The National Health & Medical Research Council (NHMRC) and Research Integrity
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Bias


"But it's an entirely different matter when people who are ill with a treatable illness are pushed therapies that don't work and, in fact, are often implausible, pushed by practitioners who we must assume either believe in magic or perhaps are just dishonest. Ill health has attracted charlatans since time immemorial. Snake oil merchants wanting to take your money by promising false hope."
- NHMRC CEO, National Press Club Speech, 14 April 2015
Introduction:

In conducting the Homeopathy Review, did NHMRC:
  • Approach the subject in the same way it would approach any other area of conventional medicine/ healthcare?
  • Uphold statutory principles of impartial, ethical, transparent, collaborative and respectful conduct in public administration (Public Service Act 1999, NHMRC Service Charter)? 

NHMRC CEO submits article to the MJA declaring personal anti-homeopathy viewpoint:

In October 2010, the NHMRC CEO, Prof Warwick Anderson, submitted an article to the Medical Journal of Australia (published December 2010) [1], in which he stated he found it:
​
  • "... disturbing that now, in the 21st century, there is an apparent retreat from reason [...]
    Many people seem to regard their own views and beliefs as being of equal value to any other, whether or not they are founded on any factual, scientific or logical base. There are many examples, such as the widespread use of such alleged therapies as homoeopathy, or the belief that crystals have magic healing powers.” ​(emphasis added)
​
The NHMRC Act 1992, Section 42A(2) stipulates:
​
  • 'If the CEO has, or acquires, an interest that could conflict with the proper performance of the CEO’s functions, the CEO must, as soon as possible after the relevant facts have come to his or her knowledge, disclose the nature of the interest to the Minister.’

NHMRC CEO advises Council to develop a NHMRC Position Statement on homeopathy on the basis of a political (not scientific) UK report:

The same month (October 2010), the CEO directed NHMRC Council to develop a NHMRC Position Statement on homeopathy [2], on the sole basis of a political (not scientific) UK report [3], which was an examination of the evidence behind government policies on homeopathy, not an inquiry into homeopathy.

The UK Parliament had rejected the recommendations of the UK Report in July 2010, in favour of supporting user-choice and also encouraged further research into homeopathy. For further details about UK Report process, click here.

NHMRC embarked upon this process without:
  • Recognising the political (not scientific) basis of the UK report - which relied almost exclusively on a single study (Shang, 2005) that had already been discredited in the published scientific literature for being methodologically flawed 
  • Recognising the undue involvement of UK anti-homeopathy Skeptics in the process
  • Consulting with any homeopathy discipline and/or research experts
  • Conducting an independent review of the wider published research evidence - despite NHMRC’s statutory role and responsibility to develop ‘evidence based health advice’.

​In December 2010, NHMRC Council approved the content of a draft NHMRC Statement on Homeopathy [4].

After NHMRC Council approved the Draft Statement's content, NHMRC contracted the Consumers Health Forum (CHF) to ensure that the Draft Statement was ‘readable’ for release to the public [5].

CHF's email to its members confirmed the Draft Statement was intended for public release [6]:


  • "The National Health and Medical Research Council (NHMRC) has developed a Draft Public Advisory Statement on homeopathy which is intended for distribution to a consumer audience."

Draft NHMRC Position Statement on homeopathy leaked to the media:

On 20 April 2011, the Draft Statement was leaked to the media, on the same day that homeopathy stakeholders accidentally learned of the process via the CHF’s distribution list. The Statement declared:

  • “NHMRC’s position is that it is unethical for health practitioners to treat patients using homeopathy, for the reason that homeopathy (as a medicine or procedure) has been shown not to be efficacious.”

The Statement declared homeopathy to be “inefficacious”, “unethical” and even “deceptive” (an emotive term); it also confirmed the UK report as its sole point of reference, in lieu of assessment of any other published research evidence.

At the time, the CHF’s complementary medicines (CM) spokesperson was the active anti-CM campaigner Dr Ken Harvey - currently an Executive member of the anti-homeopathy/CM lobby group Friends of Science in Medicine (FSM) (see 'Conflicts of Interest').


NHMRC abandons Draft Statement due to perceptions of bias & lack of rigour:

Controversy resulting from explicit anti-homeopathy bias and lack of procedural and scientific rigour apparent in the development of the Draft Statement, resulted in NHMRC abandoning the process and instigating a formal review of the evidence on homeopathy.

In correspondence to stakeholders NHMRC claimed ‘it was only a draft that had not been finalised’, incongruous with NHMRC Council having formally endorsed its content intended for public release.


NHMRC CEO appoints expert committee without subject/research experts:

In mid 2011, the NHMRC CEO personally selected and appointed members to a ‘homeopathy reference group’, which later became the Homeopathy Working Committee (HWC) upon official commencement of the Homeopathy Review on 2 April 2012.

The reference group did not include any homeopathy subject, clinical or research experts - despite lack of consultation/ collaboration with homeopathy subject or research experts being a key criticism of the abandoned Draft Statement process.

The exclusion was unprecedented in NHMRC evidence review processes and in breach of mandatory NHMRC standards regarding the composition of its expert committees.


NHMRC Chairman publically discloses NHMRC anti-homeopathy bias:

During this period in mid 2011, the NHMRC Chairman publically disclosed his personal and NHMRC’s organisational anti-homeopathy bias, when he declared [7]:
​
  • “Let me assure you I am no supporter of homeopathy. As Chairman of NHMRC I can also assure you that NHMRC does not support homeopathy.”

On the back of the bias inherent in the development of the Draft Statement, this increased stakeholders' concerns that the topic was not being managed by an agency with the required objectivity. 

From October 2011 onwards, the Office of NHMRC/ CEO did not respond to any AHA (the key homeopathy stakeholder organisation in Australia) correspondence attempting to engage NHMRC on the exclusion of homeopathy experts on its committee. NHMRC had already refused to consider suitably qualified experts the AHA had nominated for inclusion on the expert committee. 

A hallmark of ethical scientific inquiry is involving suitable subject expertise; 'collaborative' conduct is also a core statutory APS Value that applies to all government processes where applicable (such as here). 


NHMRC Complementary Medicines webpage - reiterates message of Draft Statement:

Throughout the Homeopathy Review, the NHMRC ‘Complementary Medicines’ (CM) webpage scoped the Review using pre-emptive language and tone consistent with the discredited NHMRC Draft Statement on homeopathy. The March 2012 CM webpage (live 10 April 2012) introduced the Review in the following terms, before any evidence assessment of homeopathy or any other CM therapies had commenced [8] (emphasis added):

  • “Council of NHMRC has been concerned with reports of non-evidence based complementary and alternative medicine (CAM) used in place of evidence-based treatments.”

    - echoing the message of the (abandoned) Draft Statement that homeopathy was "inefficacious". 

The NHMRC CM webpage went on to further subliminally warn:
​
  • “However, sometimes patients may be misled into rejecting practices and treatments that are evidence-based in favour of non-evidence based practices and treatments”

    - synonymous with the Draft Statement's message that homeopathy is 'deceptive'.

The webpage also reiterated the pre-formed view expressed in the Draft Statement on Homeopathy that homeopathy was 'placebo' and 'implausible' - a pre-emptive conclusion not based on any assessment of the evidence. 

NHMRC Complementary Medicines webpage & anti-homeopathy conflicts:

Between March and September 2012 (the duration of the first terminated evidence review), the NHMRC ‘Complementary Medicine’ webpage presented the official announcement of commencement of the Homeopathy Review under the heading, ‘Evaluation of effectiveness’.

Under this same heading, on the same webpage, NHMRC also presented an excerpt of a transcript from an interview with the CEO, published in Asian Scientist, which specifically focussed on and highlighted the anti-CM agenda of FSM. FSM had already identified homeopathy at the top of its list of 'pseudo-sciences' in lobbying NHMRC reviewers in January 2012 to join their cause, which the CEO had been made personally aware of (see 'Conflicts of Interest').
Picture
Why would NHMRC have given a public platform to an extreme anti-homeopathy lobby group on their official website, let alone place it right next to its announcement of the Homeopathy Review? The inclusion of this article was not balanced by any other opinion pieces regarding homeopathy – just FSM’s.

FSM’s anti-CM views were entirely unrelated to NHMRC’s Homeopathy Review (or should have been), yet their inclusion on this NHMRC webpage gave the public perception of an alignment of views between NHMRC and FSM.  


NHMRC CEO & anti-homeopathy bias in public orations:

The NHMRC CEO also directly reiterated the biased themes of the abandoned Draft Position Statement on homeopathy/ NHMRC CM webpage in his public orations on the subject; often employing explicitly rhetorical language.

For example, the bias in the tone and expression of Prof Anderson's 2015 National Press Club speech is explicit and not open to interpretation:


  • “I guess it’s one thing when people sell magic therapies to the worried well - that's mostly just a waste of money or expensive urine. Perhaps a little placebo effect, as well.

    But it's an entirely different matter when people who are ill with a treatable illness are pushed therapies that don't work and, in fact, are often implausible, pushed by practitioners who we must assume either believe in magic or perhaps are just dishonest.

    ​Ill health has attracted charlatans since time immemorial. Snake oil merchants wanting to take your money by promising false hope."

​Such biased, openly adversarial language exceeds the boundaries of acceptable conduct required by senior public officials in public engagements (Public Service Act 1999). Australian Public Service Commission (APSC) Conflicts of interest guidance stipulates:

  • “The public is entitled to have confidence in the integrity of their public officials, and to know that an Australian Public Service (APS) employee's personal interests do not conflict with his or her public duties. […] Agency heads and SES employees are required to declare in writing, at least annually, their own and their immediate family's financial and other interests that could cause a real or apparent conflict of interest.”

NHMRC CEO iterates views and language of anti-homeopathy lobby groups:

The NHMRC CEO iterated the rhetoric of anti-homeopathy advocacy groups that had openly lobbied him against homeopathy during the course of the NHMRC Review.

For example, on 8 April 2014 (the day before
NHMRC officially released the Draft Information Paper), the Vice-President of Friends of Science in Medicine (FSM), Prof Alastair MacLennan, wrote to 'congratulate' the CEO on the conclusions of the Draft NHMRC Information Paper, urging the CEO that:

​
  • “The government must now ensure that Australians are not sold snake oil.”

On 15 April 2015 (National Press Club Speech), shortly after the Review had been concluded, the CEO reiterated the FSM Vice-President's message, proclaimed the sector to be:
​
  • "Snake oil merchants wanting to take your money by promising false hope."

(See 'Conflicts of Interest' page for more details of undisclosed and unmanaged conflicts associated with the Review).

NHMRC CEO publically pre-empts Review’s findings; biased comments in QIMR Berghofer public address, 21 Oct 2014:

In October 2014, the CEO pre-empted the outcome of the NHMRC Homeopathy Review in a public address [9]:

  • “We will soon, before the end of the year, release our public statement on homeopathy. Already some pharmacists are urging their profession to stop stocking these remedies and others that don’t have an evidence base.”

The CEO made this public announcement before:
  • Extra evidence submitted during public consultation had completed being assessed (Nov 2014); 
  • It had been signed off by NHMRC Council (27 Nov 2014);
  • Undergone Ministerial deliberation (early 2015).

In the address, the CEO reiterated his anti-homeopathy bias, elevating it to a "sermon" (noting that his comments clearly allude to homeopathy) [9]:

  • “I do, though, want to talk about other wasted money. Your money, and public money. Does it annoy you as much as it annoys me that private health insurers offer rebates for unproven treatments? … and in many cases where the simple scientific basis seems implausible on the basis of known science. … Except for perhaps the placebo effect, do we really believe that manipulation of an “aura” will work for patients? Or that diluting a substance to the equivalent of one molecule in the entire volume of the solar system is likely to have a biologically therapeutic effect? …

    There are some estimates that Australians spend more money on complementary and alternative medicines than they do through the PBS, so, for ethical treatments. … 

    A final word on the sermon about complementary medicines. Of course, many of these “remedies” cause no harm; one molecule in water that dilute is unlikely to do harm. And if people want to spend their money on useless “wellbeing” products, is that really a problem?”

​Chair of Homeopathy Working Committee & anti-homeopathy public comments:

The Chair of the HWC, Prof Paul Glasziou, expressed his personal anti-homeopathy views in public engagements both during and after the Review, which exceeded the terms of reference of the HWC.

After release of the Draft Information Paper on 9 April 2014, Prof Glasziou expressed views in media interviews that exceeded the scope of the Review's coverage and appeared to pre-empt its findings.

Partisan and non-evidence based opinions he offered to the media included [10]:


  • People were "wasting their money";
  • Homeopathy should be 'removed from private health insurance';
  • People were "not getting the appropriate healthcare they need";
  • His personal opinion that "consumers, in particular, need to be a little more wary and sceptical of claims about complementary and alternative medicines, and in particular from this review, the impact of traditional homeopathy" (which the Review did not even assess).

Prof Glasziou reiterated these opinions in 2015, after release of the final report, which exceeded his committee's terms of reference and did not relate to the actual assessment conducted, for example [11]:

  • "He hoped the findings would lead private health insurers to stop offering rebates on homeopathic treatments, and force pharmacists to reconsider stocking them. […] But we hope there will be a lot of reasonable people out there who will reconsider selling, using or subsidising these substances."

He also stated [11]: 

  • "Glasziou said homeopathy use declined in the UK following a House of Commons report released in 2010 which found the treatments were ineffective, and that he hoped the NHMRC report would have a similar effect in Australia.”

HWC Chair openly vilifies homeopathy, BMJ Blog, 2016:

In 2016, Prof Glasziou vilified homeopathy as "a therapeutic dead-end" [12].

This was on the sole basis of a review associated with unusual procedural and methodological 
issues that he would have been fully aware of as Chair of the HWC, especially since he was personally involved in developing and approving them. 

“Let me assure you I am no supporter of homeopathy.
As Chairman of NHMRC I can also assure you that NHMRC does not support homeopathy.”

​- NHMRC Chairman to Australian Skeptics, 22 July 2011
​
[1] Anderson, WP (2010). A balloon, the beach, biology and blood pressure. MJA, Vol 193 Number 11/12, 6/20
[2] NHMRC Council 183rd Session Report. Item 3 CEOs report, p.4, 10 October 2010
[3] UK Parliament Science and Technology Committee ‘Evidence Check 2: Homeopathy' HC 45
[4] NHMRC Council 184th Session report. Item 6 Homeopathy, p.8, 12 December 2010
[5] Email correspondence between NHMRC and CHF re. NHMRC draft statement on homeopathy, 5 April 2011. NHMRC FOI 2015-16 002-15
​[6] Emails between CHF and Australian Homoeopathic Association (AHA) re. the NHMRC draft position statement on homeopathy, 20 April 2011
[7] Griffith Uni Rejects Homeopathy Link, Australian Skeptics Inc., 22 July 2011
[8] NHMRC ‘Complementary Medicines' webpage, 16 March 2012 (live on 10 April 2012)
[9] NHMRC CEO QIMR Berghofer Medical Research Institute 2014 Derrick-Mackerras Lecture, 21 October 2014
[10] HWC Chair, Prof Paul Glasziou, interview with SBS, 21 April 2014
[11] ​
HWC Chair, Prof Paul Glasziou, The Guardian, 11 March 2015
[12] Prof Paul Glasziou, BMJ blog, 16 Feb 2016. 
​​
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​"There are many examples, such as the wide-spread use of such alleged therapies as homoeopathy"
- NHMRC CEO, MJA Dec 2010
 


“NHMRC has developed a public advisory statement on homeopathy. ... NHMRC would like to have the draft statement reviewed by consumers to ensure the writing style is able to be read and understood by a lay audience.”
- NHMRC to CHF, 5 April 2011 (re. Draft NHMRC Statement on Homeopathy approved by NHMRC Council Dec 2010)

​


“The government must now ensure that Australians are not sold snake oil.”
- FSM Vice President Prof Alastair MacLennan to NHMRC CEO, 8 April 2014







“Ill health has attracted charlatans since time immemorial. Snake oil merchants wanting to take your money.”
- NHMRC CEO, National Press Club Speech, 15 April 2015





"There's concern some people ... are also wasting their money. …”
- HWC Chair Prof Glasziou, SBS News 21 April 2014



"Glasziou said homeopathy use declined in the UK following a House of Commons report released in 2010 [...] and that he hoped the NHMRC report would have a similar effect in Australia.”
- HWC Chair Prof Glasziou, The Guardian, 11 May 2015

​

“I guess it’s one thing when people sell magic therapies to the worried well - that's mostly just a waste of money or expensive urine. Perhaps a little placebo effect, as well."
- NHMRC CEO, National Press Club Speech, 15 April 2015



​











​Homeopathy is - "
a therapeutic dead-end." 
- NHMRC HWC Chair, Prof Paul Glasziou, BMJ Blog, 16 Feb 2016

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