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Analysis of WHCCAMP's November 2001 Draft Report

Timothy N. Gorski MD, FACOG
Stephen Barrett, MD

In March 2000, President Clinton announced the creation of a White House Commission on Complementary and Alternative Medicine Policy (WHCCAMP) to provide a report to the President on "legislative and administrative recommendations for assuring that public policy maximizes the benefits to Americans of complementary and alternative medicine." On November 16, 2001, the commission issued an 86-paragraph draft report recommending across-the-board "integration" of "complementary and alternative medicine (CAM)" into government health agencies and the nation's medical, medical education, and insurance systems. These recommendations are an affront to medical science and an assault on consumer protection. Here is our paragraph-by-paragraph analysis with the report's words in ordinary type and ours in bracketed dark-red type.

As you read our analysis, please keep these points in mind:

DRAFT RECOMMENDATIONS (11/16/01)

Coordination of Complementary and Alternative Medicine Research

  1. The Commission recommends strengthening the emerging dialogue between conventional medicine and CAM by continuing to develop ways to enhance communication, cooperation, and collaboration among conventional and CAM research and clinical professionals, research centers and accredited institutions, professional organizations, and Federal and state research and health agencies, the private and nonprofit sectors, and the general public. [By this they mean continued inroads into medical education and academic centers, replacing medical science with unscientific concepts. Referring to modern medicine as "conventional" obscures how it is grounded in reason and advances because of innovations that are backed by scientific evidence.]
  2. The Commission recommends that standards of quality for all aspects of research and related activities be the same for CAM as for conventional medicines. [If genuine standards were instituted, CAM activities would be demolished. Moreover, the standard for accepting implausible claims should be much higher than the standard for plausible ones. Extraordinary claims demand extraordinary proof.]
  3. The Commission recommends that research, journal, regulatory, and health insurance advisory and review committees in both the public and private sectors include, as needed, trained and qualified CAM and conventional professionals, and recommends adapting as appropriate, any regulations that might impede such representation. [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. There can be no objective standards for determining who is a "properly trained and qualified CAM professional." The basic qualification for reviewers should be the ability to distinguish what is scientifically sound from what is not. Self-identification or recognition as a "CAM" or "conventional" professional is irrelevant.]
  4. The Commission recommends independent or collaborative support by the public, private, and nonprofit sectors to organize multidisciplinary conferences on CAM research to increase opportunities for CAM and conventional medical practitioners, clinicians, researchers and others to exchange ideas on approaches to studying and supporting CAM research. [Again, they are interested in the trappings of science without the rigor. They want legitimate medical scientists to give them "support" for claims and practices that are not likely to be supported by rigorous studies.]
  5. The Commission encourages the creation of novel funding partnerships or consortia within the nonprofit sector and the private sector to augment, collaboratively with Federal agencies or separately, support for CAM research, research infrastructure and training, research conferences, and information dissemination. [Although the NIH National Center for Complementary and Alternative Medicine (NCCAM) and its predecessors have spent more than $100 million for such research, the yield of useful information has been close to zero. It is pointless to waste scarce research dollars on methods that are highly unlikely or already known not to work.]
  6. The Commission recommends supporting research on why people use CAM, how they determine its effectiveness, and what they find satisfying about CAM itself and in comparison with conventional medicine, and parallel this research with the public impact on the emerging integrated healthcare system. [This falsely assumes that (a) CAM is effective and satisfying in comparison with standard medicine and (b) "integrating" proven and unproven methods would produce a "system" rather than a hodgepodge.]
  7. The Commission recommends that Federal agencies supporting biomedical and health services research develop training programs for public representatives to help them provide their input in the most effective way with respect to biomedical and health services research agendas and budget policy, and the dissemination of information. [This calls for politicization of all medical research. The simple fact of the matter is that while public interest should influence where research dollars go, it is medical scientists themselves who are in the best position to determine which methods -- among a huge number of possibilities -- are most likely to yield important and useful results by doing rigorous scientific studies. The best "training program" is a solid education in the sciences; and the best "public representatives" are scientists who are the products of such education.]
  8. The Commission recommends that all Federal agencies with research or related health care responsibilities increase CAM activities relevant to their biomedical or health services missions in a more proactive manner, including the consideration of special initiatives, to ensure that CAM is properly integrated into the health care system. [This is blatant special pleading with no evidence or reason to think that it would be cost-effective. Our health care system will not be enhanced by further integration of irrational methods labeled as "CAM." Nor would it be enhanced by federal advocacy of unscientific medical practices.]
  9. The Commission recommends that state professional regulatory boards develop processes that will allow practitioners who have developed scientifically acceptable preliminary data to move successfully to clinical investigation of a non-approved treatment while maintaining their ethical and professional responsibilities toward their patients and the public. [Existing federal rules provide ample opportunity for practitioners with scientifically acceptable preliminary data to do further research. WHCCAMP's recommendation appears to be a disguised call to protect quack practitioners from disciplinary action if they pretend to be doing research.]
  10. The Commission recommends that NIH Institutes and Centers and other Federal agencies, as appropriate, develop programs to evaluate practice-based data for potential research support, communicate the availability of such initiatives in a proactive manner to CAM and conventionally-trained practitioners who believe they have promising data on non-approved treatments, and provide training in data collection, protocol development, and ethical guidelines and human subject protection. [Appropriate training in scientific methods is widely available at academic centers throughout the world. NCCAM and its predecessors have offered such training in the past, but, as far as we can tell, there has been no public benefit. WHCCAMP proposes to pour more money into this process even though no need or value for such training has been demonstrated. There is certainly no good reason to train people just because they label themselves as CAM practitioners.]
  11. The Commission recommends continuing adequate public funding for research on promising and/or frequently used CAM products that would be unlikely to receive a patent and therefore not likely to attract private research dollars. [This supports the fiction that no money can be made from natural products. The real question is who will decide what is a promising new approach: CAM advocates or those who are most knowledgeable about the medical condition or disease in question. As for "CAM products" that are "frequently used," such use is largely driven by marketing, much of which is deceptive.]
  12. The Commission recommends that the Federal government provide incentives to stimulate private sector investment in research on CAM products and NDA development, and on developing analytical methods for producing better quality CAM products. [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. Research expenditures and other incentives should be proportional to probable value, not whether something is labeled "CAM."]
  13. The Commission recommends that the Federal and private sectors provide support for workshops to discuss research needs for regulatory review and approval of 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.]
  14. The Commission recommends Federal, private, and nonprofit support for new, innovative and sometimes controversial CAM research in emerging areas of scientific study that might expand our understanding of health and disease and encourages support for basic research on core questions described in many CAM systems. [This recommendation is extremely vague. What does it mean? Remove the word "CAM" and it could apply to many areas of biomedical research. But with "CAM" inserted, it advocates taxpayer-supported "research" into psychic powers, nonmaterial "energy," and other alleged but nonexistent forces that quacks often misrepresent as "emerging new technologies." Priority should be given to research areas that are most likely to prove fruitful. Studies of CAM's "core questions" are not likely to prove fruitful.]
  15. The Commission recommends that NCCAM conduct a review assisted by the National Science Foundation, the Institute of Medicine, the World Health Organization, or other Federal or non-Federal bodies on methods to study in a credible manner, emerging areas of scientific investigation associated with CAM. [NCCAM and its predecessors at NIH are supposed to have been doing this for nearly ten years. Now, in addition to borrowing the reputation of the NIH, CAM advocates want the endorsement of the NSF, IOM, WHO and whatever other prestigious group they can press into service. This recommendation bypasses the question of whether CAM deserves such special attention and support. Advocates would like us to believe that CAM is being thwarted by economic and political forces when just the opposite is true. "CAM" is little more than a euphemism intended to divert attention from the quack practices the term includes.]
  16. The Commission recommends providing increased public and private resources to strengthen the CAM research infrastructure at strategically located conventional medical and CAM sites to expand the core of researchers knowledgeable about CAM, who have received rigorous research training in basic, clinical, and health services research. [This recommendation 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.]
  17. The Commission recommends strong support for enhanced research training by all Federal health agencies with research training programs and responsibilities that encompass CAM-related questions. [It does not make sense to train researchers to study wildly implausible hypotheses.]
  18. The Commission recommends utilizing existing resources, such as NCCAM-supported centers and the National Center for Research Resources' General Clinical Research Centers to increase opportunities to conduct clinical research and training on CAM and examine the integration of CAM into the clinical setting. [Without credible evidence that a method is safe, effective, and cost-effective, no method deserves to be "integrated" into clinical practice No unsubstantiated method should be given a free pass merely because someone labels it "CAM."]
  19. The Commission recommends continued strong support for career development awards that enable investigators focusing on CAM to develop into independent investigators and faculty members, and mid-career awards to provide the time required to mentor new CAM investigators. [There is no logical reason to believe that special training for CAM advocates is likely to be a good investment. Nor would it make sense to promote the careers of people who want to test implausible hypotheses.]
  20. The Commission recommends that public and private resources support, conduct, and update systematic reviews of current evidence in the research literature on the safety (including contraindications) and efficacy of CAM practices and products. These reviews should be written in understandable English and other languages, and should be easily obtained from multiple publicly available information services, including the National Library of Medicine's MedlinePlus database, which is accessible directly and through public libraries. [Many such reviews 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, as far as we know, 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.]
  21. The Commission recommends that the Agency for Healthcare Research and Quality expand its Evidence-based Practice Center systematic reviews on CAM treatments for use by private and public entities in developing tools, such as practice guidelines, performance measures, and review criteria. [Rigorous (evidence-based) reviews are unlikely to support "CAM" practices, but CAM propagandists will misrepresent the review process itself as evidence of effectiveness.]
  22. The Commission recommends that a summary report of current clinical evidence on CAM be produced and updated at appropriate intervals. [This is another strategy for marketing CAM. The proposed reports would enable advocates to put a positive spin on methods with little scientific support. Genuine research advances are disseminated through scientific journals and other medical education channels.]

    CAM Information Development and Dissemination

  23. The Commission recommends that the Secretary, DHHS, establish an inter-departmental task force to identify and eliminate existing gaps in the development and dissemination of CAM information in the Federal government, and that increased resources be provided to centralize CAM information for the public and the media. This should include a toll-free telephone number that directs callers to the appropriate department, agency, and/or person for specific CAM 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.]
  24. The Commission recommends that resources be made available to (a) develop CAM informational materials at a level that most of the adult general public can understand and utilize; and (b) support national and local community leaders and organizations in identifying strategies and developing materials to enhance the availability of CAM information to the communities they represent and help prevent special populations from being targeted for products or services that are unnecessary, harmful, exorbitantly priced, or otherwise detrimental. [This appears to be a restatement of #20 and #23.]
  25. The Commission recommends that current efforts of the National Library of Medicine and the American Library Association to develop training materials and provide training to librarians in guiding people to find health information be expanded to include CAM information. [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?]
  26. The Commission recommends that the Secretary, DHHS, form a public-private partnership to review new and existing websites and develop voluntary standards that will promote accuracy, fairness, comprehensiveness, and timeliness of information on CAM internet sites, as well as disclosure of sources of support and any conflicts of interest. Sites reviewed and found in compliance with the standards could publicize this achievement and display a logo identified with this level of 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.]
  27. The Commission recommends that funding be provided to the Secretaries, DHHS and Department of Education, to jointly conduct a public education campaign that teaches people, including students, how to evaluate health care information, including CAM information, particularly on the internet. [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.]
  28. The Commission recommends that Congress protect the privacy of individuals using CAM internet sites by (a) requiring all health information sites, including CAM sites, to disclose if users are tracked and how that information is utilized (including whether that information is sold to third parties), and stored; and (b) expanding existing legislation or regulations to assure that the privacy of CAM health information seekers on the internet is protected. [Individual privacy should be protected regardless of what information is sought.]
  29. The Commission recommends that barriers to identifying and translating relevant articles, reports, and other materials be identified; strategies be developed to overcome these barriers; and that relevant and high quality, scientific materials are made available to researchers, clinicians, policymakers, and others. [It might be useful for scientists to have access to English translations of high-quality research.]
  30. The Commission recommends that States and local governments require all persons providing any kind of health services or products, including CAM, to make information easily available to consumers that explains their level and scope of training so that consumers can make informed choices. [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.]
  31. The Commission recommends that States and local governments make information on state guidelines, requirements, licensure, certification, and disciplinary actions of health providers, including CAM providers, readily available to the public. [Some state licensing boards already do this. 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.]
  32. The Commission recommends that additional support be provided to the Federal Trade Commission to (a) expand efforts to identify false and deceptive CAM- related health claims and take appropriate enforcement action; and (b) increase consumer education in identifying deceptive and unsubstantiated claims in all forms of marketing and advertising. [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.]
  33. The Commission recommends that efforts of both the public and private sectors to assure the development, validation, and dissemination of analytical methods and reference materials for well-characterized dietary supplements to the public be enhanced and accelerated. [It might be useful to assure that dietary supplements and herbal products actually contain what their labels say. However, honest ingredient labeling is not enough. It would be harmful to increase public confidence in products that don't work or are less safe than approved drugs. The overwhelming majority of dietary supplements and herbal products do not perform as promised.]
  34. The Commission recommends that the Good Manufacturing Practices for Dietary Supplements be implemented to help assure the quality and composition of dietary supplements, and that a study be commenced 12-18 months after the full implementation of the GMPs by an external organization to evaluate current efforts and provide recommendations for improvement. [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.]
  35. The Commission recommends that appropriate Federal entities work with manufacturers and importers to monitor the quality of imported and domestic dietary supplements to identify and prevent products that are contaminated or adulterated from entering the US marketplace. [The FDA already has the legislative tools to do this, but many other tasks compete for attention from its limited resources.]
  36. The Commission recommends that DHHS and other appropriate Federal Departments and Agencies work with the Codex Alimentarius Commission, World Health Organization, Agency for International Development, and other international organizations to establish standards to help assure the quality of imported dietary supplements and prevent products that are contaminated or adulterated from entering the US marketplace. [The FDA does not need help from CAM advocates to set standards on product quality. It needs additional resources and stronger laws to deter wrongdoing.]
  37. The Commission recommends that information on benefits, appropriate use, and potential risks be made more easily available at the time of purchase through improved labeling, package inserts, and information at points-of-sale. When significant interactions with prescription or OTC drugs, foods, or other health products are known, this information should be on the label. In addition, labels or information provided to consumers should identify possible risks to vulnerable populations such as children, the elderly, pregnant or nursing women, and those with certain health conditions or compromised immune systems, All information on labels should be in English, even if another language is also included. [The advice about safety is appropriate. But because neither benefits nor appropriate use have been established for most supplement products, the rest of this recommendation is meaningless.]
  38. The Commission recommends that the FDA develop guidelines to assist the dietary supplement industry in understanding and complying with the FFDCA sections of 201(n) and 403(a)(1), which require that material facts be included on labels of all products regulated by the FDA. [The basic requirement is that labels be truthful and not misleading. Manufacturers who wish to market their products honestly do not need elaborate guidelines or special training.]
  39. The Commission recommends that the FDA and other agencies with regulatory responsibilities be provided with the necessary funds to employ additional professionals with expertise in dietary supplements. [The FDA's problem is not lack of personnel or expertise. Its problem is the Dietary Supplement and Health Education Act of 1994, which prevents appropriate regulation of dietary supplements and herbs.]
  40. The Commission recommends that Congress require dietary supplement manufacturers and suppliers to register their products with the FDA and that the FDA encourage voluntary registration until such a requirement is in effect. This information is for the purpose of notifying manufacturers and suppliers in the event that a problem is identified with a product. [This should have been done long ago. But when others have suggested it, CAM advocates have vigorously resisted.]
  41. The Commission recommends that dietary supplement manufacturers and suppliers be required to maintain a record of adverse events and report serious adverse events to the FDA to facilitate FDA's dissemination of information to other manufacturers and suppliers and the public, and that the FDA promptly notify manufacturers of any severe and/or clinically significant adverse events reported to the FDA to allow companies the opportunity to provide important information about known safety and product formulation. [A better adverse reporting system is a good idea. But the FDA also needs an efficient way to drive unsafe or useless products from the marketplace.]
  42. The Commission recommends that additional resources and support be provided to the FDA to simplify the Adverse Event Reporting system and increase outreach activities to health professionals (including poison control centers, emergency room physicians, CAM practitioners, mid-level marketers) and consumers to underscore the importance of reporting adverse events. [It is difficult to understand, in practical terms, what such "additional resources and support" would accomplish. It would be far more effective to demand that products be proven safe and effective before they are marketed.]

    Education and Training of Health Care Practitioners in CAM

  43. The Commission recommends that appropriate support should be made available through competitive award processes for 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.]
  44. The Commission recommends that joint research, education and training programs involving CAM and conventional institutions should be supported to focus research on clinically relevant topics, improve the quality of research conducted, and link research with evidenced-based education and training. [Adding ineffective methods to effective methods increases cost but not quality of care.]
  45. The Commission recommends that conferences should be convened by the proposed Federal CAM Coordinating Office to assemble the leadership of professions, educational institutions, and appropriate organizations to determine the feasibility of and possible mechanisms for establishing national CAM education and training standards. [It is safe to assume that WHCCAMP expects CAM advocates to control any such standard-setting process. However, it is not possible to establish science-based standards for methods that are irrational and don't work.]
  46. The Commission recommends that all 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. [It is safe to assume that WHCCAMP expects CAM advocates to control any such activities.]
  47. The Commission recommends that core elements of a biomedical science and conventional health care curriculum for CAM education and training programs should be determined along with methods for incorporation into existing curricula through demonstration projects and conferences with subsequent results, models, and recommendations compiled and available on the internet. [The meaning of this recommendation is unclear.]
  48. The Commission recommends that traditional healers should be educated and trained in accordance with their respective established traditions to ensure that culturally appropriate access to traditional healers and healing is maintained. [This appears to be another endorsement of a two-tier system of medicine: one based on science and another based on non-science. The Commission's recommendation is just the opposite of what is needed to maintain the integrity of our science-based medical system.]
  49. The Commission recommends that demonstration projects should be developed to determine the feasibility of expanding the role of appropriately trained becoming primary care providers, so that the eligibility of CAM students to participate in existing loan and scholarship programs and CAM practitioners to participate in loan forgiveness programs can be evaluated. [Few "CAM practitioners" can function competently as primary care physicians. This recommendation, if followed, would result in irreparable injury to many people as well as the public health generally. It also calls for taxpayers' dollars to support irrational methods.]
  50. The Commission recommends that a core curriculum of knowledge about CAM systems, modalities, therapies, approaches, fundamentals, and principles should be developed in conjunction with CAM experts and CAM institutions, based on minimal knowledge-related competencies, and designed with maximal latitude for easy and cost-effective implementation at conventional health professional schools, in postgraduate training programs, and in continuing education programs to increase knowledge and understanding of CAM, so that conventional health professionals can discuss and provide guidance for the appropriate use of CAM. [Here WHCCAMP demands that the entire medical education system be corrupted by giving CAM advocates free reign to promote their nonsense.]
  51. The Commission recommends that demonstration projects of joint primary care residencies for appropriately educated and trained CAM practitioners and conventional physicians should be conducted to determine the feasibility of such residencies and their impact on collaboration, clinical competency, and quality of health care. [Here WHCCAMP demands that residency training be corrupted by giving CAM advocates free reign to promote their anti-scientific nonsense.]

    Access and Delivery of CAM

  52. No later than 6 months following the receipt of the White House Commission on Complementary and Alternative Medicine Policy's report, the Secretary of Health and Human Services should establish a national policy advisory board that will support and coordinate efforts with a designated Federal office for CAM to develop policy guidelines on issues related to the access and delivery of CAM. [This is a not-so-subtle effort to extend the life of the Commission or a similar body staffed by ideologues who would continue to advocate unscientific methods.]
  53. Within 18 months of being established, the national policy advisory board appointed by Health and Human Services (HHS) will research, develop and publish a set of national standards for the practice of CAM. These standards will establish minimum educational, ethical and practice guidelines for any practitioner wishing to provide health care via CAM approaches, and focus on ensuring patients with necessary safeguards. [It is not possible to devise genuine standards for practices that don't work. Moreover, unscientific practitioners cannot agree among themselves about what they should do.]
  54. With guidance from the HHS national advisory board on CAM policy, the designated Federal office for CAM should actively promote the development of consensus and practice standards that are specific to a wide variety of CAM practices. [No CAM organization has ever published detailed standards that are based on sound science.]
  55. With the support and facilitative efforts of the designated Federal office for CAM, CAM practices and professions should establish a single, voluntary, national organization to register, regulate, and represent its members. [Registration would provide a façade of respectability but would not protect consumers. The idea that quacks can regulate themselves by forming groups and setting standards is absurd.]
  56. States strongly are encouraged to use and implement the national practice standards developed by the HHS's advisory board, and to acknowledge and recognize the self-regulating authority of single, national, voluntary CAM organizations by requiring that CAM practitioners be registered through such organizations, and by providing broad legal authority and limited uniform protection for CAM practitioners who qualify under the national practice standards and who register with a self-regulating organization. [The purpose of this recommendation is to shield unscientific practitioners from regulation under existing laws that protect against fraud and/or require proof of effectiveness before marketing.]
  57. Within 8 months of being established, the HHS national policy advisory board should begin a process to develop national uniform scopes of practice for CAM practices, primarily to address those practices deemed to present the most potential risks to patients. States are encouraged to use these scopes of practice to provide the necessary legal authority and licensure of such practitioners. [Safety should not be considered separately from effectiveness. Even tiny risks associated with worthless treatments should not be tolerated. Conversely, potentially dangerous methods that may provide benefit are justifiable when doing nothing is more risky.]
  58. State medical boards strongly are encouraged to work closely with HHS's advisory board through the designated Federal office for CAM to develop standard operational guidelines for the regulation and oversight of licensed physicians practicing CAM, which are based on national uniform scopes of practices developed by the HHS board. [Again, it is not possible to write meaningful standards for methods that don't work.]
  59. The Commission recommends that nationally recognized accrediting bodies assume leadership roles to review the most commonly used and evidence-based CAM modalities, especially those with particular relevance to a coordinated care approach, with respect to establishing accreditation standards. [This recommendation is simply another attempt to gain special status for methods that clash with medical science. New medications, surgical techniques, and management protocols are continually introduced into medical practice without any need for special accreditation.]
  60. The Federal Government, including but not limited to HHS, should fund and support efforts by the designated Federal office on CAM to coordinate detailed and expanded epidemiologic surveys of CAM patterns of use, with special attention to ethnic and vulnerable populations. [It might be useful to study the extent of quackery as a public health problem. But this is probably not what the Commission has in mind. Most studies about "CAM" utilization patterns yield nothing more than "sound bites" about CAM's popularity.]
  61. The Federal Government, including but not limited to HHS, should fund and support efforts by the designated Federal office on CAM to collaborate with private sector studies and demonstration projects that evaluate the usefulness, effectiveness and cost-benefits of collaborative care models at three delivery levels: global health care systems, such as hospitals, community health centers, and managed care settings; specialized health care systems, such as hospice care; and small clinical settings, such as individual and group practices. [It makes no sense to conduct demonstration projects for methods that have not been proven effective. In addition, this recommendation falsely implies that many CAM methods have been proven effective.]
  62. Based on studies and demonstration projects evaluating the effectiveness and cost benefits of collaborative care models at three delivery levels, the Federal Government, including but not limited to HHS, should fund and support efforts by the designated Federal office for CAM to convene strategic planning conferences addressing the needs of seriously ill and dying patients, as well as other special populations, to determine best practice guidelines that incorporate conventional palliative care with appropriate and effective CAM approaches. [This recommendation falsely implies that CAM approaches have something special to offer seriously ill and dying patients.]
  63. Within 3 years of being established, the designated Federal office for CAM shall report to the Secretary of HHS on the use of indigenous healing traditions in the United States to identify common use, best practices, and challenges and potential areas for collaborative learning between such traditions and conventional care. The Commission urges this report to include recommendations for the future as regards appropriate protection of such traditions, as well as research and development of such practices as part of community-based health care. Members from such traditions should be involved closely in this endeavor. [The study of folk healing is probably not a cost-effective way to discover new methods. "Protecting" indigenous traditions might gain political support from certain minority groups, but it is unlikely to yield significant health benefits.]
  64. The Federal Government, including but not limited to the Department of Agriculture and HHS, should fund and support efforts by the designated Federal office on CAM to evaluate the feasibility, costs vs benefits, and overall impact on allowing Food Stamp Program Participants to use food stamps to purchase specified single or multiple vitamin-mineral products that do not exceed the nutrient recommendations of the Food and Nutrition Board of the Institute of Medicine. [Most food stamp recipients would benefit more by improving their diet than by taking supplements, the purchase of which would decrease the amount of money they have available to buy nutritious food.]

    Coverage and Reimbursement
  65. The Commission recommends that purchasers and other health plan sponsors, insurance companies and managed care organizations offer coverage of safe and effective CAM interventions in a manner and through a process equivalent to that used for conventional medicine. [This bypasses the question of which "CAM interventions" are safe and effective. 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.]
  66. The Commission recommends that purchasers and other health plan sponsors, insurance companies, managed care organizations, and health care organizations which influence health policy and interventions open their processes to CAM, such as maintaining an expertise regarding CAM and including CAM experts on appropriate advisory bodies and working groups related to health benefits plans, health care coverage, reimbursement, and applicable processes including coding. [There is no valid reason for anyone to abandon or ignore scientific standards of medicine by "opening their processes to CAM."]
  67. The Commission recommends that professionals working in complementary and alternative health care actively seek opportunities to advise and participate on public and private bodies that address issues related to health services research (for CAM or, where appropriate, health care generally), CAM-related demonstration projects, coverage and payment for health services and products, and improvements to coverage-related processes, such as coding. [CAM advocates have already proven spectacularly effective at promoting through political means what they cannot accomplish through science.]
  68. The Commission recommends the Secretary, Department of Health and Human Services (DHHS), convene a public and private task force to develop a multiyear health services research plan that identifies and addresses CAM research and demonstration questions, methodologies, data, priorities, and coordination. The task force should convene within 3 months of its appointment, and submit its report to the Secretary within 18 months of its appointment. [The National Center for Complementary and Alternative Medicine (NCCAM) and its predecessors have supposedly been doing this for nearly ten years. So far, they have not produced a single significant research finding. Nor have they concluded that any CAM method either works or doesn't work and therefore should be embraced or discarded. NCCAM's 2001-2002 budget exceeds $100 million. Why waste additional money on a task force whose real purpose would be to promote unscientific and anti-scientific practices?]
  69. The Commission recommends that Federal agencies, states, and private organizations fund health services research and demonstrations on the safety and clinical effectiveness of CAM practices and products, the use of CAM in underserved and vulnerable populations, and the efficacy of various models for providing CAM services, including integration and collaboration, within the U.S. health care system. [This restates the false assumption that CAM is safe and effective and will be supported by further research. The reference to "undeserved [sic!] and vulnerable populations" also shows that #60 is intended to facilitate the continued and even expanded victimization of those currently medically underserved.]
  70. The Commission recommends that Federal agencies, state, and private organizations fund health services research and demonstrations on the costs and cost-effectiveness of CAM interventions and wellness programs. [This appears to be a restatement of #69. WHCCAMP's members apparently appreciate that a lie repeated often enough is more likely to be accepted as true.]
  71. The Commission recommends that the Secretary, Department of Health and Human Services, support the development of coding for CAM services and products and, specifically, conduct a study analyzing nationally-used coding systems (including current CAM systems) and the issues associated with integrated versus separate CAM coding systems, and make recommendations. [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.]
  72. The Commission recommends that state governments recognize and address barriers to third-party coverage of safe and effective CAM services related to the legal authority to practice CAM interventions within the state. [Few interventions promoted as CAM have been proven safe and effective for their intended purposes. There is no logical reason to force third-party payers to pay for methods that are unproven and/or irrational.]
  73. The Commission recommends the Secretary, Department of Health and Human Services, through the National Institutes of Health and other appropriate agencies, identify CAM interventions of importance to patients, health care providers, and the general public that need an assessment of the state-of-the-science, and conduct conferences to produce consensus statements. [This falsely implies that many CAM interventions are beneficial, important to patients, and deserving of special government attention.]
  74. The Commission recommends that the National Center for Complementary and Alternative Medicine, through its clearinghouse, provide information on safe and effective CAM services and products including information on health services research and demonstrations, models of providing CAM, costs and cost-effectiveness. [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.]
  75. The Commission recommends that appropriate Federal departments report to the President and Congress on the status, coverage and reimbursement, and impediments to coverage and reimbursement of CAM services and products for their respective beneficiaries or through their respective sponsorships. [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.]
  76. The Commission recommends that health care entities that influence health policy and the delivery of health care services, such as insurance and managed care associations, integrate information regarding safe and effective CAM interventions into appropriate professional meetings. [This, again, falsely implies that many methods promoted as CAM deserve to be integrated into mainstream practice. By definition, once a medical intervention is validated, it ceases to be "CAM." Moreover, effective methods do not need political pressure to gain scientific acceptance.]
  77. The Commission recommends that the Secretary, Department of Health and Human Services, provide support for the development of informational programs on safe and effective CAM services and products which are targeted to purchasers, insurers managed care organizations, health care professionals, and providers of health care services. [The amount of useful information that fits this description is trivial. If anything, the public needs more information about what CAM methods are known to be ineffective]

    CAM in Wellness, Self-care and Prevention

  78. The Commission recommends that DHHS review the 10 leading health indicators and, where appropriate, develop strategies to encourage the use of safe and effective CAM principles and practices in these areas. [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.]
  79. The Commission recommends that questions on specific CAM usage be included in the national surveys that are the sources of the HP 2010 data including the National Health Interview Survey, National Health and Nutrition Examination Survey, and the Medical Expenditure Panel Survey. [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.]
  80. The Commission recommends that CAM become part of a national focus to improve the health behaviors of children. Where appropriate, CAM practices should be incorporated into national guidelines on wellness and prevention practices for children, and a media campaign be should be conducted that includes public service announcements and involvement of public figures to teach and encourage healthy behaviors among children. [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.]
  81. The Commission recommends that, in partnership with the business community and school boards, incentives be developed for schools to make available healthier school lunches and snacks and to limit the sale and advertising of high fat snacks, soft drinks, and other products that do not contribute to a healthy lifestyle. ["CAM" adds nothing to ongoing efforts to assess and improve the nutritional value of school lunches. The Commission appears to be attempting to associate CAM with almost anything that the public regards as health-promoting activity. Moreover, some CAM promoters deny that a high-fat diet is unhealthy.]
  82. The Commission recommends that CAM wellness and prevention activities be included in all Federal worksite wellness and health promotion programs and Federal health coverage plans. [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.]
  83. The Commission recommends that, in consultation with the business community, incentives be developed for employers to include CAM wellness and prevention in worksite wellness programs and health coverage and decrease premiums. [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 nonfederal workers.]
  84. The Commission recommends that the Secretary, DHHS, establish a task force to develop strategies to incorporate CAM wellness and prevention activities in Federal programs such as Head Start, Meals on Wheels, The Special Supplemental Nutritional Program for Women Infants and Children, Healthy Mothers/Healthy Babies Program, and the State Children's Health Insurance Program. [It is unconscionable to indoctrinate needy people and children with nonsensical and anti-scientific ideas about health, disease, and the use of medical resources.]
  85. The Commission recommends that the Secretary, DHHS, establish a task force to develop strategies to incorporate CAM wellness and prevention in health care delivery programs such as the Department of Veterans Affairs Hospitals, community and migrant health centers, maternal and child health programs, and school health programs. [The same as #84 but aimed at other groups.]
  86. The Commission recommends that the Secretary, DHHS, establish a task force to develop strategies to incorporate CAM wellness and prevention activities in the nation's hospitals and long term care facilities and programs serving the aging, dying, and those with chronic illness. [This falsely implies that CAM offers special value to people who are elderly, chronically ill, or dying.]

    Coordinating and Centralizing Federal CAM Efforts

  87. The Commission recommends that The President, Secretary of the Department of Health and Human Services, or Congress should create an Office at the highest possible and most appropriate level with sufficient staff and budget to perform functions that include, but are not limited to, coordination of Federal CAM activities; Federal CAM policy liaison with conventional health care and CAM professionals, organizations, institutions, and commercial ventures; planning and convening conferences, workshops, and necessary advisory groups, centralized Federal media point of contact; and facilitation of implementation of the WHCCAMP recommendations. [It would be scandalous 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.]

WHCCAMP's recommendations imply that CAM is an innovative field of healthcare. But it is not. As eloquently noted by editors of our nation's top two medical journals:

"There is no alternative medicine. There is only scientifically proven, evidence-based medicine supported by solid data or unproven medicine, for which scientific evidence is lacking. Whether a therapeutic practice is 'Eastern' or 'Western,' is unconventional or mainstream, or involves mind-body techniques or molecular genetics is largely irrelevant except for historical purposes and cultural interest." -- Fontanarosa PB, Lundberg GD. Alternative medicine meets science. Journal of the American Medical Association 280: 1618-1619, 1998.

"There cannot be two kinds of medicine -- conventional and alternative. There is only medicine that has been adequately tested and medicine that has not, medicine that works and medicine that may or may not work. Once a treatment has been tested rigorously, it no longer matters whether it was considered alternative at the outset. If it is found to be reasonably safe and effective, it will be accepted. But assertions, speculation, and testimonials do not substitute for evidence." -- Angell M, Kassirer J. Alternative Medicine -- The risks of untested and unregulated remedies. New England Journal of Medicine 339:839-841, 1998.

The WHCCAMP report calls for an expanded bureaucracy that will waste taxpayer dollars and further the special interests of ideologues and profiteers. Its recommended initiatives are unlikely to advance scientific knowledge and will certainly not protect consumers. The White House should reject the report.

For Additional Information

About the Authors

Dr. Gorski, who practices obstetrics and gynecology in Arlington, Texas, is president of the Greater Dallas-Fort Worth Council Against Health Fraud and a board member of the National Council Against Health Fraud (NCAHF). Dr. Barrett, a retired psychiatrist who resides in Allentown, Pennsylvania, is NCAHF vice president and director of Internet operations.

Acknowledgement

William London, EdD, MPH, and Robert Imrie, DVM, were of invaluable assistance in preparing this analysis. Dr. London, a health educator, is NCAHF's program director and a former president. Dr. Imrie heads NCAHF's veterinary task force and operates the Alternative Medicine Advisory Page.

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This article was posted on March 31, 2002.