Updated Info: MBA Public Consultation Paper

Medical Board of Australia Public Consultation Paper SUBMISSION 


Dear A5M members and supporters, 

A5M are committed to supporting medical practitioners and healthcare professionals who are passionate about healthy ageing in the fields of preventative integrative and personalised medicine. On behalf of our members and community, A5M recently responded to the Medical Board of Australia's public discussion paper on the options proposed by them, for clearer regulation of medical practitioners who provide complementary and unconventional medicine and emerging treatments.


A5M educates medical practitioners on the practice of teaching nutritional education and lifestyle modifications to patients. These are fundamental and foundational health interventions and are key tools that are unfortunately not taught at the undergraduate level yet are critical to the future of healthcare and widespread practice of medicine, as well as reducing the enormous growing burden of health costs to our Medicare system.
The field of integrative, preventative, nutritional, lifestyle and environmental medicine today stems from strong scientific evidence.

A5M understands the Medical Board of Australia review process is directed for the safeguarding of the Australian public. This is aligned with the A5M Mission to "promote healthy ageing and provide better patient outcomes" and A5M supports discussion on the relative risk of conventional therapies, such as pharmaceutical drugs compared with complementary therapies, and nutritional supplements. However Complementary Medicines (CM), the use of nutritional supplements and Integrative Medicine (IM) have been inappropriately bundled together with emerging and unconventional treatments, in one unclear sweeping definition in the discussion paper. 

The MBA would better support the health of Australians and offer patient safety by working with the major stakeholders who have expertise in these areas, rather than to impose additional onerous regulation in an extensive health care sphere, which has been fundamentally ill-defined in its working document. 

The future model of health needs to prevent disease and optimise health by encouraging patients with the proper nutrition and lifestyle tools. This supports the maximum level of health, physical and mental, for each individual. It creates an optimal environment for the expression of that individual's genetic potential. This concept of optimising health for everyone is foreign to the reactive acute disease-based healthcare system and is alarmingly absent from medical school curricula and training. 

Integrative and nutritional medicine doctors in Australia have undergone extensive further training, over and above the usual post graduate pathways of general and specialty training. The MBA should not revoke, control or suppress evidence-based integrative clinical practice or protocols that are highly effective in optimising patient health. This would be an illogical outcome for the MBA, practitioners and patients, placing the spotlight on the MBA for all the wrong reasons. It also denies patients' right to make their own informed health choices and is anti-competitive.

Given all of the above, Option 1 is our preferred option, continuing the single set of standards for all Australian medical practitioners.


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Many of you will by now be familiar with the Medical Board of Australia's Public Consultation Paper on "clearer regulation of medical practitioners who provide complementary and unconventional medicine and emerging treatments", released in February.

There is concern that the guidelines and changes proposed in his consultation paper (published without prior consultation with any of the associations, representative bodies or academics in the field of Integrative Medicine), have the potential to seriously restrict the use and practice of integrative and complimentary medicine in Australia.

For this reason, and as published on the AIMA (Australasian Integrative Medicine Association) website, "it is imperative that we, as a community, come together to challenge the adoption of these guidelines".

AIMA, including other organisations (ACNEM, A5M, BioBalance Health, ACIIDS, NICM), and independent doctors have been meeting to coordinate our responses to the guidelines.

Whilst each organisation will submit a response to the MBA discussion paper specific to our own concerns and area of practice , as a community, we need to encourage practitioners, patients and supporters to express their concerns about how these guidelines will impact and could affect their practice and patients' freedom of choice.


  • Email submissions to This email address is being protected from spambots. You need JavaScript enabled to view it.
  • Marked "Consultation on complementary and unconventional medicine and emerging treatments"
  • This consultation has been extended until 30 June 2019.
  • Let your elected officials know that this is an issue we deeply care about. Contact your local member, both federal and state, and write to your State Health minister and the Federal Minister, Greg Hunt.


The following points have been identified as areas of general concern to most stakeholders:

  • The grouping of integrative medicine with 'unconventional medicine' and 'emerging treatments' may create the impression of being "fringe" rather than evidence-based
  • That many of the terms used in the rationale such as 'unconventional medicine', 'inappropriate use' and 'emerging treatments' leads to ambiguity and uncertainty
  • That the term 'complementary medicine' also includes access to traditional medicines
  • No evidence produced in the discussion paper quantifies risk in practicing complementary or integrative medicine vs 'conventional' medicine
  • That there was NO consultation with the Integrative Medicine or complementary medicine community before the document's release
  • That the current Good Medical Practice: A Code of Conduct for Doctors in Australia already adequately regulates doctors' practise and protects patient safety. There is no need or justification for a two-tiered approach
  • That the right of patients to determine their own medical care is under threat
  • That the lack of clarity on how to determine what is 'conventional' versus 'unconventional' can be misused by people with professional differences of opinion which results in troublesome complaints


We encourage you to view the following materials and podcasts to understand the implications for integrative medicine practitioners and the importance of integrative medicine as an approach to the prevention, management and treatment of chronic and complex disorders and diseases.

We would like to remind you that feedback to the MBA must be submitted before 30 June 2019 and we encourage you to reach out to your patients and communities in preparing these submissions. As published, the guidelines could impact on doctors, complimentary medicine practitioners, allied health professionals, pharmacists, compounding pharmacists and functional testing laboratories.

A5M are committed to supporting medical practitioners and healthcare professionals who are passionate about healthy ageing in the fields of preventative and integrative medicine, and assure you we have commenced work on our submission to provide feedback to the options proposed by the MBA for clearer regulation of medical practitioners who provide complementary and unconventional medicine and emerging treatments.

Kind regards,

Helen Anton | Director
The Australasian Academy of Anti-ageing Medicine

A5M Medical Education - Providing training, certification and continuing education in Preventative, Integrative & Anti-Ageing Medicine

www.a5m.net | +61 3 9853 4123 | ABN 79 763 657 407

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