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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.

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This article was posted on March 25, 2002.