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Forum on the Regulation of Complementary and Alternative Practitioners, Institute of Public Administration, 20 June 2001


Afternoon session:

From what you know about registration, what positive reactions do you have in relation to it? What are your concerns about it? Feedback from Groups Participants reported back in groups with the comments which are set out below.


GROUP 1


Positive Reactions

  • If it's a neutral framework, (and we have some doubts about that), it will be positive - provided that control remains largely within the individual profession.

Concerns

  • Regulation is positive but we shouldn't forget where we come from. There is a large deficit in the existing health care system, which is highly regulated. Perhaps we should learn from the problems of that regulation.
  • A framework regulating the scope of practice is "neutral" but it should not over-regulate the scope of practice across professions.
  • Any regulatory body should be controlled by the profession.


GROUP 2


Positive Reactions

  • The granting of the protection of title and the definition of the scope of practice would be positive.
  • Regulation would facilitate the development of a good system of training and would uphold good standards of training.
  • It would help us to know each other's therapy better and increase mutual respect across groups.
  • The marriage of scientific and empirical principles would be positive.
  • Our therapies are valid systems in the health services and regulation would reinforce the validity of individual therapies.
  • The public would benefit - regulation would increase public confidence and accountability.
  • It would provide protection for the practitioner and there would be less of an administrative burden for the individual profession.
  • Regulation would allow practitioners to leave some "baggage" behind - there would be a new agenda for all.
  • It should help practitioners to get proper compensation from BUPA and the VHI and also facilitate funding through the GMS scheme.

Concerns

  • Would there be limitation of the scope of existing practitioners?
  • Would there be a danger of patients being poached?
  • Cost concerns - how much will registration cost?
  • If the cost proved too high, would some people go underground?
  • Accreditation of schools and colleges: Who would do this? Would it be independent, transparent? What would be the appeals process?
  • It's important that we are not shoehorned into a medical model.
  • Would the disciplinary panel be able to understand the modus operandi of practitioners?
  • Fora such as today's should not be dominated by the agenda of any particular group.


GROUP 3


Positive reactions

  • It's important that there be a reasonable representation of the various therapies on the regulatory body.
  • Regulation would lead to more respect for complementary therapies.
  • It would bring order to our field and a better legal standing
  • It would help the process of developing a recognised standard for CAM therapies.

Concerns

  • The method of registration should not be based on any medical model.
  • Would there be over-control of the psycho-spiritual aspects of therapy?
  • Specific therapies should not get preference over others.


GROUP 4


Positive reactions

  • Regulation would help in the setting of standards.
  • It would allow for flexibility.
  • Regulation would be owned by the profession.
  • There should be a focus on legislation rather than on over-regulation.
  • The protection of titles is very important.
  • The regulation proposal recognises that we had intended to regulate ourselves.

Concerns

  • Would existing professional bodies have a primary role?
  • Where would the initial membership of the Registration Board come from?
  • How will you benchmark who can and can't practise?
  • What will determine what constitutes a "rogue" practitioner?
  • The "grandparenting" issue -people in practice for a long time but without appropriate qualifications Could talented people without appropriate qualifications be excluded?
  • Is the timescale for introducing registration very open-ended?
  • Would multi-disciplinary practitioners have to pay fees to more than one register?


GROUP 5


Positive reactions

  • Statutory regulation would be good for our image.
  • It would provide a database of practitioners.
  • It would provide guidance on training - for example, curriculum guidelines.
  • It would provide a framework for insurance cover - that is, group cover.
  • It would allow therapies to cooperate more closely.
  • It would formalise therapies and increase their credibility.

Concerns

  • What would happen in relation to representation if associations were to split?
  • Who will decide what is a valid outcome of a treatment?
  • Who will assess therapies?
  • There was poor notification for this meeting.
  • There is no representation today of the creative arts therapies.
  • Regulation should not close the door on future developments in each therapy.
  • Words and terminology are open to debate: perhaps holistic health and wellness are more appropriate words than complementary medicine?
  • Is practitioner a better word than therapist?
  • What constitutes a professional association?
  • Who will decide how people can upgrade themselves in order to attain registration?
  • How would we upgrade spiritual healing?


Group 6


Positive reactions

  • Regulation would enhance public accountability.
  • It would improve recognition by other health professions and peer groups.
  • It would eliminate "personalities" in the CAM therapies.
  • It would facilitate the transfer of skills within these therapies.
  • It would highlight the importance of continuing education.
  • It must be member-driven.
  • Could database/information on today's participants be circulated?

Concerns

  • Homeopathy: how will the tools of the trade be regulated? What will be the role of the Medicines Board?
  • Who will define the individual practitioner? Will this be done by the profession or by the Department of Health and Children?
  • The eclectic practitioner -what happens if there's a problem with such a practitioner? How would that be regulated?
  • Will the same rules apply to doctors who practise acupuncture as to CAM therapists? May a doctor who has done a weekend course call himself or herself an acupuncturist?
  • Appropriate vocabulary is important
  • How will accreditation work? Will the Department of Education be involved in standards?
  • Who will determine what qualifications are acceptable?
  • Could private schools have access to state libraries?
  • If the EU were to bring in its own rules, would this separate Irish process of registration be a waste of time?


GROUP 7


Positive reactions

  • Regulation would bring protection for public and practitioners and would facilitate continuing education for practitioners.
  • It would facilitate health education for the public.
  • It would bring a higher status for practitioners.
  • It would be a first step to making CAM therapies available to GMS patients.

Concerns

  • There is some fear of the unknown, apprehension.
  • Would this be a very intrusive process?
  • Might the process dilute the potential of a therapy for clients?
  • Will there be protection for homeopathic remedies while regulation take place?
  • Should therapists be affiliated to an association before they register?
  • Research should not be based on the medical model but should be carried out by research specialists in a particular therapy.
  • Quality of life is hard to measure.


GROUP 8


Positive Reactions

  • We welcome the opportunity to regulate "from the inside out".
  • This would be a good framework for moving forward.
  • 13 bodies have agreed a structure to date and we can benefit from that.

Concerns

  • An inappropriate medical and academic model would be established as a framework for CAM therapists.
  • Who will decide the admission requirements for registration?
  • We have a problem with the concept of "market leaders" - each therapy should be considered equally.
  • In relation to evidence for efficacy, how would that evidence be provided and who would provide it?
  • What would be the influence of the Department?
  • Will assistance be fostered to professional associations in order to meet registration requirements?
  • We have concerns about training through VEC courses.
  • Protection of the practitioner is equally important as protection of the public.
  • Will everything become over-academic as in Europe?


Group 9


Positive reactions

  • Regulation is necessary for the development of CAM therapies.
  • It would give support to practitioners and recognition of the CAM professions.
  • It would ensure that there is no place for rogues.
  • The public would become more open to CAM practitioners.
  • We would no longer be outsiders in the system.
  • There would be tax recognition from the Government and GMS access.
  • It would lead to better health for the public in general and to positive referrals from the medical profession.

Concerns

  • What would be the reaction of vested interests: doctors, pharmaceutical companies , the Irish Medicines Board?
  • Would the involvement of the State in our organizations damage the ability of our professional groups to run our own affairs?
  • We shouldn't adopt the French or Italian model of regulation - we need an Irish model suitable for Irish conditions.
  • If therapists can register directly, would that fragment associations?
  • Who will control individuals who have registered?
  • What happens if there is a dispute between the professional body and the proposed registration board?
  • Could there be splits on these issues?
  • Group insurance: if people can register directly, how will insurance work?
  • Would there be too much emphasis on academic issues? CAM is not academic. People can be excellent therapists but not good at passing exams.
  • What would be the situation be of people who are not members of a professional association yet practise with friends etc?
  • Accredited training - if there are academic courses from outside the State, how will these be controlled/ monitored?.
  • How will training schools here be monitored?
  • The "Grandparenting" issue - also referred to by Group 4 - was mentioned.


GROUP 10


Positive reactions

  • If it works, it would protect professions and the public.
  • It would protect individuals from legal attack.
  • It would be nice to make progress early and to influence EU policy.
  • It would allow the treatment of GMS patients and would lift the status of individual professionals.
  • There was also a strongly expressed individual view in this group that: We don't yet know enough about the proposed registration process.
  • We would be embarking on a process without knowing why or why at this time or in this way.
  • Once a law is introduced, it is impossible to change it.
  • This process represents the triumph of hope over experience.

Concerns

  • There is some apprehension about this.
  • Why not let Europe sort it out first?
  • Common law gives us freedom but the move to a legal structure set in stone will limit us.
  • We don't have enough information.
  • Orthodox medical science has a rigid materialistic standpoint while CAM is vital, growing and dynamic. Its evolutionary tendency could be stifled by regulation.


ADDITIONAL COMMENTS

  • There were some additional comments in general discussion which are set out below
  • There is a huge difference between the empiricist approach in the West and the holistic approach in East.
  • Up to now, very few people have needed protection from us.
  • Change is necessary to meet the needs of modern health care.
  • The term CAM is inappropriate - it implies that conventional medicine is traditional but that we are not. In fact, CAM therapies are very ancient and stand up in their own right.
  • What we do here will influence generations afterwards - regulation will lead to fragmentation and specialization.
  • We have a concern with the whole person.
  • We are holistic healers - we need to heal ourselves.
  • If we don't respect ourselves as healers, we will not change society where there is a lot of conflict, problems.
  • Should there be a re-think - do we need to take steps on our own first?
  • Hierarchical structures are not appropriate.
  • Who will control this?
  • When I meet another person wanting help, I give help and don't worry about his or her insurance status. Could this change with regulation?
  • Will groups which have been self-regulated for years be held back under statutory regulation?
  • We don't have a health care system, we have a sick care system.
  • Why did the Department consult only with a small number of Associations? (This was unlike the British experience).
  • The shape of proposals has been set out without proper consultation with us.
  • Why will there only be one title per profession?
  • Why is the scope of practice limited?
  • Is it possible that the views and aspirations of existing health care professions are too closely reflected in these proposals?