NCCAM Name Change: IHPC/Partners Weigh in, plus Integrator on the Name is Not the Mandate

Coalescing a response from its 13 Partners in Health

Following an extensive dialogue between many of the best informed policy leaders in alternative, complementary and integrative health and medicine, the Integrative Healthcare Policy Consortium (IHPC) submitted the following letter to NIH National Center for Complementary and Alternative Medicine director Josephine Briggs, MD. Briggs had requested public comment on her proposal that the name be changed to the National Center for Research in Complementary and Integrative Health. IHPC's 13 Partners for Health range from massage to integrative medical practice organizations. Here is there letter [bolding by IHPC].

"On behalf of The Integrative Healthcare Policy Consortium (IHPC), a national non-profit comprised of 13 organizations and institutions representing more than 400,000 licensed and state and nationally certified healthcare professionals and consumers of their products and services, whose mission is to advocate for an integrative healthcare system with equal access to the full range of health-oriented, person-centered, regulated healthcare professionals, in order to promote optimal health, we extend our appreciation for the opportunity to respond to the proposed NCCAM name change.

"While we support adding the word 'research' to the name, since all of the centers of NIH do not contain the word research, we believe it may be more appropriate to leave it out of the title.  The general purpose of the Center as stated in S.2420 is to conduct and support basic and applied research (including both intramural and extramural research), research training, the dissemination of health information, and other programs with respect to identifying, investigating, and validating complementary and alternative treatment, diagnostic and prevention modalities, disciplines and systems.

"The IHPC supports the inclusion of the words 'Complementary,' 'Alternative,' and 'Integrative Health' in the proposed name, and believe 'The National Center for Research on Complementary, Alternative and Integrative Health Care,' or more simply 'The National Center for Complementary and Integrative Health Care' would be an appropriate title for the center.

	"IHPC notes reservations about this name change's implications for research funding initiatives, infrastructure, training and agendas for complementary and alternative health disciplines, organizations, and accredited academic institutions." - IHPC, letter to NCCAM June 6, 2014

"IHPC notes reservations about this name change's implications for research funding initiatives, infrastructure, training and agendas for complementary and alternative health disciplines, organizations, and accredited academic institutions (chiropractic, naturopathic medicine, homeopathy, massage therapy, direct entry midwifery, holistic nursing, acupuncture and Oriental medicine, and others).

• "The legal mandate of NCCAM states: 'The Director of the Center shall, as appropriate, study the integration of alternative treatment, diagnostic and prevention systems, modalities and disciplines with the practice of conventional medicine as a complement to such medicine and into health care delivery systems in the United States.' (S.2420, July 31, 1998)

• "Furthermore, we agree with the following comments by John Weeks in response to NCCAM's Research Blog the '.... agency was charged to explore: alternative modalities, systems and disciplines. We have seen from the response to 'integrative health' and 'integrative practitioner' language in the Affordable Care Act that many read these as the integration of MDs with nurses and psychologists and PTs. While this reflects a positive step toward team care, it does not reflect the public interest in what has been non-conventional health care services (chiropractic, naturopathic medicine, acupuncture and Oriental medicine, etc.). These are what NCCAM is charged to explore. At this time in the evolution of the 'integrative' dialogue, the so-called complementary and alternative health disciplines and practices must continue to be explicitly included or they will, likely, be excluded. [Bold from IHPC.] Finally, the term 'integrative' is a political one which is meant to not chafe as much as [the term] 'alternative' to conventional doctors.' (John Weeks, Executive Director of ACCAHC, commenting on NCCAM RESEARCH BLOG 'Integrative-What is in a word?' May 24, 2012)

• 	"At this time in the evolution of the 'integrative' dialogue, the so-called complementary and alternative health disciplines and practices must continue to be explicitly included or they will, likely, be excluded." -- IHPC letter to NCCAM June 6, 2014

  "Therefore, IHPC supports the Academic Consortium for Complementary and Alternative Health Care's (ACCAHC's) value which states: 'Explicit inclusion of 'complementary and alternative medicine' therapies and licensed or nationally certified practitioners, 'integrative health' and 'integrative practitioners' in governmental and private healthcare policy dialogues, reports and recommendations until such time as these distinct disciplines and practices that are used by significant subsets of the population are routinely included as part of the inter-professional communities of medical and healthcare professions."
  

• "Finally, the language of the law that established NCCAM supports the study of 'alternative modalities, systems and disciplines' AND the study of their integration into health care delivery systems in the U.S. In the absence of the use of the word 'alternative,' the intent of the law may be reduced or lost. As a result, there may be diminished research priorities for these alternatives, and the burgeoning 'CAM' academic institutions and credentialed research scientists from these disciplines which Congress and the American people deemed important to study, and to develop: 'The provision of support for the development and operation of such centers shall include accredited complementary and alternative medicine research and education facilities.' IHPC supports explicit inclusion of these alternatives, which our 400,000 stakeholders and the patients they serve, believe are crucial in providing quality health care including prevention, promotion of health and improved management of chronic disease.

"IHPC continues to serve as a united voice in support of integrative health care, and welcomes further dialogue on NCCAM's name change and future agenda." 

• hating the limits and disrespect implicit in the "CAM" box;
  
• knowing that "CAM" is the only way many of the integrative health disciplines exist in the affordable care act, and still do in NCCAM;
  
• knowing that "alternative" is anathema to the MDs which whom we must one day integrate;
• believing that we want "alternatives" to what the mainstream offers;
• knowing, as noted in the IHPC letter, that for many so-called "integrative" MDs and the systems in which they work, "integrative" means MDs plus behavioral health, PT, nursing and dieticians;
  
• knowing that "integrative" often leaves the "CAM" modalities, systems and disciplines on which NCCAM is supposed to be focused on the cutting room floor; and
• knowing that NCCAM itself has successively shunted the "CAM" fields to the side in favor of members of its own more comfortable tribe of MDs and PhDs from conventional academic health centers.
  

"Unfortunately for the licensed (formerly) 'CAM' professions, this shift from CAM toward the 'integrative' term means running with a brand first widely used by medical doctors who practiced integrative medicine. The word choice may be reasonably viewed as marking NCCAM's turn away from the so-called CAM disciplines.

{mosimage}"The NIH's National Advisory Council for Complementary and Alternative Medicine that advises Briggs once had at least 50% of its 18 members from the licensed CAM disciplines. This would seem to reflect Congress' mandate that 'at least half of the members of the advisory council shall include practitioners licensed in one or more of the major systems with which the Center is concerned.' [Notably, "integrative medicine was hardly on the map as a 'system' at that time, and not noted anywhere in the mandate.]

"As of June 1, 2014, just two members of the Council held titles that declare such a background. One is a naturopathic doctor and the second is a chiropractor who is also a medical doctor. The 'integrative' MD's and DOs and PhDs from their institutions already dominate.[One ND and one DC who is also an MD.]

"The mandate also requires the agency to 'support for the development and operation of such centers' in 'accredited complementary and alternative medicine research and education facilities.' The percentage of NCCAM funds that have gone to research at CAM institutions is declining from an already paltry 4.6% estimated for 1999-2010 to below 3% for 2011-2012. Hearsay from the field suggests that in recent months the figure appears to be further declining. Resources are already heavily tracking toward the 'integrative MD' programs and institutions.

	Unfortunately for the licensed 'CAM' professions, this shift from CAM toward 'integrative' may be reasonably viewed as NCCAM's decade-long turn away from the so-called CAM disciplines.

"Briggs has said that the change in name will not change the mandate. That would require an act of Congress. However, the evidence in both these areas is that the agency has already essentially disregarded the original Congressional focus on the licensed so-called CAM disciplines. Apparently the new, de-CAMified name will merely reflect a direction the agency has already taken.

"In the agency's favor, the new focus on 'health' does capture a requirement in the laws to focus research on the role in 'prevention' of these 'modalities systems and disciplines.'
 
"Everyone working in these fields will know that part of the reason for the alternative-ectomy in this proposed name change is to appease the discomfort in conventional doctors that stems from realizing that much of the public is interested in an alternative to what they do.
 
"It makes many of them nervous. Most, with their decade plus of medical education, are challenged by the ignorance they have of what they never learned, despite all those years of medical training. Their authority is on the line.

"As it should be.

"Because, in fact, what we want are alternatives to 7-15 minute primary care visits. We want alternatives to a reactive first choice of pharmaceuticals for every illness or ache that walks through the door. We want alternatives to practitioners who know next to nothing about the therapeutic uses of nutrition. We want alternatives to definitions of 'prevention' that extend only to early diagnosis. We want alternatives to a system that does not respect the value in time-intensive practices. We want alternatives to a system that focuses on reaction and stitching things up post-facto rather than on proactive care.

"In fact, we want alternatives to research priorities that seem to focus more and more on less and less. Maybe cloaked in a new name, the agency can get on with the more radical business of seeing how all of these complementary and integrative 'modalities, systems and disciplines' can assist in creating health in the people the agency is supposed to serve."