Aesop’s fable about the wolf that disguised itself as a sheep in order to mislead and ultimately consume the flock, is a tale intended to warn us of the potential deceptiveness of appearance. We live in an age where appearance is everything. Often, what we are presented with has been carefully, sometimes calculatingly, manufactured to generate a specific reaction. The art of manipulating information and transforming it into a format designed to achieve a particular agenda is practised by a wide range of professions, from pop stars to advertisers to politicians. Because a wolf is always a wolf no matter how cleverly disguised, eventually the deceit is discovered, though often too late to avoid damage or destruction to the hapless victim.

A consultation exercise is a wonderful example of a knowing wolf masquerading as a harmless sheep, where the right sort of questions can be asked in order for pre determined conclusions to be drawn, all to be presented in an attractive package designed to minimize critical scrutiny. On 28th September 2006, the Princes Foundation for Integrated Healthcare (PFIH) published their report on the consultation exploring a ‘Federal Approach to Voluntary Self Regulation (VSR) of Complementary Healthcare’. The consultation was open to all ‘stakeholders’ within CAM, and 438 responded. The results, which can be studied in detail on the PFIH website (www.fih.org.uk) have been interpreted as giving a ‘clear mandate to pursue a federal approach’. As is usual with exercises of this nature, the greatest emphasis is placed upon areas of acquiescence, with the reader’s attention being skilfully directed away from issues that have the potential to reveal disagreement. Take question 24 as an example:

68% of respondents agreed, 14% disagreed and 18% didn’t respond/know. The 14% who disagreed largely consisted of the homeopathy profession (because we have chosen the unilateral route for VSR) and the Alexander Technique Teachers, who consider their profession to be ‘erroneously defined’. They say they do not treat people or cure diseases, but teach people to help themselves, therefore they feel it would be inappropriate to attempt to categorize Alexander Technique in the same way as other CAM therapies. This does highlight a valid point of view from the Alexander Technique Teachers, but hardly represents a criticism of federalization per se. Likewise, we are offered a quote from the Commissioner of Healthcare, who has concerns about VSR in general, stating that the public could only be truly protected by statutory regulation. The criticism is aimed at voluntary self regulation, not federalization. I know that a number of respondents from the homeopathy profession, including ARH, expressed strong views about the establishment of a federal regulating body for CAM practitioners. In the PFIH report on the consultation, this voice of dissent is conspicuous by its absence!

The craft of this federal wolf is further exemplified by the use of sweeping statements of intent that swiftly carry the unsuspecting flock to a point of no return. This is best illustrated by the proposed timescale for the establishment of a federal body. We are told that ‘A shadow regulator would be established within the lifetime of the Foundation’s (PFIH) current regulation programme’ and we are then offered a timescale to consider which basically starts now, and concludes sometime in early 2008. Though some respondents did consider the timescale too short, there was no credible resistance to agreeing to follow the agenda already set by PFIH. A verbal presentation of the PFIH consultation was offered to representatives of the various CAM therapies before the written results were released to the public. The event was well managed, the message unmistakable and the mood upbeat. Under the circumstances, it is hardly surprising that any remaining reservations about the feasibility of the timescale were quickly dissipated. For many at the meeting, federalization seemed to offer a ‘ higher recognition factor’ for their respective therapies in terms of public perception, so PFIH’s willingness to take control of the process was broadly welcomed. There was just one brief hint of the wolf lurking beneath the woolly disguise: Professor Julie Stone was asked to comment on concerns expressed relating to the size and potentially unwieldy structure of the new federal council. She suggested that one way to avoid this problem was to establish a council constituted by individuals outside of the CAM professions, who would be tasked to develop strategic planning for the federal body. Input from the professions would be incorporated into the policy making process at ‘appropriate times’. This approach to managing the proposed federal body is one way of ensuring that the decision making power stays with the regulators, and the professions are gradually parted from their autonomy. Under different circumstances, this could be referred to as a dictatorship in the making.

The justification offered for the regulation of any profession is to protect the public interest. An entire industry is generated by the fallacious separation of the principles of best practice and patient protection. In reality, they are two sides of the same coin. A competent practitioner will deliver a high standard of patient care. It will always be impossible to regulate against human error, and those few individuals who deliberately set out to harm their patients will find a way through even the most rigorous regulatory structures. The majority of practitioners are dedicated to providing a quality service to their patients, and these are people with whom we should be investing our limited resources. Regulation by its very nature is an expensive exercise, and it is the practitioner who ends up having to pay for the privilege of being regulated. We are told that one of the advantages of all CAM practitioners being regulated by a single federal body is the ‘economy’ of size: It is more economical to control a large number of practitioners via a central regulator, so that should result in lower registration fees. This supposition is open to question: My local osteopath pays over £60 a month to be registered with the General Osteopathic Council (GOsC). Osteopathy is regulated by statute, which may have some bearing on the registration fee, but given that there are nearly 4000 registered osteopaths, £750 per year, with an additional £360 for insurance, represents a substantial annual outlay. The proposed federal body is likely to register considerably more than 4000 practitioners, which may well reduce the costs to individuals, but the fundamental structure of the organization does not support an efficient, cost effective approach to VSR. Part of the problem is that the Department of Health (DoH) has made funding available to PFIH to establish this federal body. In theory, this is going to save Government vast amounts of money because statutory regulation is expensive (about £2 million to oversee the statutory regulation of a single profession), so lumping all the non-regulated CAM therapies together in order to pursue a federal approach will keep the costs down for Government. Because PFIH started its exploration of federalism with money in hand, it was in a position to engage an academic to scope out the model that then went out for consultation. It could also provide the support team necessary to analyse and interpret the results of the consultation, and run a feasibility study (another ‘academic’ exercise). This leaves us with a hypothetical structure designed to deliver ‘robust’ regulation right across the spectrum of CAM therapies. Because federalization represents a ‘one size fits all’ approach to regulation, it will be difficult to implement in practice. This will mean new layers of bureaucracy will be added to existing ones in order to ensure regulatory requirements are met across the board. In other words, federalism will inevitably feed the ever growing regulation industry, and unless meaningful checks and balances can be put in place, costs will rapidly spiral out of control.

Fortunately, the homeopathy profession has unanimously rejected the invitation to become part a federal body. We have chosen to ‘go it alone’ and retain our autonomy as a profession. We already engage in VSR, and have spent the last five years exploring the possibility of unifying standards within the profession. We have made considerable progress and have agreed a number of important issues, some of which we could begin to integrate into our existing structures, to the benefit of homeopathy as a whole. There are however some fundamental matters that remain unresolved, and we will need to work our way through these ‘blocks’ to cure, if we are to move forward. One thing is certain, if the process of unification is to work, we will have to let it take the time it needs to come together organically. If we try to impose the conventional model of regulation upon homeopathy, we could do irreparable harm to a profession that is only just beginning to emerge into the wider world. We currently have a number of registering bodies because this reflects the diversity that exists within homeopathy. We need to preserve that diversity, because it is an integral part of the homeopathic process that must be properly valued.

Following a year of relentlessly bad media coverage, the homeopathy profession is under considerable strain. Many practitioners are commenting on reduced patient numbers, most of the colleges have experienced a lower intake of students this academic year, and two colleges have closed down altogether (see announcement on page 9). This is the wolf letting its cover slip. We have all been so focused on trying to achieve a single register, we have failed to adequately address the needs of homeopathy. There has been so much emphasis on protecting the public interest we have allowed the profession itself to be placed in a vulnerable position. We need to have the courage to expose the wolf in our midst, or else we risk dissipating the fragile structures we have all worked to hard to create over the years. We must now focus on strengthening the public perception of homeopathy, so that our patients can continue to benefit from it in the future.

In my article ‘Bogeymen and Tablets of Stone’, (Homeopathy in Practice, Autumn 2006) I commented on the disastrous exposé homeopathy had been subjected to on Newsnight (Friday 14th July). I expressed disappointment at the manner in which homeopathy had been represented during the interview which followed the ‘undercover’ film. I have since received a letter from Paula Ross, Chief Executive Officer for the Society of Homeopaths (SoH), asking me to clarify matters. Paula Ross states:

I would like to correct the assertion that our Communications Manager, Melanie Oxley, was asked to appear on Newsnight as “the representative chosen to defend homeopathy”. In fact, The Society of Homeopaths was asked to defend the professional regulation of its members, not the profession as a whole. Nor were we asked to comment on the efficacy of homeopathy or its merits when contrasted with conventional medicine.

I can only say that as a member of the public, I witnessed Newsnight using very shoddy tactics to challenge homeopathy, and the homeopath in the live interview was unable to offer even the most basic defense. As a member of the homeopathy profession, I saw an organization that has been in existence for nearly thirty years fail to protect the interests of homeopathy. However you choose to view the situation, the victim here is homeopathy itself. The moral: Beware the regulatory wolf that seeks only to protect the public interest, for it is likely to destroy the very entity it purports to cherish.