Complementary and Unconventional Medicine and Emerging Treatments: A Submission in Response to the Medical Board of Australia’s Consultation on Clearer Regulation

This submission responds to the Medical Board of Australia’s consultation on clearer regulation of medical practitioners who provide complementary and unconventional medicine and emerging treatments, answering the consultation paper’s eleven questions. Research Australia agrees with the proposed term and definition and with the issues the Board identified, and is particularly concerned that some practitioners use public awareness of science, such as stem cell research, to give unproven treatments undeserved credibility, which risks eroding trust in legitimate research. Citing its opinion polling, including that 89% of Australians believe health professionals who also do research provide the best care, it maintains that patients assume treatments offered by registered doctors are safe, effective and evidence based, and are therefore unlikely to question them. Research Australia supports the Board’s Option 2, practice-specific guidelines supplementing Good medical practice, but recommends that the guidelines also require practitioners give prospective patients a standard written consumer warning, as a separate document, before treatment. The warning would be modelled on the required statements under the Therapeutic Goods Advertising Code and the information statements required under the National Consumer Credit Protection Act 2009. The submission includes a sample notice stating that there is no good evidence the treatment is safe or effective, that it is not part of a clinical trial and is not funded by Medicare or the Pharmaceutical Benefits Scheme, with questions patients should ask and advice to seek a second opinion.