Submission To The TGA On Proposed Poisons Standard Amendments

The NHAA recently made a submission to the TGA on proposed amendments to the Poisons Standard concerning two compounds commonly found in herbal medicine.

The Advisory Committee on Medicines Scheduling is considering whether to list Sanguinarine as a Schedule 10 substance (prohibited). The Joint Advisory Committee on Medicines and Chemicals Scheduling will be considering whether to amend the entry on Arbutin currently as Schedule 4 (prescription only).

Sanguinarine is the compound found in Black Salve, which has been inappropriately marketed as an alternative treatment for skin cancer.

While the NHAA supports moves to limit the misleading use of Sanguinarine, listing it as Schedule 10 could have the unintended consequence of banning two approved herbal medicine ingredients that contain Sanguinarine in amounts greater than 0.1% - Chelidonium majus and Eschscholzia californica. While these herbs may not always contain more than 0.1% Sanguinarine, literature suggests it is possible. For these reasons the NHAA would like to see further consultation on the amendment to avoid unintended consequences.

In the case of Arbutin, last year the TGA published an update stating that herbs which contain Arbutin in a concentration exceeding 10 ppm are not eligible to be included in Listed complementary medicines in Australia due to scheduling of Hydroquinone in Schedule 4 of the Poisons Standard. This has subsequently had an effect on the availability of medicines and extracts used extemporaneously by practitioners. Of concern is the loss of medicinal herbs with important therapeutic benefits that are commonly used in therapeutic goods or in extemporaneously dispensed preparations, such as Bearberry (Arctostaphylos uva-ursi) and Damiana (Turnera diffusa). Since the announcement last year we have lobbied that the understanding of the metabolism of Arbutin and clinical use of the herbs affected should be more closely considered, and an amendment to the Poisons Standard recommended.

This proposed amendment for the Arbutin entry in the Poisons Standard would thankfully see an exception for oral herbal preparations containing 500mg or less of Arbutin. The proposal is also to remove the cross reference of Arbutin to Hydroquinone. We have written in support of this amendment.

See the submission: https://www.nhaa.org.au/docs/Submissions/NHAA_Submission_on_proposed_amendments_to_the_Poisions_Standard.pdf

PHI Review Announced!

The Federal Health Minister’s announcement of a review into natural therapies is a significant step in the campaign to have naturopathy and western herbal medicine private health rebates reinstated.

The review, announced on 7th April, will look at the evidence to support certain therapies, that has emerged since the original review was undertaken in 2014-2015.

We particularly welcome the inclusion of the University of Technology Sydney’s Associate Professor Jon Wardle on the panel, and the decision to take into account the views of those who benefit from natural therapies - the public.

Recap of our 11th International Conference!

Thank you to everyone who attended our 11th International Herbal and Naturopathic Conference! This was our our biggest event to date, shared with a record number of herbalists, naturopaths, students, academics and integrative health professionals.

The three day event showcased the work of over 60 wonderful presenters, whose diversity and expertise was a testament to the quality of our work in this profession; as students, clinicians, researchers and advocates. (For anyone who couldn't attend, or if you would like to revisit your favourite topics, audio files and notes from the presentations can be ordered by completing and returning this form.)

We were proud to host the World Naturopathic Federation at our conference, who held their general assembly in Melbourne the two days leading up to the NHAA's event. It was a pleasure to have many of WNF's delegates - our international colleagues - share their knoweldge and experience with us. We were also honoured to have the Indigenous health organisation Anangu Ngankari Tjutaku Aboriginal Corporation (ANTAC) attend, share their work and run a ngangkari clinic during the conference, for delegates to experience ngankari healing.   

Importantly, our 11th International Conference kicked off celebrations for the NHAA's 100th birthday! The dedicated Centenary Room contained the fascinating and detailed timeline of the NHAA, herbal and naturopathic medicine in Australia over the past 100+ years. The Centenary Room was also host to a number of informal, but extremely passionate and galvanising conversations about the future of our profession. Watch this space!

Michelle Boyd, with the 100 year timeline she created (all 10 metres of it!) for the Centenary Room at our 11th International Conference.

Dr Ses Salmond, Ruth Trickey and Dr Sue Evans in discussion in the Centenary Room: how herbal tools have changed over their decades of clinical practice.

Dr Francesca Panzironi and Debbie Walton shared their work with ANTAC and Debbie, together with her brother Max, ran a ngankari healing clinic for delegates during the conference.

Professional Award Winners (L to R): Regina Lasaitis (2019 Notable Contribution to Herbal and Naturopathic Education), Assoc Prof Jon Wardle (2019 Notable Contribution to Herbal and Naturopathic Medicine), Andy McLintock (2019 Student of the Year) and Dr Janet Schloss (2019 Early Career Research Award).

2019 Life Membership was awarded to Dr Ses Salmond and Ruth Trickey.

NHAA members at ICCMR2019

NHAA is now a partner practitioner organisation for ICCMR2019!

The International Congress on Complementary Medicine Research is the leading research conference for complementary medicine globally and this year it comes to Australia for the first time in 10 years between 7th and 10th May 2019!

The theme for the conference is Pathways and Partnerships with a particularly strong focus on bringing clinicians and researchers together to strengthen the relevance of research in this field.

For this reason, the chairs of the organising committee have decided to offer members of partner practitioner organisations registration for all four days of the conference for only $550!

The registration fee covers all costs for practitioners including:

• Intimate pre-congress workshops conducted by world-leading experts
• Welcome drinks
• Conference party
• And of course, access to the diverse topics presented by >300 researchers and clinicians from over 30 countries as part of the main program

This is an opportunity of the decade and should not be missed! NHAA members must use this link to register and claim their discount.

PHI reform update

The Honourable Greg Hunt, MP (the federal Minister for Health)’s recent decision has effectively banned Private Health Insurers (PHIs) from covering Naturopathy and Western Herbal Medicine, despite a high level of evidence of their efficacy and valued use in chronic conditions. The Naturopaths and Herbalists Association of Australia (NHAA) is opposed to this decision. In our opinion, these new rules do not help patients, save virtually no money, create new risks to the public, deny care that is effective, and potentially encourage care that is ineffective and/or unsafe.

Most of the issues with the new rules stem from their prohibitive nature, so, whilst the purpose was to remove public subsidies for these services, the new rules actually prohibit their provision as part of a private health insurance plan under any circumstances. What has not been made clear in the new rules is why removal of public subsidies from these therapies requires that their supply be prohibited in complying policies.

Removal of Naturopathy and Western Herbal Medicine from private health insurance refundable status is of particular concern to the NHAA, primarily due to the anticipated impact on public safety.  In the absence of statutory regulation (such as under AHPRA), Naturopathy and Western Herbal Medicine currently operate in a self-regulated environment. A key safety lever in the current self-regulatory model, is the need for practitioners to join a professional association to access PHI provider numbers in order to allow patients to claim private insurer rebates on the services rendered.  In the face of inaction on the part of various governments to regulate Naturopathy and Western Herbal Medicine, the private health insurers have assumed the pseudo-regulatory role in this area by requiring practitioners be members of a professional association, to maintain current first aid training, and meet continued professional development requirements, which has acted as a steadying influence on the profession.  This allows professional associations such as the NHAA to enforce standards of public safety. For instance: ‘registered’ practitioner listings, codes of conduct, education standards and educational accreditation, monitoring of compliance with first aid certification, overseeing member professional development and continuing education activities, and ensuring practicing members hold appropriate levels of professional indemnity and public liability insurance. 

Removal from private health insurance refundable status in relation to naturopaths (and western herbal medicine practitioners) removes the ‘pseudo-regulatory’ function currently operating in the public interest and is likely to facilitate underqualified and non-compliant persons to practice Naturopathy or Western Herbal Medicine with no professional checks or balances. There are already high-profile cases of misconduct by people claiming to be Naturopaths while not meeting even the most basic requirements set by some of the other representative bodies.  Had there been statutory registration, cases like this would have been clearly described in the press as ‘fake Naturopaths’ in similar terms to those used for other fake medical practitioners. The NHAA is concerned the regulatory vacuum resulting from removal of PHI for Naturopaths (and western herbal medicine practitioners) will enable people with little or no qualifications in the discipline to misrepresent themselves and anticipate more harm to the community and to the standing of the profession. 

The Minister purports to use the “Review of the Australian Government Rebate on Private Health Insurance for Natural Therapies”^[1] as the justification for preventing PHI’s from providing rebates for Naturopathy and Western Herbal Medicine. The limitations of that review (eg., restricted to systematic reviews from 2008 onwards, missing an important review from 2007), as well as the large number of randomised controlled trials undertaken in the years since that review, make that reliance questionable. Not only was the report limited to published systematic reviews, but evidence has grown considerably since then: e.g. in 2013 there were six randomised controlled trials (RCT) comprising a total 692 patients for "whole practice" Naturopathy, however, there are now 31 RCTs comprising a total 9798 patients.  Even then the review found that there was evidence to suggest that whole-system naturopathic practice is effective in improving patient health for a range of chronic health conditions, including anxiety, multiple sclerosis, cardiovascular disease and musculoskeletal conditions. Of the studies which were included their positive outcomes were dismissed as not relevant to the Australian context due to the unregulated nature of the workforce. 

For western herbal medicine the review noted that while there is a large body of research on the effects of individual herbal agents and remedies, the study of the real-life practice and outcomes of western herbal medicine as a health service was separate to this research and as there were no studies of the real-life practice and outcomes of individualised western herbal medicine as a health practice they could not reach any conclusions as to its effectiveness or potential harms.

Had Naturopathy already been registered as a profession then it would not have been subject to the review in the first place. Naturopathy and Western Herbal Medicine have previously been assessed against the requirements for registration and found to meet the requirements.[2] It is the NHAA’s position that the lack of statutory regulation of naturopaths and western herbal medicine practitioners under the National Scheme (through AHPRA, as the agency that supports the National Boards to implement the National Scheme) is the key difference, to naturopaths and western herbal medicine practitioners’ adverse treatment under the policy change (that removes the government rebate to private health insurers in relation to a broad range of natural therapies). Registration under the National Scheme would address this issue and the NHAA has been, and will continue to, work to facilitate this.

In the interim, the NHAA will be working to have Naturopathy and Western Herbal Medicine removed from the “banned list”.  This is an administrative process, but it requires understanding of the issues by the Health Minister so that it becomes easier to make the change rather than to leave it as it is.  This requires a grass roots campaign with Naturopaths and their patients contacting their local member and the health minister to bring this to their attention and give them a reason to implement the change required.  The message needs to be succinct and to the point.  The NHAA will be keeping members updated with advice on practical action they can take to assist with the amendment process of the new PHI rules in the best interest of members and the public alike.

[1] Baggoley, C., (2015). “Review of the Australian Government Rebate on Natural Therapies for Private Health Insurance.” Australian Government Department of Health, Canberra.

[2] Lin, V., et al. (2005). "The practice and regulatory requirements of Naturopathy and Western Herbal Medicine " Melbourne: Department of Human Services.