UPDATE: Medical Board of Australia Public Consultation Paper - Submission Response


General Practitioner & Integrative Medicine Practitioner, A5M Advisory Panel Member, Steering Committee Member 

In 2019 A5M participated in a coordinated response along with AIMA, ACNEM, the Integrative Medicine Special Interest Group of the RACGP, Biobalance and many others, to the Medical Board of Australia's (MBA) public discussion paper on proposed options for clearer regulation of medical practitioners who provide complementary and unconventional medicine and emerging treatments.

I am very pleased to advise that as a result of all our efforts, the MBA will not issue guidelines on 'complementary and unconventional medicine and emerging treatments' and will continue to rely on the existing standards framework set out in Good medical practice: a code of conduct for doctors in Australia. The code includes guidance on patient assessment, basing clinical decisions on the best available information and considering the balance of benefit and harm, and informed consent.

A huge congratulations to the many doctors and health professionals who participated in this coordinated response as the MBA was deluged with over 13,000 submissions including a massive public response with a passionate voice speaking up for patient rights and health choice.

The consultation, open for six months, sought feedback about whether additional safeguards were needed for patients receiving care from medical practitioners who provide complementary and unconventional medicine and emerging treatments. It looked at options to best protect patients and minimise the risk of harm to them, without stifling innovation, making a judgement about specific clinical practices or limiting patients' right to choose their healthcare.

Medical Board Chair, Dr Anne Tonkin, said the consultation was robust and the submissions shed light on both the issues and the possible solutions.

'It is clear from the consultation that there is no simple equation linking areas of practice with risk to patients, and that high-risk practice is not confined to one area of medicine,' Dr Tonkin said.

'In effect, the solution we had proposed did not match the problem we were trying to solve and the labels we used – complementary and unconventional medicine and emerging treatments – were not helpful in defining the level of risk posed to patients,' she said.

The Medical Board said there was a persisting issue of patients being offered high-risk treatments that did not have an evidence base of safety and efficacy, which the consultation process confirmed was not limited to complementary and unconventional medicine and emerging treatments. A related issue involves vulnerable patients not being provided with the information they would need to give genuinely informed consent.

'It is clear that we need to carefully match safeguards for patients with high-risk practice, which occurs across a number of areas of medicine,' Dr Tonkin said.

'We need to calibrate our regulatory approach to address risk, while also acknowledging patients' rights to make informed choices,' Dr Tonkin said.

The Board will continue to refine its risk-based regulatory approach, so that regulatory safeguards match risk to patients across all areas of practice. This work will not be limited to specific areas of practice and will be developed over time.

'As we do this, we will continue to engage with the profession and the community,' Dr Tonkin said.

'The good thing about consultation is that feedback from the profession and the community helps make sure we target regulatory safeguards to address risk to patients, and avoid unintended consequences,' she said.

It has been a significant pioneering step forward to have had this opportunity for AHPRA to witness and listen to the persuasive voice of reason of both the Integrative Medical profession, allied health, plus the public actively accessing these services that seek to address the root health causes. The evidence base speaks for itself.

I would like to thank Dr Penny Caldicott AIMA President, for leading the response and the other members of the steering committee for their contribution and hard work in completing the joint submission.

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