CNHC Consultation
The Complementary and Natural Healthcare Council (CNHC) are running a consultation on their code of conduct. Here are my responses.
I have decided to publish them here both as a permanent record of my response, and as an explicit waiver of my right of anonymity in the survey.
If you want to get involved with the consultation, it's at www.cnhc.org.uk/?page_id=2&news_id=155 and is live until 30 September 2013.
Here's my response to the survey, shorn of all formatting:
Consultation - Review of Code of Conduct, Ethics & Performance
1. Are you responding as? Member of the public
Standard A: You must respect clients' dignity, individuality and privacy
2. Is Standard A easy to read and understand? No
If no, how can we improve it?
A2. Define when a child is competent to make his/her own decisions. Define (or refer to definition of) vulnerable adult. Informative links are provided elsewhere in the document e.g. section A3. A5. Define confidentiality boundaries. With whom is it appropriate to discuss a patient? See also A8 - define "colleague". Presumably includes other practitioners, excludes receptionist.
3. Are there any additional areas that you think should be covered in Standard A? No
If yes, which additional areas should be covered?
Standard B: You must respect clients' rights to be involved in decisions about their healthcare
4. Is Standard B easy to read and understand? No
If no, how can we improve it?
B3. Good to see that the requirement for full disclosure of necessary information is so prominent in this section. However, the wording could be improved. The phrase "the information they want or need" should be made clearer. Needed information (e.g. risk information) must always be presented. It must never be withheld just because the client did not "want" it. 2(c) It should also be made clear that the best available medical evidence must be used when informing patients about risks and benefits of any treatment.If there is no reliable evidence that a treatment is likely to work, then this must be disclosed for properly informed consent to be obtained. 15. For a competent child (or indeed anyone) to provide consent, all information about the treatment, including risks, must be made available to them. A competent adult must be able to override the child's consent if, in their opinion, the practitioner has not adequately and completely explained the risks and benefits of the treatment. B4 Where a translator is used, this must be an independent translator, not a person related to the client. Otherwise, it is impossible to gain assurance that appropriate levels of understanding have been reached, and fully informed consent given.
5. Are there any additional areas that you think should be covered in Standard B? No
If yes, which additional areas should be covered?
Standard C: You must justify public trust and confidence by being honest and trustworthy
6. Is Standard C easy to read and understand? No
If no, how can we improve it?
C4(b) Please clarify the evidence required for a claim to be properly founded. (d) Exploiting lack of experience or knowledge on health matters is difficult to define if the health matters under discussion are not backed up by robust medical evidence (e.g. existence of meridian lines in acupuncture). (e) How does this relate to regimes of ongoing treatment which are said to require regular visits to maintain optimum health / balance / flow / etc.? (f) In order to avoid misleading patients, the sources of information given about the treatment should be disclosed, or at least easily available. C4 as a whole mentions the ASA code of advertising practice, but does not make any specific requirement to adhere to it. This should be a condition, especially section 12. C6.(b) This is very vaguely written. It should be a clear conflict of interest to both recommend and supply treatments.
7. Are there any additional areas that you think should be covered in Standard C? No
If yes, which additional areas should be covered?
Standard D: You must provide a good standard of practice and care
8. Is Standard D easy to read and understand? No
If no, how can we improve it?
In addition to the rather vague advice on consultation with other, firm guidelines should be laid down for when outside advice must be sought, e.g. long term decline (or lack of improvement) in a patient's state, acute reaction to treatment, errors in treatment, aftercare, and so forth.
9. Are there any additional areas that you think should be covered in Standard D? No
If yes, which additional areas should be covered?
Standard E: You must protect clients and colleagues from risk of harm
10. Is Standard E easy to read and understand? No
If no, how can we improve it?
E6 Practitioner health guidelines should include a requirement to be immunised against any common infections which are associated with a therapy. This is especially important for any therapy where needle stick injuries or blood contact are a risk. Also, what particular risks are there in systems of treatment that do not acknowledge the germ theory of disease?
11. Are there any additional areas that you think should be covered in Standard E? No
If yes, which additional areas should be covered?
Standard P1: Practice Arrangements
12. Is Standard P1 easy to read and understand? No
If no, how can we improve it?
The introduction to section P specifies "competent and safe practice". This should also include the word "effective". Ineffective practice is neither competent nor safe.
13. Are there any additional areas that you think should be covered in Standard P1? No
If yes, which additional areas should be covered?
Standard P2: Assessing the health and health needs of clients
14. Is Standard P2 easy to read and understand? No
If no, how can we improve it?
P2.1(b), P2.6(b) Again must reiterate that robust evidence must be provided, for both risks and benefits. P2.4(c) How is competence at interpretation of results measured? If information is gathered in the context of a clinical trial, the trial protocol and outcome measures should be registered with alltrials.net prior to the start of the trial. P2.7(2) The use of the word "should" to check legal requirements must be strengthened to "must".
15. Are there any additional areas that you think should be covered in Standard P2? No
If yes, which additional areas should be covered?
Standard P3: Provision of care
16. Is Standard P3 easy to read and understand? No
If no, how can we improve it?
The requirement for best available evidence is buried here in section P3.2(a). This should be front and centre. P3.3 The client must always have a copy of their plan of care, for reference. Any changes to the plan of care must be recorded. All versions of the plan of care must be retained.
17. Are there any additional areas that you think should be covered in Standard P3? No
If yes, which additional areas should be covered?
18. Are there any aspects of the Standards that you feel could result in differential treatment of or impact on groups or individuals based on: Age, Gender reassignment, Ethnicity, Disability, Pregnancy and maternity, Race, Religion or belief, Sex, Sexual orientation, Other (please specify)
No
19. Do you have any other comments?
All consultation responses must be published, so that progress can be adequately monitored.
Thank you for your time