Quackwatch Home Page
Analysis of the Final WHCCAMP
Report
Chapter 10: Recommendations and Actions
[Comments in red by Stephen
Barrett, MD, and Timothy N. Gorski, MD, FACOG]
COORDINATION OF RESEARCH
Recommendation 1: Federal agencies should receive increased
for clinical, basic, and health services research on CAM.
Actions
| 1.1 |
Federal agencies should increase
their activities with respect to CAM in accordance with their
biomedical research, health services research, or other health
care-related responsibilities and make these activities, including
available technical assistance, known to CAM and conventional
researchers and practitioners. Activities might include funding
initiatives such as requests for applications and proposals;
CAM-focused offices or centers; CAM-focused staff positions;
CAM advisory committees or the representation of qualified CAM
professionals on such committees. [Research
priorities should depend on the likelihood that projects will
yield significant results and not on whether or not they are
marketed as "CAM."] |
| 1.2 |
Federal agencies should assess the
scope of scientific, practice, and public interest and needs
regarding CAM that are relative to their missions, examine their
portfolios, and develop funding distribution strategies to address
these interests and needs. [Since "public
interest" is not necessarily related to effectiveness, it
should not be a major factor in determining research priorities.] |
| 1.3 |
The Agency for Health Care Research
and Quality together with The National Center for Complementary
and Alternative Medicine should develop ways to expand health
services research in CAM and explore methodologies for health
services research in this area. [NCCAM
and its predecessors have produced no significant findings during
its ten years of existence. It makes more sense to abolish it
than to increase its funding.] |
| 1.4 |
The Federal, private, and nonprofit
sectors should support more research on (1) complex compounds/mixtures
frequently found in CAM products, (2) clinical interventions
consisting of multiple treatments, (3) how patient-practitioner
interactions affect treatment outcomes, and (4) individualizing
treatments. [Identifying the active
ingredients of promising herbs is a worthwhile endeavor that
has been taking place for decades. But this recommendation also
supports clinical research on crude extracts (chemical mixtures)
that is likely to be unproductive. It might also be useful to
study patient-practitioner interactions. However, research expenditures
and other incentives should be proportional to probable value,
not whether something is labeled "CAM."] |
| 1.5 |
n order to protect public health
and maximize benefits, Congress should provide adequate public
funding for research on frequently used or promising CAM products
that would be unlikely to receive private research support. [This falsely implies that their are many promising
"CAM" products. Frequency use should be considered
only if a product appears to be effective.] |
| 1.6 |
The Federal government should support
research on CAM practices that appear to be effective but may
not be profitable to private investors, such as biofeedback,
meditation, guided imagery, art therapy, and music therapy. [Research priority should be related to the
probability of obtaining useful results, not according to whether
something is marketed as "CAM."] |
Recommendation 2: Congress and the Administration should
consider enacting legislative and administrative incentives to
stimulate private sector investment in CAM research on products
that may not be patentable.
Actions
| 2.1 |
Incentives to stimulate private sector investment
in CAM research should focus on (1) research on dietary supplements
and other natural products that may not be patentable; (2) research
on other CAM products that may not be patentable, including therapeutic
devices; and (3) the development of analytical methods for producing
better quality CAM products. [Research
priority should be related to the likelihood of useful results
and not to whether products are classified as "CAM." |
| 2.2 |
The Federal and private sectors should provide
support for workshops to discuss the research needed by regulatory
agencies for their review and approval processes for CAM products
and devices. [This recommendation puts
the cart before the horse. CAM advocates do not need special
training in how to get things approved. Regulatory approval is
based on proof of safety and effectiveness. Whether methods are
standard or are labeled "CAM" is not relevant. What
counts is whether or not they work.] |
| 2.3 |
Federal agencies should develop outreach programs
to inform manufacturers of CAM products and devices about the
Federal research support available to private industry and how
the agency can assist them. |
Recommendation 3: Federal, private, and nonprofit sectors
should support research on CAM modalities and approaches that
are designed to improve self-care and behaviors that promote
wellness. [Research priorities should be
determined by the likelihood of useful findings and not whether
they are identified as "CAM." Proven self-care and
wellness strategies are part of mainstream public health and
should not be identified as "CAM."]
Recommendation 4: Federal, private, and nonprofit sectors
should support new and innovative CAM research on core questions
posed by frontier areas of scientific study associated with CAM
that might expand our understanding of health and disease.
Actions
| 4.1 |
The National Center for Complementary
and Alternative Medicine, assisted by the Institute of Medicine
of the National Academy of Sciences, should develop guidelines
for establishing research priorities in CAM . [NCCAM
has supposedly been doing this for many years.] |
| 4.2 |
The National Science Foundation,
in collaboration with The National Center for Complementary and
Alternative Medicine, should examine frontier areas of science
associated with CAM that are outside the current research paradigm
and methodological approaches to study them. [This
falsely assumes that that "frontier areas of science associated
with CAM" are rational but cannot be tested by established
research methods. This appears to include alleged supernatural
forces such as"electromagnetic energy flow" that cannot
be measured with scientific instruments.] |
| 4.3 |
Multidisciplinary workshops and
expert panels should be convened by Federal, private and nonprofit
organizations, collaboratively or independently, to explore the
challenges in design and methodology presented by research questions
in CAM areas that are outside the current research paradigm.
[The fact that quack methods cannot
be substantiated does not mean that science-based standards of
evidence should be lowered.] |
| 4.4 |
The National Institute of General Medical Sciences
of the NIH, the Department of Energy, and the Department of Defense
are among the Federal organizations that should consider contributing
collaboratively or independently to the support of research on
core questions in areas described in many CAM systems. [This is a blatant pitch for more research funds
for studying methods marketed as "CAM." Research dollars
should be allocated according to potial usefulness rather than
how they are designated.] |
| 4.5 |
The National Center for Complementary and Alternative
Medicine, working with the World Health Organization, should
examine investigative approaches for studying the traditional
systems of medical practice from a variety of cultures. [The study of folk healing is probably not a
cost-effective way to discover new methods.] |
Recommendation 5: Investigators engaged in research on CAM
should ensure that human subjects participating in clinical studies
receive the same protections as are required in conventional
medical research and to which they are entitled.
Actions
| 5.1 |
Licensed practitioners
using CAM systems and modalities who wish to conduct or collaborate
in clinical research should follow the same requirements as in
conventional medical research. They should develop, or partner
with a research institution to develop, a scientifically valid
research protocol and obtain Institutional Review Board approval
to ensure that they meet accepted standards of ethical conduct
and their responsibilities to protect human subjects. [These are standard operating procedures for
scientific research.] |
| 5.2 |
Accredited CAM institutions
and CAM professional organizations should establish Institutional
Review Boards where possible, and guide their colleagues and
members to utilize the Institutional Review Board process, which
is required to conduct clinical research. |
| 5.3 |
Institutional Review
Boards that review CAM research studies should include the expertise
of qualified CAM professionals in the review. |
| 5.4 |
Research institutions, National
Institutes of Health Institutes and Centers, and other Federal
research and health care agencies should be more proactive in
developing programs that (1) provide opportunities for expert
review of promising CAM practice-based observational data by
experienced researchers, (2) stimulate practitioner response
to the opportunities offered by the programs and (3) facilitate
communication and stimulate partnerships between CAM practitioners
and conventionally-trained researchers in designing and implementing
clinical studies. |
Recommendation 6: The Commission recommends that state professional
regulatory bodies include language in their guidelines stating
that licensed, certified, or otherwise authorized practitioners
who are engaged in research on CAM will not be sanctioned solely
because they are engaged in such research if they: (1) are engaged
in well-designed research that is approved by an appropriately
constituted Institutional Review Boards, (2) are following the
requirements for the protection of human subjects, and (3) are
meeting their professional and ethical responsibilities. All
CAM and conventional practitioners, whether or not they are engaged
in research, must meet whatever State practice requirements or
standards govern their authorization to practice. [This
proposal, if implemented, would enable practitioners of quack
methods to escape rstate egulatory action by setting up their
own Institutional Review Boards.]
Recommendation 7: Increased efforts should be made to strengthen
the emerging dialogue among CAM and conventional medical practitioners,
researchers and accredited research institutions; Federal and
state research, health care, and regulatory agencies; the private
and nonprofit sectors; and the general public.
Actions
| 7.1 |
CAM and conventional
medical researchers and practitioners should adhere to the same
high standards of quality and ethics in all aspects of research
and related activities. [This is self-evident
but exaggerates the likelihood that "CAM" researchers
and practitioners can achieve high standards of quality and ethics.] |
| 7.2 |
Federal agencies should
develop programs to stimulate cooperation and partnerships between
CAM and conventional medical professionals and accredited institutions.
[This exaggerates the likelihood that
"CAM" practitioners can enter into useful partnerships
with science-based practitioners and their institutions.] |
| 7.3 |
Committees reviewing
or advising on research, journal submissions, regulatory compliance,
and health insurance coverage in both the public and private
sectors should include as members or consultants trained, experienced,
and properly qualified CAM health care professionals. [This falsely implies that many "properly
qualified CAM health professionals" exist. TMoreover, the
choice of experts should be based on the quality of their work
rather than how they label and market themselves.] |
| 7.4 |
Multidisciplinary conferences,
workshops, and expert panels on CAM research and related activities,
including research methodology, should be supported independently
or collaboratively by the public, private, and nonprofit sectors.
[Such intermingling would have political
value for "CAM" proponents but is unlikely to add to
scientific knowledge.] |
| 7.5 |
The nonprofit sector
and the private sector should create funding partnerships, whether
independently or with Federal agencies, to augment support for
CAM research, research infrastructure and training, research
conferences, and information dissemination. [Nonprofit
and private organizations can give money to whomever they please.
Allocation of government funds should be based on scientific
standards, not how methods are classified.] |
| 7.6 |
The Federal government
should support research, including population-based research,
to learn more about why people use CAM practices and products,
how they determine the safety and effectiveness of the practices
and products they use, and what they find satisfying or unsatisfying
about them. [If done properly, research
of this type could be used to educate people on how to avoid
being quacked. But the statistics could also be used to promote
irrational methods by trumpeting about how popular they are.] |
| 7.7 |
To benefit patients and future research
protocol development and to add to our knowledge about the use
of CAM, Institutional Review Boards should consider requiring
that all research subjects be asked about their use of herbal
or other dietary supplements. [This
might be important if using dietary supplements or herbs could
confound the data. But routine questioning might convey an underlying
message that the products are so important that they deserve
special consideration.] |
| 7.8 |
Federal agencies supporting biomedical
and health services research should develop orientation and training
programs for public representatives to enhance the effectiveness
of their participation on advisory committees concerned with
CAM. [It does not make sense to train
people whose judgment is so poor that they advocate wildly implausible
hypotheses.] |
Recommendation 8: Public and private resources should be
increased to strengthen the infrastructure for CAM research and
research training at conventional medical and CAM institutions
and to expand the cadre of basic, clinical, and health services
researchers who are knowledgeable about CAM and have received
rigorous research training.
Actions
| 8.1 |
Funding should be made available
to accredited CAM and conventional medical institutions develop
programs that examine CAM research questions and that stimulate
cross-institutional collaborations involving faculty and students
in research and research training. |
| 8.2 |
Funding should be made available
to accredited CAM and conventional medical institutions support
joint research and professional education and training programs
to enhance the quality and clinical relevance of CAM research
and link the research with evidence-based education and training
of practitioners. [This falsely assumes
that training advocates of irrational practices will lead to
valuable results. There is no logical reason to assume that it
will. Moreover, CAM is a marketing term, not a genuine field
of health care.] |
| 8.3 |
Federal health agencies with research
training programs and responsibilities that encompass CAM-related
questions should be given adequate support to increase research
training in CAM. [This falsely assumes
that training advocates of irrational practices will lead to
valuable results. There is no logical reason to assume that it
will. Moreover, CAM is a marketing term, not a genuine field
of health care.] |
| 8.4 |
Existing resources, such as The
National Center for Complementary and Alternative Medicine-supported
centers and the National Center for Research Resources' General
Clinical Research Centers should be utilized to increase opportunities
to conduct clinical research and training on CAM and examine
the inclusion of CAM into the clinical setting. [Despite
nearly ten years of distributing grant money, NCCAM and its predecessors
have produced no useful clinical research findings. It makes
no sense to increase their funding.] |
| 8.5 |
Federal support should be increased
for career development awards, including those that enable investigators
focusing on CAM to develop into independent investigators and
faculty members, and mid-career awards that provide the time
required to mentor new CAM investigators. [The
basis for training career investigators should be the quality
of their work, not whether they label or market themselves as
"CAM" investigators.] |
Recommendation 9: Public and private resources should be
used to support, conduct, and update systematic reviews of the
peer-reviewed research literature on the safety, efficacy, and
cost-benefit of CAM practices and products.
Actions
| 9.1 |
The Agency for Health Care Research
and Quality should expand its Evidence-based Practice Center
systematic reviews on CAM systems and treatments for use by private
and public entities in developing tools, such as practice guidelines,
performance measures, and review criteria, and for identifying
future research needs. [This falsely
implies that current methods of scientific review are defective
and that "CAM" methods should be reviewed differently.] |
| 9.2 |
The National Center for Complementary
and Alternative Medicine should issue a comprehensive, understandable,
and regularly updated summary of current clinical evidence on
the safety and efficacy of CAM systems and treatments for health
care practitioners and the public. [Many
such summaries have been published. Whether more would serve
any useful purpose would depend on who compiles them and whether
their conclusions are supported by scientific evidence. To date,
neither NCCAM nor WHCCAMP has ever publicly concluded that any
"CAM" method is worthless and should be abandoned.
The call for dissemination of "evidence" attempts to
conceal how little there is that is worth disseminating.] |
EDUCATION AND TRAINING OF HEALTH CARE PRACTITIONERS
Recommendation 10: The education and training of CAM and
conventional practitioners should be designed to ensure public
safety, improve health, and increase the availability of qualified
and knowledgeable CAM and conventional practitioners and enhance
the collaboration among them.
Actions
| 10.1 |
Conventional health professional
schools, postgraduate training programs, and continuing education
programs should develop core curricula of knowledge about CAM
to prepare conventional health professionals to discuss CAM with
their patients and clients and help them make informed choices
about the use of CAM. [It is safe to
assume that WHCCAMP expects CAM advocates to control any such
activities and to promote unsubstantiated methods.] |
| 10.2 |
CAM education and training programs
should develop curricula that reflect the fundamental elements
of biomedical science and conventional health care relevant to
and consistent with the practitioners' scope of practice. [This falsely assumes that many methods marketed
as "CAM" deserve advocacy in training programs.] |
| 10.3 |
CAM and conventional education and
training programs should develop curricula and other methods
to facilitate communication and foster collaboration between
CAM and conventional students, practitioners, researchers, educators,
institutions and organizations. [This
falsely assumes that many methods marketed as "CAM"
deserve advocacy in training programs and that the offerings
"CAM" advocates are likely to be trustworthy.] |
| 10.4 |
Increased Federal, state, and private
sector support should be made available to expand and evaluate
CAM faculty, curricula, and program development at accredited
CAM and conventional institutions. [This
is a blatant call for promotion of unsubstantiated methods and
their advocates throughout our medical educational system. Just
the opposite is needed. Science-based accrediting bodies should
attack the quackery that that has infiltrated medical education
within the past few years.] |
| 10.5 |
Expansion of eligibility of CAM
students at accredited institutions for existing of loan programs
should be explored. [This would help
subsidize students at schools of acupuncture and naturopathy
whose teachings advocate irrational practices such as homeopathy.] |
| 10.6 |
The Department of Health and Human
Services should conduct a feasibility study to determine whether
appropriately educated and trained CAM practitioners enhance
and/or expand health care provided by primary care teams.* This
feasibility study could lead to demonstration projects to identify:
1) the type of practitioners, 2) their necessary education and
training, 3) the appropriate practice settings, and 4) the health
outcomes attributable to the addition of these practitioners
and services to comprehensive care. [This
falsely implies that "CAM" advocates have a lot to
offer. However, adding ineffective methods to effective ones
will increases the cost of health-care delivery but not its quality.] |
| 10.7 |
The Department of Health and Human Services
and other Federal Departments and Agencies should convene conferences
of the leaders of CAM, conventional health, public health, evolving
health professions, and the public; of educational institutions;
and of appropriate organizations to facilitate establishment
of CAM education and training guidelines. Subsequently, the guidelines
should be made available to the states and professions for their
consideration. [This falsely assumes
that rational guidelines can be written for teaching irrational
methods.] |
| 10.8 |
Feasibility studies of postgraduate training
for appropriately educated and trained CAM practitioners should
be conducted to determine the type of practitioners, practice
setting, and their impact on clinical competency, quality of
health care, and collaboration with conventional providers. [Here WHCCAMP demands that residency training
be corrupted by giving CAM advocates free reign to promote their
anti-scientific nonsense.] |
| 10.9 |
Practitioners who provide CAM services and products
should complete appropriate CAM continuing education programs
that include critical evaluation of CAM to enhance and protect
the public's health and safety. [There
is no reason to expect that science-based CAM continuing education
programs can be created or that "CAM" practitioners
would attend such programs or be influenced by them. To be "appropriate,"
such programs would have to advocate abandonment of "CAM"
methods that are irrational. |
CAM INFORMATION DEVELOPMENT AND DISSEMINATION
Recommendation 11: The Federal government should make available
accurate, useful, and easily accessible information on CAM practices
and products, including information on safety and effectiveness.
Actions
| 11.1 |
The Secretary of Health and Human
Services should establish a task force to facilitate the development
and dissemination of CAM information within the Federal government
and to eliminate existing gaps in CAM information. The task force
should include consumers, CAM providers, scientists, and conventional
health care practitioners. Resources should subsequently be provided
to close identified gaps and improve the availability, coordination,
and dissemination of information. [The
only real gaps in government CAM information are (a) the failure
to identify which CAM methods are worthless and (b) the failure
of NCCAM and other government agencies to refer people to information
sources that are justifiably critical of CAM methods. Setting
up more agencies with similar policies would worsen the situation
rather than improve it.] |
| 11.2 |
Federal Departments and agencies
with missions or activities relevant to CAM should 1) develop
informational materials about CAM that are easy to understand
and use, and 2) support and collaborate with national and local
community leaders and CAM leaders and organizations to identify
strategies for enhancing the development, availability, and accessibility
of information on the safety and effectiveness of CAM practices
and products. [It is safe to assume
that WHCCAMP expects CAM advocates to control any such activities
and to promote unsubstantiated methods.] |
| 11.3 |
Increased funding should be provided
to the National Library of Medicine and the American Library
Association to expand training of librarians to include helping
consumers find information on CAM. [This
is another way to promote dubious methods. Why should a particular
subset of medical literature get special status or attention
in libraries merely because it deals with unproven, disproved
or irrational therapies? Moreover, it is safe to assume that
WHCCAMP expects CAM advocates to control any such activities
and to promote unsubstantiated methods.] |
| 11.4 |
The Secretary of Health and Human
Services should direct resources to streamline the process of
identifying and making available relevant, high-quality CAM information
from other countries and in other languages. [This
falsely assumes that other countries have high-quality "CAM"
information available. |
Recommendation 12: The quality and accuracy of CAM information
on the Internet should be improved by establishing a voluntary
standards board, a public education campaign, and actions to
protect consumers' privacy.
Actions
| 12.1 |
The Secretary of Health and Human Services should
form a public-private partnership to review new and existing
websites and to develop voluntary standards promoting
accuracy, fairness, comprehensiveness, and timeliness of information
on CAM web sites, as well as the disclosure of sources of support
and possible conflicts of interest. Sites reviewed and found
in compliance with the standards could publicize the fact and
display a logo denoting their merit. [DHHS's
healthfinder.gov already does a poor job of sorting out reliable
and unreliable sources of CAM information. There is no reason
to believe that another government-sponsored system would work
better.] |
| 12.2 |
Funding should be provided to the Department
of Health and Human Services and the Department of Education
to conduct a joint public education campaign that teaches consumers
how to evaluate health care information, including CAM information,
on the Internet and elsewhere. [Whether
or not such information is useful would depend upon who compiles
and controls it. So far -- for political reasons -- the government-generated
teachings about CAM methods have been woefully inadequate. There
is no reason to believe that additional funding will modify this
situation.] |
| 12.3 |
Congress should protect consumers' privacy by
requiring all health information sites, including CAM sites,
to disclose whether they track users and if so, how that information
is used and stored, including whether it is sold to third parties.
[Individual privacy should be protected
regardless of what information is sought.] |
Recommendation 13: Information on the training and
education of providers of CAM services should be made easily
available to the public.
Actions
| 13.1 |
The Commission recommends that states require
all persons providing CAM services to disclose information regarding
their level and scope of training and to make it easily available
to consumers. [Consumers who want this
information are already free to ask for it. Requiring qualified
practitioners to provide it without being asked will merely increase
their overhead. Requiring unqualified practitioners to disclose
their background would only be useful if consumers could judge
the validity of nonstandard credentials -- something very few
people can do. The real way to protect consumers is to prevent
unqualified individuals from practicing.] |
| 13.2 |
The Commission recommends that states disclose
information on State guidelines, requirements, licensure,
certification, and disciplinary actions of health providers,
including CAM providers, and make it easily accessible to the
public. [Some state licensing boards
already provide such information.Whether doing this is cost-effective
and actually protects people has not been demonstrated. Curiously,
far less public information is available about chiropractors
than about medical doctors and other mainstream practitioners.] |
Recommendation 14: CAM products that are available to U.S.
consumers should be safe and meet appropriate standards of quality
and consistency.
Actions
| 14.1 |
The efforts of both the public and
private sectors to ensure the development, validation, and dissemination
of analytical methods and reference materials for dietary supplements
should be accelerated. |
| 14.2 |
The proposed Good Manufacturing
Practices for Dietary Supplements should be published expeditiously,
followed by a timely review of comments and completion of a final
rule. The Food and Drug Administration should be provided with
adequate resources to complete this task. [GMPs
deal mainly with the technicalities of manufacturing and the
cleanliness of manufacturing and storage facilities. They are
not a substitute for ensuring that the health claims for such
products are legitimate. Worthless or dangerous products prepared
according to GMPs are still worthless or dangerous.] |
| 14.3 |
Adequate funding should be provided
to appropriate Federal agencies, including U.S. Customs and Food
and Drug Administration inspection authorities, to enforce current
laws monitoring the quality of imported raw materials and finished
products intended for use as dietary supplements. [The
FDA already has the legislative tools to do this, but many other
tasks compete for attention from its limited resources.] |
| 14.4 |
Manufacturers should have on file
and make available to the FDA upon request scientific information
to substantiate their determinations of safety, and current statutory
provisions should be periodically reexamined to determine whether
safety requirements for dietary supplements are adequate. [Manufacturers are already required to have
information available to the FDA, but it is obvious that current
laws do not protect the public. The only way to protect the public
is to require proof of safety and effectiveness before marketing.] |
| 14.5 |
An objective process for evaluating
the safety of dietary supplement products should be developed
by an independent expert panel. [It
is not possible to evaluate safety without considering effectiveness.] |
Recommendation 15: Provisions of the Federal Food, Drug,
and Cosmetic Act, as modified by the Dietary Supplement Health
and Education Act of 1994, should be fully implemented, funded,
enforced, and evaluated.
Actions
| 15.1 |
The Food and Drug Administration and other agencies
with regulatory responsibilities should be provided with additional
resources to 1) enforce the Dietary Supplement Health and Education
Act's regulations regarding labeling of dietary supplements,
2) enforce current provisions requiring that dietary supplements
be labeled in English, even if the same information is also included
in another language, and 3) employ additional professionals with
expertise in dietary supplements. [It
is difficult to understand, in practical terms, what such "additional
resources" would accomplish. It would be far more effective
to demand that products be proven safe and effective before they
are marketed.] |
| 15.2 |
Current provisions requiring disclosure of material
facts by manufacturers of CAM products should be enforced, and
manufacturers should meet their responsibility to disclose material
facts on the label, package, and/or package insert, so
that the public will have information about known risks and well-documented
significant interactions. Information on potential benefits of
dietary supplements should also be made easily available at the
time of purchase. [Current drug laws
require that products marketed for the prevention, cure, mitigation,
or treatment of disease be labeled with adequate directions for
their intended uses. If dietary supplements (and herbs) had to
meet this standard, the industry would collapse.] |
| 15.3 |
Congress should periodically evaluate the effectiveness,
limitations, and enforcement of the Dietary Supplement Health
and Education Act of 1994, including its impact on public health,
and take appropriate action to ensure the public's safety. [The impact is obvious: since its passage, the
marketplace has been flooded with unsubstantiated claims for
dietary supplements and herbs. The only appropriate action would
be to repeal the law.] |
Recommendation 16: Activities to ensure that advertising
of dietary supplements and other CAM practices and products is
truthful and not misleading should be increased.
Actions
| 16.1 |
Congress should provide additional support to
the Federal Trade Commission to 1) expand efforts to identify
false and deceptive advertising of CAM-related health services
and products and take appropriate enforcement action when necessary,
2) use appropriate CAM experts in the process of examination
of CAM-related advertising, 3) increase activities to help consumers
distinguish useful and reliable information from deceptive and
unsubstantiated advertising in all forms of marketing and advertising,
including at the point of purchase; and 4) seek additional public
comment on the benefits and potential problems in the advertising
of CAM-related services and products. [This
is an excellent recommendation. However, although stronger federal
action could drive many CAM entrepreneurs out of business, the
U.S. Congress is dominated by CAM advocates who have seriously
weakened consumer protection during the past decade. If WHCCAMP
really wants more protection for consumers, it should advocate
repealing the 1994 Dietary Supplement and Health Education Act
which severely weakened FDA enforcement powers. And it should
also oppose CAM advocates' efforts to weaken FTC enforcement
in the same way.] |
Recommendation 17: The collection and dissemination of information
about adverse events stemming from the use of dietary supplements
should be improved.
Actions
| 17.1 |
Congress should require dietary supplement
manufacturers and suppliers to register with the Food and Drug
Administration, and the agency should encourage voluntary registration
until such a requirement is in effect, so that manufacturers,
suppliers, and consumers can be promptly notified if a serious
adverse event is identified. [This is
one of the few valid ideas in the WHCCAMP report.] |
| 17.2 |
Recent congressional support for
improving the Food and Drug Administration's adverse events reporting
system should be enhanced by requiring dietary supplement manufacturers
and suppliers to maintain records and report serious adverse
events to the agency. [This is one of
the few valid ideas in the WHCCAMP report.] |
| 17.3 |
Additional resources and support
should be provided to 1) the Food and Drug Administration to
simplify the adverse events reporting system for dietary supplements,
and to streamline the database for timely review and follow-up
on received reports; and 2) the Food and Drug Administration,
the Centers for Disease Control and Prevention, and other appropriate
Federal agencies to increase outreach activities to consumers,
health professionals (including poison control centers, emergency
room physicians, CAM practitioners, and mid-level marketers)
in order to improve both manufacturers' and the public's awareness
of and participation in voluntary event reporting. [This
might be useful, but it would be more efficient to require that
products be proven safe and effective before marketing.] |
ACCESS AND DELIVERY
Recommendation 18: The Department of Health and Human Services
should evaluate current barriers to consumer access to safe and
effective CAM practices and to qualified practitioners and should
develop strategies for removing those barriers in order to increase
access and to ensure accountability.
Actions
| 18.1 |
The Department of Health and Human Services should
assist the States in evaluating the impact of legislation enacted
by various States on access to CAM practices and on public safety.
[How useful this would be would depends
on whether it is done properly.] |
| 18.2 |
The Department of Health and Human Services and
other appropriate Federal agencies should use health care workforce
data, data from national surveys on use of CAM, regional public
health reports on CAM activities and other studies to identify
current and future health care needs and the relevance of safe
and effective CAM services for helping address these needs. [This falsely assumes that there are many safe
and effective "CAM" activities. No data can identify
a "need" for "CAM" products or services that
have not been proven safe and effective.] |
Recommendation 19: The Federal Government should offer assistance
to states and professional organizations in 1) developing and
evaluating guidelines for practitioner accountability and competence
in CAM delivery, including regulation of practice, and 2) periodic
review and assessment of the effects of regulations on consumer
protection.
Actions
| 19.1 |
The Secretary of Health and Human Services should
create a policy advisory committee, including CAM and conventional
practitioners and representatives of the public, to address issues
related to providing access to qualified CAM practitioners, provide
guidance to the states concerning regulation possibilities, and
provide a forum for dialogue on other issues related to maximizing
access. [Although standard biomedicine
can apply criteria of facts and reason in order to develop effective
methods of training and qualification, "CAM" possesses
no such body of evidence or method. Rational methods need no
special protection. Irrational methods cannot be made safe by
writing guidelines.] |
| 19.2 |
The Secretary of Health and Human Services, in
collaboration with states, should assist CAM organizations that
wish to develop consensus within their field of practice regarding
standards of practice, including education and training. The
conclusions reached by CAM professional groups concerning these
matters should be considered by states and regulatory bodies
in determining the appropriate status of these practitioners
for such regulatory options as registration, licensure or exemption.
[Although standard biomedicine can apply
criteria of facts and reason to develop practice standards, "CAM"
possesses no such body of evidence. There can be no objective
standards for determining who is a "qualified CAM practitioner."
The basic requirement for professional practice should be knowledge
of scientifically sound practices. Self-identification or recognition
as a "CAM" or "conventional" professional
is irrelevant.] |
Recommendation 20: States should evaluate and review their
regulation of CAM practitioners and ensure their accountability
to the public. States should, as appropriate, implement provisions
for licensure, registration, and exemption consistent with the
practitioners' education, training, and scope of practice.
Action
| 20.1 |
The Department of Health and Human Services'
policy advisory committee, in partnership with state legislatures,
regulatory boards, and CAM practitioners, should develop model
guidelines or other guidance for the regulation and oversight
of licensed and registered practitioners who use CAM services
and products. This guidance should balance concerns regarding
protection of the public from the inappropriate practice of health
care, provide opportunities for appropriately trained and qualified
health practitioners to offer the full range of services in which
they are trained and competent, maintain competition in the provision
of CAM and other health services, preserve CAM styles and traditions
that have been valued by both practitioners and consumers, and
determine the extent of the public's choice among health care
modalities. [This falsely assumes that
there are many "appropriately trained and qualified "CAM"
practitioners and that consumer use is a measure of effectiuveness.
Moreover, there is no logical reason why guidelines and standards
should depend on whether or not somthing is marketed as "CAM."
This recommendation calls for weakening consumer protection against
quackery.] |
Recommendation 21: Nationally recognized accrediting bodies
should evaluate how health care organizations under their oversight
are using CAM practices and should develop strategies for the
safe and appropriate use of qualified CAM practitioners and safe
and effective products in these organizations.
Actions
| 21.1 |
National accrediting bodies, in partnership with
other public and private organizations, should evaluate present
uses of CAM practitioners in health care delivery settings and
develop strategies for their appropriate use in ways that will
benefit the public. [This falsely assumes
that there are many such uses. It deliberately avoids mention
of inappropriate uses and what to do about them.] |
| 21.2 |
Nationally recognized accrediting bodies
of health care organizations and facilities should consider increasing
on-going access to CAM expertise to ensure that processes to
develop accreditation standards and interpretations reflect emerging
developments in the health care field. [Current
continuing medical education standards |
| 21.3 |
Nationally recognized accrediting
bodies, using CAM experts, should review and evaluate current
standards and guidelines to ensure the safe use of CAM practices
and products in health care delivery organizations. [This falsely assumes that there are many safe
"CAM" practices and products. As usual, it also fails
to call for review intended to exclude unsafe and ineffective
modalities.] |
Recommendation 22: The Federal government should facilitate
and support the evaluation and implementation of safe and effective
CAM practices to help meet the health care needs of special and
vulnerable populations.
Actions
| 22.1 |
The Department of Health and Human
Services and other Federal Departments should identify models
of health care delivery that include safe and effective CAM practices,
evaluate them, and then support those models which are successful
for use with special and vulnerable populations, including the
chronically and terminally ill. [This
repeats the false assumtpion that many such "CAM" methods
exist.] |
| 22.2 |
The Department of Health and Human
Services should sponsor the development and evaluation of demonstration
projects that integrate the use of safe and effective CAM services
as part of the health care programs in hospices and community
health centers. [This repeats the false
assumtpion that many such "CAM" methods exist.] |
| 22.3 |
The Department of Health and Human
Services should identify ways to support the practice of indigenous
healing in the United States and to improve communication among
indigenous healers, conventional health care professionals, and
CAM practitioners. [This falsely assumes
that there are many safe and effective indigenous healing practices.] |
COVERAGE AND REIMBURSEMENT
Recommendation 23: Evidence should be developed and disseminated
regarding the safety, benefits, and cost-effectiveness of CAM
interventions, as well as the optimum models for complementary
and integrated care.
Actions
| 23.1 |
The Secretary of Health
and Human Services should convene a joint public and private
task force to identify and set priorities for studying health
services issues related to CAM and to help purchasers and health
plans make prudent decisions regarding coverage of and access
to CAM. [The only prudent decisions
should be to cover methods that have been proven safe, effective,
and cost-effective. Whether methods are marketed as "CAM"
is not relevant.] |
| 23.2 |
Federal agencies, States,
and private organizations should increase funding for health
services research, demonstrations, and evaluations related to
CAM, including outcomes of CAM interventions, coverage and access,
effective sequencing and integration with conventional therapies,
effective models for service delivery, and the use of CAM in
underserved, vulnerable, and special populations. [It
is pointless to invest limited health-care dollars investigating
or deploying methods that have no proven value.] |
| 23.3 |
Federal, State, and
private entities should fund health services research on the
costs, cost-benefits, and cost-effectiveness of CAM interventions
and wellness programs. [This falsely
assumes that such research will provide substantial benefits.] |
| 23.4 |
The Secretary of Health
and Human Services and the National Committee for Vital and Health
Statistics should authorize a national coding system that supports
standardized data for CAM. This system should make possible the
collection of data for clinical and health services research
on CAM, and support compliance with the electronic claims requirements
of the Health Insurance Portability and Accountability Act. [Few interventions promoted as CAM have been
proven safe and effective for their intended purposes. There
is no logical reason to assign insurance codes to methods that
are unproven and/or irrational.] |
| 23.5 |
The National Center
for Complementary and Alternative Medicine, through its clearinghouse,
should provide information on health services research, demonstrations,
and evaluations of CAM services and products. [The
NCCAM and its predecessors were created for this purpose but
have not identified a single "safe and effective service
or product." Nor have they set up an honest clearinghouse.
People who ask for information about specific practices are usually
referred to proponents and almost never referred to science-based
critics.] |
| 23.6 |
Public agencies and private organizations should
support the development of informational programs on CAM targeted
to health plan purchasers and sponsors, health insurers, managed
care organizations, consumer groups, and others involved in the
provision of health care services. [The
amount of useful information that fits this description is trivial.
This appears to be a brazen proposal for goverment agencies to
help market "CAM" methods. If anything, the public
needs more information about what CAM methods are known to be
ineffective.] |
| 23.7 |
Congress should request periodic reports from
appropriate Federal departments on coverage of and reimbursement
for CAM practices and products for Federal beneficiaries, Medicaid
beneficiaries, Federal employees, military personnel, veterans,
and eligible family members and retirees, as well as any legislative,
regulatory, or programmatic impediments to covering safe and
effective CAM interventions. [The big
"impediment" is lack of evidence that they work. Unless
"CAM services and products" are proven useful, there
is no reason for policymakers to concern themselves about third-party
reimbursements unless they want to know how much money is being
wasted.] |
Recommendation 24: Insurers and managed care organizations
should offer purchasers the option of health benefit plans that
incorporate coverage of safe and effective CAM interventions
provided by qualified practitioners.
Actions
| 24.1 |
Health insurance and managed care
companies should modify their benefit design and coverage processes
in order to offer purchasers, for their consideration, health
benefit plans that include safe and effective CAM interventions.
[Most insurance companies need no prodding
to cover methods that have been proven effective. The vast majority
of "CAM" methods have not even been scientifically
tested.] |
| 24.2 |
Health insurance and managed care
companies should make use of CAM expertise in the development
of benefit plans that include safe and effective CAM interventions.
[This falsely assumes that such methods
are useful and that "CAM" advocates can be trusted
to sort out what should be covered.] |
| 24.3 |
Health insurers, managed care organizations,
CAM professional associations, CAM experts, private organizations
that develop medical criteria, and Federal agencies are encouraged
to develop appropriate clinical criteria and guidelines for the
use of CAM services and products. [This
falsely assumes that many such modalities exist and that "CAM"
advocates can offer reliable advice.] |
Recommendation 25: Purchasers, including Federal agencies
and employers, should evaluate the possibility of covering benefits
or adding health benefit plans that incorporate safe and effective
CAM interventions.
Actions
| 25.1 |
Employers, Federal agencies, other
purchasers and sponsors should enhance the processes they use
to develop health benefits and give consideration to safe and
effective CAM interventions. |
| 25.2 |
Public purchasers such as the Centers
for Medicare and Medicaid Services and the Department of Defense,
employers, other health benefit sponsors, and health industry
organizations should include CAM practitioners and experts on
advisory bodies and workgroups considering CAM benefits and other
health benefit issues. [This falsely
assumes that many such modalities exist and that "CAM"
advocates can offer reliable advice.] |
| 25.3 |
The Secretary of Health and Human Services,
preferably through the Federal CAM coordinating office when established,
should maintain a list of opportunities for CAM experts to participate
on advisory committees and other workgroups. [This
assumes that "CAM" advocates can offer reliable advice.
The WHCCAMP report shows the absurdity of this assumption.] |
| 25.4 |
The Secretary of Health and Human Services should
direct agencies under his authority to convene workgroups and
conferences to assess the state-of-the-science of CAM services
and products and to develop consensus and other guidance on their
use. [Government agencies normally promote
methods that have been proven effective. There is no reason to
give special consideration to methods that are marketed as "CAM."] |
| 25.5 |
State governments should consider,
as part of evaluating and reviewing their regulations, how regulation
of CAM practitioners could affect third-party coverage of safe
and effective CAM interventions. [Third
party coverage is normally based on scientific merit. "CAM"
advocates hope to promote through political means what they cannot
accomplish through science.] |
CAM IN WELLNESS AND HEALTH PROMOTION
Recommendation 26: The Department of Health and Human Services
and other Federal agencies and public and private organizations
should evaluate CAM practices and products that have been shown
to be safe and effective to determine their potential to promote
wellness and help achieve the nation's health promotion and disease
prevention goals. Demonstration programs should be funded for
those determined to have benefit.
Actions
| 26.1. |
The Healthy People Consortium
should evaluate the role of safe and effective CAM practices
and products in addressing the10 leading health indicators and
develop strategies, including demonstration programs, to encourage
the use of CAM practices and products found to be beneficial
in addressing these indicators. [This
recommendation incorrectly assumes that there are valid CAM principles
and practices that the scientific community is neglecting. CAM
advocates attempt to boost their credibility by including diet,
nutrition, and exercise within their scope. However, the scientific
mainstream has addressed these areas for decades.] |
| 26.2 |
Questions on the extent
and use of CAM products and practices should be included in national
surveys and other assessment tools including the National Health
Interview Survey, the National Health and Nutrition Examination
Survey, and the Medical Expenditure Panel Survey. Where appropriate,
information from these sources should be incorporated into the
Healthy People 2020 goals and objectives. [It
would be worthwhile to investigate the harmful impact of irrational
and unsubstantiated methods. However, surveys that merely assess
the "popularity" of such methods might make them appear
more legitimate.] |
| 26.3 |
The Department of Health
and Human Services, as part of the Healthy People 2010 initiative,
should support the development of a national campaign to teach
and encourage behaviors that focus on improving nutrition, promoting
exercise, and teaching stress management for all Americans, especially
children. This campaign should include safe and effective CAM
practices and products where appropriate. [This
is a crass attempt to equate "CAM" with "healthy
behaviors" without any evidence to support such an association.
There is no evidence that methods unique to "CAM" improve
the health of children. In fact, many chiropractors, naturopaths
and other practitioners denigrate and oppose the proven public
health measures of vaccination and fluoridation.] |
| 26.4 |
The Federal government,
in partnership with public and private organizations, should
evaluate safe and effective CAM practices and products to determine
their applicability to improving nutrition, promoting exercise,
and teaching stress management to children. Demonstration programs
should be funded for those found to be applicable to children.
[As noted in #26.3, there is no evidence
that methods unique to "CAM" improve the health of
children.] |
| 26.5 |
The Health Resources
and Services Administration, the Centers for Disease Control
and Prevention, the Department of Agriculture, the Department
of Education, and other Federal agencies that develop school
health guidelines should evaluate the potential applicability
of safe and effective CAM practices and products to these school
health guidelines. Those found to have benefits should be included
in the guidelines. [As noted in #26.3,
there is no evidence that methods unique to "CAM" improve
the health of children.] |
| 26.6 |
Federal agencies, in
partnership with the business community, should develop incentives
for schools to make lunches and snacks healthful, and to limit
the sale -- and eliminate the advertisin -- -of high-fat snacks,
soft drinks, and other products that do not contribute to healthy
lifestyles. [There are valid reasons
to promote good health habits to children, but this activity
has nothing to do with "CAM."] |
| 26.7 |
The Department of Health and Human
Services and the Department of Labor should evaluate safe and
effective CAM practices and products to determine their potential
role in workplace wellness and prevention activities, and include
them in Federal workplace wellness and health promotion programs
and Federal health coverage plans when appropriate. [There is no reason to believe that this would
be better than simply encouraging good health habits that have
little or nothing to do with "CAM." "CAM"
programs that disparage standard care or advocate irrational
methods would have a negative impact on the health of federal
workers.] |
| 26.8 |
Federal agencies, in conjunction
with the business community, should develop incentives for employers
to include CAM practices and products found to be beneficial
in wellness and prevention activities in their workplace wellness
programs and health coverage. [There
is no reason to believe that this would be better than simply
encouraging good health habits that have little or nothing to
do with "CAM." "CAM" programs that disparage
standard care or advocate irrational methods would have a negative
impact on the health of federal workers.] |
Recommendation 27: Federal, State, public, and private health
care delivery systems and programs should evaluate CAM practices
and products to determine their applicability to programs and
services that help promote wellness and health. Demonstration
programs should be funded for those determined to be beneficial.
Actions
| 27.1 |
The Secretaries of Health and Human
Services, Agriculture, Veterans Affairs, and Defense and the
Commissioner of the Administration for Children and Families,
should evaluate safe and effective CAM practices and products
that contribute to wellness and health and determine their applicability
to Federal health systems and programs. [This
falsely assumes that many safe and effective "CAM"
practices and products exist and need special federal promotion
to gain recognition.] |
| 27.2 |
The Secretary of Health and Human
Services should facilitate the bringing together of public and
private health care organizations to evaluate safe and effective
CAM practices and products that contribute to wellness and health
and determine their applicability to health systems and programs,
especially in the nation's hospitals and long-term care facilities
and in programs serving the aging, those with chronic illness,
and those at the end of life. [There
is no logical reason to believe that adding "CAM" services
to health systems or programs would make such programs more effective
or cost-effective. Before investing in any such research, there
should be data showing that such an investment would be worthwhile.] |
| 27.3 |
CAM and conventional health professional
training programs should consider offering training and educational
opportunities for students in self-care and lifestyle decision-making
to improve practitioners' health and to enable practitioners
to impart this knowledge to their patients or clients. [Conventional training and public health programs
already offer this. There is no reason to believe that "CAM"
practitioners have something additional to offer.] |
Recommendation 28: Research on the role of CAM in wellness
and health promotion, the application of CAM principles and practices,
and the role of CAM practitioners in the management of chronic
disease should be expanded.
Actions
| 28.1 |
The Department of Health and Human
Services should fund demonstration projects to evaluate the clinical
and economic impact of comprehensive health promotion programs
that include CAM. These studies should include underserved and
special populations. [There is no logical
reason to believe that offering "CAM" services to underserved
and special populations will enhance their health.] |
| 28.1 |
The Federal government and private
health organizations should evaluate CAM practices and products
that are currently being used for wellness and health promotion
to determine their effectiveness and applicability to the management
of chronic disease. Funding should be provided for demonstration
projects in the Centers for Medicare and Medicaid Services, the
Department of Veterans Affairs, the Department of Defense, the
Health Resources and Services Administration, and other Federal
agencies for those CAM practices and products found to have benefit
in the management of chronic disease, end of life such as hospice.
[This falsely assumes that many "CAM"
practices and products can be proven useful to chronically and
terminallly ill patients and deserve special funding priority.] |
COORDINATING FEDERAL EFFORTS
Recommendation 29: The President, Secretary of Health and
Human Services, or Congress should create an office to coordinate
Federal CAM activities and to facilitate the integration into
the nation's health care system of those complementary and alternative
health care practices and products determined to be safe and
effective.
Actions
| 29.1 |
The office should be established
at the highest possible and most appropriate level in the Department
of Health and Human Services and should be given sufficient staff
and budget to meet its responsibilities. [It
would be absurd to create an "office at the highest possible
level" to promote so-called CAM. Doing that would constitute
a government endorsement of homeopathy, therapeutic touch, cranial
osteopathy, rebirthing and many other preposterous practices
that have been embraced by one or more members of Commission.] |
| 29.2 |
The office should charter an advisory
council. Members should include CAM and conventional practitioners
with expertise, diverse backgrounds, and necessary training,
as well as representatives of both the private and public sectors,
to guide and advise the office about its activities. [Previous advisory councils have been composed
almost entirely of "CAM" advocates and have included
few if any knowledgeable critics.] |
| 29.3 |
The office's responsibilities should
include, but not be limited to, coordinating Federal CAM activities;
serving as a Federal CAM policy liaison with conventional health
care and CAM professionals, organizations, institutions, and
commercial ventures; planning, facilitating, and convening conferences,
workshops, and advisory groups; acting as a centralized Federal
point of contact regarding CAM for the public, CAM practitioners,
conventional health care providers, and the media; facilitating
implementation of the Commission's recommendations and actions;
and exploring additional and emerging topics not considered by
the Commission. |
WHCCAMP Analysis Index ||| Quackwatch Home Page
This article was posted on March 25,
2002.
|