This existence of this consultation is due to submissions made by lawyers acting for the Good Thinking Society, which writes:
This consultation represents an opportunity for organisations and members of the public to make their thoughts on CAM charities known to the Charity Commission. This is an opportunity supporters of pseudoscientific charities will almost certainly take up, so it is vital that supporters of science and evidence-based treatments get in touch with the Charity Commission in order to ensure our views are well represented.My responses to the Commission follow. I'm sure you can improve on them.
Question 1: What level and nature of evidence should the Commission require to establish the beneficial impact of CAM therapies?
Ideally any evidence of beneficial impact should be in the form of replicated, good quality, double-blinded, randomised placebo-controlled trials that demonstrate that the therapy is distinguishable from placebo for the medical condition for which it is being offered. This should be published in a recognised medical journal such as The Lancet, the British Medical Journal, or the New England Journal of Medicine.
Question 2: Can the benefit of the use or promotion of CAM therapies be established by general acceptance or recognition, without the need for further evidence of beneficial impact? If so, what level of recognition, and by whom, should the Commission consider as evidence?
No. "General acceptance or recognition" falls under the umbrella of the "Bandwagon fallacy" (argumentum ad populum), i.e. the fallacy that something should be considered to be true or beneficial because it is widely believed to be true or widely used. Benefit can only be established by replicated, good quality, double-blinded randomised placebo-controlled trials that demonstrate that the therapy is distinguishable from placebo for the medical condition for which it is being offered.
In particular, accreditation of CAM trade bodies (e.g. the Society of Homeopaths, the General Chiropractic Council) by bodies like the Professional Standards Agency, the Complementary and Natural Healthcare Council and the British Complementary Medicine Association must never be accepted as evidence of benefit, because these bodies do not require evidence of efficacy or benefit as a condition of accreditation.
Question 3: How should the Commission consider conflicting or inconsistent evidence of beneficial impact regarding CAM therapies?
Firstly, the burden of proof lies entirely with the proponent of the CAM therapy. The proponent must demonstrate that the therapy concerned is distinguishable from placebo for the medical condition for which it is being offered.
If the robust evidence is conflicting or inconsistent, this should be resolved by an independent (e.g. Cochrane Collaboration) meta-analysis that gives additional weight to higher-quality trials. In the absence of a meta-analysis, the adjudication of the Government Chief Scientist should be sought.
Question 4: How, if at all, should the Commission’s approach be different in respect of CAM organisations which only use or promote therapies which are complementary, rather than alternative, to conventional treatments?
It should not differ at all. The Commission's sole criterion must be that of demonstrable benefit over and above that of placebo for the medical condition for which it is being offered.
Question 5: Is it appropriate to require a lesser degree of evidence of beneficial impact for CAM therapies which are claimed to relieve symptoms rather than to cure or diagnose conditions?
It would not be appropriate. The Commission's sole criterion must be that of demonstrable benefit over and above that of placebo for relief of the symptoms for which the CAM therapy is being offered.
Question 6: Do you have any other comments about the Commission’s approach to registering CAM organisations as charities?
1. The absence of any mandatory reporting of harmful or adverse effects of CAM make it impossible to weigh benefit against harm for the simple reason that the harms are unknowable. The Commission must therefore not accept submissions that any CAM therapy either causes no harm or has more benefits than harms.
2. The Commission should not register CAM organisations which either promote their own therapies over, or seek to denigrate, evidence-based medicine.