Freedom of Information Act (FOIA)
Do homeopaths’ claims that trials are too expensive and that they can’t afford them hold water?
Science is simply a systematic way for carefully and thoroughly observing nature and using consistent logic to evaluate results. Which part of that exactly do you disagree with?
— Dr Steven Novella
But homeopaths have a problem: all advertising in the UK has to comply with the Advertising Standards Authority’s CAP Code and this rightly demands a high standard of evidence for any claim, regardless of whether it’s about how clean a soap powder makes your whites, how efficient double-glazed windows are or how much a skin cream reduces the appearance of wrinkles. So it is with homeopathy: high quality evidence is required.
There have been several ASA adjudications recently against homeopaths (eg Steve Scrutton), homeopath trade bodies (eg the Society of Homeopaths — and you must watch this superb demolition of their ‘evidence’) and homeopath advocacy groups (eg H:MC21) and these have shown the paucity and extreme poor quality of homeopathic research.
But there doesn’t seem to be that much new research being conducted that might allow claims to be made in the future. Instead, there are moves to try to persuade the ASA to lower their standards in the hope their evidence will meet this easier threshold, campaigns to oppose the ASA, petitions raised to force the ASA to change its ways, with frequent shouts of ‘Censorship!’, ‘Bias!’, ‘Freedom of speech!’ and double standards.
There are even moves afoot to ‘re-categorise’ the literature on homeopathy. This is in the early stages and will probably take a few more years to complete, but there will be no prizes for guessing what the conclusions are likely to be — a comparison with the farce surrounding the Swiss report on homeopathy is inevitable.
Patient success stories Anecdotes
But homeopaths insist there is ample proof that homeopathy works already, and are keen to point out the large numbers using homeopathy as if that was an indication of efficacy. Ah, that old canard — evidence in the form of anecdotes — doesn’t wash with anyone even vaguely aware of the problems of bias and with an interest in getting to the truth of the matter; and certainly not up to the ASA’s standards. Many websites of homeopaths laud their customer testimonials and there are several websites that actively gather anecdotes (or ‘patient success stories’ as they sometimes like to call them) such as Homeopathy Worked for Me, Patient Testimonials and a relatively new one, Making Cases Count. And of course there are their celebrity endorsements; where would homeopaths be without their celebrity endorsements?
A number of anecdotes may indicate that something is worth looking at in more detail, but they are no indication of the efficacy of homeopathy and they certainly don’t change the state of the robust, independent evidence for homeopathy — or rather, the lack of it.
Many homeopaths rubbish science of course, dismissing it as reductionist and entirely unsuitable as a means of testing their precious homeopathy. But they fundamentally misunderstand science. As Dr Steven Novella puts it:
What do you think science is? There’s nothing magical about science. It is simply a systematic way for carefully and thoroughly observing nature and using consistent logic to evaluate results. Which part of that exactly do you disagree with? Do you disagree with being thorough? Using careful observation? Being systematic? Or using consistent logic?
Yet homeopaths crave scientific respectability — they laud (erroneously), for example, the neutral Swiss Government for their highly positive homeopathy HTA and just about every half-baked study they can twist to make it support their favourite hobby-horse. They know that they will not make the progress they believe they deserve unless they can, finally, provide that good scientific evidence they just know is waiting to be found. As I’ve mentioned, it was this lack of good evidence that lost both the Society of Homeopaths and the homeopathy advocacy organisation, Homeopathy: medicine for the 21st Century (H:MC21) their Advertising Standards Authority adjudications for claims they had made in adverts. Not just on a few minor points here and there, but a complete and utter demolition of their homeopathic claims.
There are even some university academics who spend their time researching homeopathy, such as homeopath Dr Clare Relton, Senior Research Fellow at the University of Sheffield and homeopath Dr Elizabeth Thompson, Consultant Homeopathic Physician [sic] and Honorary Senior Lecturer in Palliative Medicine at University Hospitals Bristol. There are many others as well who see themselves as legitimately researching their sugar pills.
There are even organisations whose sole purpose is to improve research into homeopathy. Take the Homeopathy Research Institute (HRI):
The Homeopathy Research Institute is an innovative international charity created to address the need for high quality scientific research in homeopathy. We use our resources and expertise to foster new projects and to improve the quality of research being carried out in the field.
Anyway, the HRI heralded that their conference in Barcelona this year would be, “A significant step forward for homeopathy research“. A critical thinker might be considerably less than underwhelmed by what actually happened.
But at least they are trying to do some research; and scientific to boot. Indeed, they have seven research projects running at the moment:
- Case series of 20 children diagnosed with ADHD treated with homeopathy for a year
- Depression – What is the role of treatment by homeopaths?
- Irritable Bowel Syndrome (IBS) randomised controlled trial
- Online database of homeopathic scientific literature
- Physico-chemical properties of homeopathic dilutions
- Physics of homeopathic dilutions
- Theories of homeopathic dilutions
Well, by ‘running’, I mean that they are trying to raise the money to fund them.
This list certainly covers a lot of ground; most don’t require any research to answer, though…
But the one on depression says it’s simply part of a PhD:
This project will evaluate the acceptability and the comparative effectiveness of adjunctive treatment provided by homeopaths for patients with self-reported depression, in addition to usual care.
So it’s guaranteed to give positive results even before it’s started!
But how much does this research cost and how on earth could they raise the money?
In conventional medicine, pharmaceutical companies have the advantage of having funds for research. Alternative medicine lacks that.
It seems like homeopaths are so adept at coming up with excuses, anyone would think they can anticipate the outcomes…
But, other than tapping the likes of leading homeopathy manufacturer Boiron — with its market capitalisation value of just under 1 billion Euros — how on earth can they afford this very necessary research? Until they have positive results from robust, high quality trials, they will not be able to make the claims they might like to in their advertising, so the onus is definitely on them to do whatever’s required to advertise their businesses honestly.
|Depression: What is the role of treatment by homeopaths?|
|Homeopathy Research Database|
|IBS Trial: Phase 2 Fundraising Appeal|
|Irritable Bowel Syndrome (IBS) randomised controlled trial|
|Physico-chemical properties of homeopathic dilutions|
|A new quantum theory to explain homeopathy|
|Physics of homeopathic dilutions|
|Theories of homeopathic dilutions|
|ADHD case series|
Of course, these are just the target amounts they want to raise from donations and they could have additional funding secured from elsewhere, but note that four of them have offline donations already.
This could also answer the question about how much a homeopathic trial costs and it won’t go unnoticed that the Q-word rears its ugly head.
Positive by design
Their two IBS projects (IBS Trial: Phase 2 Fundraising Appeal and Irritable Bowel Syndrome (IBS) randomised controlled trial) are raising funds from two different websites: one with a target of £15,000 and the other of £10,000. However, in the past 12 months, excluding a one-off online donation of £10,000, they have raised a grand total of just £1,490 from the public.
But maybe these are one and the same trial? They certainly appear to be — and it is this trial that is discussed by Prof Edzard Ernst: Homeopathy for IBS? When will we stop wasting resources on such useless pseudo-research?
We are again dealing with an A+B versus B design, on top of it without patient- or therapist-blinding. This type of analysis cannot ever produce a negative result, even if the experimental treatment is a pure placebo: placebo + usual care is always more than usual care alone. IBS-patients will certainly experience benefit from having the homeopaths’ time, empathy and compassion – never mind the remedies they get from them. And for the secondary analyses, things do not seem to be much more rigorous either.
Obviously, I have not seen the data (they have not yet been published) but I think I can nevertheless predict the conclusions of the primary analysis of this trial; they will read something like this: HOMEOPATHY PROVED TO BE SIGNIFICANTLY MORE EFFECTIVE THAN USUAL CARE. I have asked the question before and I do it again: when does this sort of ‘research’ cross the line into the realm of scientific misconduct?
That protocol document says:
This trial has received NHS approval and results are expected in 2013.
It received Barnsley Hospital internal approval on 14 December 2009, ethics committee approval on 9 December 2010, and the protocol paper was published a further two years later, on 6 November 2012.
So, having published the protocol, and with the Current Controlled Trials entry saying it is completed, with an anticipated end date of 31 December 2012, what is the current status of this research? I don’t know. Perhaps they still need money to analyse the results and write up the paper?
Touting for money
Vital IBS trial needs your help
Funding needed: £15,000 Total raised so far: £1,900
Then in March 2103, they said:
IBS trial fundraising appeal – update
On behalf of the researchers at Barnsley Hospital involved in the Homeopathy for Irritable Bowel Syndrome trial (HIBS), HRI would like to thank everyone who donated to our fundraising appeal last November in support of this project. There was a hugely positive response to our appeal, with many warm messages of support as well as donations which totalled just over £2,000. In these hard times, it was a fantastic response from individuals. Click here to find out exactly how these funds are going to be put to use.
“There was a hugely positive response to our appeal”? It doesn’t matter what the true figure is, whether it’s £1,490, £1,900 or even £2,000, it falls dramatically short of the £15,000 they said they needed. I think they mean ‘a truly homeopathic response to our appeal’.
But they go on to give the bad news:
However, shortly after these funds were raised, changes at Barnsley Hospital meant that it would no longer be possible to carry out a second phase of the trial (involving recruitement [sic] of more patients) as intended. Instead, the aim now is to publish the existing HIBS trial results which, in the opinion of Prof Kate Thomas (an expert in Health Services Research) form a “robust pragmatic pilot study”.
After much discussion with stakeholders and those who made donations, the money raised by HRI will be used to provide seed funding for Jackie Raw RSHom (homeopath and HIBS project manager) to carry out a one-year prospective service evaluation of her work providing individualised homeopathic treatment for patients with IBS at Barnsley Hosp NHS Foundation Trust. Jackie would be aiming to treat ~ 30 patients and the total cost of the project has been estimated at £5,000.
It’s just not clear to me what’s going on but I sincerely hope they weren’t raising money for a project that has already been completed!
Bringing home the bacon
But after failing to raise very much funding from their supporters, the HRI now want the taxpayer to pay for research! In their submission to the House of Commons Science and Technology Committee inquiry into antimicrobial resistance (AMR), they want the Department of Health to consider using magic sugar pills to combat the very real threat of resistant bacteria, viruses, etc.
Without a hint of irony, they ask:
1.3 HRI recommends that the Department of Health conducts research to determine definitively whether homeopathy is efficacious for [ear infections in children] (we suggest a multi-centred randomised placebo-controlled comparative trial).
1.4 HRI recommends that Defra conducts research to determine definitively whether the homeopathic medicine Coli 30K is efficacious for reducing the incidence of E.coli bacteria in neonatal piglets (we suggest a multi-centred observer blinded, randomised placebo-controlled trial).
And of course:
1.10 HRI would welcome the opportunity to assist the Department of Health and Defra in investigating the potential for homeopathy to play a role in tackling AMR.
I’m sure they would.
Of course, the elephant in the room is the fact that, even though these fund-raising campaigns have been running for over a year, they have only managed to scrape together a measly 20 online donations. They do seem to have an anonymous offline benefactor, but even taking all donations into account, all they have managed to muster is 20% of their total.
So it seems that homeopaths and their customers aren’t too willing to pay for research.
Maybe we’re expecting too much here. Maybe the money just isn’t there in these straitened, austere times?
But maybe we also need some alternative thinking here: rather than wringing hands and saying it can’t be done, how much could be raised by practitioners with a small levy on each appointment? That sounds like an easy way of raising funding: from the very people who desperately need to keep on the right side of the rules for their advertising and who will benefit most from being backed by good scientific evidence.
After all, there are several thousand homeopaths plying their trade in the UK. The FindAHomeopath website boasts 3,032 who are members of either the Society of Homeopaths, the Alliance of Registered Homeopaths or the Homeopathic Medical Association. (They also claim to include members of the Faculty of Homeopathy/British Homeopathic Association, but none are listed.)
So, what could be raised if a small levy was charged on each appointment?
You can imagine the objections:
- We can’t afford it!
- Our customers can’t afford it!
- It’ll never work!
- It’ll be too difficult!
Well, let’s see. Let’s find out how they could raise the funds for dozens of trials — let’s play with some numbers with a handy calculator and see what drops out.
- the number of practitioners working in the therapy
- the average number of appointments per day
- the average number of days per week worked
- the average number of weeks worked in a year
- the average cost of an appointment
- the percentage levy to be used to generate funds for research
The calculator will show the number of appointments per practitioner per year, the practitioner’s income per year, the total number of appointments per year, the levy per appointment and the total raised per year.
So, using these default values of 3,000 practitioners, doing just four appointments a day, four days a week, 40 weeks of the year, asking for just 1% (50p) more from each customer — or donating that small amount from profits — means that they would raise a research fund of just under £1 million — each and every year.
This 50p would cover the HRI’s puny total of £196,000 nearly five-times over; 10p would still just about cover it.
Even if the default numbers I’ve used are optimistic (perhaps lots of them just work part-time), it’s very easy to see how they could raise a significant amount of money very easily, with just a little effort.
Try some figures for yourself.
Of course, these simple calculations can be applied to any therapy that is lacking in positive research such as reflexology, reiki, Bowen therapy, craniosacral therapy or any similar pseudo scientific nonsense.
If any practitioners — or their trade bodies — really wanted to try to come up with the good evidence they’re probably convinced exists, then what’s stopping them? After all, if they were able to produce good evidence, they might be able to convince the ASA to accept their advertising claims.
However, if they don’t even try to get good trials done, they will forever pay the price in their advertising.
The exposé by Prof David Colquhoun of the interference by the Department of Health — at the behest of homeopathy promoters — in the publication of impartial, scientifically-based information about homeopathy on the NHS Choices website has been covered by the Guardian and the Daily Mail this past week.
Damned by their own words, the DoH said in response to the draft submitted by the editors of NHS Choices that mentioned the House of Commons Science and Technology Committee’s comprehensive Evidence Check report on homeopathy:
Can we remove this statement? This report is really quite contentious and we may well be subject to quite a lot of challenge from the Homeopathic community if published.
The statement was removed. What NHS Choices were eventually told to publish was a biased sop to homeopathy, including a list of the main homeopathy trade bodies and a list of medical conditions homeopathy could, apparently, treat.
Andy Lewis, on his excellent website, The Quackometer, asked that we contact our MP over this to demand NHS Choices be allowed to replace this biased page with one that properly reflects the scientific consensus on homeopathy so that the public can make properly informed choices in their health care.
Below is our email to our MP. We urge all those concerned about the public being given unbiased information to write to your own MP — please feel free to use whatever you feel useful.
We are concerned to read that the Department of Health has been interfering with the content of the NHS Choices website to the detriment of the public’s ability to make informed choices about health care.
It was reported in the Guardian on 13 February (Prince’s charity lobbied government to water down homeopathy criticism) and in the Daily Mail on 15 February (Homeopathy charity run by Charles ‘cowed civil servants’ into supporting the therapy) that the NHS Choices website editor had been prevented from stating the lack of scientific evidence for homeopathy for fear of lobbying from the ‘homeopathy community’. This debacle came to light after a Freedom of Information request by Professor David Colquhoun.
As a result of this interference, the page on homeopathy as it stands now is in danger of misleading the public into thinking that homeopathy may be able to treat potentially serious medical conditions such as asthma, ear infections, high blood pressure and depression when there is no scientific evidence to suggest this is the case.
In his response to the House of Commons Science and Technology Committee’s Evidence Check report on homeopathy (which recommended removal of all NHS funding for homeopathy because of the complete lack of scientific evidence), the Secretary of State for Health stated:
10. In order for the public to make informed choices, it is therefore vitally important that the scientific evidence base for homeopathy is clearly explained and available. He will therefore engage further with the Department of Health to ensure communication to the public is addressed. His position remains that the evidence of efficacy and the scientific basis of homeopathy is highly questionable.
He also stated:
14. The Government agrees that, when looking at the evidence base for efficacy, it is important to focus on the most scientifically robust studies and evidence.
It is therefore incomprehensible and deplorable that the Department of Health believes it now acceptable to tell the public that homeopathy can be used to treat the following:
- ear infections
- hay fever
- other mental health conditions, such as stress and anxiety
- allergies, such as food allergies
- dermatitis (an allergic skin condition)
- high blood pressure
For such a highly respected, informative and authoritative source of sound medical information such as NHS Choices to have been forced by the DoH into publishing such erroneous information on homeopathy is disgraceful and unacceptable.
This can only lead to the public being mislead and potentially making ill-advised and dangerous health care decisions.
As we are sure you are aware, the Chief Medical Officer, Professor Dame Sally Davies, has recently made clear that homeopathy is ‘rubbish’. The DoH needs to heed this advice and allow NHS Choices to completely re-write the page on sound scientific and evidence-based principles.
We also note that Anna Soubry recently stated to the House:
The Department [of Health] does not maintain a position on any particular complementary or alternative medicine treatments including homeopathy.
We therefore ask you to request that the Secretary of State for Health explain these actions and that he allow NHS Choices the freedom to ensure that the public can make the informed choice that are entitled to make based on sound scientific evidence and principles and not to have that distorted by vested interests.
We look forward to receiving your reply.
Thanks and best regards.
I’ll let you know what response we get.
The Freedom of Information Act 2000 (FOIA) is an important tool for everyone, not just skeptics. It gives the right to anyone to ask for any information held by public authorities who are obliged to supply that information unless it is covered by a limited number of exemptions.
The House of Commons Justice Committee said earlier this year:
The Freedom of Information Act has been a significant enhancement of our democracy.
Indeed it is, but it is under threat and a campaign was started earlier this year to protect it. The threats to it are concisely summarised in an e-petition to the Government (unfortunately now closed):
Leave FOI Alone (#saveFOI)
Responsible department: Ministry of Justice
The Freedom of Information Act 2000 (FOI) has exposed the scandal of MPs’ expenses, and many examples of waste and improper behaviour by public authorities, politicians and public officials. We call on the government not to allow it to be watered down, nor for there to be a charge for making requests for information.
The public authorities covered by the FOIA are listed in Schedule 1 to the Act and include the bodies you would expect and maybe a few you’ve never heard of.
But Trading Standards (TS) is one such public authority covered by the FOIA.
Each Local Authority in the country has a Trading Standards service and they are the guardians of an impressive list [Link disabled because of possible malware on that website] of regulations, orders and rules including the Consumer Protection from Unfair Trading Regulations 2008 and, of course, the Cancer Act 1939.
I have never requested any information under the FOIA about Trading Standards, but it’s easy to see that some information could be very useful in finding out, say, information on complaints and understanding how they work and deal with complaints.
A very useful tool for all Local Authority residents and others.
But maybe not in North Tyneside.