by John Kapp, secretary of
Brighton and Hove Social Enterprise Complementary Therapy Company (SECTC) group
22, Saxon Rd Hove BN3 4LE 01273 417997,
Published as paper 9.39 on 13.12.09/24.5.10


Part 1 describes the essence of the proposal in 16 paragraphs and 14 pages.
Part 2 is the budget of estimated costs from 2009 to 2016 in 4 pages.
Part 3 is a draft constitution for the company in 2 pages.
Part 4 is an analysis of Strengths, Weaknesses, Opportunities and Threats (SWOT) of the proposal in 10 pages.
Part 5 is a list of the names, addresses and contact details of 130 existing CAM centres in the city, extracted from the Yellow Pages, in 7 pages.
Appendix 1 Draft of what we would like to see in the NHS Strategic Commissioning Plan for Brighton and Hove 2010-14.
Appendix 2 Open letter to NICE dated 5.6.10 requesting adjudication of our dispute with NHS commissioners, with copy to The Secretary of State for Health (Rt Hon Andrew Lansley MP).


by John Kapp., 22, Saxon Rd Hove BN3 4LE 01273 417997,
John is secretary Brighton and Hove Social Enterprise Complementary Therapy Company (SECTC) group. He is a member of the Local Involvement Network (LINk) and the elected member of the steering group of the National Association of LINks Members (NALM) representing Sussex. He is a former consulting engineer economist and councillor who has been a patient representative since 2000. In 2002 he founded an alternative therapy centre opposite Hove town hall called Planet Janet, now called Revitalise. Comments on this business plan by e mail or phone are welcome.

The SECTC group is open to all, and has been holding monthly public meetings since July 09 to develop this proposal. A committee was elected at an AGM on 4.1.10. Monthly open committee meetings are held on the second Monday of the month at Revitalise café, opposite Hove town hall. Observers are welcome to attend and speak.


Executive summary
This is a business plan of a proposal for a pilot project to prevent sickness in the population (250,000) of the city of Brighton and Hove. A company has been created to provide safe, effective complementary and alternative medicine (CAM) free at the point of use on the NHS. We hope that in 2014, when the scheme is fully operational, 20% of the city’s NHS budget in 2010/11 - £456 mpa - will be diverted to prevention of illness, or £100 mpa. By 2016 when the scheme has been running for 3 years, we believe that the scheme will deliver a 50% improvement in public health at half the present cost of treatment. The total cost to the taxpayer will then be £345 mpa, which is a 20% saving on present NHS costs.

Ideally this scheme should be overseen by a new trust as part of the NHS commissioners, called a ‘Complementary Care Trust’ (CCT) to provide complementary care, as shown in the diagram below. The CCT will be like the Primary Care Trust (PCT) which provides primary care by contracts with about 50 GP practices. The CCT will commission a contract with the new Social Enterprise Complementary Therapy Company (SECTC) to provide free CAM on the NHS throughout the city. The SECT company will in turn contract with the existing 140 CAM centres to provide free CAM. Similar existing contractual arrangements are in place with the PCT to provide free dental care from dental practices, free ophthalmic care from opticians and free drugs from chemist shops.


The company will print £50 vouchers for CAM and give them to General Practitioners (GPs) Half of all GPs already recommend CAM to their patients, but the patient has to pay for it out of their own pocket. Whether they get the treatment or not depends on their ability to pay. Most people cannot afford it, which is the cause of health inequalities. Those who access the preventative benefits of CAM live an average of 9 years longer, and remain dis-ability free 18 years longer, as described in the Marmot report.

This scheme will remove this inequality, as free vouchers for free CAM will be given by the GPs to patients who could not otherwise afford it. The patients can cash the vouchers at any of the existing 140 CAM centres in the city (listed in part 5). The company has already started with stage 1. SECTC1 will provide only National Institute for Clinical Excellence (NICE)- approved CAM treatments, which must be commissioned and provided because all patients have a statutory right to them under the NHS constitution, which became law in Jan 2010.

These NICE-approved treatments are as follows:

a) For lower back pain (LBP) SECTC1 will provide courses of 12 sessions of chiropractic, osteopathy, acupuncture and Alexander Technique. We hope to build up by 2013 for 15,000 people pa, requiring 180,000 vouchers pa, worth £9 mpa.

b) For anxiety and depression, SECTC1 will provide the 8 week Mindfulness Based Cognitive Therapy (MBCT) courses, at £300 per course. We hope to build up by 2013, to providing 1,500 courses for 30,000 participants pa. This also requires 180,000 vouchers pa, worth a further £9 mpa.

The total turnover of SECTC1 in 2013 is hoped to be 360,000 vouchers pa worth £18 mpa. The average number of vouchers received by each CAM centre will be 2,500 pa, worth £130,000 pa in extra turnover.

Stage 2 (SECTC2) will be added when the commissioners agree to fund free generic CAM as chosen by the patient bearing the voucher. We believe that this should be a patient right under the NHS constitution, as patients fund the NHS through their taxes, so should be able to chose the treatment that suits them, as rich people now do. We hope that this will occur by 2013, and that from 2014 other CAM treatments will add a further 1,640,000 vouchers worth a further £82 mpa. SECTC will then supply 2 million CAM vouchers pa, worth £100 mpa. The average number of vouchers received by each CAM centre will be 14,000 pa, worth £750,000 pa in extra turnover.

We believe that by 2016 this scheme will transform public health in the city by halving the present rate of alcoholism, drug taking, smoking, suicide, long term conditions, hospital admissions and GP visits. These preventive treatments will halve the need for conventional treatment, and reduce the cost from £456 mpa to £245 mpa. Including the £100 mpa for prevention, the total cost of the National Health Service (NHS) in the city will be £345 mpa, a saving of 20% on present costs of £456 mpa. The target reduction in number of persons afflicted is shown in table 1.


Target number

Statistical number of people pa affected in city


(50% of 2009)


  Deaths from all causes pa




  Iatrogenis (doctor induced) deaths (note 1)




  Hospitalisation from iatrogenesis (a million people pa nationally)




  Deaths from suicide pa




  Drug users












  Clinically depressed








  Long term conditions




  Teenage pregnancies




  On disability benefit (2.5m nationally)




  Hospital admissions




  GP visits




  Deaths in preferred place (home)




  No of patients dying with living wills

  Hardly any



  Dementia patients killed by drugs (note 2)




  Staff off sick (note 3)



Part 1 The proposal

1.1 Purpose of this business plan
This business plan is a proposal to provide free complementary and alternative medicine (CAM) at the point of use, paid for by taxation, in the city of Brighton and Hove. Its purpose is to transform the public health and social care services of the city by integrating complementary and alternative medicine (CAM) into those services. It provides the means to manifest Prince Charles’ vision of integrated healthcare in his keynote address to the Health Ministers of the world at the World Health Organisation (WHO) conference in May 2006.

We have published this plan as we hope that it will be copied in other towns, so that the whole of the UK will integrate CAM into their NHS. We also hope that other countries will integrate CAM into their state public health and social care provision, so that Prince Charles’ vision may be manifest throughout the whole world.

1.2 Meeting government policy objectives
There is an old saying that an ounce of prevention is worth a pound of cure. Since the Darzi report of July 2008, it is now Department of Health (DoH) policy for the NHS to not only treat illness, but to prevent it, promote wellness, and empower people to take responsibility for their own health. This is a paradigm shift in DoH thinking, which to be effective requires a reallocation of resources from treatment to prevention. At present the NHS only spends 4% on prevention. The Marmot report calls for this to be nearly doubled to 7%.

We are calling for a 5 fold increase to 20%, by 2014, as a pilot scheme in the city of Brighton and Hove. We believe that thereby the best value for taxpayers money will be achieved, as by 2016 it will halve the cost of treatment, reducing the total cost of the NHS to 80% of the present spend.

Complementary and alternative medicine (CAM) has been delivering all these health benefits safely and effectively to those who do it regularly (say 3 hours per week). However, this costs £1,000-5,000 pa and only about 10% of the population can afford this. We believe that denial of these benefits to 90% due to their inability to pay is the cause of the health inequality in the nation. The Marmot inquiry recently (11.2.10) reported that people from deprived areas suffered 18 years more disability and died 9 years earlier than people from affluent areas.

Polls show that 3 out of 4 patients want CAM to be provided free on the NHS. As the public pay for the NHS in their taxes, patients should be given the choice of free treatment of their choice (conventional medicine or CAM). Half of all GPs already refer patients for CAM, but the patient has to pay for the treatment themselves, which few can afford. CAM is already being provided in hospitals to keep the staff from burning out, and to the unemployed to help get them fit for work.

All healthcare providers will have to produce Quality Accounts over the next few years. These focus on safety, effectiveness, and patient experience. CAM has been delivering these outcomes for decades, but only to the well-off 10%. CAM is safe because it is harmless. There have never been any iatrogenic (doctor-induced) problems with CAM (unlike conventional medicine, where in the USA iatrogenesis has become the biggest killer, see para 4.1c, below)

Although CAM is not a quick fix, it is usually effective in curing conditions, (unlike drugs, which usually just mask the symptoms) Patient experience is highly rated with CAM, as proved by the growing market for it. (Unlike the NHS where patient dissatisfaction is indicated by the number of patients suing, and the corresponding high cost of professional indemnity insurance)

The government are consulting on the Welfare Reform bill which wants to reduce the £100 bnpa cost of working-age ill health, and the 2.6 million now on incapacity benefit 40% of whom (1 million) have mental health conditions. People on benefit are from the most disadvantaged communities, and is structural unemployment disguised as disability. Stress, anxiety and depression are a significant cause of work related problems, and non-work related sickness absence. The government’s solution is the commissioning of outside providers (consortia of private companies) to support these people back into the workplace, and this proposal to provide free CAM in the community could provide the means by which that could be done.

1.3 Healthcare in the city of Brighton and Hove
The commissioners of public healthcare in the city are the Brighton and Hove NHS (the former Primary Care Trust PCT) They are planning to spend £456 mpa this year (2010/11). This is £1.2 m per day, or £1,800 pa for every man woman and child in the city, or £50 (the value of 1 CAM voucher) per head per day.

This sum is presently spent paying around 8,000 healthcare staff providing conventional treatments, but hardly any on prevention (education leaflets, quit smoking clinics, etc). The money goes to a few big providers, namely the Royal Sussex County hospital and other hospitals for free secondary care (£180 mpa), the Sussex Partnership Trust for free mental health services (£45 mpa), the Southdowns Health Trust for free community care, (£51 mpa) about 47 GP surgeries for free primary care (£43 mpa), 56 dental practices for free dental care (£11 mpa), 23 opticians for free eye care, (£1.6 mpa) 60 pharmacies for free drugs (£41 mpa) and the ambulance service (£8 mpa). (There is £76mpa missing from this list)

There are about 2,000 CAM therapists working in around 100 CAM centres in the city, and perhaps a further 2,000 CAM therapists working from home. Not being publicly funded, they only treat clients who can pay. The going rate for CAM is about £40 per hour for one-to-one therapy, and about £48 for 6 hours of classes of an hour per week. There are dozens of different CAM treatments. Centres and therapists are fragmented, unlike conventional medicine.

Because of this fragmentation, it is administratively impossible for NHS commissioners to pay public money for CAM because it comes in millions of penny packets. This proposal solves this problem by creating a social enterprise company which would be a bulk provider of generic CAM therapies throughout the city. The company would be a consortium of those CAM centres and therapists who voluntarily decide to join the scheme, (hereafter called ‘registered centres’) which we hope will be all 100 of them. (a list of 140 is given in part 5) Joining the company would be free, as the costs of the company would be paid by the NHS.

1.4 A company providing free CAM on the NHS
This proposal would create a new ‘Complementary Care Trust’ like the old Primary Care Trust (PCT) to expand the accessibility of CAM from the present 10% well-off, to every patient who needs it in the opinion of their GP. This would meet the DoH’s objectives of making evidenced based, safe, effective treatments freely available to all patients that need them, irrespective of their ability to pay, thereby improving health and preventing long term conditions from developing. It would remove the health inequality, and help unemployed people on disability allowance back to work.

Like the existing medical providers, the company would contract with the NHS commissioners. Technically the company would be an ‘Alternative Provider of Medical Services’ (APMS) and sign a Service Level Agreement (SLA) to provide CAM at all registered centres. The company would be like a brokerage agency, matching supply of CAM at CAM centres to demand for it from patients. A simple example of a brokerage agency is a cab company (say telephone 202020) whose staff takes calls from fares, relays them by radio to drivers and the nearest cab picks them up.

The company would enable free CAM provision to follow the existing model of free primary care provision from GP surgeries, free dental care provision from dental practices, free eye care provision from opticians, free drug provision from pharmacists. The company would provide this brokerage service by issuing free CAM vouchers (for say £50 worth of CAM) to GP surgeries. The GP would give patients the choice of the conventional treatment (a prescription for drugs or an operation) or a voucher for CAM. If the patient chooses the vouchers they would trade them for CAM treatment of their choice to the value of the vouchers at any registered centre.

Payment to the centres and therapists for treatments rendered would be administered as follows. Every month the centres would invoice the company for the value of the vouchers traded, and the company would invoice the NHS commissioners. The commissioners would pay the company, who would pay the centres, who would pay the therapists who did the treatments. This would be similar to how GPs, dentists, opticians, pharmacists and their staff are now paid. The public money for CAM would follow the patient, as the government legislation in 2006 enacted.

The company’s office would be located at an accessible location in the city. It would include a CAM advice centre, where patients can get free advice in person, by telephone or e mail. The managers would be knowledgeable about CAM and provide a gatekeeper service to advise patients which CAM treatments would be best for them, and which centre could provide it. They would also publish a directory both on a website and in hard copy, which patients could access on line and keep at home for reference.

It is sometimes said that there is no evidence that CAM works, and that CAM practitioners are not professional, but this is not generally true. If CAM did not work, clients would not pay for it. Some CAM therapies are approved by the National Institute for Clinical Excellence (NICE) Demand for CAM is growing despite playing uphill against free conventional medicine. Most CAM therapists are professionally qualified with qualifying bodies. Physiotherapy, osteopathy, chiropractic are state registered professions, and acupuncture and 12 other CAM professions are in process of applying for state registration. Regulation of CAM is not as important as in conventional medicine because the risk of harm with CAM is negligible.

1.5 Forecast benefits for 2014 if this proposal is implemented.
The budget (see part 2) for the company shows that in 5 years time, (2014) the company would have a turnover of £10 mpa and employ 156 staff. The NHS would have re-allocated £100 mpa of public money (22% of its £456 mpa health budget) to prevention. This would provide 2 million CAM vouchers pa at £50 per voucher for CAM therapies which are safe, effective and prevent long term conditions from developing, instead of drugs which are harmful, ineffective, and create long term conditions. Each of the 100 registered CAM centres would be getting 60 NHS patients per day bringing in 60 vouchers per day, worth £3,000 per day or £1 mpa. This would provide full time employment for about 20 additional therapists in each centre, supported by an equal number of additional administrative staff totalling 40 additional staff per centre.

The total number of CAM therapists supported in the city by this re-allocation of public money would be 4,000 full time equivalent jobs. Each of them on average would receive a salary from the public purse of £20,000 pa. These jobs would be fulfilling because they would be contributing to the wellbeing of everybody in the community, including the CAM therapists themselves. This contrasts to the jobs in conventional medicine, which have a high staff sickness and burnout rate (5%) which is 50% more than the national average (3.3%) because they know the futility of their treatments which don’t work.

We estimate that by 2014 these 2 million vouchers issued pa would be going to about 100,000 poorest and sickest people, who would get on average 20 vouchers each pa, giving them £1,000 pa worth of safe, effective treatments and health advice. This would half the present high and increasing rates of alcoholism, drug taking, smoking, suicide, and long term chronic illness which presently afflicts 1 in 3. Mental and physical health would generally be improved throughout the population, reducing by half the number of hospital admissions and GP visits. This would halve the cost of conventional medicine from £400 mpa to £200 mpa. The total cost of the NHS would then be reduced from £400 mpa in 2009 to £300 mpa in 2014. This scheme would thus deliver a 50% improvement in health in the city with a 25% saving in cost.

1.6 improvement in public health targets by 50% for the city by 2016
The Strategic Commissioning Plan for Brighton and Hove dated March 2009 is published on the NHS/PCT website. ( It is titled ‘Improving Health and developing World Class Healthcare in Brighton and Hove 2009-14’ and is about 110 pages. Not surprisingly CAM is not mentioned. It is the source of most of the following figures for 2009, (designated c for city) Other figures (designated n for national) are deduced from national statistics divided by 200, as Brighton and Hove’s population (250,000) is about 1/200 the of the national population (50 million for England and Wales, 60 million including Scotland and N.Ireland). We will ask the director of public health (Tom Scanlon) to confirm or correct these 2009 figures. Figures designated g are guesses as no statistics were available at the time of writing.

1.7 What is the evidence that free CAM will deliver these benefits?
No study has been done on providing free CAM for a whole city before, so this proposal could be regarded as a pilot clinical trial of the efficacy of free CAM on the public health of Brighton and Hove over 10 years. Our belief that a 50% improvement in public health outcomes is possible is based on our personal experience of CAM in our own lives, and that of our clients. Not many clinical trials have been done on CAM to date, but those that have been done indicate that a dramatic improvement is possible, such as ‘the MBCT course halved the rate of relapse of depressed patients over 5 years.’ (see paragraph 1.6ei)

We cannot prove that a 50% improvement will happen if this project is implemented, any more than the PCT can prove what they claim will be the outcome of their strategic commissioning plan, which reads: '3.4.1 Impact on public health. Together they will transform the quality of care, and will be a major contributor towards reducing health inequalities and improving people’s life expectancy and quality of life’.

As the PCT’s plan only contains business as usual, there is no evidence that their plan will deliver this impact, and every likelihood that the public health of the city will go on getting worse. (as they have done since the start of the NHS) The PCT’s words are just wishful thinking. Conventional medicine cannot solve the problem of declining public health, because it is part of the problem. The solution lies in thinking outside the box, as previous pioneers of public health did, as described below.

1.8 Medicine for harm or good?
The book by Prof Edzard Ernst (chair of complementary medicine at Exeter University (with Simon Singh) Trick or Treatment – Alternative Medicine on Trial is supposed to be an indictment of CAM. However, it is really a covert indictment of conventional medicine. (see reviews in section 9.26 of (Page numbers refer to the original text)

The book should be judged by its punchline at the end: ‘We argue that it is now time for the tricks to stop, and for the real treatments to take priority. In the name of honesty, progress, and good healthcare, we call for scientific standards, evaluation and regulation to be applied to all types of medicine, so that patients can be confident that they are receiving treatments that demonstrably generate more harm than good.’ (p248) Apart from the Freudian slip in switching ‘harm’ and ‘good’, every good-hearted citizen would support this conclusion. That slip is the only clue that indicates that the authors know that it is conventional, not alternative, medicine that needs to be exposed to the light of truth.

Quoting the authors again: ‘One might argue that every individual has the right to spend money according to his or her own wishes, but if alternative practitioners are making unproven, disproven, or vastly exaggerated claims, and their treatments carry risks, then we are being swindled at the expense of our good health.’ (p240) This admirable statement should of course be applied to all practitioners. (conventional as well as alternative)

The shocking truth is that all people throughout the world are being forcibly swindled through their taxes to finance conventional therapies which do more harm than good and are killing them in large numbers. This is effectively publicly funded genocide to which all doctors, health authorities and governments are unwitting accomplices.

The culprit is Big Pharma. ‘This is the wealthiest institution in the world. The top 10 companies in Fortuna 500 are drug companies, and make profits exceeding all the other 490 companies put together. ($35 bnpa in 2002) It is primarily a marketing machine to sell drugs of dubious benefit. This industry uses its wealth to co-opt every institution that might stand in its way, including the US Congress, the FDA, academic medical centres, and the medical profession itself.’ Quote from Dr Maria Angell’s book The Truth about the Drug Companies, - How they deceive us, and what to do about it. see Want to Know

1.9 Historical innovative solutions to public health problems
Ernst and Singh’s book gives an excellent historical resume of conventional cures over 4 centuries, and describes how the following five mavericks introduced innovative solutions in spite of opposition from the vested interests of the medical establishment.

a) The cure for scurvy (lemons and limes) had been documented in 1601. James Lind did a clinical trial in 1747 and confirmed its efficacy. However, the medical establishment was promoting all sorts of other remedies, and sailors continued to die of scurvy until 1795 (48 years later) when three quarters of an ounce of lemon juice was added to the standard diet of British sailors. (p19) (This is the reason why British sailors were called ‘limeys’ and why Britain won the battle of Trafalgar and ruled the seas throughout the 19th century, as British naval crews were the only ones not to be debilitated by scurvy)

b) Alexander Hamilton did a clinical trial in 1809 which showed that the death rate for patients treated with bloodletting was ten times greater than those who avoided it. Nevertheless bleeding continued to be a standard procedure. France imported 42 million leeches in 1833. As each decade passed rationality began to take hold amongst doctors, and dangerous and useless therapies such as bloodletting began to decline. (p23)

c) Dr John Snow cured the local cholera epidemic in Soho, London in 1854 by taking off the handle of the Broad Street water pump, thereby proving that its cause was contamination of that well. (p112)

d) Florence Nightingale was prioritizing hygiene in 1854 when everybody else was focussed on other things, such as surgery and pills. The officers and doctors felt that these changes were an insult to their professionalism, and fought her every step of the way, but she pushed ahead regardless. The death rate fell from 43% to 2%. (p27)

e) Hill and Doll showed in 1954 that smoking was a surprisingly deadly indulgence, and moreover produced data that stood up against the powerful interests of the cigarette industry. (p36) However, it took until 2007 (53 years later) for smoking to be banned in public buildings.

1.10 Doctors’ duty of care to staff and patients
GPs are risking their livelihood by being struck off the register if they refer their patients to CAM therapists at present because BMA Guidelines to GPs dated May 2009 state: ‘You must be satisfied that any healthcare professional to whom you refer a patient is accountable to a statutory body or employed within a managed environment. (my emphasis) If they are not, the transfer of care will be regarded as delegation, not referral. This means that you remain responsible for the overall management of the patient, and accountable for your decision to delegate.’ ….. ‘Referral’ means handing over (usually temporarily) some or all their responsibility for the patient. ‘Delegation’ means that they share responsibility for co-management of the patient.’

Dentists, opticians and pharmacists are employed within a managed environment’ which enables GPs to safely refer their patients to dentists for dental care, opticians for glasses, and pharmacists to cash their prescriptions. GPs are themselves employed in a managed environment by practices who are employed by the PCT.

The reason why GPs cannot refer patients for free CAM is because CAM therapists are not ‘employed within a managed environment’ This is what the proposed company will provide. CAM therapists will be employed by registered CAM centres, who in turn will be employed by the company. This managed environment will be statutorily regulated (as the PCT is now) so that the doctors can refer their patients with confidence without risking being sued or struck off the register.

1.11 Public expenditure on CAM treatments on staff and patients
The official NHS policy on CAM is that no public money may be spent on it. However University College Hospital in London has had a complementary therapy unit in its cancer centre since 1999 which now includes reflexologists, massage and aromatherapy as well as healers. (see Many other hospitals have done the same, including Guildford, Walsall, Southampton. Many doctors, managers and the Department for Work and Pensions are clandestinely breaching that policy because it works to cure the patients’ conditions, and health ministers are supporting them, as described below:

a) Many doctors are qualified as CAM therapists (such as homeopaths, acupuncturists, osteopaths) and use CAM in their consultations.

b) Under the Active Exercise programme GPs are giving free membership of gyms to patients to have supervised exercise, despite the fact that this is a referral or a delegation to unknown instructors.

c) For the last 3 years a charity called Active Lightworks have been sending CAM therapists into the Royal Sussex County Hospital to treat staff with aromatherapy massage to relieve stress for donations.

d) Unemployed people are being given free courses of holistic therapy of their choice to help them to get fit so that they can return to work and reduce the number of people on disability benefit (paid to 2.5 million people at present, which pro rata is 12,500 in the city)

e) Health Minister, Mike O'Brien said on 1.12.09 when being quizzed by the House of Commons Select Committee on Science and Technology: 'We take the view that it is not our job to stop clinicians prescribing these medications (CAM) if they feel they are appropriate……. NHS homeopathy is practised by trained doctors who have to take responsibility for what they do.’

The proposed company would provide a vehicle to regularise these precedents and integrate them into the normal functioning of the NHS.

1.12 Reducing staff sickness in NHS
NHS staff sickness levels are appallingly high at 5%, which is 50% worse than the national average of 3.3%. If the NHS cannot keep its staff healthy, what chance have its patients got of keeping healthy? The Boorman report on staff sickness was accepted by the government on 1.12.09. It requires the NHS to bring their staff sickness rate down by 1% to 4% and save 3.5 million days lost pa.

The problem is that the NHS do not know how to do this. This new government target will stress staff even more, as it will be interpreted that they are now not allowed to go sick, precipitating burnout. This risks cascade failure of whole departments as the remaining staff try to keep going short-handed. Conventional medicine cannot solve the problem of staff sickness because it is the problem. The solution lies in thinking outside the box, to CAM.

The first principle of health dating from the ancient Greeks, Asclepius and Hippocrates is ‘physician heal thyself’. The proposed company will provide a managed environment for CAM therapists to be openly paid for by the NHS as part of the national health service, but who should the company treat first?.

The healthcare staff themselves are the highest priority because they are responsible for the health of the rest of the community and sick staff are a bad advertisements for the NHS. Furthermore, this transformation of public healthcare has to start with the commissioners. To be effective in life, everyone needs to walk their talk. Commissioners need to experience first hand the benefits of CAM to speak and write with conviction to influence providers to provide CAM through the company.

The commissioners number about 200, located in Prestamex house, 171, Preston Rd Brighton. We are willing to organise a mini pilot scheme for them at spare rooms at that site, putting on such CAM treatments as aromatherapy, reflexology, reiki, meditation. They can then feel the effectiveness of this, before deciding to put it into their commissioning plan for the city.

Assuming that they do, there are about 7,800 other NHS healthcare staff in the city, of which about 5,000 work at the Royal Sussex County hospital. If each member of staff was given 1 CAM voucher every week, this would require 8,000 vouchers per week, or 80 per week per CAM centre, 15 per day. 0.4 million pa. This is 50% more than the figure in the budget for year 5 (10 vouchers per day in 2015)

1.13 Who should the company treat next?
If free CAM works as we believe it will, many other classes of people will be clamouring for vouchers. There are many thousands of other public service staff who are near burnout in the ambulance service, local government, police, teachers, postmen. There are 12,500 unemployed on disability benefit who cannot work because of sickness. There are 40,000 with long term conditions. Sorting out the priorities for treatment is a decision for government, but the highest priority is the healthcare staff. Only when the Boorman target is met should the CAM service be expanded to treat the rest.

There are about 12,500 on disability benefit, who if given 1 voucher per week would require the entire budgeted output of year 6 (2016) of 20 vouchers per centre per day. There are a similar number of other public sector staff (local government officers, police, teachers). They also should be offered free CAM on the NHS.

The early drafts of this business plan diverted 25% of the health budget to prevention by CAM by 2020, but if this proposal works the public will not want to wait that long. There will be great public pressure on the company to accelerate the programme, so we have brought that forward to 2014. We would recommend at least 50% being diverted by 2020, but the rate of expansion should be an issue for public debate as the scheme develops.

1.14 How would the scheme work?
About half the GPs already provide free exercise classes under the Active Life Exercise Referral Scheme. This would be an extension of that scheme.

a) The GP sees a patient, and both agree that the patient’s care plan should include CAM. There is no need to specify which type of CAM or where. It is part of the therapy that patients (or their carers) take responsibility for themselves in choose the therapy, the centre and the therapist, rather than just being passive recipients, like children. The patient must believe in the treatment and the ability of their therapist for it to work. (placebo effect)

b) The GP gives the patient one or more £50 vouchers stapled together in a book and writes the patient’s name on each voucher, preferably by printing a label on his computer and sticking it on to the vouchers.

c) The patient can contact a manager (gatekeeper) in the Company for free advice on which complementary therapy would be best for them, and which centre could best provide it.

d) The patient contacts the receptionist at the centre of their choice, and discusses which treatment, which therapist, and their availability.

e) The patient books the session(s) and tenders the voucher to the receptionist as payment in advance. If the voucher value does not exactly equal the cost, the patient may make up any shortfall in value in cash, but may not exchange the voucher for cash, nor be refunded for any overpayment in value.

f) The receptionist writes the appointment and the therapist’s name on the voucher, files it, and enters it on the centre’s computer. On a set day of the month as determined by the company (to stagger the workload of the company staff), the receptionist fills in a proforma invoice claiming the value of all vouchers received, and e mails it to the company. Patients that do not attend, (‘no shows’) count as sessions taken and have to be paid for, as in other NHS providers.

g) The company staff process the proformas, and invoice the PCT monthly according to the agreed tariff, say £55 per voucher of £50 face value’s worth of complementary therapy, including a 10% handling fee of £5.

h) The company staff keep the administration fee (of £5 per voucher) and pay the remainder (£50) to the centre’s bank account by bank transfer.

i) The centre manager keeps the room hire and administration part (say £12) and pays the remainder (say £38) to the therapists who did the treatments, with the objective of therapists being paid within 2 months of doing the treatment.

j) Sufficient numbers of managers will be employed to handle the enquiries, and sufficient numbers of clerks will be employed to process the vouchers.

1.15 Draft Voucher
Vouchers would be printed like lottery tickets with numbers to prevent forgery. Each voucher would have a nominal face value of say £50, which can buy approximately 1 hour of one to one therapy or 6 hours of class or group therapy, at typical going rates at centres. The GP would issue vouchers singly if he thinks that the patient should do a class (say a yoga course), or in books of say 6, if he thinks that 6 sessions of one to one therapy are indicated (say of physiotherapy) Further books could be obtained if needed, like repeat prescriptions.

Proposed draft voucher for NICE-approved CAM


I promise to pay the bearer on demand the sum of fifty pounds (£50) on the following conditions.

1 Legal basis for this voucher Patients have the statutory right under the NHS constitution to free NICE-approved treatment if their doctor says it is appropriate.

2 The SECT company is an agent enabling GPs to provide their patients with free NICE-approved treatments on the NHS at registered complementary therapy centres, with appropriately qualified complementary therapists.

3 NICE-approved treatments This voucher may be used for the following National Institute for Clinical Excellence (NICE) approved treatments: chiropractic, osteopathy, acupuncture, Alexander Technique for lower back pain, and Mindfulness Based Cognitive Therapy (MBCT) courses for anxiety and depression.

4 Payment disclaimer to therapists. The company will use its best endeavours to pay the value of this voucher, less the administration fee, to the therapist providing the treatment, as soon as possible after the treatment. However, this payment is conditional on the company being paid by the NHS commissioners, so is not guaranteed, and is at the therapist’s risk.

5 Clinical governance disclaimer to patients. The company will use its best endeavours to ensure that the therapists listed on this voucher are qualified to provide the stated treatments, and that the rooms used for the treatment are fit for purpose. However, the company is not a qualifying body, and is not certifying the appropriateness or efficacy of the treatment provided, the ability of the therapist, or the suitability of the treatment room used, which are at the patient’s risk.


This voucher is prescribed by…………………………………………………………………………..(doctor)



For: lower back pain / anxiety and depression (please delete what does not apply)

Treatment provided by…………………………………………………………………………………(therapist)

On……………………..(date) Patient satisfaction: very satisfied/ satisfied/ unsatisfied (delete)

For company use. Voucher issued to GP on ………………………(date)
Received from therapist on………………………...(date)
Payment made to therapist on …………………….(date)

List of registered therapists with whom this voucher may be exchanged for treatment.









Paul Harris

Manos Chiropractic Clinic

34 Palmeira Square
Hove BN3



Mark Yacoub

Chiropractic First

32 Goldstone Villas
Hove BN3 3RN



Victor Bennett

Holistic Health Clinic

52 Beaconsfield Rd Brighton



Morten Westergard

The Clinic

34 Dyke Rd Av



Tom Sydenham

Pathway Clinic

28 Coombe Terrace Brighton BN2 4AD



Deborah Woolf

Annahata Health Clinic

119-120 Edward St Brighton BN2 0JL



Roy Haitzin

Anahata Health Clinic

119-120 Edward St Brighton BN2 0JL



Manhi Son

Anahata Health Clinic

119-120 Edward St Brighton BN2 0JL


Alexander Technique

Carolyn Nichols

Brighton Alexander Technique College

Unit 3 Hove Business Centre
Fonthill Rd
Hove BN3 6HA


MBCT course

John Kapp


86 Church Rd
Hove BN3 2EB


Issued by Social Enterprise Complementary Therapy Company (SECTC) President Cllr Ayas Fallon-Khan, Directors Anne Pether (finance) Terry Rixon (data) Company secretary John Kapp, 22, Saxon Rd Hove BN3 4LE 01273 417997, www section 9                         24.5.10

1.16 Entry criteria for centre registration
The prospective entry requirements for registration with the company would be approximately as follows as a draft. They are subject to discussion, and may be amended and agreed by meetings of the centres registering from time to time. The PCT commissioners will probably have clinical governance criteria that they wish to be incorporated into the Service Level Agreement contract, which may augment these criteria that the company decides (see part 4.4a, SWOT below).

The registered centre shall: a) Offer a health service to the whole community. The model for this is the old family GP or dental practice, but it does not have to be the expensive modern versions of these.
b) Have an address in Brighton and Hove where clients shall be treated.
c) Be open for business for at least 40 hours per week, including some evening openings until at least 8pm.
d) Be appropriately equipped for the treatments offered, and be subject to spot inspection by the company, the commissioners’ staff and others.
e) Employ a receptionist on the premises throughout the opening hours who shall take bookings from potential patients in person, on the phone and by e mail.
f) Employ a business manager who shall deal efficiently with the company’s administration staff, mostly by e mail, phone and bank.

1.17 What CAM therapies would be offered by the company?
To help patients to choose what CAM therapies are available, the company would publish a directory of their registered centres and the therapies they offer in hard copy and on a website. The following is a guide to what could be in it:

a) One to one therapies
The company SECTC1 will start with the NICE-approved CAM therapies: osteopathy, chiropractic, acupuncture, Alexander Technique, for lower back pain, and MBCT courses for depression. The most popular other one to one CAM therapies presently offered are cranio-sacral therapy, colonic hydrotherapy. psychotherapy, hypnotherapy, NLP, counselling, psycho kinesiology, nutritional therapy, herbalism, homeopathy, reflexology, aromatherapy, shiatsu, , Emotional Freedom Technique, (EFT) Eye Movement Desensitisation Reprogramming, reiki, astrology, rebirthing.

b) Groups
The most popular group classes are exercise classes, keep fit, weight watchers, yoga, pilates, tai chi, chi gung, meditation (Buddhist, Brahma Kumaris, Osho)

c) Educational Classes
The availability of public funding would encourage the provision of educational classes in self-help (such as diet and nutrition, lightning process, family constellation, vortex healing, astrology) and self-help groups for long term conditions, such as asthma, diabetes, cancer, heart disease, ME/Chronic Fatigue Syndrome.

d) Other therapies, groups and classes
The above lists are not exhaustive, and SECTC2 would not exclude any CAM therapy or class that a registered centre might wish to offer. CAM therapies and classes are developing all the time, and registered centres would be encouraged to offer the latest treatments available. We believe that ultimately the patient should choose the therapy they want, as patients pay for the NHS in their taxes.

e) NICE approved treatments.
Under clause 2A of the NHS constitution, patients have a statutory right to free treatments which have been approved by the National Institute for Clinical Excellence (NICE) provided that their doctor says it is clinically appropriate for them. NICE approved CAM treatments would therefore have a star rating in the company’s literature. We believe that the commissioners are constitutionally required to provide these treatments free at the point of use. However, they dispute that, and we are seeking the adjudication of NICE and the new Secretary of State for Health (Rt Hon Andrew Lansley MP) at the time of writing. Our case is set out in a letter to NICE published elsewhere in this website.

The following CAM treatments are NICE approved, so should be offered free to patients as a constitutional right. Under the present administrative arrangements the NHS cannot meet this constitutional right of patients. However if this proposal is adopted they can do so. The following CAM treatments are NICE approved:

i) The 8 week Mindfulness Based Cognitive Therapy (MBCT) course for depressed patients as an alternative to antidepressant drugs.(see f) below)

ii) Chiropractic, osteopathy, acupuncture, and Alexander Technique for lower back pain.

iii) Hypnotherapy for Irritable Bowel Syndrome (IBS)

1.18 Mental health service
The mental health ‘service’ is presently a mis-nomer, as the service is not worthy of the name. Drug treatments have been discredited (The Secretary of State for Health, Patricia Hewitt MP announced in May 2006 ‘the end of the Prozac nation, see 4.3a) Although 10,000 extra CBT therapists have been recruited the waiting list for talking therapies is still over a year, and CBT is not suitable for every patient.

As mentioned in 1.17 e) above, the 8 week MBCT course is NICE approved so patients have a statutory right to it free. Mental health services would be transformed if the MBCT course was provided wholesale to everyone who wanted it. This proposal enables it to be offered as widely as facilitators are available to provide courses. It is immediately available in the city to those who can pay the going prices (about £190, reduced to £ 80 for concessions) The number of facilitators offering courses is estimated to be about 20, and the estimated number of course participants is about 200 per year.

A mental health service worthy of the name could be created if every CAM centre put on 15 MBCT courses pa for 20 patients per course, totalling 300 participants pa per centre. The 100 centres in the city would treat 30,000 participants pa. Some patients might need to repeat the course annually. New facilitators could be recruited by sending meditation leaders on the one week teacher training for this course. For further details of this, together with a business plan, see paper ‘Improving Health by Ending the Prozac Nation’ published as section 9.28 on website

1.19 Registration of GPs
The following form was sent out to all 48 GP practices by post in early May.
Secretary: John Kapp,
Registered address 22, Saxon Rd Hove BN3 4LE, 01273 417997
Website section 9 of

Committee members: Cllr Ayas Fallon-Khan (President), Julie Alce, Barbara Bishop, Lyn Clark, Roy Haitzin, Patricia Holden, Carolyn Jikieni, John Kapp (secretary), Christine Kavanagh deputy chairman) , Penny Kinton (chairman) Stuart Macey (IT officer) Claire Miles, Anne Pether (treasurer), Tom Sydenham, Shirley Ward.

Open letter to GP practice managers 4.5.10

Dear Practice Manager


Research shows that about half of all GPs recommend some of their patients to have complementary therapy, but the patient has to pay for it, which some cannot afford. Under the NHS constitution, patients have the statutory right to free National Institute for Clinical Excellence (NICE)-approved treatment, including Complementary and Alternative Medicine (CAM) provided that their doctor says it is appropriate for them. The following CAM treatments are NICE-approved:
For lower back pain (LBP): chiropractic, osteopathy, acupuncture, Alexander Technique. For anxiety and depression: Mindfulness Based Cognitive Therapy (MBCT) courses (8 week)

SECTC, hereafter called ‘the company’ is a newly formed agency company which is in an advanced stage of negotiation with the NHS commissioners (the former Primary Care Trust) to administer the provision of the above treatments free at the point of use to NHS patients in the city of Brighton and Hove as a pilot project. Our company was set up according to our business plan published on the above website section 9.39, where details about it may be seen.

We intend to print vouchers for the above NICE-approved treatments (value £50) and deliver them to you. Your GPs can pass them on to those patients who require them under their care plan. Please return the attached form to register your interest in receiving CAM vouchers when the arrangements are finalised.

Yours sincerely
                                                            John Kapp (company secretary)


Registration form for GP practices wishing to participate in the SECTC voucher scheme for free complementary therapy on the NHS, as described in SECTC’s letter of 4.5.10.

Name of practice………………………………………………………………………………

Address of practice…………………………………………………………………………..

Name of practice manager………………………………………………………………..

Name of manager who will be managing the vouchers………………………...........

Phone number of that manager ………………………………………………………..

E mail address of that manager ………………………………………………………..

Names of all GPs who may be giving vouchers to patients





Please estimate the number of £50 vouchers that your practice will require in the first full month of the scheme


Any further comments about this scheme …………………………………………………



Please complete and return to John Kapp, (secretary of SECTC) 22, Saxon Rd Hove BN3 4LE, or e mail to

1.20 Registration of therapists
The following form was sent out to all therapists on the mailing list in early May.


The Social Enterprise Complementary Therapy Company (SECTC, hereafter called ‘the company’) is an agency company providing National Institute for Clinical Excellence (NICE) – approved Complementary and Alternative Medicine (CAM) free at the point of use on the NHS to NHS patients in the city of Brighton and Hove.
The company was set up according to a business plan published on Section 9.39

Under the NHS constitution, patients have the statutory right to free NICE-approved treatment, including CAM. The following CAM treatments are NICE-approved:
For lower back pain (LBP):
chiropractic, osteopathy, acupuncture, Alexander Technique.
For anxiety and depression:
Mindfulness Based Cognitive Therapy (MBCT) courses (8 week)

This form is a contract between the company (as commissioners of the above NICE-approved therapies), and therapists (who agree to provide those therapies to patients in CAM centres in the city in exchange for a company voucher).


The Company agrees to:
I, John Kapp, company secretary of the Social Enterprise Complementary Therapy Company (SECTC) of 22 Saxon Rd Hove BN3 4LE, 01273 417997, , website, e mail
on behalf of the company agree to:

a) Contract with the NHS commissioners (former Primary Care Trust PCT) to pay for free NICE-approved CAM on the NHS by means of vouchers printed by the company.

b) Print vouchers and distribute them to General Practitioners (GP) surgeries in the city for distribution to patients with lower back pain or anxiety and depression.

c) To pay therapists for treatments done to patients bearing vouchers, to the value of the vouchers returned to the company, in arrears.
Contract form between SECTC and:

The therapist I…………………………………………………………………(name in capitals)


………………………………………………(e mail address)………………………...……..(phone)


Qualifying body…………………………………………………………………………………………

(website, if any) …………………………………………………………………………………..

agree to:
a) contract with the company to provide the following NICE-approved treatments chiropractic, osteopathy, acupuncture, Alexander Technique MBCT course (please strike out what does not apply)

b) Give the above NICE-approved treatment to the bearer of the company’s vouchers, at the following CAM centre:

………………………………………………………………………………(name of centre)

………………………………………………………………………………..(address of centre)

…………………………………………………………………………(phone number of centre)

…………………………………………………………………………(e mail address of centre)

………………………………………………………………………..(website of centre)

c) Return the voucher to the company with a request to pay the value to my bank account number…………………………………………………………………………..

at…………………………………………….bank……………………………….(sort code)

d) I give my permission for my above details (not including my bank account details) to be published in the company’s literature.


For company use…………………………………………………….(therapist number)

Part 2 Budget for the company

2.1 Summary of benefits of this scheme in 2016
The benefits of this scheme are summarised in paragraph 1.6 above, which show that by 2016 the scheme could reduce by half the present high and increasing rates of alcoholism, drug taking, smoking, suicide, and long term chronic illness which presently afflicts 1 in 3. Mental and physical health would generally be improved, reducing hospitalisation and GP visits to half the present rate.

2.2 How will demand rise for free CAM on the NHS?
The CAM profession is not organised, so figures are not available for demand for CAM. However the House of Lords Select Committee report on CAM published in 2000 estimated that £1.6 billion pa was spent on CAM in UK at the time of writing. If this was spent by 10% of the population who can afford it, (6 million people) the average spent on CAM was then £270 per person pa. After allowing for inflation this is about £400pa, or about £1 per person per day. The government want the NHS to prevent illness, so it would seem reasonable to budget £1 per head per day of public money to prevention of long term chronic conditions in later life. If this sum was provided to all the 250,000 people in Brighton and Hove, it would cost the NHS commissioners £100 mpa. This is the value of 2 million vouchers pa at £50 per voucher. This amount is called the ‘target CAM demand’.

The target CAM demand of £100 mpa or 2 million vouchers pa will take time for everyone to adjust to this new integration of CAM into the NHS. We originally created the forecast to reach this target in ten years time, in 2020, but subsequently accelerated the programme to reach that in 5 years time by 2014.

We assume that this proposed scheme will start in 2011 with a low demand at 2 vouchers per centre per day. This is just a ‘nice little earner’, raising £33,000 pa for each centre, and £330,000 pa for the company. Thereafter, demand is assumed to quadruple each year for 4 years, to reach the ultimate CAM demand figure of 60 vouchers per centre per day in 2014. This would raise £1 mpa for each centre, and £10 mpa for the company. The assumed growth in demand each year is shown in table 2 below, with previous annual figures for the slower growth left in as intermediate figures.




Year and Calendar year

Number of vouchers per centre per day Vpd

Value of vouchers per centre per day


Number of vouchers per centre pa

Value of vouchers per centre pa


Number of vouchers thousands pa


Value of vouchers @£50 per voucher


Value of admin. fees @£5 per voucher

1     2011
















2     2012
















3     2013
































4     2014








2.3 Budget assumptions about the first year of operation, calendar year 2011

a) Abbreviations: V= number of vouchers. K= kilo, thousands, m=mega, millions.
b) The number of registered centres will be 100.
c) The company staff will comprise two managers at £40kpa and 4 clerks at £25kpa (total staff 6, cost £180kpa) Overheads of office rental, services, business rates, etc are assumed to equal the costs of staff. Total company cost for 6 staff is £360kpa for first 2 years.
d) Each centre receives on average: 1 voucher per day, 6 per week, 330 pa.
e) Total vouchers managed by the company: 100 per day, 600 per week, 33kpa, of face value £1.65 million pa
f) Tariff price to the NHS for each £50 voucher is £55, which is paid by the PCT to the company, who distribute it as follows:
g) The company pays the centre £50, keeping £5 as administration fee.
h) The centre distributes the £50 as they see fit, but it would seem reasonable to keep a room hire and administration fee of say £12 and pay the therapist £38 which is a reasonable take-home going rate per hour for CAM therapists.
i) Turnover of company for 33,000 vouchers pa @ £55 per voucher = £1.65 mpa
j) Total administration fees for 33,000 vouchers pa @£5 = £165kpa
k) Revenue £165k minus costs £360k = loss of £195kpa.
l) Staff work 1,700 hours pa. Average staff time for 4 clerks to process each voucher @ 33kVpa over 6,600 hours pa is 12 minutes per voucher in the first year, and 6 minutes in every succeeding year.(The details of this are given in 2.4 below)
m) Centres are open for 330 days pa.

2.4 Number of staff required
The first year demand is 200 vouchers per day (66,000 pa) We assume that 2 managers, (one a deputy to the other), will be required to handle the enquiries from patients. If every voucher gave rise to an enquiry, (as it may do in the first year) each manager could give 4 minutes to each enquiry. We assume that 4 clerks will be required to process the vouchers, taking 6 minutes per voucher per clerk.

In every subsequent year, we increase the number of managers and clerks in proportion to the increase in number of vouchers handled. This assumes the same enquiry time of 4 minutes per voucher per manager, and an administration time of 6 minutes per voucher per clerk. However, the number of enquiries per voucher will decrease as the public become used to the system.

2.5 Company Budget
The budget is appropriate to the scale of the services demanded. Figures are in £ thousands pa (£kpa) . The word ‘staff’ includes the manager and assistant managers at a ratio of 2 clerks per manager, averaging £30kpa per member of staff employed.


Year number & calendar Year

No of vouchers per centre per day from table 1

Staff number on payroll

Staff cost




Total company costs


Revenue @£5 per voucher from table 1

Surplus (deficit)


1     2011
















2     2012
















3     2013
































4     2014








5     2015








6     2016
















2.6 NHS budget
The effect on the NHS budget will be a cut in total expenditure of 20%, by halving the cost of conventional treatment and allocating £100 mpa to prevention, as shown in the appendix at the end of this document

2.7 What should the administration fee be?
It is difficult to estimate how much advice patients will need from managers, and how much time clerks will need to process the vouchers. The staffing levels depend on the amount of staff time allocated to this. The above estimate of 8 minutes per enquiry per manager, and 6 minutes per voucher per clerk in the second and subsequent years may be inadequate in the early years before people get used to the new treatments.

If staff time to handle enquiries and vouchers were doubled to 16 minutes and 12 minutes respectively, the number of staff would need to be doubled throughout the whole forecast. To pay for the doubled costs, the administration fee would need to be doubled to 20% or £10 per voucher.

For simplicity the above budget assumes a constant administration fee of £5 per voucher (10% of its face value) throughout the 6 years of the forecast. In practice, if this scheme is implemented, it would be prudent to start the scheme at an administration fee of 20%, £10 per voucher, which allows for twice as many staff at the beginning. It is better to have too many staff than too few, because if the company is understaffed the patients will not have a good experience, prejudicing the sustainability of the scheme. As patients and staff get used to free CAM, economies of scale will probably occur and staff would get more efficient in giving advice and handling the vouchers. Less staff would then be needed, and the administration fee could then be reduced in increments to 10% or £5 per voucher.

2.8 Start-up costs
To start up this company the SEATC committee will need to hire well qualified people, (who could be management consultants) to do the following tasks:
set up the company, register it with the authorities, find a suitable office premises, negotiate and sign the SLA contract with the NHS commissioners, negotiate with and register the CAM centres, print the vouchers, appoint the directors, advertise for staff, interview and appoint them. We estimate that this will require the services of 2 experienced people (a manager at £40,000 pa and an assistant manager at £30,000 pa) for 9 months at a cost of £50,000 for salaries and accommodated in an office, £100,000 for overheads, total £150,000.

We have been advised that start up grants for innovation projects such as this one are available from:

a) The Social Enterprise Investment Fund (who have £100 million to disperse over two years) We are advised to apply for this through Future Builders.
b) The Regional Innovation Fund, from our South East Coast Strategic Health Authority, who has £2 million to invest each year.

We intend to apply for a start-up grant for this scheme soon.

2.9 Proposed timetable

a) In Jan 2010 we applied for a grant for this start-up sum of £150,000.
b) in Mar 2010 we heard that we were unsuccessful.
c) In April we decided to go ahead without grant funding.
d) On 4th May 2010, we held a public meeting to create SECTC1 to provide NICE-approved CAM therapies, and appointed 2 directors (Anne Pether, finance, and Terry Rixon, data) and confirmed the company secretary as John Kapp.
e) In early May we approached the NHS commissioners to negotiate a contract, but they refused to have anything to do with the scheme on 15.5.10, confirmed on 20.5.10 .
f) On 24.5.10 we drafted a letter to NICE (copy published in appendix 2 ) asking them to adjudicate our dispute with the NHS commissioners, with a copy to the new Secretary of State for Health, as the political and financial implications are huge. We have asked the NHS commissioners to be party to this letter, and are awaiting their reply.
g) We intend to start trading as soon as we can find a GP willing to distribute our vouchers. However, we were informed by the commissioners that they have warned GPs that they are not supporting the scheme, so this may be difficult. We have warned our therapists that they have to take the risk of not being paid for the treatments they do until we are paid by the NHS.

Part 3 Draft Constitution of the SEAT Company (Memorandum and Articles, Terms of Reference)

3.1 Name
The name of the company shall be the Brighton and Hove Social Enterprise Complementary Therapy (SECT) Company, hereafter abbreviated to SECTC or ‘the company’.

3.2 Purpose
The purpose of the company shall be to promote wellness and prevent illness to the citizens of the city of Brighton and Hove, hereafter abbreviated to ‘the city’.

3.3 Aim
The aim of the company shall be to contract with the city NHS commissioners under a Service Level Agreement (SLA) to provide complementary and alternative medicine (CAM) including one to one therapy, group therapy and educational classes, free at the point of use, at registered centres of the company in the city, such as the 140 existing centres listed.

3.4 Objectives
a) To provide free CAM for NHS patients at all registered centres.
b) To invite all CAM centres in the city to become registered centres of the company.
c) To supply vouchers for CAM to all GP surgeries and other gatekeepers to issue to patients, which may be exchanged for free CAM at any registered centre.
d) To create an administration to pay CAM centres and therapists in arrears for the CAM treatments provided, preferably within 2 months.
e) To promote free classes and groups at registered centres to educate patients in self-help techniques.

f) To publish a directory of registered CAM centres and therapies in a website and in hard copy to publicise what is available.

3.5 Powers of the company
a) To contract with the city NHS commissioners as an agency on behalf of all registered centres.
b) To hire an office, advice centre, open a bank account, and employ staff.
c) To take such other powers as are necessary to fulfil the above purpose, aims and objectives.

3.6 Organisation of the board of the company
a) The Company shall be run by a board of directors, appointed by the SECT committee.
b) All meetings of the board shall be held in public. The proceedings shall be transparent and open, and the minutes shall be published.
c) Members of the public may submit written and oral questions to the board at every board meeting, which shall be answered publicly.
d) The board shall engage and employ a chief executive officer (CEO) who shall manage the company.
e) The CEO shall engage and employ such deputy managers and staff as he/she shall from time to time require to efficiently provide the services for which the company is contracted.

Part 4 Strengths, Weaknesses, Opportunities, Threats. (SWOT) of CAM and this company voucher scheme if this project were implemented

4.1 Strengths of this proposal
a) Meeting government policy objectives

i)Relocation The white paper of 2006 called for the relocation of healthcare from hospitals to community health centres. This project would provide healthcare in the 100 CAM health centres in Brighton and Hove.

ii)Removing health inequalities. Government want to remove health inequalities, particularly from people on benefit and those from the most disadvantaged communities. CAM is a popular and growing alternative health service, but at present it is restricted to those with ability to pay. (about 10% of the population) This proposal will remove health inequalities by opening up CAM centres to everybody in the community, irrespective of their ability to pay.

iii) Patient choice The keynote statement from ‘Choice at referral – guidance framework for 2006/7, dated 27.4.06, is ‘Choice is not alien, but an intrinsic part of the discussions that GPs have with patients to find the most appropriate care’. This proposal delivers to patients the most important choice of all – choice of treatment

iv)Prevention The Darzi report of July 2008 called for the NHS to prevent illness and promote wellness. This project would meet this objective by integrating CAM, which prevents disease by relieving stress, (the cause of dis-ease) before it becomes disease.

v)More healthcare staff The Wannless report called for a third more doctors and two thirds more nurses by 2020 to end the NHS staffing crisis. By 2020 this project will add about 50% to the city’s healthcare staff by adding 4,000 CAM staff to the present 8,000 conventional staff.

vi)Quality The DoH is presently consulting (closing on the 10.12.09) on their new requirement for NHS providers to produce Quality Accounts from April 2010 and April 2011, which focus on safety, effectiveness, and patient experience. This project meets these objectives as follows:

vii) Patient Safety This is a subject which is high on the political agenda. CAM treatments are safe because they are gentle and non-invasive. There have never been any iatrogeninc (doctor induced) deaths or maimings from any CAM intervention. (unlike conventional medicine, see 4.1c) below). Recommendation 8 of a recent DoH directive states:

"Accountability for patient safety rests with the Chair and Board of each NHS organisation. Each Board should therefore be expected to outline how it intends to discharge this responsibility. Importantly, each Board should also make clear how it intends to ensure that patients and carers play an integral part in all initiatives to introduce a patient safety culture change within the NHS." The writer of this business plan has been a patient representative for the last 10 years.

viii) Effectiveness Effective treatments are those which cure the condition. CAM is effective in curing patients (unlike conventional medicine) because it addresses the cause of their disease. This is stress between the ambitions of their mind (as manifest in their lifestyle) and the ability of their body to cope with that lifestyle. CAM delivers effectiveness through its active ingredient - meditation (an altered state of consciousness) in which patients become aware of why they are making themselves ill through stress, change their belief, attitude and lifestyle to relieve the stress, which allows their body to self-heal.

ix)Patient experience. CAM gives good patient experience by empowering patients to take responsibility for their own health. CAM therapists have empathy with their clients because they have previously suffered similar symptoms, have discovered how to cure themselves, and became a CAM therapist to share their understanding of their experience.

x)Welfare to work The Department of Work and Pensions (DWP) are also consulting at present on the welfare reform bill, which aims to reduce the £100 bnpa cost of working-age ill health, and the 2.6 million now on incapacity benefit, 40% of whom (1 million) have mental health conditions. This is thought to be structural unemployment disguised as disability, which is rightly thought to be curable. Stress, anxiety and depression are a significant cause of work related problems, and non-work related sickness absence. The government’s solution is the commissioning of outside providers (consortia of private companies) to support these people back into the workplace. Our proposal is just what the government wants. Our proposed company is a consortium of existing private companies which can help to cure stress, anxiety and depression, and hence help people back to work. Dr Steve Feast of DWP is speaking about this at the Future of Welfare to Work conference on 1.12.09.

xi)Avoiding privatisation. This proposal is not privatisation of the NHS because social enterprise companies have to plough back their profits, and are transparent and accountable, so cannot pay out big bonuses.

xii) NHS engagement with Local Involvement Networks (LINks) The DH is issuing a call for health and care professionals to proactively engage with their LINk, as they are having a positive effect on services including reducing waiting times, improving standards and increasing accessibility. (Gateway reference number: 13208) 10.12.09 see Action: PCT chief executives will wish to review their understanding of the role of their LINk and contribution they can make in improving services and facilitating communication between the PCT and the local community. The SEATC secretary writing this (John Kapp) is an active member of LINks, and represents Sussex on the National Association of LINk Members (NALM)

b) Integration of CAM into conventional medicine
This is the aim of the Prince of Wales charity ‘Foundation for Integrated Health’ ( which has been campaigning for more than a decade. Despite excellent arguments, this aim has not been realised because no-one has solved the administrative problem of paying public money for CAM. This proposal solves that problem, and puts CAM on an equal footing with primary and secondary care, dentistry, opticians and pharmacies. Prince Charles gave the keynote speech to the World Health Organisation in May 2008, attended by all the health ministers of the world. He called for the integration of CAM into conventional medicine. This has given rise to integrated health departments, chairs and degrees (such as those given by the Universities of Westminster and Buckingham) now replicated all over the world.

c) SHA support for innovative schemes to improve the NHS
The inspiration for this proposal occurred to the writer at the DoH innovation exhibition 18-19th June 2009, as described in his paper ‘Integration of CAM into the NHS via Social Enterprise Alternative Treatment Companies’ published on section 9.38 of We have already received advice from Dr Alan Kennedy and Mr Joop Tanis of the Strategic Health Authority (SHA) who are engaged to support innovative schemes like this one through their gestation and teething problems.

d) The public prefer CAM to drugs
The public prefer CAM because it empowers them to create health and prevent illness, (unlike drugs which usually just suppress symptoms) CAM is based on the holistic paradigm of treating the whole person in body, mind, spirit and environment. It gives patients a healing environment in which they can take responsibility to heal themselves by addressing and removing the cause of their illness, which is stress in their mind.

Conventional medicine is based on the materialistic, reductionist, mechanistic paradigm which treats only the body by cutting, burning or poisoning. It does not address the cause of their disease, which is in the mind. By suppressing the symptoms, drugs prevent self-healing, and have side effects which can seriously damage your health and even kill you. Iatrogenic (doctor-induced) illness has become the biggest single killer in the USA (mostly from adverse drug reactions) with 800,000 iatrogenic deaths pa, compared to 700,000 deaths pa from heart disease and 590,000 deaths pa from cancer ( ‘Death by Medicine’)

e) CAM has the soundest evidence base, and some have NICE approval
Contrary to drug company propaganda, many CAM treatments (such as meditation and touch therapies) have an evidence base going back thousands of years, whereas the oldest drug (aspirin) is only about 110 years old. The proof that CAM treatments work is that the public continue to pay for them in increasing quantity, in spite of playing uphill against free drugs. Some CAM therapies are NICE approved, such as Mindfulness Based Cognitive Therapy (MBCT) as an alternative to anti-depressant drugs such as Prozac, (see 1.6e above) acupuncture, cranial osteopathy, Alexander Technique for back pain. Many CAM therapies are being researched, with prospect of more becoming NICE approved. Under the NHS constitution, patients are entitled to free NICE approved treatments provided their GP says it is appropriate. This proposal will make it possible for patients to have NICE approved treatments paid for by the NHS in accordance with the constitution.

f) The public like vouchers
Luncheon vouchers were big business in the 1970s. The rise of the Transition town movement has recently given prominence to voucher schemes, such as the ‘Totnes pound’.(see and LETs schemes. The innovative idea in this proposal is to use vouchers to enable the NHS to pay for CAM in the community as a practical solution to the problem of breaking bulk in a fragmented CAM market.

4.2 Weaknesses of this proposal
a) CAM’s holistic paradigm is not recognised by conventional science

Doctors used to be taught at medical school that CAM is quackery practiced by charlatans. This attitude was acquired during the reforms leading to the creation of the General Medical Council in 1853 which is maintained out of habit. The old guard of doctors are therefore prejudiced against CAM which blinds them so that they cannot see the evidence. For example, Prof Edzard Ernst (chair of complementary therapy at Exeter University) wrote a book in 2008: ‘Trick or Treatment – Alternative Therapy on Trial’, which he claims to ‘deliver the ultimate verdict with clarity, scientific rigour and absolute authority. …Most UK doctors consider it (CAM) to be little more than superstition and a waste of money…..Our mission is to reveal the truth’. He rubbishes CAM, and even says that ‘there is no evidence whatsoever for the existence of innate intelligence or its role in health’ (p147) or for ‘a vital force’.(p104) (My review of this book is published in section 9.26 of

Who is out of step? Conventional medicine is based on conventional science which is based on the materialist, reductionist, mechanist paradigm (underlying belief system) Materialists believe that only the body is real, and that it is a machine. Spirit, soul, mind, intelligence, and even life are illusions or delusions. It is therefore not surprising that conventional medicine cannot accept CAM which is based on the holistic belief that spirit creates life, which creates mind, which creates body. A dis-eased mind created a diseased body. A healthy body requires a mind which is at ease with itself. Healing means dropping negative beliefs and attitudes, which can only be done by going beyond the mind in meditation, allowing the body to cure itself.

The old guard’s Victorian attitude to CAM is no longer scientific, because the new sciences of psycho-neuro-immunolgy and neuro-physiology confirm that the body’s physiology depends on what the mind believes and thinks each moment. There is now a huge literature and evidence base for this mind/body view, including books by many eminent doctors such as Dr Deepak Chopra and Dr Bernie Siegel.

Recent experiments in quantum physics now proves the existence of another world outside physical space time, known as ‘non-locality’, and ‘entanglement’ of particles. The mechanism by which CAM works in unblocking the flow of the life force is well explained by quantum physicist Prof Amit Goswami’s book God Is Not Dead (2008) using Dr Rupert Sheldrake’s concepts of telepathy by morphic fields, published in A New Science of Life, (1981 revised 2009) They believe that spiritual and mental energy is waves which collapse into particles of matter when observed by consciousness. (A review of these books by me was published in Scientific and Medical Network Review in Dec 09)

b) Some CAM lacks regulation and clinical governance
CAM comprises dozens of different types of treatment. Some of these have professional qualifying bodies and learned societies to regulate them, such as physiotherapy, osteopathy, chiropractic, and acupuncture. A further 12 CAM professions are presently negotiating with the government to become state registered and recognised. Some CAM therapies (such as reflexologists, homeopathy, reiki, meditation) have several rival professional bodies competing for members. The government want competing regulatory bodies to amalgamate into a single body to represent the whole profession, but some members are resistant to that, remaining loyal to their old institution. There is a ‘British Register of Complementary Practitioners.’ There is also a ‘Complementary Natural Healthcare Council’ (CNHC) which was endorsed by the DoH at the bi-annual meeting with Professional Associations on 17.11.09, when Kate Ling, from the professional standards branch confirmed that

CNHC is the only voluntary regulatory body which has official government backing. No other organisation has the same exacting criteria or focus on safety and quality..... The more people who register with the CNHC the more it will be recognised as the only organisation which provides the guarantees that members of the public are looking for.

There are some CAM therapies which have recently been adopted in the West which do not yet have recognised qualifying bodies, such as Bert Hellinger’s family constellation therapy developed from shamanism. It has been found effective in healing individuals, families and societal wounds, such as holocaust, slave trade, apparteid. This is sweeping Germany, Spain, South Africa and elsewhere. The innovative process for developing this healing modality could not have happened if it had been regulated.

The lack of scientific and medical recognition of CAM has hampered the development of effective regulation to protect the public against cowboys. The more that public money becomes available for CAM, (such as by the implementation of this proposal) the easier it will be to get CAM therapies better regulated. However, the need for public protection is not as necessary as in conventional medicine, for reasons given in 4.4a) below.

c) Not all CAM therapists are professional
Being professional costs money, and making a living as a CAM therapist is not easy. Some CAM therapists see only a few clients a week, so make hardly enough money to live on. Some cannot afford to rent a room in a centre, so treat clients in their home. The centres listed below are small businesses, usually converted homes with a few therapy rooms hired out to other CAM practitioners, who work freelance, renting a room as and when a client books them. Some CAM therapists do not belong to a professional body. Some do not keep up to date with continual professional development (CPD)

d) The problem of playing uphill against a free NHS
The reason why it is not easy to make a living either as a CAM therapist or a CAM centre proprietor is that the free NHS has devalued the currency of health. People are used to free treatment, so consider £30 for an hour of CAM treatment as too expensive, whereas they readily spend that on a meal out for two, or £200 per hour on a solicitor.

e) Competition between CAM therapists and centres
Difficulty in getting clients (now worse in the credit crunch) has created a competitive attitude among CAM therapists and CAM centres. This makes them see others as rivals. They seldom see them as colleagues with whom they should co-operate for the common good of their profession. Few see CAM as a profession in its own right. There have been schemes to get the NHS to pay for CAM before. For example, about 3 years ago the physiotherapists tried to get the NHS to pay for physiotherapy. We do not know why it was not implemented.

4.3 Opportunities for this proposal
a) The lack of public trust for drugs and paradigm shift to holism.
Repeated doctor and drug bashing in the media for decades has eroded public trust in the safety and efficacy of conventional medicine, eg report by MPs shows that 300,000 are at risk of hospital-acquired infections (Nov 09) Public consultation meetings held by the NHS shows that the public do not generally believe NHS spokesmen. The drug companies rightly see CAM as their principal rival, and have been using their power in the media to rubbish CAM by saying that CAM has no evidence base of efficacy in randomised clinical trials. Although this is true, it is irrelevant as trials are not the only test of efficacy.

The media spotlight has now turned on the evidence base for drugs, which is unravelling. Repeated scandals in news bulletins show that drug trials have been fudged, resulting in the forced withdrawls: Thalidomide c1970 after children were born deformed, Vioxx in 2004 after 300,000 deaths from heart attacks, Seroxat for children in 2007 after many suicides. Report: ‘Prozac doesn’t work’ (Feb2008) despite 16 million prescriptions pa written for it in UK and 40 million pa worldwide. ‘Pfitzer fined $1.5 billion for deception’. (Sept 09) The drug companies have also been publicly criticised for the lavish way that they promote drugs to doctors with free holidays abroad, and paying doctors to ghost write reports on trials for which they have not seen all the data. (Sept 09) 1,800 deaths pa from anti-psychotic drugs ‘chemical cosh’ which benefit only 1 in 5 dementia patients (12 Nov 09)

Books such as Food is better medicine than drugs by Dr Jerome and The Great Cholesterol Con by Dr Richard Kendrick, expose the problems of drugs. Health service reform is the big issue the USA, from where news bulletins show people at public meetings shouting at each other. There is a battle of belief systems (paradigm) going on - materialist v holist. The vested interests (medical profession and drug companies) are ranged against the public, who are winning the battle of ideas. A paradigm shift is under way which will eventually give CAM the opportunity to take its rightful place as the safest and most cost-effective healing modality, but it will be a long, hard struggle.

b) Opportunity for a marriage between conventional medicine and CAM
A marriage by integration of CAM into the NHS is needed to heal both the NHS, which has been in staffing crisis for decades, and society, which is getting increasingly sicker. The more that a nation spends on public healthcare, the sicker it gets, due to the poison in conventional treatments. In UK we spend 10% of GDP, which politicians of all parties now warn that the nation can no longer afford. In the USA they spend 15%, and as mentioned in 4.1c) above, iatrogenesis (mostly from adverse drug reactions) is now the biggest killer, killing 800,000 Americans pa. A report published in the diamond jubilee of the NHS (2008) showed that the healthiest year in the 20th century for the British people was 1944. There was no NHS, and all available healthcare went to the war-wounded. When doctors went on strike (in other countries) people’s health improved.

Conventional medicine is male dominated, and needs the female sensitivity and wisdom of CAM to moderate it. The time has come for the overwhelmed male conventional therapists and the underwhelmed female CAM therapists to stop shouting at each other like neighbours from hell, get married, co-operate and live happily ever after. Integration of CAM therapists into the NHS will increase the number of public healthcare staff by half as many again, as called for in the Wannless report. Integration of cost effective CAM interventions into the NHS will also solve the NHS funding crisis. The public benefits of this proposal are so great that NHS managers will eventually be forced to take this proposal seriously.

c) Opportunity for collaboration with welfare reform companies
Welfare reform companies (such as A4E, Workdirection, Reedinpartnership) are working towards the government’s objective to get unemployed people into work. Their objectives and ours overlap concerning the 2.6 million nationally who are on incapacity benefit because of sickness. We are contacting these companies to work with them.

d) Real accountability: guidance on the NHS duty to report on consultation
New legislation will come into force in April 2010. The NHS duty to report on consultations will require all PCTs and SHAs that commission services to explain how they have acted upon feedback from patients and the public. ‘Real Accountability’ aims to help the NHS get ready for the legislation. The guidance explains the legal obligations and provides practical help and advice in terms of preparing and publishing reports. This will make it more difficult to consult and ignore.

e) Revolution or evolution: the challenges of conceptualizing patient and public involvement in a consumerist world
This is from the abstract of a new report by Prof Jonathan Q. Tritter, which indicates a change in the paternal attitude of public health services throughout the world giving opportunity for patients to have a say in public health matters.

Background Changing the relationship between citizens and the state is at the heart of current policy reforms. Across England and the developed world, from Oslo to Ontario, Newcastle to Newquay, giving the public a more direct say in shaping the organization and delivery of healthcare services is central to the current health reform agenda. Realigning public services around those they serve, based on evidence from service user's experiences, and designed with and by the people rather than simply on their behalf, is challenging the dominance of managerialism, marketization and bureaucratic expertise. Despite this attention there is limited conceptual and theoretical work to underpin policy and practice.
Objective This article proposes a conceptual framework for patient and public involvement (PPI) and goes on to explore the different justifications for involvement and the implications of a rights-based rather than a regulatory approach. These issues are highlighted through exploring the particular evolution of English health policy in relation to PPI on the one hand and patient choice on the other before turning to similar patterns apparent in the United States and more broadly.

f) Patient designed services could save the NHS billions
This paper from the National Endowment for Science, Technology and the Arts (NESTA), argues that savings in the NHS could be achieved through radical patient-centred service redesign and more effective approaches to public behaviour change. Allowing doctors and patients to design healthcare services could save the NHS £20bn by 2014. (see

g) Consultation on the NHS Constitution
This DoH consultation proposes new patient rights to treatment within a maximum of 18 weeks from a GP referral and to be seen by a cancer specialist within 2 weeks from a GP referral, or where this is not possible, for the NHS to take reasonable steps to offer a range of alternative providers; and NHS Health Checks for those aged 40 to 74 to assess their risk of heart disease, stroke, diabetes and kidney disease It also welcomes views on areas where the Department of Health believes they will soon be able to offer rights, such as dentistry, evening and weekend access to GPs, personal health budgets, the ability to choose to die at home and rapid access to diagnostic tests.

Following the commitment in Building Britain's Future to strengthen advocacy and redress systems, the consultation also seeks views on the proposed role of the Constitution Champion. Go to the Department of health web site to respond to the consultation by 10th Feb at:
DoH Consultation

4.4 Threats against this proposal
a) Doctors’ prejudice against CAM.

As mentioned in 4.2a) above, the medical profession are prejudiced against CAM. Under their materialist paradigm the only valid intervention is what is done to the body. Mind, spirit, holism are not in their vocabulary. Doctors are the most conservative members of society, so they are the last people to voluntarily accept a paradigm shift to holism, which underlies CAM. (However, this might change in 2011 when the DoH will require doctors to be revalidated.)

It is not managers who run hospitals but doctors. This was the conclusion of Gerry Robinson in the TV series on ‘Fixing the NHS’ in Nov 2007 and ‘One Year After’ in Nov 2008. This proposal can therefore expect opposition from the prejudice of the old guard of doctors, backed up by the vested interests of the drug companies for patients to ‘keep taking the pills’, to maintain their profits.

The biggest threat to this project is that the old guard will pressurise the commissioners (who are managers, but without power over the treatments they commission) to refuse to contract with the company that we create. The NHS commissioners have a monopoly over the spending of public money. Without a contract the company can do nothing. The trump card of the old guard of doctors is: ‘contract for CAM over my dead body’ which can kill this proposal stone dead in its tracks.

b) Refusal to sign a contract for CAM
This threat has already materialised. We received a letter dated 5.10.09 from Darren Grayson, the chief executive of Brighton and Hove NHS stating: ‘we are not intending to commission practice based generic alternative therapy provision at this point in time’. He confirmed on the phone that this letter is intended to shut the door on this proposal for the next 5 years. However, we regard it as a test of our resolve. It has galvanised us into redrafting this business plan in a more robust way and recruiting potential allies to our cause.

We intend to put pressure on Darren to change his mind and come to the negotiating table. His team is required to publish their strategic commissioning plan for the next 3-5 years soon (the present target date is 25th Nov) They then have to consult the public on it. We will then challenge him to justify the absence of generic CAM in it.

We are therefore publicising our scheme in the media and to people who may have an overlapping interest, such as the SHA, DoH. DWP, and companies such as A4e Workdirection and Reedinpartnership. Even if Brighton and Hove NHS do not take up this scheme as a pilot, some other PCT might do so.

We also intend to test public support by a petition as follows:

Free complementary therapy on the NHS
We, the undersigned, support the proposal for a social enterprise company to contract with the NHS commissioners to provide free complementary and alternative medicine (CAM) vouchers for use in the existing CAM centres in the city, see section

Brighton and Hove Council are launching an online petition service on 21.11.09. on ‘Get Involved Day’, when we hope to launch it.

c) Throttling registering centres with red tape and unnecessary expense
As and when the Brighton and Hove commissioners change their mind and come to the negotiating table, new threats will arise. The next threat will be that the old guard will try to kill the viability of this scheme by burdening the registered centres with un-necessary red tape and expense. For example, they may put into the contract the same clinical governance arrangements as prevail in conventional medicine, such as all therapists have to have membership of a state registered professional body, and have expensive professional indemnity insurance.

This is required in conventional medicine because patients’ health is often damaged by their invasive treatments, known as iatrogenesis, - doctor-induced illness, described above. If that happens, patients or their relatives can sue for damages. The risks of being sued are now so high that professional indemnity insurance can cost tens of thousands of pounds pa for doctors.

CAM treatments are gentle and have no side effects or adverse reactions. We have never heard of any iatrogenic death or serious injury from a CAM intervention, nor of any CAM therapist being sued by a client. The worst outcome of CAM is a nil effect. The company will prevent unreasonable clinical governance demands being imposed on registered centres and CAM therapists.

d) CAM centres declining to register with the company
As mentioned in paragraph 2e) above, CAM professions are not used to working together. They may have an attitude of‘ territorial rivalry, such as the osteopaths not wanting to join a body that includes chiropractors or physiotherapists. For the scheme to provide CAM as a community service there need to be at least as many registered CAM centres as GP surgeries (47) If the company does not get enough, it will not be viable. We believe that the prospect of receiving £1 mpa per centre of public money by 2020 will concentrate proprietors’ minds so that all who have suitable premises will register. We assume in the above budget that this is 100.

Part 5 List of CAM centres in Brighton and Hove





Contact and Email



86 Church Rd,
Hove BN3 2EB


Mr & Mrs R. Brown


The Acupuncture Clinic

143 Portland Rd
Hove BN3 5QJ


Chris Dance


Chiropractic Life

88 Portland Rd
Hove BN3 5DL


Dr Richard McMinn


Evolution Arts

2 Sillwood Terrace


Tessa Chisholm/Miranda


Holistic Health Centre

53 Beaconsfield Rd
Brighton BN1 4QH


Sally Roberts, Ann


Wilbury Clinic

64 Wilbury Rd
Hove BN3


Julian Barker


Dolphin House Clinic

14, New Rd
Brighton BN1 1UF


Sara Plumb


Dyke Rd Clinic

274 Dyke Rd
Brighton BN1 5AE


Steve Guthrie/Mandy Majendie


Kemptown Osteopathic Clinic

34, Chesham Rd
Brighton BN2 1NB


Mark Andrews


Albion Clinic

1 Albion St
Brighton BN2 9NE


Jasmin Uddin


Chinese Medicine

49 Queens Rd
Brighton BN1 3XB


Dr Sun


Avicenna Centre of Chinese Medicine

98 The Drive
Hove BN3 6GP


Mrs Al-Khafaji/Tracy Black


Chinese Herbal Health Centre

7 Trafalgar St
Brighton BN1 4EQ


Mark Cai


Andrew Kane Clinic

209 Preston Rd
Brighton BN1 6SA


Andrew Kane/Lester


Anahata Health Clinic

119-120 Edward St
Brighton BN2 0JL


Deborah Wolf/Phillip Tucker


Adhara Natural Therapy Centre

11 Arundel House
22 The Drive, Hove BN3 £JD


Sharron Martincramp


Brighton Acupuncture Clinic

22 Spring St
Brighton BN1 3EF


Susan Truce


Brighton Bowen Clinic

32 Bates Rd
Brighton BN1 6PG


Kirsty Seaborne


Mind and Body Health Clinic

7 Portland Place
Brighton BN


Lis Morris


The Pathway Clinic of CM

28 Coombe Terrace
Brighton BN2 4AD


Tom Sydenham


Move Active Meditation Centre

20 Kirby Drive
Peacehaven BN10 7DY


Paul Collins


China Centre

44 Boundary Rd
Hove BN3 4EF




The Rock Clinic

270 Eastern Rd
Brighton BN2 5TA


Melanie Withers


Hove Skin Clinc

13 New Church Rd
Hove BN3 4AA


Dr Russell Emerson


Sussex Medical Chambers

126 New Church Rd


Junia Bentley


SAKS Beauty Salon

David Lloyd Centre
Brighton Marina
Brighton BN2 5UF


Lisa Grebby


Fiveways Acupuncture Clinic

207 Ditchling Rd
Brighton BN1 6JB




Acupuncture and Herbs

112 St James St
Brighton BN2 1TH


Vivien Zhong


Marine Clinic

12 Marine Drive
Rottingdean BN2 7HQ


Anne Pether


College of Clinical Massage

Unit 4, 20-26 Round Hill St
Brighton BN2 3RG


Michael and Elaine Gibbons


Herb Kingdom (Hove) Clinic

89 Church Rd
Hove BN3 2BA


Di Wu,


Coast Chiropractic

198 Church Rd
Hove BN3 2DU


Dr Anne French/Debbie Brown


Dragon Acupuncture

Upper Gardner St


Nicki Ritchie


The Clinic

34 Dyke Rd Av
Brighton BN1 5LB


Dr Morton Westergaard


Back2Balance Chiropractic Clinic

35 Goldstone Villas
Hove BN3 3RT


Rebecca Nicholas / Barbara


Browns Chiropractic Clinic

177 Preston Rd
Brighton BN1 6AG


Dr David Brown


Sundial Clinic

111 Queens Rd
Brighton BN1 3XF


Mathew Bennett / Nathalie


Sundial Clinic

52 St James St
Brighton BN2 1QG


Dr Richard Hollis







Chiropractic First

82 Goldstone Villas
Hove BN3 3RU


Mark Yacoub


Healing in Motion

LA Fitness, St Helier Av
Hove BN3 3RE


Judith Eaton/ Nicola Dow


Hove Chiropractic

2 West Way
Hove BN3 8LD


Chris Pearcey



Clinic on the Level

2 Ditchling Rd
Brighton BN1 4SF


John Lewis


The Physioterapy Practice

105 Havelock Rd
Brighton BN1 6GL


Susan Foulds / Vicki


Wilbury Physiotherapy Ltd

40 Wilbury Rd
Hove BN3 3JP


Susan Carnaghan


Esporta Health Club

Village Way


Penny Lucy


Soft Tissue Clinic

10 The Drove
Brighton BN1 5NN

Amanda Oswald


Natural Fertility Clinic

Unit 4, 20-26 Roundhill St
Brighton BN2 3RG

Houri Alavi


Brighton Physiotherapy Clinic

56a Marine Parade
Brighton BN2 1PN


Sara Baxter


Palmeira Practice

62 Palmeira Ave
Hove BN3


David Bradley/Susan Sharman


Turning Tide Pilates


Tansy Blaik-Kelly


Evolution Arts

2 Sillwood Terrace
Brighton BN1 1UR



Brighton Buddhist Centre

17 Tichborne St
Brighton BN1 1UR



Jasmine's Wellbeing Centre

10 Blatchington Rd
Hove BN3


Yangli Xu


Pathways to Health

15 New Rd
Brighton BN1 1 UF


Jane Healey


Kemptown Osteopathic Clinc

34 Chesham Rd
Brighton BN2 1NB


Mark Andrews


Fiveways Osteopathic Clinic

308 Ditchling Rd
Brighton BN1 6JG


Nicholas Mitchell


Withdean Osteopathic Clinic

5 Withdean Rd
Brighton BN1 5BL


Pat Maccarthy


Brighton Alexander Technique College

50 Grantham Rd
Brighton BN1 6EF


Carolyn Nicholls


Seven Dials Osteopathic Clinic

71-75 Dyke Rd
Brighton BN1 3JE


Nick Webbe


Sussex Back Pain Clinic

58 New Church Rd
Hove BN3 4FL


Steven Morris


Hove Osteopathic Clinic

235 New Church Rd
Hove BN3 4EE


Tanya May, Richard Skudder


Pain Relief Clinic

77A Carlisle Rd
Hove BN3 4FQ


Stephanie Witts


Charter Medical Centre

88 Davigdor Rd
Hove BN3


Meta Pike


Rex Brangwyn Associates

2 Wilbury Crescent
Hove BN3 6FL


Rex Brangwyn


Cheetahs Gym

King Alfred Centre
Kingsway, Hove BN3


Mark Harper


Coral Health and Fitness Centre

Orchard Rd
Hove BN3 7BG


David Funnell


Korina Biggs

16 Leicester Villas
Hove BN3 5SQ


Korina Biggs


Curves, Ladies only Fitness

353 Portland Rd
Hove BN3 5SF


Bev Baker


LA Fitness Hove

St Helier Ave
Hove BN3


Ryan Tully


Falmer Sports Complex

Ridge Rd, Falmer
Brighton BN1 9PL


Simon Tunley


Fit for All

Unit 1 Portland Rd Ind Est
Hve BN3 5NT


Sera Bates


Fitness First Clubs

78-81 Queens Rd
Brighton BN1 3XE


Mary Sassi / Hannah


(Brighton and Hove)

1st Floor, Blatchington Rd
Hove BN3 3YH


Janet Stokes


Healthy Vibes
Fitness Studio

200 Church Rd
Hove BN3 2DJ


Sue Archer / Finnie


Hilton Metropole
Living Well Club

106-121 Kings Rd
Brighton BN1 2FU


Carl Tudor


LA Fitness

Tower Point,
44 North Rd, Brighton


George Gordon


Lanes Health Club

Queens Hotel, Kings Rd
Brighton BN1 1NS


Lee Willingham


Portslade Sports Centre

Community College, Chalky Rd


Graham Whittaker


Riptide Fitness Centre

150-153 Kings Rd
Arches, Brighton BN1 1NB


Matt Bartsch


ZT Fitness

7 Hove Business Centre
Fonthill Rd, Hove BN3 6HA


Sol Gilbert


Brighton Natural Health Centre

Regent St



Bikrams Yoga College

26-28 Franklin Rd
Portslade BN44


Carolyn Jikieni (CJ)


Dynamic Yoga

Unit 9, Business Centre
Fonthill Rd, Hove BN3 6HA


Stuart Tranter


HSP Holistic Energy Training Centre

79 Trafalgar St
Brighton BN1 4EB


Clare Gaudie


Institute of Ivangar Yoga Sx

17 Langdale Gardens
Hove BN3 4HJ


Andy Roughton


Natural Bodies Yoga Centre

28-29 Bond St
Brighton BN1 1RD


Garry Carter


Sun Power Yoga

18 Baxter St
Brighton BN2 9XP


Michelle Winter


Robert Bonner Chiropodist

25 Windlesham Close
Portslade BN41


Robert Bonner


Ardens Health and Wellbeing Clinic

26 Upper Hamilton Rd


Sarah Arden, Jade Diable


Regina Neming AT

1 Clarendon Villas
Hove BN2


Regina Neming


Claudia Weiss AT

75 Southover St


Claudia Weiss


Sole Sister Chiropody

136 Preston Drive
Brighton BN1 6FJ


Jane Faulkner


Withdean Foot Clinic

1 Valley Drive
Brighton BN1 5FA


Linda Antram


BE Pilates CoachingStudio

121 Eldred Av
Brighton BN1 5EL


Carla Armour


Goodwood Court Medical Centre

52 Cromwell Rd
Hove BN3 3DX


Luke Hawkins


Breakthrough Therapies

15 Braybon Av
Brighton BN1 8EA


Jenny Jenner


Greg Sturges Drama

55 Rugby Place
Brighton BN25JB


Greg Sturges



5b Third Ave
Hove BN 3




European Shiatsu School

Brighton Natural Health Centre
27 Regent St
Brighton BN1 1UL


Markus Grasser


Manos Chiropractor Clinic

34 Palmeira Sq
Hove BN3 2JP


Paul Harris


North Laines Holistic Centre

1 Kemp St
Brighton BN1 4AP


Geraldine Coffey


Alive Fitness and Health Centre

25 Castle St
Brighton BN1


Jose Munns


Shenyang Herbal Centre

106A Western Rd
Brighton BN1 2AA




Back to Health

3 Hove Park Villas
Hove BN3


Patricia Holden


Vitality Acupuncture

40 Coleridge St
Hove BN3 5AD


Penny Boyland


Dyke Rd Natural Health Clinic

274 Dyke Rd
Brighton BN1 5AE


Trevor Gunn


Phoenix Homeopathy

44 Rutland Rd
Hove BN3 5FF

0845 166 8108

Sarah and Paulo Whitaker


Gillian Buck Osteopath Clinic

72 The Drive


Jeremy Buck


Creative Health Connections

18 Eaton Place
Kemptown BN2 1EH


Jocelyn Jones


Miranda Holt Homepath

12 Queens Square
Brighton BN1 3FD


Miranda Holt


The Homeopathic House

35 Carlisle Rd
Hove BN3 4FP


Veronica Walton


Purely Pilates

35 Church Rd
Hove BN3 2BE


Charlie Allerton


Kemptown Homeopathy

18 Prince Regent's Close
Brighton BN2 5JP


Ione Powell


Jane Dickinson Homeopath

11 Hollingbury Terrace
Brighton BN1 7JE


Jane Dickinson


Isis Centre

3 Dorset St
Brighton BN2 1WA



The Spence Practice

22 Elizabeth Av
Hove BN3 6WG


Andrew Spence


PJ Solutions Hypnotherapy

28A Ventnor Villas
Hove BN3


Paula Newman


Nikolov Nik

52 Walsingham Rd
Hove BN3


Nikilov Nik, Francesca Zannoni


Lynne Somerville Hypnotherapy

39 Grange Rd
Hove BN3


Lynne Somerville


Sussex Hypnotherapy Practice

11 Thornhill Way
Portslade BN41


Dave Fowle


Julie James Hypnotherapy

56 Berridale Ave
Hove BN3 4JJ


Julie James


Robinson Cathy

36A Grange Rd


Cathy Robinson


Smart Nutrition

47 Lansdowne Place
Hove BN3


Emma Wells


Ocean Wave Pilates

30 The Drive
Hove BN3 3JD


Jason Thomas


Brighton Shiatsu Centre

55A Grantham Rd
Brighton BN1 6EF



Brighton Shiatsu College

Debbie Collins


No Nonsense Nutrition

20 Lowther Rd
Brighton BN1 6LF


Lindsey Krabbendam


Nutrition Diet and Weight Management

33-35 Beaconsfield Villas
Brighton BN1



Choice for Change

3 Hollingbury Cres
Brighton BN1 7HD


Mary Condell


Centre for Mindfulness Based Education

28 New Rd
Brighton BN1 1UG


Rory Singer


Seaside Practice (homeopath)

3 Langdale Gardens
Hove BN3 4HJ


Lyn Clark


Hove Naturally

66 Sheringham Terrace
Hove BN3 5AF


Chris Kavanagh


Julie Alce

61 Loder Rd
Brighton BN1 6PL


Julie Alce


Herbal Inn Ming Imperial

Western Rd
Brighton BN1




1 Hartington Rd
Brighton BN2 3LJ


Toby Whitehead


Hove Manor Clinic

8 Hove St
Hove BN3 2DF


Hayley Broughton


Crystal Claire

26 Islingword St
Brighton BN2 9UR


Clair Miles


Brighton Ki Centre

12 Queens Square
Brighton BN1 3FD


Hove Therapy Centre

41-43 Portland Rd
Hove BN3 5DQ


Julie Cleasby



This list was compiled by going through the yellow pages. It is incomplete. Please check your entry and send any corrections to us by e mail at If you know other CAM centres in the city which are not on the list and would like to be, please send us their details or tell them to get in touch with us.

Appendix 1

Draft Strategic Commissioning Plan for 2010-16

The following is what we would like NHS Brighton and Hove to put in their Plan, as requested in our letter to Dr Geraldine Hoban, Director of Commission dated 13.12.09.

Much has happened since the last Strategic Commissioning Plan was written in March 2009. The Darzi reforms of July 2008 has forced the NHS into a paradigm shift by placing a statutory duty on us to prevent illness as well as to treat it. The NHS constitution has given patients new statutory rights, including having free NICE approved treatments which their doctor says is clinically appropriate for them. We now have to increase patient safety, improve effectiveness, improve patient experience, reduce our staff sickness by 20%, while planning cuts in spending of 20%, which reduces our present budget by £87 mpa from £432 mpa in 2009/10 to £345 mpa in 2014.

Prevention of illness and promotion of wellness
Accordingly we are planning a massive reallocation of resources from treatment to prevention. We will increase the budget spent on prevention from £4 mpa (1%) now to £104 mpa (30%) in 2014. The emphasis will be on courses which teach patients to take responsibility for their own health, and empower them with self-help techniques by which they can remain well and fit, such as the NICE approved Mindfulness Based Cognitive Therapy (MBCT) course, and the Expert Patient Programme, (EPP).

To fulfill our new statutory requirement to commission the prevention of illness and promotion of wellness we will create a new Trust called the ‘Complementary Care Trust (CCT) which will commission complementary and alternative medicine (CAM) in the same way as the Primary Care Trust (PCT) commissions primary care. The CCT will contract with a social enterprise company to be the sole provider of free CAM on the NHS. This will provide free CAM on the NHS by printing £50 vouchers for CAM which will be distributed to gatekeepers, such as GPs and other healthcare staff. Patients will be offered the choice of conventional treatment as usual or CAM vouchers which will be tradable at any of the 100 registered CAM centres in the city. The budget cost for these CAM vouchers is shown in the ‘prevention’ column of the table below in addition to what we already spend. The ‘treatment ‘ column is conventional treatment as before.


Year Cost £million pa


Prevention                               %

Total Reduction on 2009


















      4 + 4=8







      4 + 14=18







      4 + 33=37







      4 + 100=104







      4 + 100=104







      8 + 100=108





Target number

Statistical number of people affected in city pa


2016 (50% of 2009)


Deaths from all causes pa




Iatrogenis (doctor induced) deaths
note 1




Hospitalisation from Iatrogenis (1 million people pa nationally)




Deaths from suicide pa




Drug users












Clinically depressed








Long term conditions




Teenage pregnancies




On disability benefit (2.5m nationally)




Hospital admissions




GP visits




Deaths in preferred place (home)




No of patients dying with living wills

Hardly any



Dementia patients killed by drugs




Staff off sick (note 3)








'40,000 deaths pa' from TV programme Nov 2000 'Why doctors make mistakes'




'1,800 dementia patients killed by anti-psychotic drugs' News bulletin 1.12.09'




5% staff sickness on 8,000



End of life care.
Polls show that 3 out of 4 patients want to die at home, so that intention will drive our commissioning. Acute hospitals are not designed for dying in, so we will assist GPs to make strenuous efforts to support their patients to die at home, by commissioning hospice at home services. We will also instigate an Advance Decision (living will) form (on the lines of that downloadable free from to go prominently in the patient’s notes. This will empower terminally ill patients to specify interventions that they do not wish to have, such as resuscitation for loss of consciousness, antibiotic for chest infections, intravenous feeding, ventilation, hospitalization. It will also specify to whom they wish to give power of attorney to make decisions for them should they lose capacity. This will help staff and paramedics to take action on which the patient has previously made a conscious decision. This subject is covered in paper ‘Better Planned and Managed deaths at home’ on 9.47 of this website.

Appendix 2

Open letter to

Chief Executive Officer
National Institute for Clinical Excellence (NICE)                 5.6.10
Midcity Place, 71, High Holborn, London WC1V 6NA , 0845 003 7780

The Secretary of State for Health (Rt Hon Andrew Lansley, MP).
Department of Health, Richmond House,
79, Whitehall,
London SW1A 2NS

Dear Sirs


1 Background

The following parties are in dispute about the rights of patients under the NHS constitution in relation to NICE- recommended treatments, and request NICE/SoS to answer the above questions.

a) Plaintiff: John Kapp, secretary of Social Enterprise Complementary Therapy Company (SECTC) representing complementary therapists providing the above treatments, of 22 Saxon Rd, Hove BN3 4LE,, section 9, which contains 10 papers totalling nearly 200 pages in support of SECTC’s case.

b) Defendant: Amanda Fadero, interim Chief Executive NHS Brighton and Hove, and Dr Geraldine Hoban, deputy director of commissioning, (former PCT) commissioners, of Prestamex House, 171, Preston Rd, Brighton, BN1 6AG, 01273 295490,

2 The plaintiff claims that:
a) The above treatments have been recommended by NICE so patients have the right to them under the NHS constitution if their doctor says they are clinically appropriate.

b) Those treatments should therefore be commissioned by the defendant, and provided free at the point of use to such patients within a 18 week wait.

c) The defendant is legally obliged to fund these treatments.

3 The defendant claims that:
a) The only treatments that they, as NHS commissioners, are legally obliged to fund are those recommended by a NICE Technological Appraisal (TAG)

b) None of the above treatments have been recommended by a NICE TAG.

c) Therefore, patients have no legal right to any of these treatments under the NHS constitution.

d) Therefore, they as NHS commissioners, have no legal obligation to commission, provide or pay for any of those treatments.

4 Summary statement of case for the plaintiff:
The plaintiff:
a) Has proposed to the defendant that their new provider company (called Social Enterprise Complementary Therapy Company or SECTC) will print and issue £50 vouchers to GPs in Brighton and Hove to give to their patients for the above NICE- recommended treatments.

b) Claims that chiropractic, osteopathy, acupuncture, Alexander Technique are NICE- recommended for lower back pain.

c) Claims that Mindfulness Based Cognitive Therapy (MBCT) courses are NICE- recommended for depression.

d) Claims that patients have the right to these treatments free under the NHS constitution if their doctors say that they are clinically appropriate.

e) Claims that the condition under d) is met, as the GP would not issue the vouchers to patients for treatment that is not clinically appropriate for them at that time.

f) Has requested the defendant to contract with SECTC an agreement to pay £50 for each used voucher after the patient has received the treatment, so that SECTC can pay the therapist who provided the treatment, in arrears.

5 Summary statement of case for the defendant
The defendant has made the NHS position clear to the plaintiff in the following statements:

On 15.5.10: ‘The PCT would not be supporting the proposal (for CAM vouchers). I would therefore like to reiterate that this is not a model the PCT endorse and we will not be reimbursing SECTC therapists for their treatment sessions.’

On 20.5.10: ‘the PCT is obliged to provide funding for NICE Technology Appraisals Guidance (TAG) within three months of it being issued. However, we also work with providers to ensure all our services are compliant with NICE guidance, but it is not something we are obliged to, or can, deliver immediately in all cases.‘

On 1.6.10: ‘The PCT has a robust system in place for the consideration of all NICE guidance and takes this into account when planning its services. Whilst NICE TAGs are mandatory, we are not legally obliged to adhere to clinical guidance (which includes CG 88 for lower back pain and CG 23 for depression) …The footnote to the constitution says ‘recommended’ means recommended by a NICE TAG. In other words, there is a clear and important distinction in the NHS constitution between NICE TAGs and NICE clinical guidelines. The CAM treatments you refer to are clearly not NICE TAGs, but are the subject of clinical guidelines.’

6 Implication of the defendant’s statements
The above statements imply that the defendant believes that:
a) None of the above treatments are recommended by NICE because they are not the subject of NICE Technology Appraisal Guidance.

b) Therefore patients do not have any right to any of them under the NHS constitution.

c) They as NHS commissioners have no legal obligation to commission, provide, or pay for any of these treatments.

7 NHS constitution
The NHS constitution became statute law on 21.1.10. It states under paragraph 2A: We have added the following italicised emphasis and prefix numbers and letters for future reference.

‘6.1 Nationally Approved treatments
You have the right
to drugs and treatment that have been recommended by NICE for use in the NHS if your doctor says that they are clinically appropriate for you.
6.2 Involvement in your healthcare and in the NHS:
a) You have the right to be involved in discussions and decisions about your healthcare, and to be given information to enable you to do this.
b) You have the right to be involved, directly or through representatives, in the planning of healthcare services, the development and consideration of proposals for changes in the way those services are provided, and in decisions to be made affecting the operation of those services.

6.3 The NHS also commits:
a) to provide you with the information you need to influence and scrutinise the planning and delivery of NHS services (pledge); and
b) to work in partnership with you, your family, carers and representatives (pledge).
6.4 Complaint and redress:
a) You have the right
to have any complaint you make about NHS services dealt with efficiently and to have it properly investigated.
b) You have the right to know the outcome of any investigation into your complaint.
c) You have the right to take your complaint to the independent Health Service Ombudsman, if you are not satisfied with the way your complaint has been dealt with by the NHS.
d) You have the right to make a claim for judicial review if you think you have been directly affected by an unlawful act or decision of an NHS body.’

Footnote: ‘NICE (the National Institute for Health and Clinical Excellence) is an independent NHS organisation producing guidance on drugs and treatments. ‘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.’

8 NICE Guidance CG 23 (Dec 04 Amended April 07) Depression
On p13, under the heading of ‘Psychological treatments’ this document states: ‘Mindfulness based CBT should be considered for patients for recurrent depression. B’ On page 15 under the title of ‘Grading of the recommendations’ it says:

‘B Based on level ll or level lll evidence (well conducted clinical studies but no RCTs) or extrapolated from level l evidence.
‘N Evidence from NICE technological appraisal guidance.’

The plaintiff accepts that the MBCT course is not subject to a NICE TAG because it has a suffix ‘B’, (not an .’N’) after it, and therefore is technically not ‘recommended’ by NICE for mandatory funding by commissioners within 3 months.

However, under the heading of ‘Implementation’ this document states:
‘Local health communities should review their existing practice in the treatment and management of depression against this guideline. The review should consider the resources required to implement the recommendation…….It is in the interests of patients that the implementation timeline is as rapid as possible. Relevant local clinical guidelines, care pathways and protocols should be reviewed in light of this guidance and revised accordingly. ‘

The plaintiff complains that although this guideline was issued 6 years ago, the intended result of CG23, (namely the provision of the MBCT course in sufficient quantity to meet the demand within a 18 week wait) has still not materialised. Furthermore, the defendant is in breach of their own statement quoted above dated 20.5.10: ‘However, we also work with providers to ensure all our services are compliant with NICE guidance, but it is not something we are obliged to, or can, deliver immediately in all cases.‘ (our emphasis)

The defendant commissions mental health services for Brighton and Hove from the Sussex Partnership Foundation Trust (SPFT) which is the sole provider of mental health services for the whole of Sussex, with a population of 1.5 million. There is still only one therapist (Robert Marx) providing MBCT courses each year on the NHS for up to 20 patients per course. His capacity is to provide 4 courses pa, so up to 80 patients can be treated pa. The source of this information was a letter to the LINk dated Nov 2009 in answer to their question.

The plaintiff complains that the defendant has ‘ticked the box’ declaring their good intention to implement all NICE- guidelines (whether TAG or not) given sufficient time. However, they are either not aware, (or unwilling to acknowledge) that they have failed to do so in the case of the MBCT course. The plaintiff has been campaigning for nearly 2 years to both the commissioners and the SPFT providers that this provision is inadequate for the potential demand, and should be increased a thousand times to 70,000 patients pa, or 1 in 20 of the population to provide a mental health service worthy of the name ‘service’.

9 CG 88 dated May 09 Low back pain
Box D
Choice of treatment states: Offer one of the following treatment options, taking patient preference into account. Consider offering:

  Structured exercise programme
  Manual therapy, course of manual therapy, including spinal manipulation up to 9 sessions over up to 12 weeks. (A footnote on p7 states that this includes spinal mobilization and massage by chiropractors, osteopaths, and also by doctors and physiotherapists who have undergone specialist postgraduate training in manipulation)
  Acupuncture : course of acupuncture needling, up to 10 sessions over up to 12 weeks.
  If the chosen treatment doesn’t result in satisfactory improvement consider offering another of these options.

It goes on: ‘Having received at least one of these (box D) less intensive treatments, under the care pathway, if this results in a poor outcome, or unsatisfactory improvement, or significant psychological distress and/or high disability’, another box applies, as follows: ‘Consider referral for a combined physical and psychological treatment programme which comprises around 100 hours over up to 8 weeks, which should include a cognitive behavioural approach and exercise. ‘

The plaintiff claims that the MBCT course would be clinically appropriate for these ‘depressed low back pain’ cases, but that these courses are not available, because the defendant is not commissioning the courses in sufficient numbers.

Unlike CG23, there are no gradings or suffixes on CG 88 to indicate whether CG88 has the status of a TAG or a ‘guideline’. The plaintiff believes that it therefore has the status of a TAG, because it says in the opening paragraph: ‘About this booklet. This is a quick reference guide that summarises the recommendations NICE has made to the NHS in ‘low back pain’. (our emphasis) The plaintiff therefore claims that the defendant is honoring neither the letter nor the principle of CG88.

The plaintiff therefore claims that the defendant should therefore have been commissioning manual therapy (including spinal manipulation by chiropractic and osteopathy), according to CG 88 since Sept 09 (3 months after CG88 was issued, in May 09). Furthermore, the plaintiff believes that Alexander Technique has been subsequently added to the list of manual therapies since CG 88 was issued, so it should also be commissioned by the defendant for low back pain.

10 The case for the plaintiff’s complaint of discrimination
The plaintiff therefore claims that the defendant’s refusal in principle to pay for used vouchers for the above treatments recommended in CG23 and CG88, is in breach of the letter and the spirit of those guidelines, and discriminates against the following:

a) GPs, by denying them the opportunity to prescribe those clinically appropriate treatments by voucher to patients with those conditions.

b) Those patients by denying them the benefit of receiving those treatments, in breach of their rights under the NHS constitution.

c) Complementary therapists providing those treatments, by denying them the opportunity to treat NHS patients free on the NHS.

d) 3 out of 4 patients who say in polls that they want complementary therapy free on the NHS, who should be given that choice of treatment because they pay for the NHS through their taxes.

e) The government’s pledges under items 2 and 3 above of the NHS constitution, which commit the NHS to involve patients and their representatives in decisions about their healthcare treatments. The plaintiff has been an active patient representative in the Patient and Public Involvement Forum (PPIF) since 2006, and the Local Involvement Network (LINk) since 2008, and has been actively campaigning on these issues throughout that time, without satisfactory result.

f) The government’s pledge to remove health inequalities, because it leaves access to those treatments dependent on patients’ ability to pay for them out of their own pocket, which most patients cannot afford.

11 Questions for answer
The plaintiff requests NICE and SoS to answer the following questions:

1. Whether or not the following treatments are NICE TAG recommended:
a) Chiropractic for lower back pain.
b) Osteopathy for lower back pain.
c) Acupuncture for lower back pain.
d) Alexander Technique for lower back pain.
e) Mindfulness Based Cognitive Therapy (MBCT) courses for depression.

2 Whether patients have the statutory right to any of those treatments under the NHS constitution?

3 Whether the NHS commissioners have a statutory duty to commission, provide or pay for any of those treatments?

4 If ‘yes’ to question 3, whether patients have a right to those treatments within a 18 week wait?

12 Implications of a determination favourable to the plaintiff
a) Numbers of patients affected

About a third of patients in GP’s surgeries are said to present with lower back pain, and a further third present with anxiety and depression. The total number of patients affected by these conditions is not known exactly, but the approximate numbers are indicated by the following statistics. The number of people in UK affected with arthritis (which frequently starts with lower back pain) is about 8 million, and with depression 6 million. The number with long term conditions is 17 million.

b) Efficacy of conventional and complementary treatments
Conventional treatment for lower back pain is pain-killing and anti-inflammatory drugs. That for depression is anti-depressant medication, such as Prozac, (for which 16 million prescriptions were written in 2005) yet has been shown in a meta-study in 2008 to be no more effective than placebo. The media headline at the time (Feb 08)was: ‘Prozac doesn’t work.’

These conventional treatments temporarily relieve the symptoms, but do not address the cause, so usually do not effect a permanent cure. They may have harmful side effects, which may make the condition worse rather than better. The fact that the nation’s health is deteriorating, despite the doubling of the healthcare budget since 1997 indicates that these conventional treatments are not working.

To improve public health we therefore have to switch to the complementary approach of the above treatments. Their evidence base that they work is proved by becoming robustly established in the market place, despite playing uphill against free conventional treatment. These complementary treatments are not interventions in the conventional sense of something being done to the patient’s body. Rather they are facilitation of lifestyle changes that the therapist teaches to the patient, who has to do them for himself to cure the condition by removing the cause. Accordingly, they are not quick fixes, but need many (typically 10-20) treatments at weekly intervals. This is a re-invention of the word ‘doctor’ which comes from the latin ‘doctare’ to teach.

Lower back pain is caused by dis-functional use of body as seen it its posture. The cure is self-help by teaching the patient to become aware of this, and learning better use. Depression is caused by negative thoughts, and the cure is teach the patient to become aware of them through meditation practice, and to dis-identify self with them.

b) Cost implications
Assuming that there are 8 million patients with lower back pain, who each need an average of 15 treatments each costing one voucher (£50), the cost to the NHS would be 8mX15X£50=£6bn. Assuming that there are 6 million depressed people who want a MBCT course costing £300 (6 vouchers) the cost would be 6mX£300= £1.8bn. The total cost to the NHS would be £7.8bn.

These treatments are potentially curative of long term conditions and are also preventative of them getting worse. If this sum was spent on them every year it would be about 7.8% of the total UK health budget (£100bnpa) The Marmot inquiry (Feb 2010) called for 7% (£7 bnpa) to be spent on prevention. The plaintiff believes that the Darzi requirement to prevent sickness, and the Boorman target of saving 3.5 m days lost pa by NHS staff sickness would both be met if these NICE recommendations were implemented by the NHS commissioners. The health of the nation would be dramatically improved, and much of the present cost of conventional treatments would be saved, so that the overall cost to the taxpayer of the NHS would be reduced.

13 Conclusion
The plaintiff requests NICE/SoS to resolve this dispute by adjudicating on the above questions, and making public their adjudication.

Yours sincerely

                                                  John Kapp (for SECTC as plaintiff)

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