SSR

[Guest guest]

Tim

Yes, high fees should be the most effective way yet to get rid of

herbalists. Considering we are already so poor as a profession. Seven

hundred quid....just after Christmas....and the tax bill!! Has anyone

actually asked (or got any idea) what would happen if we told the government

that because we can not afford this process we do not want to pursue it?

What happens if we say no? DOES ANYONE KNOW? After all the osteopaths are

now in bits and seems to me they were better off before. Oh, and they still

work exactly as before regardless of their SSR status (just how many

patients have private medical insurance anyhow?). The only people to benefit

were the civil servants. Jobs now secure because the mess will, I'm sure,

take years to sort out.

Home inspections, blimey! That, I'm sure, would be rather like having the

trading standards descend. Sorry (says Mr. Jobsworth of the local council)

you can not have your clinic here you do not have adequate fire escapes,

your bread bin's the wrong colour etc. Bound to happen isn't it. That's

another way to get rid of us....me included.

On a more serious point, and I think I am ok to ask as the people involved

publicly announced their intentions. I want to know what diplomatic attempts

were made by the council of the Institute to ensure that C & S Church did not

leave the Institute so prematurely. I really do not know about anyone else

but I can not believe that such valuable members of the Institute were just

allowed to walk. Is the Institute happy to dispense with those who express

concern over this process (regardless of their status or standing in the

'profession'). Is it happy to, apart from anything else, lose the income!!

The Institute is happy to lose some of the finest herbalists in the country

...............why? The answer of course is not just to fob it off as a

personal decision because the process of SSR itself, as far as I am aware is

still not yet certain to actually happen. So I want to know what was done by

the Institute to keep hold of some of its most valuable members, at least

until the process is most definitely irreversible. Is anyone (from the

Institute) actually in contact with them? Does anyone give a damn? Is the

Institute happy to see a new 'Institute' formed even before we have actually

gone through the process?

Stuart Fitz

[Guest guest]

Dear Tim, it seems to me that insurance companies are much more likely to pay

for the herbalist treatment if herbalists are registered – that would be at

least one benefit.

I chatted recently to my osteopath who said that his non-registered colleague

found it difficult to attract the same amount of patients because Bupa, PPP etc.

would not recognise him. Regards

Newton

> I have been speaking with a colleague who is heavily involved with SSR for

another therapy. He recently attended a commitee meeting in London where, in

passing, the likely annual registration sum for herbalists was mentioned- it

seems that it will be in the region of £400.00. Add this to the current annual

NIMH fee and this comes to a not insignificant sum of £770.00 per annum. It is

interesting to add (and typical of the 'look after number 1' attitude of

politicians) that when a department was set up to oversee the business of

donations to political parties, that this department was funded by central

government. We, however, are expected to fund the department overseeing our

registration ourselves........

> Also, the government has produced a white paper covering the situation of

therapists working from home, and as I have been informed, an annual fee of

£200.00 has been proposed to cover inspection of such premises by the local

authority.

> I have also been led to believe by my colleague that in spite of the move

toward registration, it will still be possible to legally practice outside this

framework as a non- registered practitioner. Can anyone comment further on

this???

> So, £400.00 for nothing- our standing in the eyes of the orthodox medical

profession will change not one iota if we are registered, it is most unlikely

that there will be any significant numbers of referrals from GPs, as medical

insurance companies do not cover herbal medication we will not be affected by

any exclusion for non-registered practitioners, and it seems as if it is

entirely possible to carry on practising outside the registration framework as

we do at present anyway, as long as we can obtain professional insurance. In or

out of a registration system, I would assume that in terms of malpractice that

legally we would be in an identical situation regarding any claims made against

us.

> It would be possible (and of course desirable) to maintain suitable standards

of ethics, training CPD etc outside a registration framework, and I personally

do not feel that this will mean the general public will avoid non-registered

practitioners.

> We all offer patients value for money in our care and treatment of them, and I

do not feel it is unreasonable for us as practitioners to expect value for

£400.00. At the moment I have not seen anything that even remotely comes near

giving us, as a profession or as individual practitioners, any benefit. The more

cynical might feel that this registration fee is another indirect tax to provide

more lucrative posts within the civil service and to send Tony on another 'round

the world' political mission.

>

> Happy New Year!

> Tim Lane.

>

>

>

[Guest guest]

I think there is also the benefit of VAT exemption, although I can't imagine

the day when my turn-over will reach such giddy heights.

Choudhury MNIMH

claire.choudhury.01@...

> Re: SSR

>

>

> Dear Tim, it seems to me that insurance companies are much more likely to

> pay for the herbalist treatment if herbalists are registered - that would

> be at least one benefit.

> I chatted recently to my osteopath who said that his non-registered

> colleague found it difficult to attract the same amount of patients

> because Bupa, PPP etc. would not recognise him. Regards

> Newton

>

> > I have been speaking with a colleague who is heavily involved with SSR

> for another therapy. He recently attended a commitee meeting in London

> where, in passing, the likely annual registration sum for herbalists was

> mentioned- it seems that it will be in the region of £400.00. Add this to

> the current annual NIMH fee and this comes to a not insignificant sum of

> £770.00 per annum

> >

> >

>

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[Guest guest]

Dear Tim, You might also be interested, as will other herbalists in the

following figures related to SSR. It is of interest to all because if SSR

goes ahead then all herbalists are supposedly to be subject to registration

not just institute members, The figures on which the percentages were

calculated were provided to Church by the Treasurer and the figures

given below are his conclusions which he has communicated to President and

Council asking them to re-consider where we are going with this given his

conclusions.

Last year 21.7% of membership required concessions. If we add lapsed

membership , usually the result of financial failure this rises to 25%

If in addition we add new members who pay a concession rte this rises to 50%

of membership on concessions of one sort or another.

To date the picture is a little better for this year but we are only one

month into the financial year and concessions may be applied for during the

year as circumstances dictate.

64% of members declined to pay the EHPA levy.

calculates that the minimum SSR fee is likely to be £1,000 with

little facility for concessions. If members cannot afford our existing fees

how are they going to raise the increased fees involved in SSR!

Whilst I was on Council it was perceived that new members would be the

means to boosting numbers and fees but the above figures disprove this,

added to which many are young and already in debt when they finish their

training. Interestingly from one year alone only two of thirty graduates are

still looking at herbal medicine as a potential future career so we have a

very definite return to the poor drop out rates of the years before PTB.

The 64% declining to pay the EHPA levy is commented on by as follows

" Either most members feel they have already been paying out as much as they

can justify, or they don't want to pay because they don't want to fund the

EHPA's work. Either way, this is likely to prove a reliable guide to the

outcome of a full postal ballot on SSR that the last AGM vote in it's

favour. "

An interesting point to add to this is that the £50.00 levy is already

subsidised by the Institute for each member to the tune of £25.00, the total

levy requested by the EHPA being £75.00 per member. In addition I understand

the levy for this year set by the EHPA is to be £100.00 and next £200.00 and

it is to be compulsory. So members will e paying £370.00 membership fee plus

a further £100.00 levy.

We could end up in the very interesting situation of only half the

membership, 250 odd actually applying to register which means that unless

the other organisations involved in the EHPA have sufficient numbers to make

this up though the Government's required minimum which I think is 1,000 we

shall be unable to raise the funds or numbers to support the process.All of

which needs some very hard thinking. Perhaps members might like to consider

making some positive response to Council about their intentions as to

whether they will be going forward to register as individuals or not because

otherwise these people are going to be left in a very embarrassing

situation.

SSR

[Guest guest]

Dear ,

In fact, you do not have to have any turnover whatsoever to register for

VAT. . The thing about businesses turning over more than £50K or whatever it

is, is that they have to charge VAT whether they want to or not.

However, if you do register then you currently have to charge VAT on your

outputs, effectively putting up your prices by 17.5% . But if our services

become zero rated, (in the way that foodstuffs, education and certain

aspects

of medicine currently are) you do not charge VAT on any of your zero rated

outputs.

The great advatntage of registration for VAT then becomes: each month or

quarter (depending) you can re-claim in the form of a cheque from the VATMAN

the 17.5% you currently pay on all your electricity, petrol, bottles, herbs,

cleaining materials, stationary, computer, car repairs, building

maintentance costs you name it ..absolutely anything which you can sensibly

pass off as any sort of business expense and where you currently pay VAT to

the provider. Thats the law and zero rating in particular helps small

businesses. It makes no difference to the bigger businesses.

Many farmers reclaim their VAT but do not have to charge on their output if

it is destined for the food market. Otherwise even more of the small farmers

would be bust !

I am not an accountant but if that is unclear, would be happy to try to help

explain it more.

Best wishes,

Re: SSR

>

>

> Dear Tim, it seems to me that insurance companies are much more likely to

> pay for the herbalist treatment if herbalists are registered - that would

> be at least one benefit.

> I chatted recently to my osteopath who said that his non-registered

> colleague found it difficult to attract the same amount of patients

> because Bupa, PPP etc. would not recognise him. Regards

> Newton

>

> > I have been speaking with a colleague who is heavily involved with SSR

> for another therapy. He recently attended a commitee meeting in London

> where, in passing, the likely annual registration sum for herbalists was

> mentioned- it seems that it will be in the region of £400.00. Add this to

> the current annual NIMH fee and this comes to a not insignificant sum of

> £770.00 per annum

> >

> >

>

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List Owner

Graham White, MNIMH

[Guest guest]

Hi Tim

I am a member of the EHPA Committee (each professional body has

representatives here, I represent the CPP) and I am pro-SSR though I

understand the concerns that practitioners have been expressing on the

list. I have concerns too and I certainly don’t have all the answers.

I will attempt to address some of your points to the best of my

understanding though I stand open to correction:

I think it is unreasonable to expect definite answers re the NHS; things

just don't work like that. SSR will enhance the potential for working

within the NHS, it certainly can’t harm it. It is likely, as mentioned

in the House of Lords report (House of Lords Select Committee on Science

and Technology, 2000, 6th Report – Session 99-00, Complementary and

Alternative Medicine, House of Lords Paper 123, Stationery Office ISBN –

0104831006 Online – www.publications.parliament.co.uk

<http://www.publications.parliament.co.uk/> ) that two criteria will

have to be met before any extensive NHS funding of herbal medicine is

possible = regulation of the profession + a convincing evidence-base

(probably subject to the standards of NICE) for the clinical efficacy

and safety of herbal medicine. I believe SSR will strengthen the hand of

those practitioners who might want to work more closely with the NHS to

set up individual arrangements and initiatives. No one can force us to

participate in the NHS – it is a matter of choice. I personally would

like to see some free availability of herbal medicine within mainstream

health care provision but I am not prepared to compromise my principles

to do so, nor is anyone asking me to.

SSR is “self” regulation, that means we have the power to develop our

own profession in the ways we want within a statutory framework and that

we do not hand over control to any other authority (that can occur in

state-registration which is a path we have chosen to avoid but which

could be imposed upon us should we fail to regulate ourselves). SSR does

not mean that we become a “profession supplementary to medicine” it

means that we remain a profession with our own self-determination.

Herbal medicine is a proud tradition and I can assure you that nobody

working within the EHPA would compromise our history or our future – nor

could we do so without the express permission by a vote at an AGM or EGM

by the members of each professional body.

Nick Lampert of the Register of Chinese Herbal Medicine has written an

excellent discussion of the pros and cons of SSR which is available on

the EHPA website www.euroherb.com <http://www.euroherb.com/> – from the

Home Page under Issues select Statutory Self-Regulation and then

Briefing Document on Statutory Self-Regulation for Herbal Medicine in

the UK. Perusal of this article and other documents on the website

should answer many of the questions being raised on this list.

SSR status will strengthen our ability to retain access to the full

range of our materia medica and I am not aware that there are any plans

to influence the composition or preparation of the products we use.

Regulation of practice and of products are separate legislative issues

and there is no direct link between SSR and products. Should issues

arise regarding products in the future our position as regulated

professionals will enhance our ability to argue against measures we

disapprove of. This is one of the ways I perceive SSR as being enabling

rather than disabling.

The new regulatory body, possibly to be called the General Herbal

Council, would hold a Register of qualified herbal practitioners and

would serve as an ethical and disciplinary body. The more positive

aspects of herbal activity (CPD, research, seminars, PR, education,

Journals, etc) would remain in the hands of the EHPA and the

professional bodies such as NIMH. In many ways this should free the

existing professional bodies up to put their energies into developing

herbal practice. I personally would like to see more effort going into

PR so that we can increase consultation rates.

I’m not sure that the issue of medical insurance is particularly

germane, patients rarely ask me about this. However SSR can only enhance

our chances of being included within insurance plans.

My feeling is that we can make some comparisons between Section 12 of

the 1968 Medicines Act and the SSR issue. We owe an enormous debt of

thanks especially to Fred Fletcher-Hyde for his extraordinary

achievement in retaining the recognition of herbal practitioners within

that Act. His achievement is staggering when you realise that the herbal

profession was much smaller than it is now. Unfortunately Section 12 is

no longer sufficient to protect our right to practice; we have known

this since 1994. It is my view that McIntyre, a protégé of

Fred’s, is carrying forward the great tradition of herbal survival and

perseverance as Chair of the EHPA and that future generations of

herbalists will look back on the attainment of SSR somewhat in the way

we now consider the 68 Act. I do find it ironic that some practitioners

are happy enough to claim sanctuary under the 68 Act whilst constantly

sounding off about the dangers of legislation!

Best wishes

Conway

SSR

Thanks to all those who have contributed to the SSR debate so far.

I feel that SSR is the most important current issue by far for us all,

whether members of the Institute or of other organisations

(contributions from others more than welcome!). The ramifications and

repercussions of both accepting or rejecting SSR will be felt for some

time to come, if there are any of us left by then.

I have been wrestling with the pros and cons of SSR ever since its

inception. One big problem I see is that inadequate thought has been

given to the possible medium to medium and long term outcomes of

acceptance. Indeed, have these questions even been asked??

Just imagine planning a holiday. You plan to journey to a destination

for a peaceful and relaxing two weeks. Do you turn up at the airport and

choose a flight at random, not knowing where you will end up? Maybe you

find yourself on a sunny beach in Greece, great! However, you may

equally turn up in the middle of the Palestinian conflict (or another

similar hell hole), not so great! The big difference between ourselves

as holiday makers is that if the worst comes to the worst, we can come

home again on the next flight; the problem with SSR is that we do not

know entirely where we are going, and once we are there, we are there

for good with no chance of turning back.

I feel we need to know many things before even contemplating taking

'flight SSR'. Once registered, where would we fit in specifically with

the NHS? A nebulous 'we would work more closely together' is frankly not

good enough. We must have specific and detailed information as to how

this will occur and over what sort of time scale. What openings will be

made available for treatment under the NHS, what will we and what will

we not be allowed to treat? Who will decide this??

What requirements are going to be introduced regarding herbal

preparations? Are ever tighter QA controls to be introduced? There seems

to be a current fetish to tighten up on safety and percieved risk even

where the actual risk can be shown to be extremely small. Will there be

requirements for minimum percentages of (percieved) active constituents?

If so who will make the judgement as to what these constituents actually

are? Will this be a step towards standardised extracts?

What exactly are the implications as the law currently stands regarding

practising outside the registration framework? What specific powers will

the Comittee overseeing registration have when and if registration is

accepted?

To specifically answer 's point; an osteopath colleague has told me

that the majority of insurance companies require referral through a GP

(although not apparently BUPA). Even when/if insurance companies accept

claims for herbal medicine, do we see ourselves getting significant

numbers of referrals from GPs? Of even more significance, why do the

majority of insurance companies currently not accept claims for herbal

medication in spite of its popularity and the fact that it is a

'mainstream' complementary therapy, with all the evidence that backs up

its effectiveness??

Can anyone answer these questions? Have they even been explored? We need

to know where we are going before we even contemplate taking the

journey. Can anyone give any specific reasons which can be backed up

with firm commitments why we should accept SSR? Being able to claim back

is a valid point in its favour, however the sort of figures being quoted

for registration (and higher prices for herbs if more stringent QA is

introduced), and the extra time involved in what is almost certainly

going to be increased paperwork all has to be paid for- how much will

the general public be prepared to pay for our services???????

The idea of SSR as I understand it is to provide greater regulation

over complementary therapies. When one looks at many aspects of

conventional medicine (the recent message from Morag regarding Benilyn

is a case in point- advertising restrictions do not apply when making

medical claims for a drug/herb combination) it would perhaps be better

putting this house in order before picking on easy targets- just look at

the number of successful claims made against drug companies for a start.

And if you can practise outside of the registration framework anyway it

is all a bit self defeating.

Further contributions welcome especially from pro SSR and non NIMH bods!

Best regards,

Tim Lane.

[Guest guest]

Dear Chevalier,

Thanks for the info in response to 's message. Would you be able to

comment in similar fashion on the following-

1) From what you say the Herbal Medicine Council will be drafting statutory

rules AFTER implementation of SSR. As practitioners we will therefore be asked

to make a decision regarding SSR 'in principle' but will not know the specifics

of the statutory rules. If I may put possible consequences a little more

diplomatically than my last message on this point, I feel that it is not an

acceptable situation to ask practitioners to make decisions affecting their

future without knowing precisely what they are agreeing to- this is a situation

which is potentially open to adverse influences, however well intentioned the

situation may be initially. By accident or design, what we end up with may not

be the same as what we thought we would end up with! Legal advice is 'to always

read the small print'- our problem is that we do not (and will not have prior to

the vote on SSR) any definitive small print to read.

1- Who will be the members of the Herbal Medicine Council, who will apoint them

and what degree of autonomy will they have?

2- Why do the 'statutory rules' need to be implemented after (assuming

acceptance) of the vote on SSR?

3- Why can these rules not be agreed prior to the vote?

2) It seems from a number of messages on this list that cost of SSR is the

single most significant factor for many herbalists. As I understand it, the

figure of 1000 members minimum to pursue SSR is required to confirm its

financial viability. This figure has been knocking around for some time now

(years as far as I remember). I must assume that this figure was not just

plucked out of thin air by the Government but was calculated in some way. In can

only see one way in which this can have been done. Firstly there must have been

some idea of the sort of profit margin of a practitioner (particularly those on

the lower end of the scale). Secondly, some sort of formula would need to be

applied to determine what reasonably could be afforded by each individual, in

the light of the profit margin. Thirdly, some reasonably accurate figure of the

total overall cost of SSR must have been decided, for it is only by dividing the

total cost by the individual levy that a minimum number of practitioners

required (in this case 1000) for SSR could be determined. So far, there has been

a reluctance by those in a position to potentially to do so, to give any idea of

the cost of SSR- all we have had is guesstimates from the practitioners

themselves! Again, I feel it is unreasonable for anyone to be asked to vote on

SSR without knowing the exact financial implications.

1- What exact calculations and figures did the Government use to propose the

figure of 1000 minimum practitioners.

2- Why is there an inability to provide at least a reasonably accurate estimate

for the individual cost for SSR, especially considering the number of years the

process has been rumbling on?

3- If Government is dragging its feet on this, what is the EHPA doing to get a

figure?

4- When will we have a figure?

5- Will we get a figure before we have to vote on SSR?

Looking forward to your reply!

With best regards,

Tim Lane

[Guest guest]

I'm sure many members out there will be waiting the reply with bated breath

Tim. Just to add, what efforts are being made to inform members who are not

part of the e-list, or even on computer, and may not have access to the web

sites so often quoted? How many members have actually been able to attend

roadshows? My understanding was that the Government was very keen to ensure

that all herbalists were consulted on this process, not just the ones who

are computer literate. I found when I joined Council two years ago that very

little of what was being discussed behind the scenes was even known about by

the majority of members and although things have improved a little, there

are still many issues which we are not being consulted about before the

event, rather being told about after they have been decided upon by the

great and the good and then not in a way that we can really have any

effective imput into what is going on. Remember too that the only elected

representative that members have on the EHPA, or the other bodies is the

President, anyone else is there either because they have chosen to be or

because they are members of other organisations and are representing them,

so there is very little accountability to the membership of NIMH which

brings us full circle to the question of cost as this was my reason for

refusing to pay the EHPA Levy.

AS I pointed out to Council in my refusal I am steward of my families

finances and I cannot justify paying any money to a body which still has no

legal constitutional accountability to the bodies represented on it, and

this applies equally to the regulatory Working Groups as to the EHPA. This

argument would apply even if I agreed with the principles of such a group.

I shall look forward to reading the replies to your queries.

SSR

> Dear Chevalier,

> Thanks for the info in response to 's message. Would you be able

to comment in similar fashion on the following-

>

> 1) From what you say the Herbal Medicine Council will be drafting

statutory rules AFTER implementation of SSR. As practitioners we will

therefore be asked to make a decision regarding SSR 'in principle' but will

not know the specifics of the statutory rules. If I may put possible

consequences a little more diplomatically than my last message on this

point, I feel that it is not an acceptable situation to ask practitioners to

make decisions affecting their future without knowing precisely what they

are agreeing to- this is a situation which is potentially open to adverse

influences, however well intentioned the situation may be initially. By

accident or design, what we end up with may not be the same as what we

thought we would end up with! Legal advice is 'to always read the small

print'- our problem is that we do not (and will not have prior to the vote

on SSR) any definitive small print to read.

> 1- Who will be the members of the Herbal Medicine Council, who will apoint

them and what degree of autonomy will they have?

> 2- Why do the 'statutory rules' need to be implemented after (assuming

acceptance) of the vote on SSR?

> 3- Why can these rules not be agreed prior to the vote?

>

>

> 2) It seems from a number of messages on this list that cost of SSR is the

single most significant factor for many herbalists. As I understand it, the

figure of 1000 members minimum to pursue SSR is required to confirm its

financial viability. This figure has been knocking around for some time now

(years as far as I remember). I must assume that this figure was not just

plucked out of thin air by the Government but was calculated in some way. In

can only see one way in which this can have been done. Firstly there must

have been some idea of the sort of profit margin of a practitioner

(particularly those on the lower end of the scale). Secondly, some sort of

formula would need to be applied to determine what reasonably could be

afforded by each individual, in the light of the profit margin. Thirdly,

some reasonably accurate figure of the total overall cost of SSR must have

been decided, for it is only by dividing the total cost by the individual

levy that a minimum number of practitioners required (in this case 1000) for

SSR could be determined. So far, there has been a reluctance by those in a

position to potentially to do so, to give any idea of the cost of SSR- all

we have had is guesstimates from the practitioners themselves! Again, I feel

it is unreasonable for anyone to be asked to vote on SSR without knowing the

exact financial implications.

> 1- What exact calculations and figures did the Government use to propose

the figure of 1000 minimum practitioners.

> 2- Why is there an inability to provide at least a reasonably accurate

estimate for the individual cost for SSR, especially considering the number

of years the process has been rumbling on?

> 3- If Government is dragging its feet on this, what is the EHPA doing to

get a figure?

> 4- When will we have a figure?

> 5- Will we get a figure before we have to vote on SSR?

>

> Looking forward to your reply!

>

> With best regards,

> Tim Lane

>

>

>

[Guest guest]

Hi

That is a very good point concerning lack of knowledge about behind the

scenes processes, & one which, as editor of the HT, I am attempting to

address at the moment. It is my intention to sit in on as many meetings

regarding SSR as I possibly can (where permissible) purely in a wallflower

capacity in order to write it up for the HT & give people more of an idea of

what does actually happen.( I,m sure they are not actually all sitting

around smoking & playing cards - but we need to know!). Nigel Wynn has been

very helpful in giving me a few contacts with regard to this (hopefully EHPA

& NIMH meetings), so hopefully the HT will become more informative on the

subject - watch this space.

Best wishes

[Guest guest]

Dear Tim,

Without making this mesage impossibly long I will try and give you

my understanding of what the position is re. your further points.

> Things are hotting up again!

> Just a few (more) thoughts-

>

> 1) Messages from several contributors have polarised herbalists into

> two groups- those pro-SSr and those who are anti. Perhaps this does

> not accurately reflect the feelings of many herbalists and has in fact

> been an inaccuracy which needs redressing?? The criticism aimed at

> those labelled 'anti-SSR' is that herbalists as a group have been

> clamouring for more legal recognition, and now it is on its way many

> are not happy! However, spare a thought that it is not legal

> recognition itself that is the problem, but the form that it is

> currently in that is causing many to baulk.

>

No one is yet in a position to know what form of regulation we will

have to decide on. As explained on the NIMH website - we have 3

options open to us as a profession: to stay as we are with

voluntary self-regulation; to go for SSR or to go for regulation under

the Health Proessions Council (formerly the CPSM). Anyone who

looks in detail at these choices is in my view likely to conclude

that provided we get it right SSR offers the best opportunity to

survive and grow - as an INstitute, as western herbal medicne and

as a profession. To talk of two camps is to polarise a debate that

has hardly started yet.

> 2) (Chevallier), thanks for your reply of 19/3/02. You stated

> that the figure of 1000 minimum members to proceed with SSR was 'more

> of a rule of thumb than anything that has been closely costed'.Yet the

> 'Summary of Project Scoping Study' states that 'At present only about

> 1200 practitioners belong to a professional organisation. Experience

> shows that this is barely enough to generate the funds needed to

> support a fully functioning regulatory body.' So what are we looking

> at? A rule of thumb or experience? Either way this is an entirely

> unsatisfactory situation. A 'rule of thumb' should have been clarified

> long before now. DoH 'experience' should also have been clarified long

> ago. Please can you elaborate? Also, can you confirm that, assuming

> SSR goes ahead, that the annual fee will be no more than £250.00 per

> member?

>

I have to be honest and say that I don't understand what your

question is. Yes, these two figures are not the same - but they are

in the same ball park. The point is not the figure but the relative

size of the profession that can resource the developments - ideally

we would be bigger than 1000 - 1200 but where we are will just

about do. Yes, I can reaffirm that the best estimate that we can

make is that members will not have to pay more than £250 per

year for the next 4 - 5 years. As a stop press, the Dept of Health

have just granted the EHPA £20,000 towards costs involved in

moves towards SSR. Further grants are likely ot be forthcoming

and are a recognition by the DH that we are a small and not

wealthy profession.

> 3) The summary of the scoping study also mentions approx 200 WHM and

> 800 TCM practitioners in the UK who do not belong to any professional

> body. As members of a professional body we are being asked to

> subsidise the activities of the EHPA for the next 3 years. If SSR goes

> ahead, what (if any) back payment will be asked of any currently 'non

> professional body practitioners' for the EHPA should these

> practitioners wish to be included in SSR?

>

I agree that this is a problem and I for one do not know what can or

will be done about it. It is clearly unfair if all professional

practitioners end up subsidising those who are not currently within

a prof assocation. One possible way forward is that all those on the

register of an EHPA professional assocation (PA) would be leigible

as of right to join a new statutory register, while those who are not

members of a PA woudl have to go through a longer and more

costly process of individual accreditation. This is simply one of

many issues that will need to be resolved as we move further down

the road towarsd SSR.

> 4) I am increasingly concerned by the fact that the EHPA is unelected,

> and there seems to be an increasing blurring of lines of demarcation

> between the EHPA and the NIMH.

>

AS I understand it a draft constitution is now readt for publication

and debate and will be available this week. The simple answer is

that the NIMH (and other EHPA PAs) is increasingly having to work

as a unified profession. Its only as a united front that we can get

our voice heard - especially on a Euroepan level. Given that there

are very few people who have the time and experience to go to

meetings at the DH, etc. many activities involve reps using different

hats at the same time. Given that NIMH members make up a large

proportion of the EHPA it is not surprising that there appears to be

blurring as you describe it. A simple answer to this is for people to

stand for Council and start to play a more active role in the huge

amnount of work thats going on - at both an NIMH and EHPA level.

> 5) The possiblity of working within the NHS will not be governed by

> any legislation, rather by the opinions of individuals. It is

> currently technically possible to work within an NHS framework. The

> reason that this is not happening regularly is due to the resistance

> of those who could allow it. I think we are deluding ourselves if we

> believe this will all change because of SSR.

I entirely agree with you!! SSR will not mean that we can all

suddenly start working in the NHS. It wil however mean that over

several years an increasing number of openings for herbalists will

occur in an NHS context - for those who choose to take up such

an opportunity. My personal view is that it will take about 10 years

after SSR for there to be a real sea chaneg in NHS views on herbal

medicine.

>

> 6) Some of my most conservative (and probably Conservative) patients

> are horrified to think that Government are to become more closely

> involved with the workings of herbal medicine. Conway's message

> dated 27.3.02 advises that there has been no survey on the opinion of

> the general public but that he 'considers it safe to assume the public

> are very unlikely to object to;........' I would respectfully suggest

> that it is folly to think anything is safe to assume in this

> situation. History is littered with disasters based upon assumptions

> of this nature. Would it be safe to assume the public would be happy

> to see fees rise due to the increased cost of SSR, or the possibility

> of herbalists ceasing to practise because they are unable to accept

> financially the costs of SSR?

>

You're sounding off here I think. As with everyting in life the answer

you get depends on what question you ask. There is no point in

going for SSR if in the process we alienate the public. The most

important reason for SSR is to provide assurance to the public that

in consulting a registerd practitioner they can feel confident that

they will receive safe and, hopefully, effective treatment - in terms

of practice and in terms of medicines. The increase in costs due to

SSR is not going to be that great. Costs will undoubtedly increase

to some extent whther we go for SSR or not , e.g. dispensary

standrds, standards of QA of medicines, etc. These issues will

have to be resolved whatever choice we make re. regulation.

> 7) We have overseas herbalists contributing to the SSR debate, and I

> have found their contributions most interesting! I think I have asked

> at least once, possibly twice for the opinions of non-NIMH UK

> herbalists on SSR but to date, as far as i am aware, no-one has

> contributed. I would like to add to Fiddaman's request (dated

> 1.4.02) for their input on this subject.

>

> 8) I am sure all of us in the NIMH (and in other organisations too)

> appreciate the voluntary work that our official representatives put

> in, regardless of whether our opinions agree or differ on any one

> subject. Mention has been made in the NIMH of the increasing workload

> our representatives have (and I would guess this would apply to other

> organisations also), and that at some point this workload will become

> intolerable for the individuals concerned. The only way this can be

> overcome is to have paid representatives on a full or part time basis.

> This presumably will lead to an increase in subscriptions to enable

> this to be financed. Add this to whatever figure SSR will cost us, and

> what sort of figure would we be talking about?

>

Thanks for this! Though there's a sting in the tail! I suspect that one

reason why we will not be having an election for COUncil this year at

the AGM is because the level of work required of COUncil members

and those on the EHPA is getting to unsustainable levels. SOmething

will have to be done about this, no question. This is just one of the many

challenges that we will face over the next few years.

We all need to cultivate a cool head, and the kind of dispassionate

care that we bring to bear on our patients' problems, in confronting

these challenges in our own back yard!

Best regards and hope to see everyone at the Conference

Chevallier

> Tim Lane.

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