstacle 8 Paying the CT therapists for providing these treatments

At present there is no administrative arrangements in place for paying for those treatments. However, the following scheme has been proposed by the writer under the innovation initiative launched by Lord Darzi at the Innovation Exhibition in the Excell Centre in London in June 2009. (23)

A new company to do this has been set up by the writer, called Social Enterprise Complementary Therapy Company (SECTC) The company will print £50 vouchers for these treatments and give them to GPs who register with the company. The GP will give them to the patients, who can trade them for the NICE-recommended treatment with any of the registered therapists listed on the back of the voucher. The proposed registration forms and vouchers are shown in reference (6)

If the commissioners decide to commission and fund these treatments, they should negotiate a service level agreement contract with SECTC (or other prospective provider of complementary therapy) to provide these treatments.

14 Obstacle 9 Clinical Governance arrangements

As taxpayers money is to be used to fund these treatments, the commissioners should see that proper clinical governance arrangements are in place to protect the patients against ‘cowboy’ practitioners, who are insufficiently trained and qualified to provide these treatments. Therapists who are publicly paid should be registered with a recognised qualifying body, and the premises in which they treat the patient should be subject to regulation and inspection that they are fit for purpose, as with GP surgeries.

The providers (such as SECTC) should be responsible to the commissioners to enforce these matters. The following regulatory arrangements are in place for the above treatments. Chiropractors and osteopaths are state registered with the Health Professions Council, costing a registration fee of £1,200 pa. Acupuncture, Alexander Teachers and Yoga Therapists (for meditation) are regulated by the Complementary and Natural Healthcare Council (CNHC) costing a registration fee of £45 pa.

GPs should register with SECTC (or similar bodies) to provide vouchers, and complementary therapists should register with SECTC (or similar bodies) to provide those treatments in exchange for vouchers. (6)

15 Obstacle 9 Lack of NICE-recommendation for other complementary therapies

The above NICE recommended treatments are for the commonest ailments (low back pain and depression) which collectively account for 2 out of 3 GP consultations. These have achieved the gold standard of evidence, having been proven safe and cost effective by achieving NICE-recommendation.

However, there are many other complementary therapies which have not yet been adjudicated by NICE, including whole systems of medicine, such as traditional Chinese medicine, and Ayurveda, which is traditional Indian medicine. They have an evidence base of efficacy going back thousands of years. They and others should be evaluated by NICE so that if recommended they can be commissioned and funded by the NHS in future.

The evidence that matters is not what Prof Ernst thinks, but what the patients’ experience is. If they work for a representative sample of patients, then they should be funded by the NHS, as the patients pay for the NHS through their taxes. Complementary therapy passes the test of the market place, playing uphill against free drugs on the NHS. To get a healthier nation we have to change from drug-based treatments, to complementary treatments which are meditation-based, addressing the causes of sickness in the mind.

16 Conclusion – all these obstacles can be removed or bypassed

Others are saying similar messages to this paper, such as the NHS Alliance in their paper: ‘Whose NHS is it anyway’, launched at the House of Lords on 30.6.10, and endorsed by Earl Howe, Minister of Health (25) If commissioners follow the recommendations in paragraph 2, decommission treatments which do more harm that good, and commission complementary therapies which have been recommended by NICE, by 2020 the UK could be twice as healthy, at half the cost to the taxpayer.

17 References

1 ‘News report ‘Prozac Doesn’t Work’ Feb 2008, and Times article about all antidepressants not working better than placebo, 14.6.10
2 Report for government on Dementia by Prof Banajee, Oct 09, saying that 1,800 patients are killed each year by antipsychotic drugs.
3 Paper ‘Better Planned and Managed Deaths at Home’ by John Kapp 9.47 of www.reginaldkapp.org and Paper: ‘Reducing the numbers dying in hospital bedblocking’ by John Kapp 9.24 of www.reginaldkapp.org
4 Paper ‘Meeting with NHS commissioners 11.3.10’ by John Kapp 9.48 of www.reginaldkapp.org and Business Plan of Social Enterprise Complementary Therapy Company (SECTC) 9.39 www.reginaldkapp.org
5 Paper ‘Creating User-Centred Services – A Mission for LINks to make extinct Provider-Centred Dinosaurs’ by John Kapp 25.6.09 9.37 of www.reginaldkapp.org
6 Letter to GPs and voucher dated 16.6.10 ‘Invitation to register to provide free NICE-recommended complementary therapy to your patients’. 9.50 of www.reginaldkapp.org
7 Community Wellness Clubs, Community Wellness Clubs
8 Paper ‘Where is the evidence? A level playing field for public funding of conventional and complementary treatments’ by John Kapp 9.44 of www.reginaldkapp.org
9 Paper ‘Removing the obstacles to the integration of CAM’ John Kapp 9.45 of www.reginaldkapp.org
10 Letter dated 17.6.10 from Natalie Whelan, Communications Executive NICE and Letter dated 22.6.10 from Alex Demetris of Customer Service Centre, Department of Health to SECTC in reply to SECTS letter of 5.6.10
11 Foundation for Integrated Health fihealth.org.uk
12 Report on ‘Prevention and Health Inequalities Conference’, and Marmot inquiry, at the Kings Fund, 30.3.10 paper 9.49 of www.reginaldkapp.org
13 Book ‘The Truth about the Drug Companies’ by Dr Maria Angell, 2010
14 Report by Dr Gary Null shows that 800,000 Americans are killed each year by adverse drug reactions and other mistakes, compared with 700,000 who die from heart disease. garynull.com
15 ‘TV documentary Nov 2000, ‘Why Doctors Make Mistakes’ showed that 40,000 people pa un UK were killed by doctors mistakes
16 Article ‘Could Mercury Be In Vaccines Specifically because It Is Deadly, Not In Spite of It?’ by Paul G. King, PhD, President of CoMed, Mercury-free Drugs , Health freedom USA
17 Report of Dr Andrew Wakefield’s first media interview after being struck off, on BBC Radio Sussex on 21.6.10 taped and available from John Kapp
18 Reviews of ‘Trick of Treatment – Alternative Therapy on Trial’ by Prof Ernst and Singh by John Kapp 9.26 of www.reginaldkapp.org
19 Report published during NHS diamond jubilee celebrations, June 2008 reported on the radio about 1944 being the healthiest year of the 20th century.
20 Letter from John Rosser SPFT to Brighton and Hove LINk dated 9.11.09 in response to their question dated 12.10.09.
21 Patricia Hewitt (Health Secretary) speech to a mental health conference in May 2006 was headlined ‘The End of the Prozac Nation’.
22 Paper ‘Integration of CAM into the NHS via Social Enterprise companies’ by John Kapp 9.38 of www.reginaldkapp.org
23 Paper Integration of CAM into the NHS via Social Enterprise Complementary Therapy companies, 9.38 of www.reginaldkapp.org
24 Paper ‘Proposed Clinical Trial of Astrology as a diagnostic tool in the NHS’ dated 2.1.10 9.42 of www.reginaldkapp.org
25 Paper ‘Whose NHS is it Anyway? nhsalliance.org

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