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Alert Plus: Responses to US HHS on the New Prevention & Integrative Practice Strategy: Samueli, ABMP PDF Print E-mail
Written by John Weeks   

ALERT+: Comments until 1/13 on "National Prevention Strategy" plus Samueli Institute and ABMP Views

Summary: This posting alerts you to a comment period until January 13, 2011 on the draft "National Prevention Strategy." The law behind this process represents the most significant inclusion of "integrative health care" in federal policy. Yet the draft Strategy only poorly reflects the health promoting or health-focused clinical strategies of integrative practices. Participation is critical. Perspectives of the Samueli Institute and Association of Bodywork and Massage Professionals on the framework that birthed the strategy are included here. Each will offer you or your organization useful starting points. More organizations need to weigh in. The draft plan does not reflect the principles and value of integrative health care. Consider sending your responses to the Integrator for future community reflection. Be heard!
Send your submissions to
for inclusion in a future Integrator.

Comments on DRAFT National Prevention Strategy
until January 13, 2011: Enter here to respond.

The link to the draft 8-page Strategy is on this page.

"The National Prevention and Health Promotion Strategy (National Prevention Strategy) provides an unprecedented opportunity to shift the nation from a focus on sickness and disease to one based on wellness and prevention."
US Senator Tom Harkin: Does this include the "integrative health care" focus he wrote into the law?
So reads the first line of the DRAFT National Prevention Strategy, subtitled "An Unprecedented Opportunity to Improve the Nation's Health Through Prevention." Sounds good. However, related responses from the integrative practice community indicate that the strategy falls very short of a full embrace of this opportunity.

In November 2010, the Integrator urged members of the community to comment on the framework for the National Prevention Strategy which preceded this December 22, 2010 posting of the draft Strategy. Responses below from the
Samueli Institute, led by Wayne Jonas, MD, and from the Associated Bodywork and Massage Professionals (ABMP) underscore short-comings that exist not only in the framework but also in the draft Strategy.

One key point: Strategy developed without Advisers!
The cart is before the horse: This strategy was to
be developed via a community advisory board.
But the advisers
haven't yet been appointed.

See Section 4001(f) here.

Recall that the integrative practice community has unusual standing to respond and comment. "Integrative health care" is directly referenced in 3 of the top 4 purposes of the federal entity that is developing the strategy, the
National Prevention, Health Promotion and Public Health Council. Responses are needed.

Here are the questions on the draft to which you are asked to respond. Just choose just one if you want.
1. What are your suggestions on the Draft Vision, Goals, Strategic Directions, or Recommendations?

2.What evidence-based actions should the federal government take to address the Draft Recommendations?

3. What evidence-based actions should partners (national, state, Tribal, local, and Territorial governments, non-profit, and private) take to address the Draft Recommendations?

4. What measures should be used to monitor progress on implementation of the National Prevention Strategy's Vision, Goals, and Recommendations?

Additional Comments or Suggestions:


The following responses to the "framework" are useful guides for offering input on the draft Strategy. Thanks to the Samueli Institute and ABMP for their leadership in representing the community, and for sharing their responses. Hopefully these will facilitate further participation. Respond as individuals and get your associations moving on this!

Key player in the plan raises serious questions
1.  Samueli Institute

Brian Thiel, the vice president for strategic partnerships and advancement of the Samueli Institute forwarded the following response which was submitted under the name of Wayne Jonas, MD, the Institute's CEO. Jonas, Thiel and the Institute played leading roles in promoting the development of the National Prevention, Health Prompotion and Public Health (PHPPH) Council through their visionary Wellness Initiative for the Nation (WIN). A 2009 Integrator article on Thiel's views of the emerging wellness agenda in the Obama administration is here. The Samueli Institute response was all posted in response to the first query on the fraework: What are your general suggestions on the development of the National Prevention and Health Promotion Strategy?

1. The PHPPH Council was deliberately constructed to focus on how Federal policies either facilitate or inhibit health, not solely on the reduction of mortality or through operations of the health care system. As a cross-agency Council, it should first map out metrics for health and flourishing (of which premature death is only one), develop ways to model policy impact on those metrics, and then apply current policies to that model. In this way, the Council can become the guide for how the Federal government can improve national health and lower health care costs.

2. The Council is tasked with processes for continual public input yet one of the best sources would be the Advisory Group which, to our knowledge, has not been appointed (despite the timeline that has passed as established during the July meeting), so I believe that ought to be a priority.

3. Administratively, the title of the Strategy has been shortened to "National Prevention Strategy" which shortchanges the breadth of the Council's title and mandate, so an appropriate title should be used that focuses on health promotion.

4. The Council's purposes include "(4) consider and propose evidence-based models, policies, and innovative approaches for the promotion of transformative models of prevention, integrative health, and public health on individual and community levels across the United States."  It seems the Surgeon General and the Council should implement a more aggressive than is apparent approach to identifying, researching and evaluating approaches--a dedicated effort to identify and provide visibility to approaches effective and not widely implemented.

5. The influence and effectiveness of the Council would be enhanced through access to and recommendations on funding, so a more formal alignment and influence of the Council over the section 4002 Fund would be appropriate (probably through formal recommendations to Congress and HHS leadership).

6. The approach of the draft strategic direction is narrow to prevention of death and seems to be oriented so that "all Federal agencies are included and have a role" more so than covering the wellness spectrum. So a focus on Total Health as a more inclusive approach to wellness would be beneficial. 

7. The Council should highlight the advances made by DoD in view of its challenges of sustaining a healthy force in the face of two prolonged conflicts.

8. The draft goals are two: create community environments that make healthy choice the easy and affordable choice; and implement effective preventive practices.  Seems they are much too narrow and should be enhanced to be more integrative, more wellness and health-promotion oriented, more transformative models, with more recognition of the need to tap the power of positive or negative individual behaviors.

9. The most gain in health and reduction in cost is to focus on the social and environmental determinants of health. More health for the healthy is a marginal investment. Focus on eliminating health disparities would provide greater impact per dollar spent.

10. Specific links to successful community models of health promotion is described in the Council mandate, but the report makes no provisions for creating such links.

11. Insufficient attention is paid to addressing the role of integrative health care, which is an explicit requirement of the Council.
Comment: This is an excellent, direct, if unsettling submission that shows, above all, how quickly the agency will revert to limited views of "prevention" and leave out "integrative health care" without sufficient education and input from the integrative practice community. Show up or be left out is clearly the guiding rule.

Presenting both massage and the integrative practice perspectives
Associated Bodywork and Massage Professionals (ABMP)

The Associated Bodywork and Massage Professionals, a for-profit national business serving the massage and bodywork industry, contracted Diana Thompson, LMP to fashion a substantial response to the framework as an
ABMP Position Statement on behalf of the field. Thompson is a clinician, author and immediate part president of the Massage Therapy Foundation.

The 12 page (including 3 pages of references) ABMP Position Statement is here as a pdf. While the document focuses on the potential contributions of massage therapists, its also represents significant advocacy for the broader philosophy and practice of integrative care that remains poorly reflected in the draft National Prevention Strategy.

The ABMP Position Statement begins by asserting that
"massage therapy traditionally resides in the prevention and wellness domain and therefore we believe we have much to contribute to this endeavor." The document then directly references sections of the Obama-Pelosi Affordable Care Act viewed as important to the massage field (ands other integrative practitioners). The responses to the first question follows: What are your general suggestions on the development of the National Prevention and Health Promotion Strategy? (This is also the question to which the Samueli Institute responded, above.)

  • Include CAM practitioners, specifically massage therapists, in the planning and implementation phases of these strategies

  • Ensure that integrative health care strategies reflect the true meaning of the word integration, not parallel care (referrals to massage therapists without consultation on treatment planning) or restrictive care (limiting the scope of massage therapy to only address pain conditions, for example)

  • Consider the full scope of massage therapy and the contribution massage therapists can make to prevention and wellness strategies, the foundation of most massage therapy practices]

  • Consider the need for compliance strategies, an issue that massage therapy can influence. For example, include strategies to enhance self-awareness and self-esteem in an attempt to enhance change motivation and promote healthier choices.

  • Take action on factors that impair quality of life such as chronic pain (not only those factors that result in death and disability)

  • Consider allocating funds for research on combinations of therapies, adjuncts, or add-ons, not simply comparative either/or studies.

Other brief highlights in the ABMP Position Statement include: crediting the framework for focusing on health, and noting research that shows massage is used at times for health and wellness; noting how issues of self-esteem influence healthy behaviors (and evidence on how massage can assist in esteem building); and suggestions that massage be researched as an alternative to pain medications; and to populations with little access to massage.
CommentThis is a model response for any discipline or professional association. Have integrative medical doctors, yoga therapists, holistic doctors, chiropractic physicians, holistic nurses, naturopathic doctors, licensed acupuncturists and similar groups registered their potential contributions?
Initial comments note lack or reference to integrative practice
3.  Integrator Comments on the draft framework

These comments were published in the Integrator here in November: There is much that is very exciting here, starting with the vision of shifting toward a focus on health and prevention. That sounds like the mission statements of scores integrative health organizations and initiatives going back decades. Hip-hip-hooray!

Yet clarifying the meaning and role of "integrative health care" in this construct is challenging. Some ideas to me are slam dunks. For instance, yoga in the schools or mind-body practices in the schools would be exceptional programs under the Strategic Direction of "Mental and Emotional Well-Being."

"Excellent as most components are, the framework
presently appears to side-step the optimal role of
clinical services in moving our nation toward a focus
on wellness and prevention. These is much room
for work here. Let's step up!

Still, most of this framework, excellent as most components are, presently appears to side-step engaging the optimal role of clinical services in moving our nation toward this focus. For instance, there is no explicit mention of health and wellness coaching, a recent, debated Integrator theme. Nor does there appear to be awareness that whole person-oriented integrative care can produce significant secondary health, wellness and preventive outcomes. Witness the Seely-Herman study of the integrative, naturopathic care which found, through patient self-reports: less fatigue, better sleep, lowered weight, diminished stress, fewer allergic symptoms, less hypertension, lower coffee consumption, and fewer muscoloskeletal problems.

The historic estrangement of "public health" and "clinical practice" in the United States is a function of the dominant type of clinical care that focuses almost entirely on reacting to sickness and disease. It behooves members of the integrative care community to seize this moment and redefine, forever, what we mean by "high impact, quality preventive services."

So get your comments in then share them, if you like,
 via .

Above all, take this opportunity to respond to the
draft National Prevention Strategy!

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