WHITE HOUSE COMMISSION
on
COMPLEMENTARY and
ALTERNATIVE MEDICINE POLICY
+ + +
Volume I
+ + +
Thursday, October 4, 2001
8:07 a.m.
Neuroscience Building
National Institutes of Health
Conference Rooms C & D
6001 Executive Boulevard
Bethesda, Maryland
PARTICIPANTS:
Chairperson
James S.
Gordon,
M.D., Director
The Center for Mind-Body
Medicine
Commission Members
George M. Bernier,
Jr.,
M.D.
Vice President for
Education
University of Texas Medical
Branch
David
Bresler,
Ph.D., LAc, OME,
Dipl.Ac.
(NCCAOM)
Founder and Executive
Director
The Bresler Center,
Inc.
Thomas
Chappell
Co-Founder and
President
Tom's of Maine,
Inc.
Effie Poy Yew
Chow,
Ph.D., R.N., DiplAc (NCCA)
Qigong
Grandmaster
President, East-West Academy
of Healing Arts
George T. DeVries,
III
Chairman, CEO, American
Specialty Health Plans
William R.
Fair,
M.D. [Not
present]
Attending Surgeon, Urology
(Emeritus)
Memorial Sloan-Kettering
Cancer Center
Chairman, Clinical Advisory
Board of Health, LLC
Joseph J.
Fins, M.D.,
F.A.C.P.
Associate Professor of
Medicine,
Weill Medical College of
Cornell University
Director of Medical
Ethics,
New York Presbyterian
Hospital-Cornell Campus
Veronica
Gutierrez,
D.C.
Gutierrez Family
Chiropractic
Wayne B.
Jonas,
M.D.
Department of Family
Medicine
Uniformed Services
University of the Health Sciences
F. Edward Hebert School of
Medicine
Charlotte
Kerr,
R.S.M.
Traditional Acupuncture
Institute, Inc.
PARTICIPANTS
(continued)
Linnea S.
Larson,
LCSW, LMFT
Associate
Director
West Suburban Health
Care
Center for Integrative
Medicine
Tieraona Low
Dog, M.D.,
A.H.G.
(Private
Practice)
Dean Ornish, M.D.
President/Director
Preventive Medicine Research
Institute
Clinical Professor of
Medicine
University of California,
San Francisco
Conchita M.
Paz,
M.D.
(Private
Practice)
Joseph E. Pizzorno,
Jr.,
N.D.
Co-Founder/Founding
President, Bastyr University
Buford L.
Rolin
Poarch Band of Creek
Indians
Julia R.
Scott
President
National Black Women's
Health Project
Xiaoming
Tian, M.D.,
LAc
Director, Wildwood
Acupuncture Center
Academy of Acupuncture &
Chinese Medicine
Donald W.
Warren,
D.D.S.
Diplomate of the American
Board of
Head, Neck & Facial
Pain
Executive Staff
Stephen C.
Groft,
Pharm.D.
Executive
Director
Michele M.
Chang,
C.M.F., M.P.H.
Executive
Secretary
Joseph M.
Kaczmarczyk, D.O.,
M.P.H.
Senior Medical
Advisor
Corinne
Axelrod,
M.P.H.
Senior Program
Analyst
PARTICIPANTS
(continued)
Geraldine B.
Pollen,
M.A.
Senior Program
Analyst
Joan
Albrecht
Program
Assistant
Doris A.
Kingsbury
Program
Assistant
Consultant Staff
Kenneth D.
Fisher,
Ph.D.
Senior Scientific
Advisor
Maureen
Miller,
R.N., M.P.H.
Senior Policy
Advisor
James Swyers
Writer/Editor
P R O C E E D I N G S
[8:07 a.m.]
[Moment of silence observed.]
DR. GORDON: Thank you. Thank you all very
much.
Opening Remarks
DR. GORDON: Just a couple of
things to begin with. One is it
seems to me that our work, always important, takes on a whole new dimension in
the light of the kinds of healing that we all, and all of us as part of a
nation, need after the events of September 11th.
What we would like to do is on Saturday morning, we will set aside a
little bit of time, if there is specific thoughts that people have about the
contribution that CAM might make to the general process of healing in our
country, and we can focus on that on the 11th.
I wanted also just to say how grateful I am to all of you for being
here. I think it is really
important that we are here and that we are together, and that we are here in the
Washington area at this time. It is
a very important statement about the importance of our work and about how
healing and help is so necessary right now.
The other thing I wanted to say before Steve goes into the order of how
we are going to proceed is, as some of you know, I was out of the country. I was actually in the middle of a war
when this war began over here. It
was very strange being in Macedonia and then coming back
here.
One of things that I appreciate so much is all the work that everybody
has done in preparing for this meeting, all the Commissioners and all the
staff. It is just an extraordinary
document that we are going to be working with these next three days. I am terribly grateful to everybody for
all the work that everybody put into it.
Steve is going to talk about how we are going to move through the next
couple of days and then we are going to move through quickly, and Michele is
going to be keeping us on time, all of us, very strictly on time as we move
through.
Steve.
Since the Interim Progress Report, which as I mentioned in an e-mail to
you was signed off by the Secretary last Friday afternoon, and we have copies of
it at the desk and we will be putting it up on our Internet site to make it
available for comments, and anything that anybody would like to respond to that,
your friends or colleagues, just ask them to send us a note, and we will
communicate that information to you, as well, so I do appreciate
it.
I just want to mention, two other people who are in the room, Mary
Plummer and Mandy Stoneberger, a couple people from our Committee Management
Office, if you want to stand up really briefly.
They ask you to update your files as far as conflict of interest and
everything else. It is not a matter
of them wanting to know everything that is going on, and this information is
confidential, but we need to know where funds come from, where your support is
coming from, so if anyone raises an issue we can say yes, we know about this and
you are cleared as a member of the Commission.
We don't take these things lightly.
We just never know where people will be asking us, when they will be
asking us for information about the Commission. We had this early on about the
membership, so I would ask you just to please update the requests that are
provided to you on a regular basis.
Usually, it is at each meeting.
I think as we approach the meeting, especially as we have completed the
Interim Progress Report, we were looking at how would we pull this meeting off,
how would we begin to write the Final Report, and there were two possible
approaches that we thought about and normally you would go through I
guess.
One is to write the report and then develop the recommendations. The other way is to develop the
recommendations and define the issues, and then write the report. I think after the whole process of going
through and preparing the Interim Progress Report, we thought that we needed the
foundation on agreement with the issues and recommendations, and that is why I
think we took the approach we did of trying to define issues and recommendations
that we could discuss at this meeting, develop some of the background
information for the Final Report, although the background information that you
received and is in front of you really is the rationale for the
recommendations.
That may change, and probably will change, as we go through the next
three days as we being to prepare the final report, at least the Draft Final
Report, for the December meeting that we will be discussing at that point in
time.
So, we will be picking up maybe more appropriate examples, better ideas,
better concepts, so this is fluid and it will remain fluid until we have final
agreement on the part of the Commission either in December or perhaps at a later
meeting depending on the progress that we make.
We ask you not to focus so much on the language in the text of the
background information, but we really want to focus on the issues and
recommendations that are before you.
The workgroups will continue to function as they have. They will be
responsible for developing that section of the Final Report that they are
currently working on.
So, it is going to carry through until completion, so each of the
workgroups will maintain their status and their activity level.
People have said can we change, we prefer that you don't, but if someone
wants to join another group, they are welcome. I think you all realize how much work is
involved with each individual group, especially the facilitators, so I don't
know how many people want to take on an extra burden of an additional workgroup,
because it has been a lot of work.
Today, tomorrow, and Saturday morning, we tried to break out each of the
sessions into two-hour periods. We will open up with a 10-minute introduction
by the facilitator or co-facilitators, talking about the process, how they got
to where they are, some of the remaining issues that are problematic. These are the types
of things that will be brought out.
We then will have five minutes to go around to the other workgroup
members to see if they have anything additional to add to what the facilitators
mention in the introductory comments.
Following that, we will move into about a 75-minute discussion of the
issues and recommendations that are before you. We will just sort of run through and see if
there are areas of agreement or disagreement, and then we will take it from
there.
I will be passing out a little bit of a cheat sheet here that has all of
the issues, the time frames, and then the disposition of the issues and
recommendations.
After the discussion, we will have about 30 minutes that Jim will take to
take care of the recommendations and the issues, and we will be asking you to
make some decision whether to accept the issue or recommendation as presented,
accept it with change, return the issue to the working group with all the
discussion that we have, delete the issue of recommendation.
There may be some of the recommendations that you want to knock out, and
not include, or determine that it shouldn't be the status of a recommendation,
they may not be worthy of that as far as emphasis.
If there are new issues or recommendations, and we think there will be,
we ask you to limit your discussion of that issue, that new issue, a very, very
brief discussion.
We have time on Saturday morning to pick up and discuss in greater detail
the new issues.
We only want to get them on the table now. Our concern with the very limited amount of
time is if we spend a lot of time working on the new issues, we will never
complete the recommendations that are presented. So, I think what we would like to have is,
raise the issue, your brief rationale for your concern, state it, and then get
out. You know,
we are finished with it for now. We will bring it back. The workgroup,
then, will address that as they prepare the draft of the report. So, I think we have
to rely upon the workgroups to do their work, and they will be in touch with the
individual who raised the issue or the concern.
So, I hope that is okay. We just are reluctant to spend 10, 15 minutes
out of 75 on a new issue, that the workgroup really needs to hear from you and
then expand a little bit in their procedures.
So, I ask you to be patient and let the workgroup do their thing after
this meeting to bring this to completion for you.
I think that is about it. I apologize for some of the confusion, but we
have to be out of here at 5:00 both days. It is security, added security. They are closing
government facilities at 5:00 for meetings, so we will be bumped out of
here.
What happened, also, we tried to get the meeting at the Pooks Hill
Marriott for Saturday morning. They had no meeting room, so we are going to
what is called the Marriott Suites Hotel over on Democracy Boulevard, not real
far from here, and we will make arrangements again to get you out to the
Marriott Suites Democracy Boulevard location, which is a breezeway walk over to
our offices.
Once we heard that we didn't have the Pooks Hill Marriott for meeting
space, we ran over there, and they fortunately had a space for us to meet. So, my apologies
for the confusion on that Saturday. Again, that is quite accessible to the
interstates and to the airport, so it will be a little bit easier I think in the
long run.
On Saturday morning also, I will talk about how we are going to prepare
the Final Report.
We have procedures in place to continue utilizing the workgroups, and all
of that will be discussed on Saturday morning. A couple of you I think have to leave, and we
will make sure you get a copy of what we will be talking about at that point in
time.
DR. GORDON:
Thank you, Steve.
Let me just make sure that everybody is on the same page with how we are
going to proceed.
If there are any questions about that, we can deal with them now.
The basic idea after the presentations by the workgroup facilitator and
by any additional comments, and after any additional comments from workgroup
members, is that the major discussion of all the recommendations will take place
in that next 75 minutes.
The final 30 minutes is -- and that will be led by the facilitators --
the final 30 minutes is to make sure that we are all on the same page as we move
ahead, and that part I will facilitate.
My job is just to make sure that we have heard each other correctly and
that we agree about where we are, and that we put a recommendation into one of
the categories that Steve mentioned, that Ken has listed up on that board, that
either we accept it or we change it, there is a new issue, we decide we don't
want to make that recommendation, et cetera.
So, I am going to ask a question at that point, which will worded
something like can we live with this recommendation, and if we can, then, we
will put it up there in that category; if we can't, it will go back to that
workgroup.
So, this is a continuing process. If we decide we can't live with the
recommendation, then, it is up to the workgroup to keep on working with it, and
working with whoever has issues or concerns.
One of the things that Steve said that I think is important to emphasize
is if you have concerns or issues about any recommendation, the workgroup will
be available to you, but we really want each person who has those concerns to
get in touch with the workgroup facilitator and to make those concerns
clear.
Okay?
So, if there is an issue, let whoever is in charge of that particular
workgroup know about the issue, so they can grapple with it and if you have new
information you want to bring to them.
Once again, if there are new issues, new possible recommendations, we
will just raise them and then come back to them on Saturday morning.
Any questions about the way we are going to proceed for Steve, me, or
Michele, or anybody?
Michele.
MS. CHANG:
I just want to mention as we start each new topic, we are going to ask
the facilitator or facilitators and the staff lead to move from where they are
sitting now to that table there, so that everyone can see them clearly. Take your name
plate with you.
DR. GORDON:
Just one thing about my role. In the early discussion, I am a member of the
Commission, the facilitator is in charge, and then I will step back and my job
is to help make sure we have the recommendations as everybody wants it in the
final 30 minutes.
MS. CHANG:
I am going to start the clock at 90 minutes for the full discussion,
which includes your 10-minute overview and member group around the table, and I
will give you a 10-minute warning when you need to start summing up to get ready
for the disposition.
Thank you.
MR. CHAPPELL:
Would you repeat the time sequence?
MS. CHANG:
Yes. I
am going to set the timer at 90 minutes, which includes the 10-minutes overview
and the 5-minute comment by other members of your workgroup before you move into
the full discussion.
I will give you a 10-minute warning, so that you know that you need to
start to summing up.
MR. CHAPPELL:
Great.
Session I: Definition of CAM
I am going to help us through the section on the CAM description and
definition, Dr. Jones will help us with the guiding principles, and Jim Swyers,
the writer of the material, will contribute as he wishes.
I want to thank particularly Jim Swyers for the great work that he has
done for this group, this committee. It has not been an easy topic, trying to get
our hands wrapped around the definition of CAM has not been easy, and I just
want to thank Jim for his good listening and good encouragement and good
drafting for us.
I also want to thank our committee for the time and attention, thought,
and guidance that each has given on this process.
With that as way of introductions, shall I proceed with my piece? Fine.
MR. CHAPPELL:
Great.
In looking at the definition of CAM, I will be referring us all to pages
1 through 6.
The structure of our dialogue will be built around basically describing
CAM, speaking about the marginalization issue of CAM, talking about the
differentiation of the different practices of CAM, some of the common
characteristics of CAM, and then looking at a summary definition of CAM. So, that is the
structure of my portion for us.
Why don't we begin then looking at pages 1 and 2 as we look at the while
question of describing and defining. We tried to say let's define CAM, and
throughout our sessions over the last year and a half, this has been a provoking
question, are we all talking about the same thing here, or do we really need to
come up with a definition.
So, my thanks to those of you that have been probing and forcing us to
wrestle with this.
As you can see by our attempt to define CAM, it began with a description
of CAM. It is
just too broad to wrestle to the ground that simply, so we have let ourselves
cast the net here with being sure that we are touching down on all of the points
that we need to in describing CAM, and that is what you have before you.
It is a diverse set of both ancient and modern health care systems and
practices.
These systems and practices, not always supported in the Western
countries, focus on the support and stimulation of the healing processes and on
the whole person care to prevent and treat illness.
The health care system and practices are shown on the following table,
and there you see the diversity in the chart and have gained increasing
acceptance and recognition by mainstream health care. This is our attempt
to circumscribe the various modalities and practices.
Before I move on to the marginalization section, could we have some
discussion?
DR. JONAS:
I just want to mention this definition. Just to kind of reorient you, I think we have
talked about this before, there have been multiple different definitions that
have come down through the years and we had in our discussion and certainly in
our subcommittee we saw many of these.
Jim put together a very nice kind of summary list of definitions that
have come over a number of years. This one is one that has been pulled from,
and modified slightly from, the Cochrane definition, which in turn was pulled
from an OAM definition working committee on definitions back in 1995. So, this is kind of
the link to this particular one.
This had input from a number of international groups, so it was felt that
this was important that this be something that would have worldwide
applicability or at least the potential to have worldwide applicability in those
areas. So,
that is just a little bit about the history and the background of that.
MR. CHAPPELL:
Great.
That is helpful, Wayne.
Tieraona?
DR. LOW DOG:
Just a couple thoughts. Especially given the state in the United
States and how we are going to talk about dietary supplements and that,
complementary and alternative medicine is a diverse set of both ancient and
modern health care systems practices and products.
I do think that in many cases, people are using dietary supplements
without the context of anything, and I think it is a multibillion dollar
business in this country, and I think products may be appropriate there.
The other thing is, these systems and practices which are not usually
available or supported in most Western countries. I am not sure I know what we are trying to
say, but it is not really accurate when you consider that osteopathy,
chiropractic, naturopathy, homeopathy, therapeutic touch, applied kinesiology,
and relaxation therapy really developed in the West. That is their
origin. That
is where they came from. Spiritual healing, nutritional therapy,
aromatherapy, and herbal medicine are really worldwide.
I think what we are trying to say there is that it is not supported often
by the dominant systems within Western countries, but to say that they are not
available, when that is where they came from and they still flourish, I think is
somewhat misleading.
Those were my only two comments.
MR. CHAPPELL:
Thank you very much.
Yes?
DR. PIZZORNO:
Actually, I would just like to start with a general comment. On the long
cross-country flight, I had a chance to sit down and read this document in one
sitting in its entirety.
I actually would like to compliment the staff and the commissioners for
an incredibly well-done job. This document is very, very impressive. If I had my
druthers, I would say I move to accept and let's all go home.
[Laughter.]
It is still 5:00 in the morning for me. I would also like, as a comment, to second
Tieraona's insightful comments. Indeed, many of these did arrive from the
West and I think there needs to be some tweak in the language to recognize
that.
Thank you.
DR. JONAS:
I just want to say there is no word originated from in this,
Tieraona.
Maybe we want to change tweak the readily available or something like
this, there is no statement in here about that they did not originate from.
DR. LOW DOG:
My comment, though, is that I think it is somewhat misleading or not
usually available.
I mean chiropractic and osteopathy are readily available, therapeutic
touch is readily available, herbal medicine is across the board in the United
States. I mean
you can buy it at any health food store or Wal Mart.
Spiritual therapy goes on in churches every day all around this country,
so I think it is a bit misleading. This comes back to the problem again about
when you are saying CAM, some of which are not supported by the dominant systems
or medical systems of Western countries.
I think that what we are really talking about is not so much availability
as the acceptance of them, and that is what leads to marginalization.
DR. JONAS:
I think availability is also part of it. I mean access is a whole section that we are
talking about, so it is certainly not one that we would take out.
We had in the original definition from the OAM, and actually, Cochrane I
think maintained it, the word "dominant" meaning the politically dominant, and I
think it was stated "politically dominant," was part of the definition, which
the committee decided we wanted to alter or remove.
Is that reasonable? I mean am I hearing that we should insert
that back in?
MR. CHAPPELL:
Dr. Gordon.
DR. GORDON:
Wayne, one of the things that might help address some of your concerns,
Tieraona, is to have more of the history and the background to give a sense of
where the different perspectives and where the different practices are coming
from.
I agree that the definition needs to alter slightly to accommodate these
concerns, but if we provide a sense of the development of some of these
modalities and how they have entered into the world and the United States, not a
huge treatise, but some background, I think that that will be helpful in helping
us understand where we are in this issue.
MR. SWYERS:
One of the main pieces here that we have talked about is doing a history
like that, and I think that will help inform some of the language in this, but I
think right now we need to focus on the major pieces, because this is kind of
different than the other sections, we are actually reviewing text, but I think
now we need to focus on the major chunks and then we will go back and we will
wordsmith this.
As we see those other pieces fall into place, it will help inform our
definition and some of our descriptions.
MR. CHAPPELL:
Go ahead.
SISTER KERR:
I would like to request, Wayne, Tieraona started speaking, I think it
might benefit us to read that definition that included the politically dominant
and why we perhaps thought it might be a yellow flashing light to the
listeners.
The other thing is, is it appropriate to point out that we have another
summary definition of CAM on page 6?
MR. CHAPPELL:
We are coming to that.
SISTER KERR:
Just because of where people strayed, thank you.
MR. CHAPPELL:
Thank you.
I would like to take as a guideline to any edits to this work, that we
simply ask ourselves whether a specific phrase or word choice, whether it needs
to be there at all.
I think if we are going to be building the case for the history and
including that, that history section will speak for itself, but when we get to
the actual description or definition of CAM, I think we have to ask whether or
not that language needs to be there at all.
In the case of the phrase "which are not usually available or supported
in most Western countries," I just don't think that needs to be there at
all.
So, that is kind of the way we can comb without asking the Commissioners
to wordsmith this from here, I am just giving us some guidelines of if there is
going to be a history section, and there will be, perhaps some of this can drop
right out and we just get the focus right to what it is we do, what is it we are
all about.
Go ahead, Joe.
DR. FINS:
Thanks, Tom.
I want to just piggyback on what Charlotte was getting to because I think
that her flashing forward to page 6 is I think relevant, because I think this
definition is more of a historical conception, and what you have on page 6,
which we will get to and I don't want to discuss now, is probably more
reflective of what we all believe.
So, I think that the reason why you have the dominant, and you were
trying to do the history and go forward at the same time. So I think if we
simply said the prevailing views from Cochrane, and the earlier reports, viewed
CAM as blah-blah-blah, because if we go to page 6, which we are not going to get
to, it is a more integrative tone. This is more dualistic and antagonistic and
defensive. So,
I think we have evolved to page 6.
This is a historical definition, and not necessarily a definition that we
are currently embracing. I think that might be my reading of how it
played out.
MR. CHAPPELL:
Thank you, Joe.
Yes, Effie.
DR. CHOW:
Just onto that statement, I think if we change the word from "usually,"
like someone suggested "readily," I think available means not only the fact that
it is available on the shelves and acupuncture is available, homeopathy is
available, and chiropractic is available, but it is available limited because of
finances, as well.
This is what I am interpreting into this. It is not readily available and supported in
most Western countries, is that it is not funded, we have to pay out of our own
pocket usually for these CAM services or products.
So, for me, I think that is important to keep that in, maybe not
"usually," you know, that word. Maybe "readily" is more suitable. Maybe we need to
say "financial" in there.
MR. CHAPPELL:
I am not accepting edits to the language. What I am accepting is what thought is
missing for you, what thought is in the way, what thought is missing for
you.
DR. CHOW:
This is what I am presenting is that the financial aspect is not apparent
in here.
MR. CHAPPELL:
Okay, financial limitations is not apparent.
DR. CHOW:
Yes.
MR. CHAPPELL:
Thank you, Effie.
Tieraona?
DR. LOW DOG:
I think Charlotte's and Joe's comments, I would just like to echo that
perhaps leading in, since this is really what you begin to read when you first
read the report, I think a non-defensive, antagonistic opening is important, I
think for the people that are reading it.
When I read it, and I am a pro-CAM person, I felt I had a lot of
disagreements with it, and I am pro. I like the definition on page 6 quite well,
and I just want to echo sort of what has been said, just for consideration when
we are looking at it.
MR. CHAPPELL:
I think we could actually open this section with the summary definition,
and I am even asking whether we should be dealing with the guiding principles
before we get to the definition, because the guiding principles really are the
orientation of the whole report.
My reflections on this are to flip the guiding principles to the very
front and then move into the description and definition of CAM, and to
everyone's concern here about the summary, in fact, I was going to open our
discussion on the summary paragraph because I think that is where the real work
becomes focused.
We could open that section with the definition and then proceed from
there. I see
some heads nodding.
Yes, Joe?
DR. FINS:
The work that I didn't see anywhere in the whole chapter was
"integrative."
In fact, the very last sentence of that paragraph, the summary
definition, is saying that the lines are getting blurrier. In fact, I think we
want to encourage that blurriness a little bit.
There may be a way of trying to say that patients, as we have said many
times, patients don't define themselves as CAM or allopathic, they are just
patients, and they are going back and forth and the lines are blurred, because
they are going back and forth.
So, I think we need to recognize that up front, and that is really the
motivation for the entire commission, that people are utilizing it, so the
inversion might be helpful.
MR. CHAPPELL:
Thank you.
DR. JONAS:
I think it is a double-edged sword. Certainly, "integrative" and encouraging the
blurriness of the definition is accurate. On the other hand, it can come back to bite
you and that suddenly there is no field called CAM.
Yesterday, I was meeting with some folks at the NIH, and they were
talking about all the CAM research they were doing, and I looked at it and I
said, boy, this is the stuff that has been going on in the intramural program at
NIH for years, but now all of a sudden it is redefined as CAM.
So, I think we have to be careful about being too integrative. We just have to be
sensitive to that, because a powerful system, the politically dominant system
can indeed swallow up and claim an area without really getting the fundamental
issues of holism, of healing, et cetera, and end up kind of focusing on
products. This
is a new way to look at the kind of products we haven't looked at before. So we have to be a
bit careful with keeping the boundaries blurry.
There are some advantages to try to at least be clear about what the core
issues are that we want to make sure are unique to complementary medicine, or at
least what complementary medicine is providing.
MR. CHAPPELL:
I would like to ask the group to go to page 6 to look at the summary
definition of CAM, and then we will work backwards from there.
Go ahead, Joe.
DR. FINS:
I take Wayne's point seriously. I think perhaps a diagram right here, Figure
1, might be a Ven diagram, which shows that there are polarities, there are
elements of allopathic and CAM medicine which do not overlap, but there is an
area in between that does. Very simple; everybody would understand
that.
That would also show that we are trying to create in integration while
maintaining the differences that are instrumental and valuable to our health
care system.
DR. JONAS:
I like the idea that one of our goals is to properly integrate, and that
puts this kind of blurriness into a positive perspective, I think, a proactive
perspective.
So I would like to have that term in there.
MR. CHAPPELL:
Thank you.
Let's look at the summary definition. I will just ask whether there are any
thoughts that are missing there for you or thoughts that are simply not stating
it as you understand it.
Dean?
DR. ORNISH:
This may fall into your definition of wordsmithing language except that I
think that this particular paragraph, of course, is crucial to the entire
document because it is really defining what the rest of the document is
about.
When we say that it is other than those intrinsic to mainstream health
care, I just want to emphasize that we start by marginalizing ourselves. I think that what I
would like to see as a common theme throughout the document is something that we
really take the middle ground that says that it marginalizes people who are
going to criticize the report.
For example, in our report, what we talk about later, to say that CAM
research should be held to the same standards as non-CAM research, no higher, no
lower. Well,
that is kind of hard to argue with. Then, you force people to say no, it should
be held to a different standard, and that marginalizes their argument.
Here, we are in effect, marginalizing ourselves literally by the
definition of saying that is outside the mainstream, when I think one of the
reasons that the Commission was formed in the first place was Eisenberg's, and
other's, research, talking about how it really in many ways is mainstream.
So, I think those words have such different connotations that we should
choose them carefully, and if there is some way that we can say even in the
definition that this is something, it is not a question of should people be
using this marginalized stuff, but rather they already are in some way even more
so than conventional medicine, and therefore, that is why these are worth
looking at.
That, to me, is what is missing here.
MR. CHAPPELL:
Thank you.
Joe?
DR. FINS:
Along those lines, it is really a means and ends kind of argument. You know,
allopathic medicine, primary care, general primary internal medicine, family
practice might have the same ends, but a different means to the same ends. So, that might be a
way of overcoming this sort of dualistic or dichotomous language that sets up a
false antagonism between the goals of the holistic CAM provider and the holistic
allopathic provider or modality.
This is an aspirational model that applies to different vehicles to
achieve the same end.
MR. CHAPPELL:
Yes, Dr. Gordon.
DR. GORDON:
This is really just procedural. I think that the more that the facilitators,
as the discussion kind of comes to a natural end about a particular issue, the
more you can sum up what you have heard and where you see things going, the
easier it will make it for us to move along, so I am just giving that back to
you.
MR. CHAPPELL:
Thank you.
Joe?
DR. PIZZORNO:
I think one of the challenges we are facing here is a historic
perspective where this clearly was way outside the mainstream, and now a more
moderate perspective where there is definitely some overlap and some mutual
appreciation.
So, I think maybe if we put some historic language in here just for some
of the separations, it will help clarify this, because clearly, this did come
from outside the conventional academic institution, federally-funded system that
has dominated health care in this country for so long.
MR. CHAPPELL:
Great.
Thank you.
Tieraona?
DR. LOW DOG:
I am going to raise it now because it is going to come up again and
again, but when we talk about the major CAM systems, we have never identified
the major CAM systems. We listed a whole bunch of systems, but we
didn't say these are the major CAM systems, and when we refer in this document
to major CAM systems, this is what we are referring to.
DR. JONAS:
Do you want to list them?
DR. LOW DOG:
Well, that is my problem.
DR. JONAS:
It is our problem, too.
DR. LOW DOG:
I think if we are going to use the phrase, though, my first question
would be, if I didn't know much about this and I am somebody reading this in
Congress, I would say, well, what are they; what are the major CAM systems; what
are you talking about.
DR. JONAS:
You can list some of them very easily, Ayurvedic, et cetera, et
cetera.
DR. LOW DOG:
Just put them down there then.
DR. JONAS:
But the problem with listing them, as you know, is that some are not
listed.
DR. LOW DOG:
I think we are going to have to deal with it, though. If you are going to
use it as the major CAM systems, then you are going to build all these systems,
have X, Y, and Z, and they do X, Y, and Z, and they are this, you have to define
them. Whether
it is difficult or not, if we are going to use the phrase, it is going to have
to be defined, because we build an awful lot upon it.
MR. CHAPPELL:
I am hearing a lot of comments that are addressing the history of the CAM
movement and how that has begun very much in polarity with the Western culture,
and yet how that has come to an integrative state in many different modalities
today, that there are some that are still not as well accepted or incorporated,
but there are some that are very much in the integrative reality in this
country.
So, I think if we add history and evolution as notions in our definition,
those will help bring about this kind of where we are today and it gets at what
it is. I think
this is the struggle with this definition, what is CAM.
I don't mean to belittle all the work that has been done. It is just to say
what it is now can be achieved if we offer the historical perspective in the
drafting, the evolution to date of specific practices.
Then, quite frankly, we can't describe this unless we are addressing the
world view, the very different perspective that we have. This is why I feel
that the guiding principles will serve the definition better if they come before
the definition, because it helps the reader get oriented to the fact that we are
not a group just about illness, we are about illness and wellness. That very
difference has set up apart.
So, I would encourage us to flip the order, help us throughout the
drafting get clearer on history, evolution, how certain practices have moved
from polarities to integration, and then really focusing on what this is.
Those would be my thoughts, Jim, in trying to help identify what I am
hearing.
DR. GORDON:
What I was going to say is, it might be helpful if we had a sense that
what Dean and Joe in particular were talking about, about focusing on aspiration
rather than opposition, if there were some kind of commonality among all of us
about that at this point.
I am saying that partly because I agree that I think that that is more
important and that the definition is going to be crucial, so we need to be in
tone, as well as in the specific words.
MR. CHAPPELL:
Good.
Thank you.
DR. FINS:
Following on what Tom said, I think it is very helpful, but just to put
it into a philosophical context, it is very Hegelian. There is antithesis
and a new synthesis.
That is part of how this has happened. There has been a reaction to, and a moving
towards, which is an integrative model.
There are some things that are clearly not intentioned, and are in
parallel. So,
I think there are really two ways that we got to CAM, and the other thing, Tom,
you said what CAM is, but it is also is and becoming, whatever this new thing
is.
So, it is a moving target, and I think we have to acknowledge that the
very fact of producing this document changes a lot of definitions. So, it is an
evolutionary phenomenon and I don't think we want to be static, and I think it
is very much an evolutionary framework.
MR. CHAPPELL:
Thank you, Joe. Yes, Dean.
DR. ORNISH:
Again, I won't belabor this point, but particularly at the very beginning
of the document, to the degree that it is read as a criticism, it is harder,
people stop listening.
When we talk about systematic and consistent suppression of CAM
professions, et cetera, I mean that just immediately polarizes people and to a
degree that I think is really counterproductive, if there is some way we could
find a different way to express that.
MR. CHAPPELL:
Yes, Tieraona.
DR. LOW DOG:
But I think it is important that it is included in the document, because
it gives the context to where we are today, so I think that it needs to go into
the historical section.
So, my comments would be that I like the guiding principles, that we
start with those.
They are very positive, and when you read them, I think we are going to
have very little disagreement over them. I think they are powerful. This is who we are,
this is the commission, this was our charge, these were our guiding principles,
and then we go into it.
You could put the summary of CAM, and then you could give a historical
context. I
don't think it has to be antagonistic, I think that it can be factual, and it
also gives place to how science did bring about very positive changes, as well,
but how things through a number of reasons happened and that some of these are
considered mainstream and some are not.
I think it is important in the document to have a historical context of
how we are, but I think when that is what you open with and that is what you
read to begin with, it just is hard to read.
DR. ORNISH:
When you talk about systematic suppression, those are strong words, I
mean really.
MR. CHAPPELL:
Can we hear from Jim for a moment, please. Jim.
MR. SWYERS:
I think what Tieraona is saying makes sense. I had not
envisioned putting the guiding principles in the introduction of the report, but
I think that might be a better place for them than here. I like the way she
laid it out.
DR. YOUNG:
Great.
Joe.
DR. PIZZORNO:
I have some mixed feelings here. On the one hand, I agree with you, we don't
want to be antagonistic, but on the other hand, we have to talk about the
historic reality.
The historic reality is that the AMA lost an antitrust lawsuit that
documented the systematic suppression, and right now, today, the state medical
associations are blocking the licensure of other of the CAM professions in
states all across this country, so it is happening today.
I don't want to be antagonistic, but let's not pretend that this is not
happening.
MR. CHAPPELL:
I think these matters can be handled just as we have been speaking. First of all, we
open the section with the guiding principles, i.e., world view. Next, we have a
description of the history of this as we have been describing it, although we
might open that section with the summary definition, but either the summary
definition at that point or following, but I think we can craft this with a
different structure and a better focus.
So, I think all these comments are helpful. I am running out of
time on my section.
I am just going to take your comments here as ways to address more
specifically the sections of the CAM material on pages 1 through 6, which are
very well identified I think, but we will work on the order of presentation and
the tonality without forsaking any kind of accuracy in the history.
MS. CHANG:
Tom, just so you know, you have got about 10 minutes for this part of
it.
MR. CHAPPELL:
Well, but according to what was handed out here, I had only 20 minutes,
and I have been 30 minutes so far.
MS. CHANG:
I think you have pretty much put the two together, the description of CAM
and the summary definition of CAM. So I have given you 40 minutes for that. So, you have about
10 minutes before Wayne's part.
MR. CHAPPELL:
Okay.
Joe.
DR. FINS:
On the point here of showing how we are moving towards integration, I
think a nice example, which I would like to see sprinkled throughout the report,
is the role of hospice as a meeting ground for the allopathic and the CAM.
In other words, if we are looking at this evolution and this new
synergism that is evolving, that is a nice part of the middle of the Ven diagram
is really end of life care and the hospice movement when you are using therapy,
you can get massage, you can get morphine, you can get a PCA pump, you can get
radiation. I
mean there is a lot of things.
So, I think that is an example of how people are kind of coming together
in that aspirational model, like on page 5, in that area, we are talking about
spirituality.
MR. CHAPPELL:
Thank you, Joe. Effie, and then I will take a few minutes
just to look at the section.
DR. JONAS:
Go ahead.
I just want to mention one thing related to what Joe and Dean have
said.
MR. CHAPPELL:
Why don't you go ahead, then, and then we will go to Effie.
DR. JONAS:
I have a suggestion. I like the idea of a Ven diagram. It is a moving
target, there is a spectrum of CAM all the way from things that are clearly
antagonistic and outside of mainstream, all the way to things that it is hard to
tell the difference, and, in fact, there is no difference.
I would just like to suggest we introduce something like the Ven diagram
illustrating the spectrum and illustrating that it is dynamic, that, in fact, it
is changing, that there are things that used to be very much outside and that
are now much closer, there are things that are emerging, there are things that
are completely overlapping, and that one of our goals is to really move these
things closer and closer together to have a common understanding and get them
into the health care system when they are safe and effective.
I think the idea of a spectrum, especially a dynamic spectrum, which we
could then illustrate with a figure, might be a very useful way of doing this,
and also illustrating I think, as Dean and others have mentioned, a little more
emphasis on the fact that these are being used and that they are actually, at
least for the public, already part of the mainstream, which I think needs to be
very clear and perhaps up front.
MR. CHAPPELL:
Effie, and then Dean, then Joe.
DR. CHOW:
I also like the spectrum and diagram aspect, too. I hope the history
will go back to reporting on the times in the 70s when people were being jailed,
acupuncturists were being jailed, and so it shows the evolution, homeopathists
were being jailed and Christopher Hill, the holistic practitioner, was being
jailed, and how we have to help them get out of jail, and so forth, to now that
acupuncture is being funded, and then the integration like the model that Joe
gave, the total integration. So it does give the history of the
difficulties that it has come through.
I think we have to remember always, because I think a lot of comment of
fear and antagonism is because we think that the Commission Report is coming
from us as Commissioners, but we are really speaking for the people, and I think
we have to keep that in mind and that we must speak for the people that have
spoken so forthright about the prosecution that is still going on.
I think it is our duty to speak to those aspects without talking about
antagonism from our standpoint, but from the fact that we have heard this from
the people, and we must represent the people from both ends, from the
traditionalists, who want to integrate and don't know how to integrate, and from
the people who have been trying to practice and have been indicted, and still
find great difficulty.
So, if we keep remembering that we are speaking for the people, and this
document isn't from us only as Commissioners, perhaps that might help us from
being fearful of speaking what is the truth right now.
MR. CHAPPELL:
Thank you, Effie.
Dean.
DR. ORNISH:
For me, it is not an issue of being fearful, it is an issue of being what
I think is being accurate, and I have I guess what really amounts to a process
question, which is, I have pretty strong feelings about this language, "the
marginalization of CAM results into the systematic and consistent suppression of
CAM professions, institutions, and practitioners by mainstream health care
professions through a variety of political, institutional, and economic
means."
That is such inflammatory language, and I don't agree with it. I mean, there are
certainly examples, as Joe Pizzorno has pointed out, and we will agree to, I
have certainly had my own experiences, but in terms of making it so sweeping,
systematic, consistent, I don't agree with that.
So the question is, if one or more Commissioners has a minority point of
view that he feels strongly about it, I am not quite sure what the process is at
this point.
MR. CHAPPELL:
Dr. Gordon, would you comment on that?
DR. GORDON:
My perspective is, I agree with both sides. I think there has
been some systematic oppression, but I think that it can be dealt with in a way
without making it inflammatory. I think there is some truth in the history,
that is part of the historical segment, and I would really hope that as we move
ahead, we can find common ground.
I mean, I think this is really our effort here throughout these three
days, and as we have ahead, is to see if there is a way that we can come
together, not to serve us, but it is going to serve the public far better if we
can come to a shared perspective.
So, we may need to come back to this at some later time to understand
what each of us means in each of the sides, and then give it back to Tom and
Wayne and the group, and ask them to come up with a way of talking about it that
makes sense to all of us.
So, that is what I am hoping for rather than a minority perspective.
DR. ORNISH:
I am leaning towards something that says we recognize that at times there
have been examples of suppression, et cetera, et cetera. We are encouraged
that there seems to be a growing movement and commonality of purpose, something
that puts it in that kind of perspective, as opposed to the way it currently
reads.
MR. CHAPPELL:
I would support that as well, Dean.
Joe, and then Joe.
DR. PIZZORNO:
I want to be very clear that I agree with the intent that Jim and Dean
just stated.
We should say this in the least antagonistic way and the most
facilitating cooperation and collaboration way that we can, and we cannot leave
out the historic reality that CAM practitioners and institutions have had to
deal with.
My teachers were taken out in handcuffs in front of their patients for
practicing what is now becoming popular. So, this is what happened.
MR. CHAPPELL:
I think what I am hearing is that there is a need to structure this
historical section in terms of where we have been, where we are now, and then
where we are trying to go. Those are the three frames of time that I
think might help this moving target, this evolutionary aspect of CAM.
That way, you are able to honor the realities of the historical ugliness
of this. That
is just documentation, it is not orientation of language or attitude. You can talk then
about where we are now, Jim. I think we can do where we have been, where
we are, and where we need to go as this kind of evolutionary issue.
That is what is making this whole task so difficult for us all, because
we can't get into the same time frame together to have a dialogue, and unless
you do break it down that way, we can't reach agreement, and I think that is one
way to do it, that there is a historical reality, there is a real flux of where
we are now, and there is a real hope of where we need to go on this.
I am going to encourage that kind of frame to the historical piece. That will allow us
to be much more specific about what CAM is and how it relates to the aspirations
and orientation of the Commissioners, because we have a world view that has
shifted from the historical perspective here.
That is how I am offering up these combinations of suggestions. I am almost out of
time, and, Joe, I know wants to say something.
DR. FINS:
I want to echo what you said, I completely agree with that historical
evolution, but I also want to say that this Ven diagram concept can also be
utilized as a political picture, because the more overlap there is, the more
consensus there is, and consensus is really what we are after.
So, maybe we need two pictures. We have the Ven diagram from 30 years ago,
like this, and we show the convergence, not the complete overlap but that there
is an evolution.
There wasn't consensus to even have a commission like this 10 or 15 years
ago. There is
now. There is
a political balance.
The bigger that overlap can be, the more attraction this will have
politically, because we have all agreed to that overlap.
MR. CHAPPELL:
Great.
Charlotte.
SISTER KERR:
I just wanted to say, and it is congruent with what has been said in your
summarizations, but for myself, I would like to speak that the spirit of this
chapter for me was that it was to be an invitation to the reader to listen to
the story about the evolution of healing in America. This is why these
points Dean and Joe, and all, are making, when you talk to someone, you invite
them to listen.
You have to, I believe, start with a conceptual framework, the overview
that I think that people want to hear, the world view piece that we don't have
yet. The
history, you don't start off with, which has been acknowledged, the
marginalization, that kind of conversation at the beginning.
This is just a point I have, and I don't know what will happen when we
get to reading the overview, conceptualization, or the world view part, how
congruent are we as a commission, still. My own feeling is when we get to that, we may
have some discussion we didn't expect, and that will affect, of course, this
whole chapter.
Thank you.
MR. CHAPPELL:
Thank you, Charlotte.
Dr. Gordon.
DR. GORDON:
I just wanted to make a procedural point that as we go through the day,
it is important that the order that is here is not necessarily the order of the
report, and that is still to be determined.
So, in this section, marginalization, just for an example, could be very
much fitted into a history section that could be further down in the list. Just because
something is at the top now, doesn't mean it stays at the top. That is really up
to all of us, and to the workgroups in particular.
MR. CHAPPELL:
I want to thank the commissioners for each of your contributions. This is very, very
helpful. I
think you have given us very good guidance, and I think we can accomplish what I
hear many of us asking.
DR. JONAS:
Are we ready to talk about principles? Let's turn to page 6, Guiding Principles of
the Commission.
These actually are taken directly from those 10 principles that were
initially put up on the flip charts that the different groups came up with and
then were kind of put together.
There has been an attempt to simplify them. The initial ones,
some of them had quite a number of words in them that were overlapping, so this
version is an attempt to kind of bring some of those overlapping things together
into a single set, and also to put a label on them, which certainly all of this
is open to change, but a descriptor that kind of encapsulates what that
"principle" is, because if you have an entire paragraph, you have to look at the
entire paragraph to say, well, what is this about; what is the meaning
about.
So that, the bold terms are really terms to try to help you identify what
the core issue is.
It may be that we want to make that several words or several phrases, or
something like that, without making it too long, so that then one can't get the
gist of it.
In some ways, we have been preempted by the Institute of Medicine,
because many of the principles, not all of them, and I think this is an
important area for discussion, have been outlined in the 10 principles and core
values of the National Academy of Sciences' report on the way to improve health
care in the 21st Century. That is on page 8, "Crossing the Quality
Chasm."
Does anybody know, has this been published? Is it is officially
out and sanctioned, and this type of thing? Because I think before, it was not officially
out.
So, here are core 10 beliefs. I have marked the first five as being almost
exactly parallel with many of the core principles that we have in ours. Some of the others
deal with health system management, which this is largely about, so I think we
are really in congruence with some of the mainstream thinking that is going on
in terms of what is needed in the health care system.
I like that.
I would like to make sure to emphasize that bond, and it may be that the
wording of these principles are such that we can make it clearer that we are
congruent with those.
So, that is one item I think that needs to be discussed.
The second item is, these are not in priority order, and I think it is
important that we figure out, is there a priority to these and, if so, what do
we want to have up front, and not.
MR. CHAPPELL:
Thank you.
I actually would like to begin with the opening paragraph of this
section. I do
think, knowing that this will probably come at the beginning of the document
now, that we need to address this shifting paradigm or shifting world view from
preoccupation with illness to one that is concerned with both illness and
wellness and that CAM is very much the promotor of health.
I would like to see this paragraph identify the part that we play in
helping to promote this shift in world view or paradigm from a focus on illness
to a focus on illness and wellness.
It doesn't occur anywhere, yet we speak about it all the time in these
meetings, and this would be in the introductory paragraph of whether we call
them guiding principles or whatever, this really helps set up that shift.
We can do that apolitically and very positively by referring to a
shifting paradigm of health orientation.
Go ahead.
DR. JONAS:
Yes, I agree with that. In many ways I think the summary definition,
which I personally think ought to be up front, I think when you are starting
something, you ought to have at least some kind of definition up front and then
go to the guiding principles, but they all should be crammed in as close to the
front as you can.
Actually, I think we have some wording in there about the world view of
shifting more towards wellness and health promotion, so I like that. I think maybe we
should make sure that is in the principles.
Joe, and then Linnea.
DR. FINS:
I just want to say, though, that there really are parallel tracks here
and I wish Dean were here, but the Framingham study and cholesterol management
and Healthy People 2000 and 2010, the United States Public Health Service and
the great work that they do, we are doing a lot of the same things in parallel,
so again, to overcome the dichotomous world view.
One vector ended up being coronary bypass grafts, another vector was Dean
Ornish's work.
They both have similar origins and different vehicles to achieve
promotion of cardiovascular health. So, I think that that is one thing.
The other point, if I could put a hierarchical thing in first, I think
the partnership is probably something we want to maybe highlight in a rank order
as being so important, because partnership enables all the other things.
DR. JONAS:
Let's not get into prioritization yet because that is an area that I
think we should discuss. Just other general comments about the
principles, and then I think we actually have time to go through the principles
and then say, all right, then, which ones do you want first and are there some
wording changes that you would like, unlike the wordsmithing of the definitions,
I would like to see some wordsmithings on these preparations.
Does that sound like a reasonable approach, should we do that? Yes.
MS. LARSON:
This is to the comment of the similarity between some of the principles
and the core beliefs, core beliefs of Crossing the Quality Chasm. We might want to
actually highlight that and be saying this is noteworthy that two independent
bodies came up with very similar core principles, beliefs, and then to actually
detail how they are.
You made a statement, Wayne, the first five, so then we write here is the
correspondence, and I think it is important to say these are two independent
bodies that came up with these at similar times, but with no overlap.
DR. JONAS:
So, make the link more clear.
MS. LARSON:
Make the link more clear. Also, I have a technical question. I have no idea
about what "safety is a system of property" means.
DR. JONAS:
Actually, that relates I think directly to complementary issues because,
in general, many CAM practices are inherently more safe than more aggressive
types of approaches, so it is a system, it is a property of the system of many
CAM practices, I think if you were make an analogy of that or make an example of
that.
I think CAM is an example of systems in which safety is more inherent
than some other types of more aggressive practices, but I am not sure if that is
what they meant.
Shall we go through the principles? I think we should do that, again realizing
that the initial phrase, we might want to make it clearer like instead of just
saying "evidence," saying "the importance of evidence," or a small phrase to
kind of capture that.
DR. GORDON:
Wayne, that is fine. If there are other issues, though, that you
want to cover here, or anyone else wants to cover, we need to leave some time
for those, as well, in your section.
DR. JONAS:
Well, there was nothing on my section, but there may be some other things
earlier than this that people want to talk about.
DR. GORDON:
If you want to spend some time on these and then leave at least 10
minutes at the end, and maybe Michele can give you a signal, and if there are
other issues that people have, they can raise those issues and we can talk about
them before we come to see where we are at the end.
DR. JONAS:
Who is going to signal me?
MS. CHANG:
The problem is when you have approximately 12 minutes for just the
guiding principles, and then you have got five minutes each for mission
statement and historical context. So, how you want to manage that is up to
you.
DR. JONAS:
Jim, are you referring to other issues besides those?
DR. GORDON:
If there are any other issues besides the ones you have listed here.
DR. JONAS:
How much time do I have for the guiding principles?
MS. CHANG:
You have about 12 minutes left.
DR. JONAS:
When I have 10 minutes left, let me know, and we will go to other
issues.
MR. SWYERS:
Since we have already dealt with historical context, we could probably go
into that at that time.
DR. JONAS:
Let me make a suggestion. Rather than now going through and
wordsmithing each one, which I think maybe would be a secondary thing, I think
we should talk about priorities and links, so how about if I open that up. I think Joe had
already mentioned that, one, partnerships was important.
Is there a particular order, are there particular principles that you
think should go up front?
DR. FINS: Crossing the Quality Chasm in the
earlier IOM report about quality and safety was about systems, so there may be a
segue there between systems of care and partnerships. You can't have a
system without partnerships and dialogue and communication, so that might be an
umbrella under which everything else follows just logically.
DR. GORDON:
The issue that seems important to me is that it be very focused on
people, on individual people and on sort of the community of people rather than
from a professional perspective.
I think if we focus on issues like wholeness at the beginning, and if
when it comes to partnership, part of that partnership is also the partnership
between ordinary people, whom we call patients, and people who are
professionals.
For me, that is the strongest feeling that needs to be there. I am not
deprecating any of the other pieces, but I feel that that is our up front
representation that needs to be in that area.
DR. JONAS:
We have got two votes for partnerships, one for wholeness.
MS. SCOTT:
I do support what Jim is saying. For me, I think the bolded words are not
resonating with me.
Wholeness was one word I had down, safety, wellness, equity, and it may
be embodied in all of this, so I would just like to keep open the idea that we
would not necessarily stick with these bolded words, because they don't bring
that wholeness, people perspective.
DR. JONAS:
Right.
So, taking the bolded phrases and making them more phrases similar to in
the IOM report, which gives a little bit more meaning to it without doing a
whole paragraph.
MS. SCOTT:
Right now that is what I am feeling.
SISTER KERR:
I would just like to point out, and I have brought this up many times
over the last months, and as a group, I would like us to decide what we would
like to do.
Under Health and Healing, we often have statements throughout the report
that we have been working on, interim included, when it started, you see the
line that says, "The body has remarkable capacity," do we want to, as a group,
state things like the body-mind has a remarkable capacity for healing? Do we believe that
as a group?
We say, when we start with wholeness, as Jim is pointing out is a good
place to start, we talk about body-mind-spirit, environment da-da-da, but I
think today, we should decide, so that when we read the report, all the time we
are consistent.
Do we want to say body-mind-spirit, do we want to say body-mind, and
assume that includes spirit, and do we not want to do it?
Thank you.
So, what do we want to do?
DR. JONAS:
Well, I know what you want to do. I agree, I think we should put in
body-mind-spirit actually.
Joe.
DR. PIZZORNO:
I would like to second what Jim suggested, as well as what Charlotte
suggested. I
like the idea of the first principles being those which emphasize the philosophy
of healing and wholeness. Charlotte, thank you very much for the
body-mind-spirit language. I think that is wonderful. We should use that
consistently.
DR. JONAS:
So, is that a vote for health and healing being somewhere towards the
front?
DR. PIZZORNO:
Absolutely, wholeness, health, and healing right there at the front. That is what this
is about. A
little bit of wordsmithing on the principles, after "Practitioners," I would add
to words, "disciplines, institutions."
DR. JONAS:
Where are we?
DR. PIZZORNO:
Under "Partnerships," right after "Practitioners, complementary
practitioners," add "disciplines, institutions."
DR. JONAS:
"Disciplines, institutions." Okay.
DR. PIZZORNO:
It would just be more comprehensive in how we are stating this.
DR. JONAS:
Okay.
Other comments?
DR. FINS:
I worry about it getting a little too fuzzy and a little too -- I mean I
agree with it in principle as something that informs my own work as a physician,
but I think that it can be misunderstood, it can antagonize people. Secular science
might be antagonized by notions of spirit in this context.
So, I think we need to be very careful. Maybe Dean can help me here, but I think it
is his red flag land mine comment.
DR. ORNISH:
I wasn't called on.
DR. JONAS:
You are called on.
DR. ORNISH:
Thank you.
I think all of us certainly agree with the idea. Maybe if we could
have somewhere in here, just like you defined earlier on that CAM -- there is
some footnote here -- basically, you are saying, like on page 6, complementary
and alternative and integrative are kind of synonymous. Maybe we could say
somewhere that when we say "body," as a general principle, we are talking about
the larger issues that encompass the psychosocial, the emotional, and spiritual
dimensions.
I personally think that language sounds better than body-mind-spirit, and
that when we talk about the body, you know, throughout the document, we are not
limiting it to that, but that every time you say it, just like you don't say he
or she, even though you might say when we say he, we really mean all
genders. It
just becomes clumsy and awkward to have to actually say that every time you
mention the word "body."
MR. SWYERS:
So, you are suggesting a footnote.
DR. ORNISH:
Well, just something that says, early on, that as one of the overall
principles, that we are talking about incorporating the psychosocial, the
emotional, the spiritual dimensions, and that later in the document, when we
make reference to the term "body," it is really in that larger context. And leave it at
that. I don't
think you have to say it every time.
SISTER KERR:
I think I would understand what is being said. I think "body-mind"
has become more the generic term that includes the body-mind-spirit environment.
If you are going to footnote something, I mean, this could get deep here in
terms of issues of he/she, et cetera, and gender.
I think maybe I would eliminate it all and put "spirit" if I wanted to
make a point, but since I am trying not to be too radical here, I think the
body-mind footnote is a common use.
DR. FINS:
Another possibility is to give it the importance that it is due and put
it in the historical section as a major element of what has motivated CAM in
contrast to the secular, scientific, allopathic approach. We don't want to
give it short shrift, but we also don't want it to be pervasively antagonistic
that people would find it offensive.
DR. JONAS:
I think that is an excellent point.
MS. CHANG:
Wayne, you have about 10 minutes.
DR. LOW DOG:
I thought if we put something like wholeness at the beginning, I also am
in favor of that, and it says, "Health involves all aspects of life, mind, body,
spirit, relationships, environment," and if that is our opening statement, I
think that is a powerful one to begin with, and I agree, too, that if you start
reading mind, body, spirit throughout, that it also loses its power when it is
used like that, but I think that that is an important one to open with, because
I think it truly does reflect healing on all kinds of levels.
DR. JONAS:
So, another vote for wholeness being up front, right, and healing, I
think also partnerships, and I think relationships is a word that is not too up
front out here, but is inherent, and we maybe want to make it more up front is
another thing that I heard. It is up front in the IOM report.
MR. CHAPPELL:
I do think we need to, as we order the priorities here, these priorities
need to come from the true perspective of where we are as a CAM community, and
not trying to tailor a document for a particular reader.
This is the most powerful presentation we can make in this section as a
group of commissioners because this is saying what we believe, what are the core
values, and I look at something like evidence, and I agree that that needs to be
certainly in the first half of the group, but I don't think that it needs to be
first just because we are trying to speak to an audience that is trying to
dismiss us.
Therefore, I think we need to be true to ourselves on this, be strategic
in the way we use some of these other principles like evidence, but I don't want
to see us dilute our power. So, I am agreeing with the idea of wholeness
and health and healing, partnerships, prevention. I mean, my goodness, that is what we are
about.
DR. JONAS:
Comments on evidence?
DR. WARREN:
Well, I am looking at what does a holistic practice really entail, and
your guiding principles is part of every bit of it. What is utmost in
this whole thing is health and healing and wholeness for the patient. Those are the first
two.
I like wholeness first because it defines life, it defines mind, it
defines body, and it helps define what health and healing is. So, I would say
wholeness one, health and healing No. 2. No. 3 is every single person that walks into
our office is an individual. I think No. 3 ought to be an individual.
No. 4, every individual has choices. No. 5, every individual is educated and needs
empowerment.
No. 6, I think prevention. No. 7, the public involvement in the
prevention through education and empowerment. No. 8, dissemination of that information.
No. 9, then, you get to evidence, and No. 10, you get to the
partnerships.
DR. JONAS:
I am going to take two very short comments, and that's it.
Joe.
DR. FINS:
I think there is a confusion here between principles and process. Health and healing,
wholeness, individuality, I think are principles. Process is evidence, dissemination,
partnership, in other words, so we are talking about two different categories of
things here.
MR. CHAPPELL:
No, we are not. No, we are not. I am just going to
intervene here.
We are talking about what we deeply believe in as a group of people, and
that is why we scripted this group. That is why we put this group, and then we
started calling them something else. These are our core values. This is what we
believe in.
DR. FINS: Right, we believe in all of this, these are
all principle beliefs.
MR. CHAPPELL:
Right, we do believe in all of that.
DR. FINS:
What I am saying, though, is that, for example, evidence is a way of
achieving health, healing, wholeness, and individuality. Using that, but
evidence, in and of itself, is a subset of those more transcended
principles.
MR. CHAPPELL:
I don't agree with that.
DR. JONAS:
Tieraona asked one, and then I am going to ask everybody to do what
George just did, but I want you to write it down, and we are going to actually
see kind of what we come up with.
Go ahead.
DR. LOW DOG:
That is kind of where I was at. I just wanted to, before we do that, I like
the first four, but I think evidence then drives a lot of -- to have education,
to have dissemination of that education, to have all of that, you have to have
some evidence for what you are talking about.
I would have ranked it a little bit higher up, but probably No. 5, and
then driving it on the rest. I agree, I think that as a provider of
healing, as somebody that works in that field, I think most of us are driven
pretty much by seeing our patients as being whole, and their freedom of choice
and their individuality, but I would rank evidence higher. I would have put it
up around No. 5.
DR. JONAS:
One of the things I hear is that it would be nice to kind of link some of
these, so that you can see how one follows, and what you mentioned, certainly
individuality and the importance of choice, and this type of thing, that that
could probably be done better throughout here after we get kind of our
priorities established is to try to link those.
Dean, last comment.
DR. ORNISH:
Real quick.
I mean, even under "evidence," I think if we could put something in
there, instead of just saying that it will enhance the development and delivery
of these services and products, something that turn out to be scientifically
valid, the way it reads now is like we want to get evidence to do things that we
want to do as opposed to looking at evidence to see which things are worth
doing, and I think that is a really critical thing that anyone is going to pick
up on as a bias of the Commission if we don't change that.
DR. JONAS:
I would have some wording issues on that because I do not word that in
that statement.
I see help to identify, in other words, you use scientific evidence
actually to find what is safe and effective. I mean that is how I read that.
DR. ORNISH:
Well, apparently other people share this, too, so if you could just put
something at the end, something along the lines that those that turn out to
have, those that are scientifically based, those that have evidence to support
them as opposed to --
DR. FINS:
The phrase "generating evidence" in the sense that you are fabricating
evidence.
DR. ORNISH:
That is important actually. You are trying to come up with evidence to
prove what you think you already know as opposed to trying to search for
truth.
DR. JONAS:
Okay.
So, wording on that, so that it makes it a little bit stronger in terms
of -- yes.
DR. GORDON:
I think one thing that would be helpful, and I know you want to get
specific words, but it may be helpful in this period of time to get some of the
principles flushed out, just as we are doing with evidence for all of the
different categories, and then the point that you make about linking them, I
think seems crucial to everyone.
I think the more we can contribute to expanding and focusing what we
mean, just the way Dean and Joe were doing with you, on each of these, the
better.
DR. JONAS:
How much time do I have?
MS. CHANG:
Just a few more minutes before you need to finish up with mission.
DR. FINS:
May I make a parliamentary question here? I am just wondering, I think we are reaching
consensus on this.
I don't know what the utility is of a half-hour for Jim to do what these
guys seem to be doing already. If we could maybe get more time for them to
finish up.
DR. GORDON:
I think on this one we can, because I feel like I have a pretty good
order, so I would like to give them 15 more minutes and just take 15 at the
end.
DR. FINS:
Thank you, Mr. Chairman.
MR. SWYERS:
Yes, I think it would be helpful at the end if we can summarize just for
my purposes to try to figure out where to go from here.
DR. JONAS:
So, we have 15 minutes, we have been reprieved. Breathe.
George.
DR. BERNIER:
I would like to cast my vote for the inclusion of evidence as one of the
very strong parts of our outcome. It is I think something which is more and
more being looked for and being utilized.
DR. JONAS:
Another vote for evidence, and so, as has already been mentioned, a
rewording of it to make it clearer that we are really trying to separate the
wheat from the chaff, if you will.
Joe.
DR. PIZZORNO:
I fully agree with the comments that Dean and George stated, and maybe
something along the lines of we perform the research to provide evidence to
enhance the development of these healing arts to make them more effective and
safe. I think
that is both issues, the safety and efficacy.
I don't know how you put in language to say, remove things that don't
work, but it would be nice if we have some kind of language like that.
DR. JONAS:
I think you can say it.
DR. FINS:
I think safety should be one of the bullets, which somehow is not
here. We are
going to talk a lot about adverse event monitoring and the OIG report, to be
consistent, we need to do that.
DR. JONAS: You are proposing another principle?
DR. FINS:
I might be, if it is not here.
DR. JONAS:
So more emphasis on safety.
DR. FINS:
Well, it is a subset of evidence, but evidence means something else, so I
don't think I am proposing something that we haven't agreed upon.
MR. CHAPPELL:
I think, Joe, what we need to do is move from the single word "evidence"
to the phrase "evidence of safety and efficacy."
DR. FINS:
Yes, evidence of safety and efficacy.
MR. CHAPPELL:
That is where your phrase can be more helpful than the single word.
DR. FINS:
The other point which I think might be very helpful, and it gets back to
the point that Tom completely disagreed with, but I know we fundamentally agree,
is in a paragraph here, we set out those over-reaching points that are embedded
in these other principles, again, health, healing, wholeness, and individuality
as the core issues.
Then, maybe we just do it alphabetically, in other words, because I think
we could really split a lot of hairs, and if we say it is alphabetical, which we
believe they all are very important, because I think that some of us feel very
strongly about evidence, others are going to feel very strongly about
choice. This
might be a way of reaching a Solomonic compromise without spending a lot of
time, and then it's all there, we apprise all of these points.
So, I just put that out as a possible hedge to compromise.
DR. JONAS:
Thank you.
Jim.
DR. GORDON:
I think that is one way to do it, but I kind of like the idea of trying
to pull it together in a coherent way, so that each of these 10 flow into each
other. I
understand the notion of compromise, but I think it becomes a much stronger
statement if it is done narratively that way.
DR. JONAS:
Ming.
DR. TIAN:
I have a suggestion. I think a good idea was using efficacy and
safety for the first one. I still prefer we put that the first, because
I believe that CAM is a medicine. If it is a medicine, you have to answer the
first question, efficacy and the safety.
The other principles are important, but again, if there is no efficacy,
there is no safety, you are not talking about a medicine. I think all the 10
principles are very important, but I prefer this will be the first.
Thank you.
DR. LOW DOG:
I just think that evidence needs to rank high up there. I just think that
healing is something much more than that. I think that healing, I mean the "who," I
think did a good job, sort of it is the active integration of our minds, bodies,
spirits, and social beings, and that that is really what healing is all
about.
That, I think is true whether you are talking mainstream or CAM. So, I think some
statement about who we are, the essential essence of who we are, about holism, I
think is very important.
I don't think evidence should be down at the bottom of the list, because
I think it then informs how you are going to do education and prevention, and I
think all of those things without evidence, you don't know what you are doing,
so I think it needs to be up there, but I am still high on the list for sort of
the healing overarching principle.
The IOM, I think they talked about sort of healing relationships and
patients, so even they, they had evidence as No. 5.
DR. JONAS:
Their fifth bullet was evidence. You want it higher than that?
DR. LOW DOG:
I want it higher.
DR. JONAS:
You mentioned one thing, Tieraona, that I wonder if it is a general
consensus, is that we at least conceptually in the text somewhere link to the
WHO definition of health.
DR. FINS:
That has been widely criticized as being way too expansive. It has been
criticized as being overly inclusive and saying that health has gotten to other
human sectors, and it is no longer health care, it is something else.
DR. ORNISH:
I just want to say I really like Tom's suggestion about expanding the
word "evidence" to "evidence of safety and efficacy." I do think that
should be first for a lot of reasons. It really brings people together.
It is not distorting what we say to please another reader, but it is also
mindful of the fact that this is something that really brings everybody
together, and then it marginalizes opposition, because if you say we are in
favor of evidence of safety and efficacy, then, what do people say, oh no, we
want things that aren't safe and effective?
You know what I am saying, it really seizes to the high ground and the
middle ground all at the same time, so I like your suggestion.
DR. JONAS:
Strategically, politically, and strategically correct, yes, not just
correct, but valuable for integration purposes.
DR. CHOW:
I have always liked the broad statement of the World Health Organization,
and if we delineate that further with our own definitions, I think it would be a
nice combination.
I think the four, wholeness, health and healing, individuality, and
choice can be put in a nice paragraph, and then evidence comes right after that,
before the others, and the others, it is okay.
DR. JONAS:
So, put them in.
DR. CHOW:
Yes.
MS. SCOTT:
I feel very strongly that wholeness needs to be first. I would recommend
we really could fold in wholeness, health, and healing as one, and then I could
support evidence being No. 2, evidence for safety and efficacy being No. 2, and
then the rest following, individuality, choice, because I think they are both
important.
I originally had evidence as No. 5, but based on the discussion, I could
see moving it up to a No. 2, but I really think the essence of CAM is really
between wholeness, health, and healing.
DR. JONAS:
Health and healing, right. Okay.
DR. LOW DOG:
I like Julia's suggestion, and I think combining wholeness, health, and
healing, I think makes sense, that that could be just as if we were doing
evidence, safety, and efficacy, I mean that we have sort of made the phrase, I
think that that goes.
I think that also, it is recognizing all of those aspects that drives
evidence. You
know, evidence doesn't exist on its own. You have to have it within some sort of
context, and it is partly through defining wholeness and the body's ability to
heal that will drive some of the new research that is going to be done.
So, I still think that wholeness, health, and healing, and I think again,
it could be 1, make it 1, and then, No. 2, your evidence, safety, and efficacy,
No. 2, which is right beneath it. So, I would support Julia's.
DR. JONAS:
I think they are both very important. I would be careful not to make them one. I think they are
different. I
think healing processes, the stimulation of healing process is one concept, and
the idea of then everything being connected and the importance of paying
attention to that is another concept, but I wouldn't merge them.
MR. CHAPPELL:
Yes, Wayne, I support your comment there. I do think they are different enough to be
treated separately, to combine them will dilute the opportunity, so the order of
priority, I think is great, but I would like to see them kept separate.
DR. JONAS:
Joe has the last word, and then I am going to summarize.
DR. FINS:
Maybe as a compromise, because there is the evidence crowd that will not
be happy, maybe if the opening paragraph, Julie, maybe if you could live with
this, the opening paragraph stresses wholeness, health, and healing, and then
the first bullet is the evidence, efficacy, and safety, and then the second
bullet would be health, healing, and wholeness, if we broke that up, in other
words, so it is in the opening paragraph as an important over-reaching
principle.
Then, we get the evidence, efficacy, and safety, and then health,
healing, and wholeness as 2 and 3, so we have kind of created an evidence
sandwich.
DR. LOW DOG:
I just wanted to ask Joe something. Joe, I am just in full support of evidence,
but I am confused where we are blocking on this wholeness as being the
first. Is it
the word "wholeness," because this is a principle that guides us in mainstream
medicine, this is what we all believe.
We didn't become physicians to study evidence. I mean we believed
in humans and their wholeness, and we wanted to participate in that process, and
evidence supports the art of medicine.
We are artists basically that use evidence to support what we do, but it
seems like the fundamental foundation of all medicine, all healing all around
the world is this belief, and I am not sure if wholeness should be it, or
health.
Maybe it is the word "wholeness" that is a trigger or something, I am not
sure, but I think we could come up with some phrase. I think evidence
then supports that, but that is the core value. I am just wondering where we are at with
that.
DR. FINS:
I guess the issue, if we define wholeness as mind, body, and spirit, we
don't have evidence for faith, so there is a tension. So, it is a
language issue.
Again, I don't want to be overly defensive, but I think we have to write
a defensive document.
DR. ORNISH:
A mindful document. Again, I think if you can bring people in at
the beginning, around something that everybody agrees on, it just makes
everything flow easier. It is not a rank order of values, of
importance, it is the best strategy of bringing people in, that's all.
DR. JONAS:
I have Charlotte over here and then I want to just make a couple summary
comments, because I think -- are we getting towards the end?
MS. CHANG:
You have five minutes for summary and five minutes for a mission
statement.
SISTER KERR:
I would like to give Tieraona an award for her statement, please, and
then I would like to say, when we look at the National Academy Institute, the 10
principles, they have healing relationships as No. 1, and patients' needs and
values.
So, when we get into, we call it sort of individuality and partnerships,
I am not so sure our partnership paragraph emphasizes health coach and patient,
or practitioner and patient enough, but I think we have got to get back here to
sort of the art form and what we are all about in relationship.
Thank you.
DR. JONAS:
Okay.
We have heard a lot of comments, I am sure we will hear more, and welcome
to accept any suggestions on wording, principles, et cetera. What I have heard
is that we need to do some changing of the phraseology especially the areas in
bold, for example, in order to get it clearer about what we want, in some cases,
maybe mixing some of the areas, so that we get the principles out.
We have had a number of suggestions, I would welcome some suggestions
from you, and I am going to ask you to do that in just a minute. The importance of
wholeness and healing are clearly there. The importance of evidence, safety and
efficacy is clearly there.
The emphasis on relationships and the development of relationships is not
so clearly here and needs to be brought out.
I think linking in perhaps a more specific way to some of these IOM
issues, as well as to some of the others like Healthy People 2000, perhaps the
World Health Organization, et cetera, would be something we would also look at,
making clear that we are talking about mind-body-spirit, perhaps not in every
single phrase, but in one of the up front statements or at least in one of the
guiding principles.
What I would like to ask you to do now is I would like you all to take a
piece of paper, and I want to spend five minutes, and I want you to rank order
on that piece of paper, 1 to 10, the principles, and I would like next to the
principles, I would like you to put if you have any wording changes to the
bolded areas.
Remember, we have to keep that pretty short, notice the IOM is a phrase,
not even a sentence, and that you rank order your principles from 1 to 10 with
any kind of changes in the phraseology of the bold statement in that, and,
Michele, if you could collect those, we will take those.
[Pause.]
DR. JONAS:
Tom recommended doing the top five. Is that reasonable? Okay. So, just do five,
that is a minute each. I am trying to get both the order and also
some phrase changes that you might want to have in that, and we will take a look
at those and try to put those together for revision of this.
[Pause.]
DR. GORDON:
Wayne, Steve has reminded me that the audience has not seen the 10
principles. Do
you want to read them out loud, the way they are written down here?
DR. GROFT:
Just the bold parts.
DR. JONAS:
Just the bold parts?
DR. GORDON:
Yes.
DR. JONAS:
I will try to paraphrase them a bit perhaps.
The first one is on evidence, that is, commitment to using science and
evidence-based medicine for identifying safe and active, effective
practices.
The second one is dissemination of quality information, promoting efforts
to thoroughly examine the current evidence and make information about that
available in a timely fashion.
The third one is prevention, emphasizing the importance of the promotion
of health in addition to the treatment of disease and its prevention.
The fourth or the next one is health and healing, emphasizing the marked
ability of individuals to heal and recover, and to support that. Wholeness, that
health involves all aspects of life, mind, body, spirit, relationships, and
environment.
Individuality, recognition that the person is unique and has a right to
have their health care customized to that uniqueness. Choice, the
freedom, individuals should have the ability to choose freely among the safe and
effective therapies that are available.
The next is education and empowerment, especially emphasis on educating
individuals continuously about prevention, healthy lifestyles, and empowering
them to self-care.
The next is public involvement, recognizing the public and consumer as
being the main driving factor in this and that they become more integrally
involved in setting prioritizations and decisions.
The last one was partnerships, emphasizing that good health requires
collaborative teamwork between conventional practitioners, research, and also
between health care practitioner, patients, and among patients, both in research
and in --.
MS. CHANG:
I am going to come around and get these now. Wayne, do you want
people's names on these or do you care?
DR. JONAS:
It is up to you. Optional.
MS. CHANG:
We are out of time, unless the chair cedes you some of his time.
DR. JONAS:
Well, the historical context, I don't think we need to talk about. I guess I would
just like, I mean the plan is to do a mission statement, so perhaps just a
general comment on is that something that people would like to see and would
like to see us try to come up with a mission statement.
DR. GORDON:
Wayne, do you want to say what you mean, a little bit more, by "a mission
statement"?
DR. JONAS:
Tom? He
is much better at that than I am.
MR. CHAPPELL:
I am wondering whether the mission statement was a thought that came out
of the core values, what we believe work. I am trying to remember the origin of the
mission statement.
Basically, if we have got a set of core beliefs which we are calling
guiding principles, that is sort of the philosophical orientation, and then the
mission statement is more what are we going to do about it. It is the here what
we are about.
I am not sure a mission statement is actually relevant for us, so I want
to raise my doubt about the need for it, but I don't want to preempt Wayne's
idea about this, or Jim's. I have forgotten where this came from.
DR. JONAS:
I do too, actually. Linnea.
MS. LARSON:
We actually had a mission, and it was given by the Executive Order. I think that
highlighting the Executive Order, and this is how we have organized our
understanding under the guiding principles is useful.
DR. JONAS:
That was actually my sense, too, is that this was sort of a reiteration
of what our charge was, and that is our mission, is to try to meet that charge,
so that comes out of the Executive Order. I didn't know if we wanted to rephrase that
or emphasize that.
I mean, it is going to be right up front in the actual report.
MS. LARSON:
I really do believe that we need to emphasize and quote directly what
that Executive Order is and then make it very clear about how we have shaped
what we are doing, and that would be our mission.
MR. CHAPPELL:
That is very helpful, Linnea, and I think it is probably worth the
task. Let's
try it. It is
the action orientation of the Commissioners' work, whereas, the guiding
principles are more the belief orientation, one's belief, one's action.
Why don't we give it a try. I am willing to have our committee give this
a try, unless you already have done it.
DR. JONAS:
A mission statement?
MR. CHAPPELL:
Yes.
DR. JONAS:
No.
What I heard is that maybe we don't need one actually, as long as the
charge, what we have been tasked with is up front.
Let me say that this section is different from all the ones that will
follow, because we are not talking about recommendations here, we are talking
about the structure of the section itself, so we are at a different stage with
this particular section. So, I feel comfortable, and hopefully it will
work, taking less time.
When we come up with a lot of recommendations, there may be much more
discussion that will go on. I will say where we are, and people will then
have a lot of different thoughts about whether or not we really are there and
what we should do with the recommendations.
So, let me go through this as quickly as I can, and as I go through this,
I want to find out if this is accurate as I go through each one. So, if you could
all make some kind of motion to indicate that it is or it is not.
First of all, when it comes to definition, and, please, especially,
Wayne, you and Tom, if your understanding is different, please feel free to jump
in.
The definition on page 6 is the one that everyone felt much more
comfortable with rather than the definition that the document opened with, is
that correct?
This may seem kind of dopey to go through each one so carefully, but I
really want to make sure because these are the instructions that we are giving
back to each of the groups as they do the presentations. So, that is number
one, okay, everybody?
Yes.
Good.
The second is that the emphasis is on the kind of goals and the
aspiration rather than on conflict in presenting the whole field, is that
correct, is the feeling tone? Okay.
Third, that there is a sense of some of the issues related to history and
related to some of the conflict will be dealt with in the context of presenting
where we have been, where we are, and where we are going. Correct? Okay.
Fourth, there is an importance placed on emphasizing areas of overlap and
that diagrams may be useful in presenting some of this information. Okay.
One of the other issues that was raised here, that seemed important, is
that there be an emphasis on the fact that people are actually using these
approaches and that there was a feeling, a number of people felt that that
wasn't as strongly emphasized in the section on definition and on where we are
right now.
Beyond that, Joe raised one example, and I think other people have in the
past raised other examples that it may be useful both here and elsewhere to
present a number of examples. It may have to do with hospice, it may have
to do with school wellness, it may have to do with treatment of chronic illness,
to illustrate some of these points. Okay? All right.
That is what I have on definition, and as I said, integration and
spectrum be both emphasized, that there is an integration of some approaches and
that there is a spectrum and some approaches are not integrated, but that they
are part of the whole CAM world.
Generally speaking, what I heard, and this I really want to make sure we
are correct on, is that we would begin with definition and then move into
guiding principles.
Is that correct? Tom, no, you are not in agreement?
MR. CHAPPELL:
No, I am not in agreement with that.
DR. GORDON:
Okay.
So, let's check and see where we are with that, because is there general
agreement on that?
If there is not general agreement, and if there is significant
disagreement, then, we need to bring it back to refer the order of presentation
back to the subgroup, so I would like to get some feedback about that now,
definition first or principles first, or are we not clear yet.
Tom.
MR. CHAPPELL:
For me, the first piece of business to do in a communication piece is to
address the shift in world view, and it is basically the orientation
question.
We have said this time and again throughout the material that we need to
have a special section on this. We have come this far with it. It needs to be
presented early on, and then we move into the definition of CAM, and then into
the history.
DR. GORDON:
I am going to move this part of this discussion along very fast. I want to hear
other opinions about that, so we can make a disposition of this order of
order.
Dean.
DR. ORNISH:
Well, I would vote for putting definitions first, not as a relative
value, but just to orient the reader, particularly since I would say that the
majority of people reading this may be people in the media and politics, or
whoever, who don't have much familiarity.
I remember in medical school when we get lectures, and there was a
certain assumption that you had a basic familiarity with things, which for me
wasn't the case, and it was totally confusing. I think it is nice to kind of define things
and then go to the historical perspective and values.
DR. GORDON:
Wayne, and then Veronica.
DR. JONAS:
I agree.
I think we should world view shift as something --
DR. GORDON:
I'm sorry, have what?
DR. JONAS:
The shift in world view and what that is should be up front.
DR. GORDON:
Before definition?
DR. JONAS:
Yes.
DR. GORDON:
Okay.
Veronica, and then Linnea and Joe.
DR. GUTIERREZ:
I support Tom's model myself.
DR. GORDON:
Which one do you support?
DR. GUTIERREZ:
The world view.
DR. GORDON:
The world view first?
DR. GUTIERREZ:
Yes.
DR. GORDON:
Linnea, and then Joe.
MS. LARSON:
Maybe I am back in organic chemistry, but I really like those boxes that
says here are the definitions, and then we will explain it.
DR. GORDON:
Joe.
DR. PIZZORNO:
It seems to me that we will have some kind of an executive summary to
start out this thing.
I think that there we will need to put the definition.
When we get into this section, I think it is much more important to start
with the world view and principles, and such, and then show how we then arrived
at the definition.
So, I think we will achieve both needs that way.
DR. GORDON:
Effie.
DR. CHOW:
I go with what Joe has just said, that assuming that the definition is in
the executive summary, and the world view is very appropriate to be up front
here.
DR. GORDON:
Let's hear from Jim Swyers. Will we have an executive summary, so we can
see how it flows?
MR. SWYERS:
Typically, you wouldn't write an executive summary until the report is
done, but what we had envisioned was this definition section was not going to be
the first section of the report, but what I am hearing is that people would like
the guiding principles put in the introductory section of the report. That will be done
by December.
DR. GROFT:
I think there is a format that we use in reports to Congress, and I think
where you capture the most important parts are in the executive summary, which
actually precedes then the full report.
MR. SWYERS:
Typically, you wait until the full report is done, then, you write the
executive summary.
DR. GROFT:
We are capturing what you are saying as far as what are the important
issues. I
think as we go along, we will earmark those as to go into the executive
summary. You
will have a chance to read that shortly after the December meeting. Maybe we will even
have a draft.
DR. GORDON:
I think, Steve, we will need it. If we are going to resolve the issue on which
a significant number of people want to have the principles first, others want to
have the definition first, I think we have got to see how, and the proposition
that Joe made was to see how it looks with the executive summary with the
definition, and then moving the principles.
I think we need to see it if we are going to make a decision about
it.
DR. GROFT:
We can prepare one. It would definitely be a draft, and based on
what follows, then, at the December meeting. As far as the full report, there will be
changes, but I think we could prepare one, but to have you keep in mind that it
is very preliminary based on where we are on December 5th as opposed to December
8th.
DR. GORDON:
Effie, do you have anything?
DR. CHOW:
No.
DR. GORDON:
Julia.
MS. SCOTT:
I am just confused. Perhaps, Tom, you can tell me the
difference.
What are you thinking about in terms of the world view as different from
the history?
MR. CHAPPELL:
The world view is that section dealing with the guiding principles. It will have an
opening paragraph that talks about the shifting paradigm. That is what we
meant by a world view. History is walking you through the
evolutionary stages.
DR. GORDON:
My personal opinion is definition is better right up front. I think that,
clearly, we have different opinions. I think what we need to do is to see the way
you do it in December, to sort of refer this back to your group, see how you
present it, see if you are satisfied with it, understanding that we are putting
this up front.
It sounds like there is general agreement that this is what we want up
front at the beginning of our report. Is that correct?
SISTER KERR:
Jim, say "this" specifically, rather than "we want this," because I am
getting confused on, are we going to do overview first or definition first.
DR. GORDON:
I'm sorry, what, Charlotte?
SISTER KERR:
When you say "this," say what you meant. Did you mean we agree that the overview
should come first, or did you mean the definition should come first?
DR. GORDON:
What I meant is that this whole section that we have been talking about,
as I am understanding the general sense, is this is what we want at the
beginning of our report, together with the issue about the mission we have been
given by Congress and by the Administration.
Is that correct? I can't read body language all together. I just need to know
if we are on -- yes, okay.
MR. SWYERS:
Jim, what I am hearing is that in the introductory section, people want
to have the guiding principles included in that, and then, the next section
could start with the definition of CAM.
DR. GORDON:
That is what I am hearing, but I am not hearing that unanimously. I am hearing that
at least several of us are saying the other way, that we want to see the
definition first, but more people are saying they want to see the guiding
principles first.
My sense of us is that we should give it back to the subgroup and let
them show us how they are going to do it, and then set aside time for discussion
of this in December.
Does that make sense to everybody? Okay.
I want to move very quickly through the second part of our discussion
about the guiding principles.
First of all, again, there is something of a division here. The more general
sense was that in the guiding principles, that wholeness and health and healing
need to be absolutely up front and that evidence is second in importance, but
very close behind it.
That is the general sense of what I am hearing, with some people saying
evidence should be first.
What Wayne and Tom then do is collect our preferences for how it should
go, with what the order should be. My sense is, again, that this is something,
and I don't think this is going to happen in every instance with every other
group, but I think with this group in particular, because we are at an earlier
stage, we are referring much more back to the group.
So, Wayne and Tom, my sense is that what we are looking for from you is
to take what you have gotten from us, both in the discussion and in the written
comments, and to reshape and re-present the principles in a coherent narrative
order back to us including possible name changes for some of the categories.
Is that what everybody has a sense of? First of all, Wayne and Tom, is that your
sense? And
everybody else agreeing with that? Again, we will be spending time, taking a
look at that when we come back in December.
The second piece has to do with that there was a strong feeling, and I am
just focusing on what we have said, that there needs to be more emphasis on
partnership and relationship among all parties in the healing process than is
currently here in the document. Okay?
The third piece is the issue of body, mind, and spirit, that somehow
there needs to be some statements about that we don't want to get cumbersome or
invoke something continually that begins to sound like jargon, but we want you
to grapple with the inclusion of body, mind, and spirit, and then present it in
a way that is not continually repetitive.
Is that right, Charlotte, does that reflect everybody's feeling about
that?
There is also a strong sense of emphasizing, in the principles, safety,
as well as efficacy, that that is an issue that needs to be addressed.
Finally, we want to relate our efforts to define guiding principles in
particular to the IOM report, and to indicate in a kind of generous way that
even though there are differences between some of the principles or particular
to what we are doing, that there is a kind of coherence with the larger movement
of which the IOM report is a representation.
That is what I have heard from this discussion, and we are finishing
right on time.
MR. CHAPPELL:
Shall we have a break? That was well done.
DR. GORDON:
It was well done all around. Thank you.
MS. CHANG:
We do have a break. Please, please, please, I implore you to come
back at 10:30.
Then if David Bresler, Tieraona Low Dog, and Corinne Axelrod could be at
the front table, we can get started right away.
DR. GROFT:
Just a thank you to Tom Chappell and Wayne Jonas and Jim Swyers for
putting this session together. Thanks very much for your work.
[Applause.]
[Recess.]
MS. CHANG:
This is actually Session II. I am going to give you 15 minutes for the
overview and then the workgroup around the table, and then we will start your
discussion period for 75 minutes. I will give you a warning time just to let
you know what the time checks are periodically.
DR. GORDON:
Because you weren't here in the beginning, the more you can sort of focus
on the issues that you need feedback about and where you are not hearing
something you need to hear from people, address the question directly about what
you would like to get back. That will make the task of figuring out where
we go from here easier at the end.
Thank you.
Session II: Information
Development and Dissemination
Basically, we have many recommendations in this session, 10
recommendations that we need to go through, and we will go through them one by
one. Again,
the emphasis doesn't need to be on wordsmithing at this point, but let's make
sure that what we are recommending really reflects the consensus of the
Commission, and let's make sure we are not missing something in our
recommendations that we think is important to include.
Tieraona, have you got other comments?
DR. LOW DOG:
Let's just get going.
DR. BRESLER:
Yes, let's get going.
I hope that people have had a chance to look through this. Probably one of the
real concerns we have had in our group is about information that is on the
Internet. As
most of you know, this is a bit problematic because due to free speech, people
can say basically whatever they want to say within certain limits, make any
claims and representations that they want, and they have a lot of protection
under free speech to be able to do that.
As a result, there is a lot of misleading, inaccurate, or downright
fraudulent information on the Internet, which we think needs to be addressed,
and that is basically what issue 1 begins to do.
We also have concerns about access to the Internet. Fortunately,
through schools, a lot of children have access to the Internet, but
approximately half the population probably doesn't.
That is going to be changing over time, as we know, but again, we have
concerns about making sure that people have the ability to check the reliability
of information that they are getting on the Internet, because some of it could
be potentially hazardous to them.
In your report, there is one typographical error that I caught on page
No. 1 of this section. It is the bottom of the first paragraph,
"WebMD reports 4.7 unique visits," I am sure it is 4.7 million unique
visits. We
don't know what it is now.
Are people pretty much familiar with this, do we need to have more
discussion? We
have talked about this before, but let's look at the recommendations and see how
people feel about it.
Our first recommendation that we have discussed is to form some sort of
public/private partnership of a review board that can look at this information
kind of like other standards boards are in place for rating movies and the movie
industry, a way of evaluating the accuracy of information, setting up standards,
making sure that claims are evidence based and identifying when they are not,
and so forth, and so on, and basically, being able to give like the Good
Housekeeping Seal of Approval and an appropriate logo that is associated with
that, to those sites that are in compliance with the recommendations of the
standards board.
I don't think that it was so much our intent to have a rating system
where Internet sites would be A, B, C, D, and so forth, but rather to develop
certain guidelines for presenting information, for documenting the source of any
claims or representations that are made, and hopefully, those sites that are in
compliance with those guidelines will get this seal of approval.
So, basically, the first recommendation is that we establish a
public/private partnership to develop voluntary standards to promote accuracy,
and so forth, and to develop some sort of process to continually review Internet
science and new sites as they come aboard, and those who do meet the standards
of such a review board would be able to say that they do and to use some sort of
identification, perhaps a logo saying that they have met those standards. This is pretty much
what the first recommendation is about.
Can we open it to discussion now, do people have any ideas, concerns, or
thoughts about this particular recommendation? Joe.
DR. FINS:
Yes, I think we should cite a parallel to -- I think it was called the
Vancouver Agreement, that the leading medical editors of the journals use to
have voluntary standards, that there is a precedent for that, and I would like
to concretize Recommendation No. 2 more specifically and suggest that the
National Science Foundation develop an RFP or some kind of mechanism for
scientific literacy, which is critically important, and there may be also the
National Library Association has some kind of partnership there, you might
mention them later on --
DR. BRESLER:
Yes, we do.
DR. FINS:
But I think it is also relevant here.
DR. BRESLER:
Other thoughts and comments?
Let's stick with the first recommendation. Let's take them one at a time.
DR. GORDON:
Just a point of procedure. Joe is addressing Recommendation No. 2, not
No. 1, right?
DR. FINS:
Both.
We are on Issue 1, but there are three recommendations.
DR. GORDON:
Right, but David has just mentioned the first recommendation.
DR. FINS:
Oh, I'm sorry.
DR. GORDON:
So, if we can focus on that one, that would be helpful.
DR. BRESLER:
What we want to focus on now is this idea of public/private review
board. As we
have previously discussed, the idea would be to have people from academia,
people from interest groups, people representing the public, consumer advocates,
and so forth, and so on, just to basically set policies and procedures for
identifying information and the source of any claims or representations that are
made, and the extent to which people are in compliance with that, they would get
that seal of approval.
Dean.
DR. ORNISH:
As Joe was saying, there is a more recent conference of medical editors
that came out about a month ago, editors of JAMA, New England Journal
circulation, Lancet, et cetera, that specifically address the issue of conflict
of interest and how important that is to address. Particularly, they were referring to
drug companies funding research on drugs and then suppressing the articles if
they didn't show favorable findings, that kind of stuff.
So, I think, as Joe was indicating, to the degree we can cite other
precedents that directly relate to this, it certainly makes it more mainstream
and sees as the middle ground, as well as I think being a good precedent.
The other thing, though, is I think there are already some existing
agreements. I
know like WebMD has in terms of privacy and accuracy, and I know Dr. Koop took a
lot of flak for those issues, and he has come up with some stuff, too.
I am not familiar exactly what they are, but it would be nice to include
that in here, too.
DR. BRESLER:
I want to table that for a minute because there is some concern about
Recommendation No. 3 that we will discuss in a moment, but let's stick with No.
1, about this public/private review board.
Does this reflect the general consensus of the Commission, are we all in
agreement that this would be an important thing to do, to have some sort of
agency that has interest from both sides?
Joe.
DR. FINS:
I think I actually made this recommendation at an earlier meeting, but I
want to modify the idea just a tad, maybe with the preamble saying, "While
recognizing the importance of freedom of speech, the Commission recommends," not
in any way abridging, but just being clear that you can say whatever you want,
but it may not be credible.
DR. BRESLER:
We have always been clear that this is voluntary standards that we are
asking for and that people, just like certification in any kind of agency,
people can apply for it and be reviewed, and if they meet the standards, they
get the seal of approval. It is a voluntary program. I think we have
always considered it that way, but your point is well taken, that we need to
emphasize that in no way is it our intention to restrain the freedom of speech
through this recommendation.
Other concerns about this? Does this generally reflect the consensus of
the Commission, that we would like to see such a public/private review board to
help give consumers some idea as to the accuracy of information that they are
finding?
May I ask, does anybody have any objection to this recommendation? Can we move on?
Joe.
DR. FINS:
Maybe there should be some reporting mechanism, of we come up with CAM
Central or some idea down the road, what does this Commission do, and how does
that information get disseminated? I mean what is the feedback loop?
DR. BRESLER:
Again, I think our thinking about it was that an Internet site could
apply to this commission or board, or whatever it is called, for their seal of
approval, there will be a review process in which people will go and take a look
at the information that they are providing.
There needs to be a way to update that and make sure people would have to
reapply or recertify periodically, like we do in continuing education
programs. I
mean, we don't want to give somebody certification that is good forever. So there does need
to be a way of, not necessarily policing, but watching those people that have
given the seal of approval and make sure that they continue to deserve it.
Again, these things, the mechanics of it, need to be worked out further
down the line.
DR. GORDON:
I think one thing about the mechanics is some of this will relate to
recommendations later on, for example, for the Central Office, so that that may
be the place out of which this comes.
I think we shouldn't focus too much, as we go through these
recommendations, on figuring out all the mechanics and implementation because
otherwise we will get bogged down, and we can come back at that later on when we
have the whole picture in front of us.
MR. ROLIN:
Just a comment. I am concerned about the fact that not all
people will have the Internet. So definitely, I would support the idea of
some type of report, and that can be worked out within those mechanisms.
DR. BRESLER:
Can we move on to the next recommendation?
The next recommendation is that the public really needs to know how to
evaluate the information that is coming across the Internet, and this
recommendation was to establish a public education campaign that teaches people
how to evaluate information and again to look at it in partnership with schools
and other educational institutions that use computers, that have an interest in
the Internet, and basically to look at it as a set of fundamental skills in
being able to get the information that you want and to be able to check to see
if it is accurate information.
This is basically an educational campaign. That is what this recommendation is
about.
Do people have comments or concerns about this recommendation? Joe made a comment
that I think is very well taken, that we ought to look and see what the Library
Association is doing, we ought to look and see what NSF and some of the other
agencies are doing along these lines to increase literacy in terms of getting
access to health information on the Internet, and I think that that possibly
should be incorporated into our recommendations.
Other comments or thoughts about this?
SISTER KERR:
I know you addressed this with the library, teaching people how to use
it, but have you thought, how would this look differently if we did not have
access to the Internet, and are we considering carefully the population that
will not?
Particularly, who knows what is going to happen in the future?
But just to be sure it has been thought of, and then to say, but at this
point in history we have got the Internet, so we won't, obviously, use
billboards as much.
Are we thinking about it enough?
DR. BRESLER:
We are going to be coming to some of these discussions about access
issues and ways of getting information to other people in Issues 2 and 3, but I
think we could see the possibility that there will be industries developed to
take information off the Internet and provide it to people that don't have
access, that if people have a health care concern, there are probably going to
be private sector businesses that basically will do that, will do a search for
you, will check things out, and so forth. I think this is probably going to be a growth
industry that will enhance access, but we will discuss access more in the next
issues.
Again, we are going to focus on the public education campaign to
basically let people know how to get information off the Internet and how to
check the accuracy of it, and again in collaboration with other organizations or
institutions that have a similar interest.
Jim.
DR. GORDON:
I have a procedure point and then a content point. The procedure point
is one of the things that we should be thinking about is how we are going to
order the recommendations. I mentioned this earlier, as well, whether or
not, for example, the issue that you raised, Charlotte, should be combined here
in this place.
That is, making access more easily available to people who don't have
access.
The content point that I would like to make maybe follows up on what Joe
was saying. I
think it is important that we say that it is all scientific information, of
which CAM is a part, and I think that this is the domain that we are working in,
or we are stating right from the beginning the principles of evaluating should
be similar.
DR. BRESLER:
Which, again, makes a lot of sense to be working with other organizations
and institutions who have a concern and are already probably working on this
issue.
Joe?
DR. FINS:
It also allows us to be funded by different sources of appropriations,
everything from the Defense Department, if we are talking about misinformation
about bioterrorism, all the way to the Department of Education.
So, it really is a tremendously generic problem, of which CAM here is a
subset.
DR. BRESLER:
Other comments?
Joe?
DR. PIZZORNO:
I am not sure where this best fits in, maybe one of the earlier
ones. I really
like this because there is a lot of bad information on the Internet that we have
to be careful about, but how do we set this up in such a way that we facilitate,
and not become simply a censorship body by vested interests?
Unfortunately, this happened a lot in our history as a nation, and
unfortunately, I don't know how to do that, because we need to help people
determine what is good information, but we don't want vested interests to keep
out ideas they don't want to see come into the system.
DR. BRESLER:
Tom?
MR. CHAPPELL:
Thank you, Joe, for that comment. I have been noodling with that as we have
been talking, and I do think that in your first recommendation, you are talking
about developing the standards. I mean what that means to me is that by
practice, you are going to have some standards. There may be some standards that are uniform
to all practices, but I am still trying to make the link between the efficacy of
the practice and the information that is being provided on a website here.
DR. GORDON:
Speak a little closer to the mike, everybody, so you make sure that the
audience can hear and we get everything recorded, too.
DR. BRESLER:
Say a little more about it, Tom.
MR. CHAPPELL:
Well, I am trying to avoid creating a censorship organization, too,
because that is negative and controlling as opposed to promotion of information
that is credible and efficacious.
I am wondering if you could give me an example of what a standard would
look like. You
have said to promote accuracy. I know I am back on No. 1, but it is related
to No. 2, as well.
DR. BRESLER:
That is okay.
The way I think about it, I sit on the editorial review board of several
professional journals. Those journals have standards which need to
be met for articles that are submitted in terms of representations and claims
that they make.
I think that our thoughts are, it is not to tell people what to put on
the Internet or what not to put on the Internet. It is to look at the validity of claims and
representations that are being made and how well documented the sources are that
support those claims and representations are.
It is to establish the same kinds of standards for making claims and
representations on the Internet as we would in setting standards for what
constitutes a random clinical trial, what constitutes peer review, what
constitutes various other types of claims that you make on the basis of your
research.
Those are fairly well standardized by these journals now, and my way of
thinking about it is basically to establish standards and to put the seal of
approval on those Internet sites that do that.
When they make a claim and they say there is no scientific basis, it is
all anecdotal information, and there is not yet any published controlled studies
to document this, but here are four case studies. Basically, to validate any claims and
representations, and to provide the source or the basis that validates those
claims, I think that is our intention.
MR. CHAPPELL:
Thank you.
DR. BRESLER:
We need to move on in a minute.
DR. FINS:
Just to pepper the setup here, Jefferson said, "Democracy without
education is impossible." So, we are not in any way constricting
choice, but we want people to be able to make informed educated choices.
DR. BRESLER:
Good.
Any other comments about these because we are going to spend a little bit
of time on the third one.
Joe, quickly.
DR. PIZZORNO:
These are very well stated. I was thinking about when we had that
presentation by the Berkeley Wellness Letter and by Goldberg's group. Both of them are
publishing things, and they were both looking at the same information, and had
totally separate conclusions, and I think both were on the extremes, and the
truth was somewhere in between.
Again, how do we facilitate that we get the truth that is in between
those two extremes, that we don't let either group dominate this process, so
that when people are given advice on what is reliable and what is not reliable,
that we are not too restrictive, but we are also not too inclusive.
DR. BRESLER:
Well, what would make sense to me is that there are some issues in which
there is evidence in both directions, and part of the standards are, in those
kinds of situations, both sides need to be presented fairly.
Again, it is for this group, this public/private group, to establish
those standards, and they are going to take some time to do it. It is not for us to
establish those standards right now. We are making the recommendation that a group
needs to be formed in order to do that.
Any further discussion about this one?
Again, the question that Tieraona raises is do we want to talk about
transparency, potential conflicts of interest, full disclosure, and so
forth. Again,
I wouldn't get into the mechanics of what such a body might do. We are just
basically recommending that a body be formed to do this.
Is that clear?
DR. GORDON:
I think that the issue of transparency may be one that we want to talk
about on Saturday morning. That may be a new issue that we want to bring
to this particular area of information or maybe to all the areas. So, let's put that
down as a possibility.
DR. BRESLER:
Okay.
Moving on, the third recommendation has to do with privacy and
confidentiality of information. As you will recall, we heard a lot of
testimony about this from various people, and a large number of people are very
concerned that when they go to visit an Internet site, that they are going to be
tracked and that either the health insurance company, big brother, their
employer, the government, whoever, is going to look at where they are visiting
on the Internet and it is going to have an impact on health insurance premiums,
things of this sort.
Now, the language in our recommendation is what I want to discuss for a
few moments because in the recommendation we say, "The Commission recommends
that the privacy of individuals using CAM Internet sites be protected by
encouraging CAM sites to disclose if users are tracked and how that information
is utilized."
The question that I have is I think we ought to put more teeth into this
one. I would
like to make that a requirement. I would like it to read, "The Commission
recommends that the privacy of individuals using CAM Internet sites be protected
by requiring CAM sites to disclose if users are tracked and how that information
is utilized."
Can we have some discussion about this?
DR. BERNIER:
How would you police that?
DR. BRESLER:
Comments?
How would we police that?
DR. FINS:
I think that is addressed in Issue 2 about the FTC and all that. The point here is
whether or not we would endorse such a thing.
DR. GORDON:
It could also be in Recommendation 1 of this voluntary group, that that
would be a condition of being a member of that voluntary group.
DR. BRESLER:
Good point.
Here is an opportunity also to look at what other agencies are
doing. This is
not a unique concern of people going on to CAM sites.
Joe.
DR. FINS:
Did you guys come up with any information on HIPAA and how it relates to
this, because there may be provisions in HIPAA that we are not aware of.
MS. AXELROD:
The information on HIPAA is still evolving, but that is one thing that we
want to just make sure that CAM is included, so that it is not like the CAM
Internet sites would really be treated any different than the other health
information sites, but it is not clear to us at this point if those sites are
included, so that is what we want to make sure about.
DR. FINS:
It might be wise to mention that HIPAA, for instance, it is kind of
evolving, any evolution or amendment to HIPAA consider the CAM-related
issues. Now,
HIPAA is a very complicated piece of legislation, but that is where a lot of
this stuff is happening.
DR. GORDON:
Joe, do you want to explain?
DR. FINS:
It is about the confidentiality of the medical record and the exchange of
information between providers within organizations, between organizations, and
liability for disclosure.
Even the originating institution, as I understand, and I am not an expert
-- it would be liable if I were -- passing between me and Effie, if something
happened between George and Effie, I could conceivably be responsible for
this. So there
is a chain of responsibility.
Again, I am not an expert, but I think that we need to envelop this in
the context of major legislation on privacy and confidentiality that is out
there right now.
MS. AXELROD:
It is partly addressed in Part B of this recommendation because there is
some other legislation that addresses this issue, as well, so we can add this to
the background information that it is HIPAA and other legislation, and just make
sure that CAM is included in those.
DR. BRESLER:
I would like to focus for just a minute in how much teeth we want to put
into this recommendation.
Are people comfortable saying that we want to encourage CAM sites to
disclose if they are tracking people, or do we want to say that we require them,
we recommend that they be required to disclose if they are tracking people?
SISTER KERR:
I don't know the technology, but I would like to say "required."
DR. BRESLER:
Other comments? Everybody is nodding their head. Is there any
objection to changing the language from "encouraging" to "requiring"? Does anybody have
any concerns about that?
DR. ORNISH:
I just think it needs to be clear that we are not saying this is
something unique to CAM, as Joe was saying. I think that, here again, if we can not make
this marginalized, or make this part of the mainstream, it has a double
benefit. It
makes the particular recommendation more acceptable, but it also makes it clear
that this can be part of the mainstream.
DR. BRESLER:
I think we are all in agreement with that.
Any further comments or discussion about this recommendation? Okay.
Let's move on to Issue 2. Issue 2 is regarding adequacy and
accessibility of CAM information from the Federal Government. Does everybody
remember this one?
Basically, there is lots of agencies within the government that have
interest in this in various ways, and I think we are still learning about other
agencies in the government who already are fairly far down the line and nobody
knew about it.
Why reinvent the wheel? The idea is some coordination between all the
federal efforts to provide information, to assemble information, sponsor
research, things of this sort.
The recommendation is for an interagency task force basically to identify
what information we need that we are not getting, and also to develop strategies
to stay up with activities of the government along these directions and to
improve communication links.
We talked about Internet, too, but are people familiar with
Firstgov.gov?
I had never heard of it until I got it from this document, and I can only
imagine what other resources might be lurking within the federal infrastructure
that could be tremendously valuable to all of us interested in this.
Again, the recommendation is that an interagency task force be
established to see what is going on, identify those gaps, and do something about
it.
Jim?
DR. GORDON:
Although I agree with that, I think that the whole recommendation is a
little too tentative for my taste. I really feel we have to not only identify,
but to develop strategies for remedying the gaps, I would say, number one, and
number two, I think we need to indicate that we are responsive to the questions
that people are asking, which is basically does glucosamine work for my
arthritis or not, what is the state of the evidence for all these various
approaches.
I think the way it is worded here, it is too vague and it doesn't really
deal with the central issue of what works, what doesn't, and where can I find
people who are qualified to help me with it.
DR. BRESLER:
Again, we are focusing on what is going on within the Federal
Government.
DR. GORDON:
I know, but they have been asking these questions right from the
beginning. For
example, in the early days of the OAM, 70 percent of all questions were from
people with cancer and their families saying what else can I do.
I think that we have got to address those concerns and indicate that we
want to remedy those concerns that people have, and give them the information
that they want.
DR. BRESLER:
Remedy them by telling them what activities are going on within the
Federal Government that could be of interest to them?
DR. GORDON:
No, no, remedying them by telling them -- which is I thought we had
pretty consistent testimony on that -- that people are saying we want the
government, whether in partnership with private groups or not, we want the
government to be able to provide us, as an impartial arbiter, and some of the
government agencies including particularly NCCAM are trying to do some of
this. What can
you tell us about these approaches?
DR. BRESLER:
Joe.
DR. FINS:
I don't think that is my recollection of it, and I think Recommendation 1
under Issue 1 was to address it. In other words, I think everybody was
uncomfortable with saying there was one site that said glucosamine worked or
that was a definitive site. The idea was to have a plurality of sites
that met a certain set of standards, and then with education that the consumer
would have, they would be able to navigate that a bit.
I think they have a single voice about what works and what doesn't
work. First of
all, I don't think that is an answerable question. I mean does
chemotherapy work in a particular cancer? Well, there is a lot of disagreement about
the particulars.
DR. GORDON:
But at least what you can do is you present the state of the art, and
that is what people are looking for. Let's say, does chemotherapy, what is the
nature of the literature, the research literature out there about X and Y, and
we come to some of that later on when we talk about some of the meta-analyses or
systematic analyses that we are looking for.
DR. FINS:
As a clinician, when I have a question about what works, what I do is I
go to the National Library of Medicine, and I do a search. I find articles
that have reached a threshold and been indexed as NLM, so I think for No. 2,
Issue No. 2, that I didn't see NLM mentioned, I know it is mentioned in Issue 3,
but I think NLM is the leadership organization for this information kind of
constellation.
I would also, just dovetailing about the cancer patient who is looking
for a CAM modality, I would also link it up with NGOs, responsible NGOs, like
the National Hospice Association, so a patient would have an idea about what are
the options.
It is not exclusively a government --
DR. GORDON:
I hear what you are saying and I think the linkages are good, but CAM
already has a statutory responsibility to provide information, and I think we
have to take account of that, as well, here. That is part of the authorizing legislation
for the OAM, was that there be information made available.
All I am saying is I think we have to address the public -- what you are
talking about has been significantly as researchers' or clinicians' concerns --
we have to really respond to the public need for information.
DR. FINS:
The National Library of Medicine has Pub Med, which is a site
specifically designed for the public. I think, getting back to what we were talking
about this morning, the point is that there is this integrative continuum, so
somebody might not know they are looking for CAM information, so they wouldn't
go to the NCCAM site, but they might go to the National Library of Medicine and
find glucosamine, because they were looking under nonsteroidals and arthritis,
and they found a paper that said nonsteroidals versus glucosamine, they say,
well, that sounds better, and I have got an ulcer, that might be a better
choice.
DR. BRESLER:
This issue, to me, is not about CAM Central and having an authoritative
source within the government that can tell people what the status of information
is, and so forth.
This particular issue, the way that we have recommended it, is about
finding out what is going on within the government and all the different
agencies, linking it together, so that people know what is going on in the
government, seeing what gaps are there that need to be addressed, and remedying
them.
DR. GORDON:
I hear you.
I think then the issue becomes one of ordering recommendations, because
the most important thing to the public is not all the things that are going on
in the government.
The most important thing is what do I do next. So, it is a
different issue, and I appreciate the clarification.
I think we do have to look at the way we have ordered things in order to
present it in a way that people will say okay, they are meeting my needs and
here is another issue.
DR. FINS:
There is a micro and a macro economic dimension to this. It is like what an
individual person encounters is based on these macro economic decisions about
what the agencies are doing. So, they are related, and maybe when we set
up the structure of this chapter, you might consider the infrastructure that
would need to be in place to allow consumers and patients to make informed
choices, and they are mutually reinforcing.
MS. CHANG:
Just a time check. You have 20 minutes left for this
section.
DR. BRESLER:
I understand.
I was just pushing forward and I was going to tell everybody the same
thing. We have a lot of material to cover, so we are going to need to go
relatively quickly.
Sticking with Recommendation No. 4, is there any further discussion or
concerns about it?
Effie.
DR. CHOW:
Would you see this as being part of this other section, Coordinating and
Centralizing Federal CAM Efforts, that this is one aspect of what we are
recommending on the whole?
DR. BRESLER:
Yes, and as you will see in Recommendation No. 5, we really address it
more specifically.
Let's stick with Recommendation 4. I would like to get this one wrapped.
Any other concerns or comments about it?
DR. FINS:
Does this relate to enforcement issues, as well, or is that in a
different place?
DR. BRESLER:
We hadn't considered that.
DR. FINS:
Should we?
I would really like to give the FTC authority to enforce --
DR. BRESLER:
I think what we are trying to do right now is find out what the hell is
going on, what agencies are doing what kinds of things, and who is doing
nothing, where is the big gap, what agencies should be doing things that
aren't.
That is really the intention of this recommendation: what is being done;
how can we coordinate the efforts of these agencies, so that they are not
duplicating efforts; and what things in the public's interest need to be done by
the government that are not being done. This is the intention of this
recommendation.
Corinne.
MS. AXELROD:
I just want to add this is not just about the Internet. This is the
Internet, this is fact sheets, these are all information from the government
that comes in all sources.
The government produces a lot of fact sheets, they have a lot of clearing
houses, there is a lot of toll-free numbers, but if somebody is looking for
information on arthritis or diabetes, there is FDA, there is CDC, there is HRSA.
They all have
their pamphlets, they all have their sources of information.
We want to get those agencies at the table to look at that and make sure
that they have some CAM information in there. So, it is a way of bringing them onboard with
this, identifying where the gaps are in the information they are producing, and
enhancing the links, so that the consumer will have easier access to this
information that is right now all over the place.
DR. BRESLER:
Is everybody clear about this? Any further discussion? Five follows on
it.
Effie?
DR. CHOW:
I think this is very necessary, this recommendation. Do I see in there,
after what you just said, that it is promoting agencies that don't have
information to CAM, to include CAM information? I don't see this in here. It should be
included in here?
MS. AXELROD:
Well, if you bring all these parties to the table and talk about the gaps
in their CAM information, it is going to happen, and it is not explicitly in
here. We can
certainly add that.
DR. CHOW:
Okay.
DR. BRESLER:
Moving to Recommendation No. 5. It is basically once we have determined what
is going on in the government with CAM, we would like to have one centralized
place where consumers or other interested parties could go and find it out.
Any comments about this particular recommendation? We were going to
establish a toll-free number and just as that information is assembled, it needs
to be utilized in a form that can be helpful to consumers who are looking to
find out what the government is doing in particular areas.
Don?
DR. WARREN:
I like this.
We are going to discuss this Saturday morning also.
DR. BRESLER:
Good.
Effie?
DR. CHOW:
I wonder whether it is established in DHHS, because I think in our other
centralized CAM effort, we are questioning whether it is really good to be in
DHHS or the Secretary's Office or elsewhere.
So, I don't know whether saying specifically DHHS, or it could say within
government in this recommendation.
DR. BRESLER:
Joe.
DR. FINS:
I have no problem with having a place for information, but I do have
problems with practicing medicine or anything over the phone, and I would hate
this to be a kind of a proxy for --
So, I think we have to be very clear that we delineate the parameter of
the activity, and it is just an information source, but it is not clinical
advice.
DR. BRESLER:
It is not even close, Joe. What we are saying is these are the
activities of the Federal Government around this issue.
DR. FINS:
That's right.
I just want that on the record, and I don't think we disagree, but I
think we have to understand that people will be calling up with medical
questions about what is wrong with them, and whatever enabling legislation or
regulation has to make it very clear that this is just a generic information
source, and not a clinical enterprise.
DR. BRESLER:
It is information about what the government is doing, it is not
necessarily information about what the consumer should do for their particular
problem.
DR. FINS:
But you know that is how people are going to use it.
DR. BRESLER:
We know.
We need to move on quickly. Any further comments about this? Does anybody have
any concerns about this? Wayne.
DR. JONAS:
I think the last issue that was brought up is an important one to
address, and that is, what is going to be the public value of this. If the vast
majority of the public is calling to get clinical information, and they don't
get it, then, it is not going to be something that is very publicly useful.
We found this at NCCAM. I mean there is a public clearinghouse
specifically mandated at NCCAM to do that, and they do answer questions, but
they don't give out clinical advice and clinical information, and when people
call there to try to get that information, they are not going to get it.
It may be that there needs to be, that the perceived value of this from
our perspective may not be what the majority of people who are going to use this
line would perceive as a value, so that has to be addressed in some say.
DR. BRESLER:
Well, again, I think if such an agency were in place, I bet every one of
us would learn about activities in the government that has gone on that we
didn't have a clue about, and because of those activities, there needs to be
some kind of centralization of those activities. That is what this is to address. Okay. And we understand
your concerns that it not be to provide specific medical diagnosis or treatment,
that is obvious.
Quickly, Joe?
DR. PIZZORNO:
How much does this duplicate what is already being done at NCCAM?
DR. BRESLER:
Do you have comments about that, Wayne?
DR. JONAS:
Well, I haven't tracked and followed the recent events, because I know
they are actually growing that, and there are actually some representatives here
who are involved in the clearinghouse, and we should probably get close with
them to find out what they are doing, because it may be that they are doing a
lot of this.
DR. GORDON:
One thing we could do -- it is a long subject -- maybe Anita could talk
with you about what is going on. Now, Anita Green, do you all know Anita
Green, everybody?
Anita, do you want to raise your hand? Sure, come up.
DR. BRESLER:
We don't have time now, Jim.
DR. JONAS:
Chris Thompson is here, and she actually runs the clearinghouse.
DR. GROFT:
We will get together with Chris. We have 10 minutes to finish the rest of our
session. Let
us get together with them and we will get the information for you.
DR. BRESLER:
Is everybody okay? All right.
Issue No. 3 is about availability and adequacy of information, basically
about access, the diverse groups of consumers. We have two recommendations based on
this. Number
one, that in partnership with NLM and the American Library Association, that we
provide specific information to librarians to help people find CAM information
on the Internet and within the library system.
Comments about this one? Does anybody have any concerns about it?
The second recommendation that CAM information materials be at a level,
at a reading level that the public can understand and utilize. We gave you some
background information about that, and that specific information be targeted to
specific groups.
Comments about this? Is everybody in agreement with this?
MR. CHAPPELL:
I am wondering if this goes far enough in scope to accomplish the aim of
informing particular groups. I recall at one point during the hearing
process we discussed the sort of training tours, people going into communities
to try to help make people more aware of what the possibilities are with
CAM.
I am just concerned that again a source like a library, as sound as that
appears to be, whether that is enough to really communicate the benefits of CAM
practices and products to particular diverse groups as opposed to going in like
a public health issue, making this a public health issue and saying we are
intentional about an education program that reaches very specific
populations.
DR. BRESLER:
A comment, Tieraona?
DR. LOW DOG:
Yes, just as another person here. I felt that we have more of this under Issue
5, false and deceptive health claims on the Internet. Here, we talk about
limited language skills, cultural isolation, poverty, and we make
recommendations about bringing national and local leaders of communities, of
special populations, together, and I am not sure why we have got under the
Internet, because actually, culturally isolated people with limited language
skills, they are not the biggest users of the Internet.
DR. BRESLER:
Right.
DR. LOW DOG:
I think that would actually fit better under Issue 3 where we expand and
-- because I think this addresses some of your comments, Tom, about local
leaders of communities working with groups, bringing them together, and how do
we get information to them, because the only thing we are talking about here is
unnecessarily harmful or detrimental aspects of CAM, nothing potentially
beneficial at all.
So, we fit it under this Internet, false, deceptive health claims, and I
think it should be moved.
DR. BRESLER:
For the sake of simplicity and time, can I make a recommendation? This particular
recommendation is in regards to the library system, which is a major
infrastructure that is in place in every city in America, and how we can work
with that infrastructure and upgrade the skills of those librarians to make that
an information source.
In addition, as a separate issue and recommendation, I like what Tieraona
said, that perhaps we should get a consortium of interested parties together to
discuss how we go into those communities and provide information, as Tom is
recommending.
DR. LOW DOG:
It's already here.
DR. BRESLER:
It's in No. 10.
DR. LOW DOG:
I am just suggesting that we move it, that we move it out of False and
Deceptive Health Claims on the Internet, and we put it under Availability and
Adequacy of CAM Information, and include it under library recommendations,
that's all.
DR. FINS:
So, you are saying move 10?
DR. BRESLER:
Yes.
DR. FINS:
I just want to put a little more teeth into No. 6 just on that point.
DR. BRESLER:
Go ahead.
DR. FINS:
You are saying training materials be developed. I think we should
say we should recommend an appropriation to build the infrastructure of local
libraries and librarians by giving them training in assisting the public in
educating them about access and health care information on the Internet
including CAM.
I think the First Lady would probably be a proponent of that, so we
should look for that alliance, being a librarian, and I think that again, this
gets back and dovetails back with the scientific literacy questions and the fact
that people don't necessarily start off their search looking for CAM
information.
They look for information about what is wrong with them, and they might
end up in CAM, they might not, it depends, and it is a generic skill set.
DR. BRESLER:
Jim?
DR. GORDON:
I was just going to ask Joe, so, how would you amend that recommendation
then?
DR. FINS:
A new sentence. The Commission recommends federal
appropriations for local librarians for training, to assist the public in
utilizing health care information on the Internet.
DR. LOW DOG:
Including CAM.
DR. FINS:
Including CAM materials.
DR. BRESLER:
Is everybody okay with that? Any concerns about that? We will take that
back to our committee.
Any concerns about Recommendation 6 and 7? We are pretty much in agreement that it has
to be in a language that is comprehensible to people. Any comments? Joe?
DR. FINS:
For background, the AMA has a program on literacy that might provide
helpful citations about this that could go into the background section.
DR. BRESLER:
Anything else on this?
DR. GORDON:
The other thing there is the issue that Tom raised, I am not sure where
we are on that regarding No. 7. Does No. 10 take care of that?
DR. LOW DOG:
Yes. On
page 6 of this report, where we have, "Due to limited language skills," et
cetera, et cetera, we have included that under Internet. We have suggested
moving that under here, and moving Recommendation 10 under there. So it expands and
fits.
DR. GORDON:
The No. 10 statement is a kind of protective statement, and I think it
needs to be also a more positive statement about educating and providing
strategies of information.
DR. BRESLER:
Does everybody follow that, we are moving No. 10 to 3, and taking Jim's
comments? Any
further comments about this? Tom?
MR. CHAPPELL:
I would just like to point out that I think what this is all trying to
serve is that CAM is a public health issue. I am not sure we are broadly stating it to
have that kind of level of value and importance in our time.
CAM is as important as dental hygiene or nutrition. It is a public
health issue, and I don't want to lose that general overview of what is driving
what we are trying to do about information and accessibility of that
information.
DR. BRESLER:
Well, would you be comfortable with us saying that because it is a public
health issue, going back to No. 10, that we feel it is important to get a
coalition of people that have interests in communities and public health within
the communities, and so forth, and so on, and to frame it in that way? Would that be
comfortable for you?
MR. CHAPPELL:
Yes, that is fine for that specific piece, and I am making my comment in
general in lots of uses, too.
DR. BRESLER:
Good.
Joe?
DR. FINS:
Just another vector of information, which I think goes in Issue 3 as a
new kind of recommendation, we shouldn't forget the corporation for Public
Broadcasting, PBS, and opportunities for disseminating more information. It is not just the
Internet, not just libraries, so that is another very important site. We heard testimony
from those folks and other media outlets, but I mean those are ones that do
receive, I think, still some federal appropriations.
DR. BRESLER:
Other comments? Quickly because time is short.
Moving on to Issue No. 4, there is a tremendous amount of information and
good scientific information being done in other countries and other research
institutions that are basically unknown by researchers, clinicians, others here,
and this is a recommendation that barriers to access to this information be
addressed and this information be translated and made available.
Comments about this? Tom?
MR. CHAPPELL:
Will this public/private interagency be awarding the seal of acceptance
to international websites?
DR. BRESLER:
Comments?
If they apply for it and they meet the criteria, I see no problem with
it.
Does anybody have any concerns about this? Joe?
DR. FINS:
Just justification, recognizing globalization and the plurality of
populations that have made America their home, we think this is even more
relevant and important.
DR. BRESLER:
Any other concerns on the part of Commissioners, are we all in agreement
with this recommendation?
Moving on, we have had a lot of discussion about false and deceptive
health claims on the Internet. This is Issue No. 5. We have two
recommendations, one, that we support the FTC in its efforts to identify false
and deceptive advertising or health-related claims on the Internet, and to take
action about those; to monitor various minority groups or other constituencies
that we think are particularly vulnerable to deceptive claims in
advertising.
Again, an educational campaign for consumers and to help them identify
deceptive and unsubstantiated claims.
Now again, this is a broader issue, and it relates to any health care
information that is on the Internet. But again, a lot of this does focus down on
CAM-related sites. So we want to address this.
DR. GUTIERREZ:
I would just like to recount a chiropractic experience. We had a
chiropractor who was sued by the FTC for some literature that he publishes for
the entire profession, and the FTC saw that as fraudulent advertising, and he
was in the legal process for over six years.
It cost him many dollars, obviously, and if we are going to use the FTC
at all, I think we should recommend that the FTC put CAM-type providers on their
review board, so that when they look at it, they are not looking at it with
their own limited perspective.
This chiropractor did win, but it was a horrific battle.
DR. BRESLER:
Comments about this recommendation?
DR. LOW DOG:
I would support that recommendation. It is not really if we want to involve the
FTC, they are already are involved. They are there, and we have to deal with
them. But the
recommendation that they might include people that are experts in this area, I
think is a good recommendation.
DR. BRESLER:
I do, too.
SISTER KERR: I don't remember where now, but so much -- at
least, one of the things I learned, and, I think, as a group we learned, is that
we needed to be at the level of decisionmaking and advisors as CAM people.
But my question becomes, in light of, particularly, what Veronica said,
and as Tieraona just said, well, we are dealing with FTC whether we want to or
not. What
happens if they say, well, we can't get to that recommendation for 12 years?
It is a big deal. Can we say more than that? Can you put in a
time? Is there
anything else?
Because I don't know that all these boards, and all, that we are
recommending they put us on, whether it is insurance companies or HCFA, or
whatever, are going to do it. It is a big deal.
DR. BRESLER:
Comments?
Joe?
DR. FINS:
I think we have a very strong ally here. Senator Breaux had really remarkable hearings
a few weeks ago, in the context of the elderly being taken advantage of by
health fraud, and so I think there may be a real confluence here, and I just
wanted, as a segue, say we probably should cite that testimony.
I would modify the recommendation regarding the FTC. I would say it is
not our prerogative to suggest who gets appointed to FTC, but rather to say that
the FTC consult with its brother and sister organizations like NCCAM in the
federal infrastructure to get appropriate information, but I don't think
membership is necessarily our purview.
DR. BRESLER:
To consult with other agencies that have expertise in this area.
DR. LOW DOG:
Yes.
DR. BRESLER:
Comments?
Joe?
DR. PIZZORNO:
I have two things. One is I really support the recommendation of
including CAM professionals. Second is under the challenges, just a
technical piece.
I know that the number of successful actions taken now is 10, so just
before we publish the report, staff should contact the FTC and see what the
current status is, because there are a lot of cases ongoing right now.
DR. BRESLER:
Good point.
Linnea?
MS. LARSON:
I guess I am already to the recommendation, the specifics, and it is just
a clarification.
I think it is problematic to have highlighted "Spanish-speaking." You know, it's
English and all.
DR. BRESLER:
Is everybody okay with that? Jim?
DR. GORDON:
I think when we look at how we are going to make a recommendation for
what the FTC should be including in terms of expertise, we can look at what
Tieraona will be talking about very soon with the FDA, and I think we can make
similar kinds of recommendations across the board for federal agencies. That will make it
more consistent, and it will become clear as we move on to the next section.
DR. BRESLER:
Okay.
Time is tight.
Do we have any other burning comments?
Moving on quickly, I think the next two are fairly straightforward
recommendations.
It is basically about disclosure of training, certification and
qualifications of CAM practitioners to consumers to make more informed
choices. We
have two recommendations, basically that it is a requirement that health
professionals clearly identify and post information. It explains the
level and scope of training.
No. 2, let's take them together, that state and local governments make
information about their guidelines, requirements, and so forth, because it is
tremendously diverse.
In some states, even psychologists are not licensed and anybody can call
themselves a psychologist. People in that state need to know that.
Joe?
DR. FINS:
When we get to the education section, the group had come up with a kind
of taxonomy or hierarchy, and there is also a little bit of that in the access
and delivery, so I think this is really not the place where we really get into
the detail, but it will need to be cross-referenced because it is probably
addressed more fully elsewhere in the report.
DR. BRESLER:
The only other thing that I would mention is it seems to me that
information under challenges on page 3, where it talks about information on
licensing and certification requirements, and different providers or different
levels of training, and so forth, it seems like this paragraph would fit better
under Issue 6 than under Issue 2.
Anyway, let's look at these two recommendations. Are there any
further concerns or comments from Commissioners about these two?
Great.
Thank you all very much.
DR. LOW DOG:
Okay.
Moving right along. Now we are sort of moving into the product
side, if you will, of CAM, and adverse events, labeling, and that. We want to start
with Issue No. 7 on page 7, and this is relating to adverse events
reporting.
We all know that with the recent OIG report, that really said that this
was inadequate, the system that is in place now, and one could argue that it is
inadequate kind of across the board. It is a dinosaur of a system really.
So, we have the background and the challenges here, but I wanted us to
focus on our recommendations here, and I want to clarify something in the
recommendation because if you read it right now, it says, "The Commission
recommends that the adverse event report system be strengthened by" -- and then
it has "encouraging voluntary registration of dietary manufacturers, so that the
FDA can identify and contact them if an adverse event is reported." This is a system
that is in place in Europe, so that if there is a problem with a particular
ingredient, that you know who you need to contact immediately to notify
them.
Then, if you go to C, it says, "mandating registration," so it looks like
we have both.
We just wanted you to know that we are going to rework that. That is just a
wording issue.
We wanted to encourage voluntary registration until mandatory
registration could be implemented, that we believe this actually should be
mandatory, but this is an interim sort of step until that takes place. So, if you were
confused by that, we apologize.
Then B, requiring dietary supplement manufacturers to report serious
adverse events to the FDA, which is required of all other OTC medications, so if
somebody is reporting something, you should be required to report that to the
appropriate body.
D.
Simplifying the system. To facilitate increased usage and easier
reporting of adverse events, and increasing outreach activities to everybody
really, health care professionals all across the board, really everybody, and
also patients and consumers, so that they know where to go, but right now it's
very cumbersome to try to go onto the FDA and report an adverse event, and most
people would become frustrated in the attempt and just stop. So, we wanted that
to be made easier, as well.
Comments?
Joe?
DR. PIZZORNO:
Again, excellent recommendation. I wonder if under the last one, D, if we
should include in there the people who actually sell the dietary supplements,
like health food store employees, because they are kind of a separate category,
and yet they are selling a lot of these things to the consumers.
DR. LOW DOG:
Pharmacies, retailers. Again, I think it needs to be a campaign for
everybody.
Yes, I think everybody.
Is there any disagreement with that? Joe?
DR. FINS:
I want to add a section F or something. This is all reporting of what happens. It presumes that
things that happen get reported.
DR. LOW DOG:
Surveillance.
DR. FINS:
So I would like a surveillance function exactly, and I think that CDC
should be involved in that, and those kinds of activities and any kind of
citations by FDA that pose a real public health threat should be reported in
MMWR, so that everybody who is not necessarily in the FDA loop will hear about
it, who were just the rank and file practitioners.
DR. LOW DOG:
I think that is a good recommendation.
DR. GORDON:
I am not clear what you are saying because you are saying surveillance
and you are saying reporting, so can you clarify that a little?
DR. FINS:
If there is an epidemic or something, the CDC is involved in tracking and
identifying it, and then characterizing it and reporting is. It is part of a
containment strategy, and I am looking for some sort of parallel language.
If something were out there that posed a threat to the public health,
like the tryptophan story a few years ago, how would that get disseminated, how
would that get identified, because it is really an epidemic, because it is
really an epidemic.
It looks initially like an epidemic of a new disease that has to be
figured out, and it may not be apparently a supplement or drug interaction or
causal relationships.
DR. LOW DOG:
Right.
I think it is important that if there is not one central place, what
normally happens now is it is reported in so many different places that it would
be very difficult to see if there was any kind of pattern.
So, I think the point of this is to try to have, one, make one central
area where adverse events are reported, and then to have somebody that sort of
oversees that and makes accessible that information if there looks to be a real
health problem.
DR. FINS:
Just maybe to clarify, but a word like epidemiologic surveillance versus
a recipient of information to know what is going on and to help to characterize
it, but maybe Joe K. and Corinne can help us with the public health language
here.
DR. LOW DOG:
We can take this back, and if there is anybody that really has an issue
with that, I mean I would like to leave some of those things to the group to try
to re-present to everybody with our working on it.
DR. FINS:
There is another mechanism that actually came up in my own hospital,
where the consideration was, if we want to allow supplements into the hospital,
how does a hospital deal with that question in the context of an established
hospital formulary system. We are talking here about a macro, sort of a
national system, I think -- adverse monitoring within organizations -- and how
institutions would begin to integrate this stuff into their setting.
It is something I think may be really ripe for an RFP. How do you
integrate a conventional formulary with a supplemental inclusion, do you limit
it to certain manufacturers, certain drugs, do people bring in their own
drugs?
DR. GORDON:
I would like to say that this is a new issue.
DR. LOW DOG:
I think that is a great question for Saturday. Would somebody keep
track of those things for Saturday?
DR. GORDON:
Yes.
DR. LOW DOG:
So, I would like to leave that for that discussion, because I think that
is important, Joe.
Is everybody pretty much in agreement with this recommendation No. 13
under Issue 7?
DR. GORDON:
Tieraona, I would just like to get a clearer sense of the voluntary to
mandatory, a little bit more about the background on that, and just make sure
that everybody is --if you could explain it a little bit more and then get a
sense whether everybody is in agreement and if you see any down side to it, too,
so we could discuss that.
DR. LOW DOG:
I think that it will probably require some sort of legislation to make a
mandatory registration, so obviously, that may or may not happen, right, I mean
because of that, but we do feel that there should be at least an attempt. We believe that
that is where we should move, our group did, but we would strongly suggest that
there be a voluntary registration at this point until legislation could be
enacted, and whether that happens or not, I think there needs to be something in
the interim.
Now, they do this in other countries, and you are supposed to clearly put
What is in
your product on your label, so this shouldn't be something hidden from
view. You
don't have to get your formulas or your recipes, you just have to provide what
are your major ingredients, what are your ingredients that are in your product,
so if there is some sort of adverse event, manufacturers could be notified
immediately.
We do not have that system in place, and if we did have a bad batch of
something in this country, if there was a contaminant, et cetera, that came in,
there would be very little way of trying to go back and figure out who we needed
to notify.
DR. GORDON:
My point is that this is potentially a very strong recommendation, and I
just want to make sure the Commissioners are aware that this is strong, this
would require legislation, that it is well backed up with documentation by your
group.
DR. LOW DOG:
I think we can get the information. If you think we need to strengthen that, we
certainly can.
We can also bring in how they do it in other countries including Europe,
their system, which they are a little more advanced in some ways of following
this, and if you think that would be important, we could do that.
DR. GORDON:
I do, and I also wanted to make sure that everybody is on board with this
one, because it is a major recommendation and does have legislative
implications.
DR. LOW DOG:
Does anybody not agree or strongly feel that we should not be
recommending for legislation for mandatory registration?
SISTER KERR:
Why wouldn't we recommend it?
DR. LOW DOG:
Well, that is what I am asking.
SISTER KERR:
What is the coaching on that? The other one is what does it mean to report
serious and who decides what is serious?
DR. LOW DOG:
Well, a lot of things end up getting reported that may be just a tummy
upset, or things like that. Serious adverse events tend to be ones that
are more serious and may require hospitalization, or enough that you would have
go visit somebody, a practitioner.
So, those are already laid out what constitutes serious adverse
events.
DR. FINS:
It is in the OIG report.
DR. LOW DOG:
Right.
But I guess I would like to know, is there anybody that dissents on this
or do we have an agreement on going towards mandatory?
MR. DeVRIES:
I am wondering if we have enough information to really make a good
decision. I
guess what I am questioning is, we have a recommendation. Have we really
gotten some outside input, whether it be in terms of legislation, what it is
going to take to get the legislation done, or in terms of regulation, what it is
going to take to regulate, and what the perceptions are, and the input of people
outside of this commission who maybe are more directly involved and have perhaps
a level of understanding that would help us in formulating a recommendation.
I feel like I am somewhere in the middle, I can neither support it nor
oppose it, because I just don't have enough information right now.
DR. LOW DOG:
Joe?
DR. FINS:
I think the issue is that if, god forbid, something were to happen, and
the manufacturer was not registered, you cannot fix that after the fact. We are just saying
register. We
are just saying know how to reach you so we can get additional information about
the formulary and what was constituted in the supplement.
So, it is really, I mean I don't think it is all that stringent, and it
seems to me it is common sense, and it is good public health, and it would be a
good preventative strategy, and I don't think it is going to adversely affect
that marketplace in a way that would be anything other than that.
It is sort of like -- and I think Tieraona's idea of having it as
initially a voluntary thing -- that we encourage that. People could say
they have voluntarily registered, which, as a consumer, I would be more likely
to buy that product, that one that didn't choose to voluntarily register before
there was any legislation.
MS. AXELROD:
I just want to mention that the OIG report addresses this in depth, and
they recommend mandatory registration. Just for the sake of the length of the
document, we didn't include everything from the OIG report, but we can put a
little bit more in if that would make people more comfortable.
DR. LOW DOG:
I think doing that, but also I am saying, with a lead-in sentence,
similar to mechanisms that are in place in Europe where dietary supplements are
available and widely used, so that it is consistent also.
MR. CHAPPELL:
Item C.
So, if a company has 300 different products, they are going to list the
ingredients and formula of all those products?
DR. LOW DOG:
They are going to list the ingredients, right.
MR. CHAPPELL:
Some kind of order of importance.
DR. LOW DOG:
Exactly.
You don't have to put your formulas in.
MR. CHAPPELL:
You run into this in your profession as do I, and it is not the
ingredient, but it is the adulterant. How are we going to discern between the
adulterant and the ingredient itself?
DR. LOW DOG:
I think that's a great question. I mean part of this will be implemented
when GMPs are implemented. I mean so part of that, we will take care
of. If it is
an adulterant or a contaminant in a product, but we trace it back to like with
plantain, in 1996, if we know that the plantain was actually contaminated with
fox glove, we have a way then to get to all the people that are selling
plantain, so that they know that we have had contamination, and we can inform
them of batches that we believe were contaminated.
Everybody should be keeping lot numbers and all of that, so they should
be able to test, but if you have no way of knowing, and that is what happened in
'96, there was no way to know who to contact who may have even purchased the
contaminated plantain.
MR. CHAPPELL:
Perhaps then this recommendation ought to be including language that
cross-references to GMPs in that regard, because I think is an important
feature.
DR. GORDON:
Come closer to the mike, please.
MS. CHANG:
Tieraona, this is a time check. Fifteen minutes.
DR. LOW DOG:
All right.
So, Tom, we have got that, too. We move on to Issue No. 8. We are going to
rework this a little bit as far as wording goes. We would like actually Issue No. 8 to be
Issue No. 9.
We are going to move quality control up front, ahead of labeling, just
for the way it flows, just so you know that.
So, I would like to look at Issue 9 first, if you just would, quality
control of dietary supplements to assure consumer safety. Here, again, we are
going to tweak the language a little bit, but I would like us to look at the
recommendations here.
"The Commission recommends that the FDA's Good Manufacturing Practices be
implemented to help assure the purity of dietary supplements."
Is there any dissent on that? Ming?
DR. TIAN:
I have a question for you. You talk about purity. What does that
mean?
DR. LOW DOG:
I had a little issue with purity, too. Be implemented, I think to help assure either
safety, or just the Commission recommends that the FDA's Good Manufacturing
Practices be implemented to help assure the safety of dietary supplements."
DR. TIAN:
Can we say quality instead of purity?
DR. LOW DOG:
Quality?
DR. TIAN:
Yes, and also you talk about the GMP. That is special GMP procedure for dietary
supplement, it is not for pharmaceutical company.
DR. LOW DOG:
Right.
DR. TIAN:
Because if I understand, a lot of dietary supplements are not
purified. It's
naturally get extract. We don't even know more than 100 of few
hundred components in it.
DR. LOW DOG:
Right.
DR. TIAN:
All right.
DR. LOW DOG:
And we can be more specific actually in the dietary supplement. These have been
agreed by industry, and we are just waiting. They are just kind of held up right now.
DR. TIAN:
They have different standard. We don't want, also, it is impossible to
improve that quality up to the pharmaceutical standard. There are two
standards. We
ask too much, we will kill everybody.
DR. LOW DOG:
We are just looking for the ones, and we will be more specific in our
language of the dietary supplement, Good Manufacturing Practice, that have
already been agreed to including industry member representation. It is not
pharmaceuticals.
DR. TIAN:
Okay.
Thank you.
And page 10, second paragraph, No. 15. You mention limited to the products with
industry-approved standards. What does that mean?
DR. LOW DOG:
Where are we?
DR. TIAN:
Page 10.
DR. LOW DOG:
Did I skip something?
DR. TIAN:
Yes, but this is the same question.
DR. LOW DOG:
I would like to come back to that. That is under Issue 8. Let's come back to
that. We will,
I promise, get to that.
DR. TIAN:
Okay.
Thank you.
DR. LOW DOG:
Do we have consensus with changing also from "purity" to "quality," which
I think is a better word, and we are going to make sure we include the proper
GMP, so everybody knows what we are specifically talking about? Do we have
consensus on this?
Tom?
MR. CHAPPELL:
I believe I heard safety and quality.
DR. LOW DOG:
Quality and safety being a relative term, safety. 17. The Commission
recommends that the DHHS, USDA, Environmental Protection Agency, U.S. Custom
Services, and other appropriate federal departments and agencies work with
manufacturers and importers to monitor the quality of imported and domestic
dietary supplements and identify and prevent contaminated or adulterated
products from entering the U.S. marketplace when possible. And then DHHS,
USDA, EPA, and others work with the WHO and other appropriate international
organizations to establish guidelines to help assure the purity, or quality, I
guess, or herbal ingredients and, where possible, set international standards
for consistency.
Questions?
Comments?
Issues?
And also just supporting for initiatives that we mentioned somewhere here
about AOAC, USP, NSF, other groups that are setting standards, that we probably
want to move that into this section. That is just a technical -- never mind,
forget it.
Technical thing for us. This goes there.
Any questions or problems with that recommendation? Basically, that we
have had some issues and problems with contaminants and adulterants in a number
of the raw botanicals and formulas, prepared formulas that have come into this
country, so there has been a desire to try to get a handle on that.
Tom?
MR. CHAPPELL:
Yes, thank you for that reference. I am wondering why we include domestic in
this?
DR. LOW DOG:
Is there a reason you would not include domestic of our raw botanicals
and raw materials here for adulteration and contaminants, which we have known to
be a problem for many, many, many, many years, echinacea being a prime example
of substitution with parfineum and tegra folium.
So, I mean we have issues of substitution, adulteration, and contaminants
here in this country, as well. It is not just foreign material.
MR. CHAPPELL:
I guess I just would like to ask how manufacturers would proceed under
normal circumstances with this recommendation.
DR. LOW DOG:
I think this is more of an issue of trying to get some of the agencies
involved to help in this whole big arena. As long as manufacturers are pretty much
following GMP, they are going to be doing the best that they can. I think that we
need to perhaps involve some of the other agencies to look for ways of
identifying quality and ways of helping to assure that we are identifying
adulterants and contaminants when possible. It is a big task.
MR. CHAPPELL:
I appreciate that. I am just wondering is that covered in 16 for
domestic companies.
I guess what I don't want to do is accomplish 16 and then put on
additional encumbrances and bureaucracies that prevent domestic companies from
proceeding in an orderly way to get their products to market.
DR. LOW DOG:
So, your issue is with the word "domestic" here.
MR. CHAPPELL:
Yes.
DR. LOW DOG:
Because you believe that if they are in compliance with 16, 17 naturally
follows.
MR. CHAPPELL:
I think 17 really deals with imports.
DR. LOW DOG:
We will take that and work with that. That's a good point, Tom.
DR. FINS:
The other thing is whether or not there is a role under 17 with the
appropriate state agencies, as well. It is not a purely federal problem, but there
are state departments of housing, environmental protection, et cetera.
DR. LOW DOG:
Any other comments? Those were good comments. Anything else? Joe?
DR. PIZZORNO:
One piece left out here, and it may actually be a totally new issue, but
I would just like to raise it for the committee to consider, is we haven't dealt
with the Environmental Protection Act about some of these botanicals being well
crafted, being endangered species.
It seems to me that this would be an appropriate place somewhere in this
section to discuss that.
DR. LOW DOG:
Threatened and endangered, working with groups like United Plant Savers,
working on that.
Okay.
New issue.
DR. GORDON:
That would be a new issue, right?
DR. LOW DOG:
Make sure we write that down. That's good.
Anything else?
Is there sort of general agreement about this? We can tweak it a
little bit and add some things, look at the domestic issues and GMP, sort of
look at that and bring it back to you all. But is there general consensus?
DR. FINS:
Is there a role for DEA in any of this? There is some herbals that would be under
their jurisdiction.
DR. LOW DOG:
Yes, but they are not being sold at Wal Mart.
I am going to move to 8 kind of quickly here, Issue 8, that we skipped
over. This was
about labeling, adequacy of labeling. Part of what we are going to do here, part of
this has to do with labeling, but part of it has to do with quality control.
So, if you say that your St. John's wort has 0.3 percent hypericin, and
it doesn't actually have it, is that a labeling issue or is that a GMP
issue? I mean
did you not meet your label claim because of your analysis, your analytical
method, or your quality control.
We are going to take that and tweak that a little bit and re-present that
to you, okay, because we think we can make it clearer for people that are
reading this.
Our big thing with labeling is the issue about structure/function claims,
drug claims, some of the issues that were raised by a number of people who
presented here.
This is what we wanted to address, safety, people putting what is known
if there are safety risks on their potential interactions, and also the issue,
then, of benefit, structure/function.
So the recommendations that were made, where the Commission recommends
that the availability of consumer information of dietary supplements be
increased through improved labeling, package inserts, and information at points
of sale, inclusion of information on possible interactions with prescription or
OTC meds, foods, or other health products, and I think we should put "when
known" or "when established," because a lot of it is very theoretical right now,
and theoretically, anything could interact with anything, so I think we need to
tweak that a little, and inclusion of information on possible risks to
vulnerable populations, such as children, elders, pregnant, nursing women, and
those with certain health conditions that compromise the immune system.
Basically, if we know that there is somebody who shouldn't be taking
this, should it be on the label.
Joe.
DR. GORDON:
Tieraona, here, I think that the recommendation needs to be much more
specific about the whole area of what kind of information we feel should be on
there. You
present it in the section on Challenges, and also just in discussing the issue,
but the recommendation just says "improved information," and I think this is an
area where we can make -- I am not saying we have to do it in this next few
minutes, decide what to do -- but I want to hear from the Commissioners.
My personal opinion is we need to provide more of the available
information about what we know about the utility of these substances that are
being marketed.
DR. GORDON:
All right.
Joe, and then Tom.
DR. FINS:
It is sort of along the lines of what Jim was suggesting, we have a
little more specificity. Another area which I don't think you have
covered is the issue of dosages and toxicity. In other words, if people take one vitamin C,
it is one thing, if they take a tremendous amount, they get kidney stones, so I
mean I think we want to have people aware of what a safe dose is or what the
recommended dose is, so they don't get toxic by taking too much.
DR. LOW DOG:
Tom.
MR. CHAPPELL:
I think it might help you to begin -- the doorway here is either a DSHEA
claim, it is claim based, it is either a DSHEA claim or an over-the-counter
drug. If it's
an over-the-counter drug, there is a monograph that requires certain dosages
that you must adhere to, the language of the claim must be adhered to.
If it's a DSHEA claim, there is strict language about what you can say,
and then if you have knowledge of the biological activity of any one ingredient
in there, that doesn't fall under either DSHEA or OTC, you are really required
to apply for a New Drug Application, because it's a drug and you are not
claiming it to be.
I think we have to ask how are our aims going to mesh with the regulatory
world today, which is claim based. That is the starting point in improving
information, and if we think we have the liberty of adding information to the
label, believe me, we do not. The FDA will absolutely slam us for saying,
oh, in addition to the zinc citrate that we have in this toothpaste that is
going to help your gums, we have chamomile in there, too.
Well, good luck. If you have got clinical evidence to show
that chamomile is helping the gums, then, you will be invited to do a New Drug
Application, but this is so structured that I just want us to be aware we don't
have the liberty of providing a lot of information to consumers that we might
like to, but we are very much constrained by the regulatory world here.
DR. LOW DOG:
One could divide this really into two pieces, one which is benefit, and
the other which is risk, because much of this right now is -- because it's
really two parts, isn't it -- one is the structure/function claim or drug claim,
and the discussion of soft claims and somewhere where that might be in
there.
The other then is potential risks -- I hear you, Michele -- is the
potential risks, which is then about adverse effects or risks for certain
populations or interactions with particular drugs. So, we have two
pieces.
This one really focused on or our attempt was to really focus on
Recommendation 14, on potential interaction, harm, side effects, that aspect of
the label. Do
you have any concerns about that?
MR. CHAPPELL:
Only to say that the whole world wants to know about interactions.
DR. LOW DOG:
No kidding.
MR. CHAPPELL:
I am just wondering where the burden has to lie here for providing that
information.
DR. GORDON:
Just a point of procedure or order. We will take 10 more minutes, because I think
this is really important to focus as much as we can on this.
MR. CHAPPELL:
There are a whole world of pharmacists. May I speak?
DR. LOW DOG:
Yes.
MR. CHAPPELL:
There are 110,000 pharmacists out there that would like to know more
about drug interaction. As you say, we need to tweak this, but since
there is so much analytical information required here, and further study on
interactions, that I am concerned that we may be setting up a hope here that we
can't deliver on.
DR. LOW DOG:
Right.
I think it is an excellent point. We are going to work on the language. We have discussed
this on when it is known, when it is clearly established. Certainly, we do
know for some things, where it has been clearly established and there is
consensus, but we want to work on this a little bit and bring it back to the
group.
Joe.
DR. FINS:
This gets us back to what we do with DSHEA. I think we have all
sort of agreed that that is a huge thing and it is probably not something we can
really modify at this point, but I do think, my understanding, in a sense, DSHEA
was written, not to make claims that were too grandiose, but it really didn't
address the toxicity or the risk side.
I think the way to carve it out, and we are providing more information
about interactions, about toxicities, about vulnerable populations, all of that
is protective and, if anything, it doesn't enhance the desirability of people
wanting to take these entities, it is not an inflated kind of claim.
So, I think that in the spirit of the public health, given all the
testimony that we have heard and the interactions that we have been aware of, I
think we are really operating under the spirit of DSHEA, but we are providing
absolutely necessary information that would allow people to maximize their
utilization of these products in a safe and efficacious manner.
I think we have to, as you were beginning to suggest, it is about the
toxicity, it is the down side that we are providing more information on, and not
necessarily the up side. I don't think that is inconsistent with what
was the legislative intent.
I think the other thing I would couple in here is that we should track
this information, the FDA should track this information, and there could be a
possibility of revisiting this legislation in a more formal way down the road,
that there should be a report to the Secretary in five years based on if our
recommendations are implemented, because I think that this remains an open kind
of question.
It is not a question we want to open right now, but there should be some
future revisiting of these concerns.
DR. LOW DOG:
Dean.
DR. ORNISH:
Just to emphasize again, I think it is really important to add issues
like this. I
know it is going to be, as more research is done, more side effects will be
known. There
is an article coming out next month in The New England Journal showing that
antioxidants interfere with statin drugs, for example. So, I think
addressing this issue now will be important now and even more important
later.
DR. LOW DOG:
Thank you, Dean. Thank you for all those comments. We are going to
work on that a little bit, and we will bring it back.
DR. GORDON:
I have one more, which I believe is a new issue, which we raised several
times in the course of the hearings, which is should there be some kind of
education for health food store employees.
DR. LOW DOG:
Put that for Saturday.
DR. GORDON:
Thank you.
That is what I wanted to do. I just wanted to raise it now, though.
DR. LOW DOG:
Yes.
Put that on our agenda.
Recommendation 15. The Commission recommends that claims of
standardization be limited to products with industry-approved standards.
That, we need to go back and rework, who is the industry, what standards,
which products.
So, we would like to beg your forgiveness and sort of go back and rework
that a little bit and re-present that to the group.
Finally, in our last one, Issue No. 10, on page 11. Federal oversight
to assure public access to, and safety of, dietary supplements.
Recommendation 18. The Commission recommends that there be
adequate staff of professionals within the FDA and NIH with expertise in dietary
supplements especially areas other than vitamins and minerals, plant, animal, et
cetera.
This could include hiring people with these specific skills and/or
providing training to current staff, and may require increased staffing levels
or funding.
Many of the biologics and the plants are extremely different than looking
at vitamin and mineral metabolisms. They bring their whole set of issues and
sometimes we feel that maybe these organizations might need increased funding to
be able to enhance their staff for people that have special expertise in those
areas.
Joe.
DR. PIZZORNO:
Another good recommendation. I would also like to suggest that after the
"adequate staff of professionals," say "and an advisory board, which includes
amongst others, CAM professionals experienced in clinical use of these
agents."
DR. GORDON:
Excellent.
DR. LOW DOG:
Corinne.
Go ahead, Corinne, you can speak.
MS. AXELROD:
I think there should be a little bit of discussion on that because we
don't want to be telling FDA what to do. Part of that is just their management, if
they choose to have an advisory board or not. I think there are a lot of implications.
So I would just like to be aware that advisory boards are not just
casually assembled and have a lot of implications that, maybe, we should
discuss.
DR. LOW DOG:
Thank you, Corinne.
David.
DR. BRESLER:
I want to talk about this point, too, because there are lots of people
that have academic information about biochemistry and physiology of some of
these products and supplements, and so forth, but have no experience clinically
whatsoever in their utilization.
I do think this is an important point. Maybe the language we use is to encourage the
FDA or something like that, but I think it does need to be addressed. Clinicians with
clinical expertise need to be involved in decisionmaking at this level, I
think.
DR. GROFT:
Tieraona, if I may add, that there is an advisory board already in
existence for dietary supplements at the FDA.
DR. LOW DOG:
You are so good. Thank you, Steve.
Tom.
MR. CHAPPELL:
I am really not sure what I want to say, but I am having trouble with
this. As I
have been sitting here for a year and a half, the concern is about safety more
than efficacy on these products. As I speak as a company involved in herbal
products -- I didn't say a professional, because I am not a professional -- I
know that we don't know enough about the mechanisms of action of these
individual herbs to understand what to use for a marker to establish a
standard.
For us to be seeking standardization of, let's say, a DSHEA-type claim
product, we really need more knowledge than we know today. On the other hand,
if we are talking about standardization of an OTC item, the OTC has a
benchmark. We
know what the drug is that is accomplishing the effectiveness.
The OTC, that already is set up, so we are really talking about DSHEA
items here, and there is so little known about the individual herbal mechanism
of action that I would think we ought to be encouraging, not claims of
standardization, but rather more knowledge on the bioactive ingredients.
DR. LOW DOG:
Tom, I hear exactly what you are saying. That is why we didn't go through 15. You are back on
Recommendation 15.
We are on Recommendation 18.
MR. CHAPPELL:
I beg your pardon. I thought we were talking about 15.
DR. LOW DOG:
No, we left that one. We said we would like to beg your
forgiveness, because that needs a tremendous amount of work. We are real aware
of those issues, so we don't like Recommendation 15. We would like to rework it with your
permission and bring it back.
MR. CHAPPELL:
Okay.
Well, you didn't have my permission to take it away yet. I wanted to comment
on it.
[Laughter.]
DR. LOW DOG:
We were out of time, that's all, we were aware of the issues.
DR. GORDON:
Procedurally, Tom, what might be most helpful is if, Tom, if you worked
with Tieraona and that committee on No. 15.
DR. LOW DOG:
He is on now.
We realized all the pitfalls with that one, so we wanted to come back to
it.
On 18, anything else on Recommendation 18? Ming.
DR. TIAN:
I think the advisory board is very necessary, very important, and the
advisory board, I would suggest to have some subcommittees for different CAM
products or subjects, because the qualification to be an advisor, to understand
all the 31 CAM, we are talking about the definition, who could do that,
understand everything? I am afraid not.
I think it is very important. We must have a subcommittee and also to hire
the qualified person to be advisors. I don't feel shy to recommend this to the
FDA, and as we all know, and you can't ask FDA officers to understand
everything.
DR. LOW DOG:
Thank you.
DR. LOW DOG:
If they could keep their comments very brief, could we hear from Wayne
and Effie just real quickly? They were waiting.
DR. GORDON:
Sure, go ahead.
The collaboration aspect, the importance of having input from experts in
particular areas including clinical experts is important, but I wouldn't say you
need to hire more people.
DR. LOW DOG:
Okay, leave it out.
Effie.
DR. CHOW:
I would like to confirm what Xiaoming said, and in addition, that it is
not just people from institutions, but individuals, because at some point we
mentioned include institution, but individuals who don't belong to institutions
and are known as excellent practitioners should be considered as part of
advisory, subcommittees or whatever.
DR. GORDON:
We have minutes. I am going to move through it again pretty
quickly. Thank
you very much, Tieraona and David and Corinne. This is really a very nice job of making
recommendations and taking us through it.
I am just going to go through the recommendations one by one.
Basically, No. 1 is approved as is. If you have a problem, I think the best way
is if there are issues with my summary, raise your hand or turn on the mike and
let me know or let us all know.
No. 1 is approved as is.
No. 2.
The issue had to do with we want to find out what other kinds of
education campaigns are going on. We are talking, not just about CAM
information, but information about science and medicine more generally.
No. 3.
There was a strong sentiment for changing "encouraging" to "requiring,"
and there was an issue raised here about the whole transparency of the
process. I
think this is a larger issue that all of the groups need to take into account as
we go back and formulate both issues and recommendations. It is not just one
that applies here.
Recommendation No. 4. There was a recommendation that -- go ahead,
Joe.
DR. FINS:
Point of order. You are obviously going through this, not
mentioning everything that was covered.
DR. GORDON:
Right.
DR. FINS:
But things that were said that were agreed upon are still on the table,
like, for example, the relationship to HIPAA is just an example in No. 3.
DR. GORDON:
Right, exactly. I am not giving every detail, but I am trying
to deal with the recommendation, and that is sort of filling in.
No. 4.
One that did come out strongly was to find out what is going on with
NCCAM as we make that recommendation.
In No. 4 and No. 5, we sort of ran into some confusion because this is
really about letting people know what is happening in the government. This is not
necessarily about providing definitive information. It became clear
that as this is presented, the distinction between the provision of information
and providing, in a sense, information about information has to be made.
No. 6.
DR. BRESLER:
Back up one second.
DR. GORDON:
Go ahead, David.
DR. BRESLER:
Go ahead, Corinne.
MS. AXELROD:
I just want a clarification on Recommendation 4, what the disposition is,
please.
DR. GORDON:
The understanding is that we need to find out what NCCAM is doing and
include that as part of our background information and as part of our
understanding and statement about what is going on. If that reshapes
the recommendation in any significant way, that needs to be brought back here,
otherwise, it is all right as stands.
Is that okay?
Did you have something on that, Corinne?
MS. AXELROD:
My understanding was that that was approved and that we can certainly add
the background information.
DR. GORDON:
That is my understanding, as well, unless there is some way in which it
changes things materially.
DR. BRESLER:
We will bring it back to you if it does.
DR. GORDON:
On to No. 6.
Here, there is an emphasis on providing other kinds -- on working with
local librarians and other media other than the Internet needed to be
included in No. 6, in that recommendation, but that otherwise, the
recommendation was as stands.
DR. FINS:
Didn't we want to put an actual appropriation?
DR. GORDON:
I'm sorry, what?
DR. FINS:
An actual appropriation for infrastructure building and training of
librarians, in other words, it is not that we are encouraging a partnership, we
are actually talking about real money going to libraries in our communities to
train librarians.
DR. GORDON:
Let's check on that.
DR. GROFT:
Yes, I think we want to check on that because I think some of that is
already going on with the Library of Medicine. When Dr. Lindberg spoke at our session, he
talked about --
DR. FINS:
I don't think it was to local libraries.
DR. GROFT:
Yes.
DR. FINS:
We need more information on that.
DR. GORDON:
Let's get some more information on that.
DR. GROFT:
We will get more information for you on that.
DR. GORDON:
No. 7 is as stands, and then the recommendation was that No. 10 go in
this section.
No. 10, if everybody looks at No. 10 on page 6, we are not just talking
about protecting the constituency, we are talking more generally about educating
those and other constituencies.
DR. BRESLER:
And also determining the needs of those communities, as well.
DR. GORDON:
Right.
No. 8.
This was accepted with just the understanding that we ought to provide a
context and talk about globalization as we talk about No. 8.
No. 9.
There was some concern about wording here. In particular, one of the issues had to do
with not to focus on Spanish media, but I think Linnea said that we are talking
about all media and all languages and that we needed to somehow tie in education
here, as well, and that if we are talking about the FTC, that we have to make
sure that the FTC understands the issues that are involved.
There was a suggestion that some of the wording that we used when we talk
about the FDA might be brought in here, as well.
Is everybody following what I am saying here? The kind of
information that the FTC needs in order to make these judgments, they may not
have at this point, and that they may need the same kind of input that we
describe in a later recommendation about the FDA.
I think we can just bring that recommendation back with those
additions.
Does that feel okay to everybody? Okay. I will take silence for agreement.
Recommendation 11 was approved as is.
Recommendation 12 was also approved with the understanding that the
issues, that this is simply a recommendation for making information
available.
This does not relate to the guidelines for licensure or credentialing,
which will be dealt with elsewhere.
No. 13.
There was considerable discussion about. There was general agreement, although some
questions about mandatory registration. There are two issues here. One had to do with
mandatory registration, and George DeVries in particular wanted to hear a little
bit more from the group before we went ahead with that.
Then, there was a second issue, an addition of an (F) here to (A), (B),
(C), (D), (E), and that Joe Fins was talking about, which I think there was
general agreement about, about some kind of centralization of the functioning of
monitoring adverse events and making information about them widely
available.
My sense of this one is that to be absolutely sure, that we just want
some of that background, Tieraona, that you were talking about gathering and
presenting, and that you can bring it back to the group, but that there was a
general feeling that the movement from voluntary to mandatory made sense, but
just some questions about exactly what that might mean.
Is that fair enough? Okay.
MR. DeVRIES:
Let me ask a question, though, because I think I was the one who voiced
the question, and I am not sure anybody else did. I didn't actually sense a general feeling
that -- I think that was more my question, is that right?
DR. GORDON:
Right.
MR. DeVRIES:
I think we can move ahead on this. I would just like to follow up maybe directly
with you, if I can, and maybe talk with you off-line. I think that will
be adequate.
DR. GORDON:
Fine.
Is that okay with everyone? Perfect.
No. 14.
This one, both No. 14 and No. 15, goes back to the group, to the
workgroup, for refinement, and refinement particularly about issues both of
benefits, harm, how we make decisions about what should be included, what should
not be included, and then, coming into No. 15, what the whole issues are with
standardization, and the subcommittee recognized those needed to be elaborated
on.
DR. FINS:
Jim, could I just ask, I think No. 14 is so critically important, I want
to be a little more clear about what we think, if I could.
DR. GORDON:
Sure, go ahead.
DR. FINS:
If we can nail this down, because the specific question is whether or not
we feel under the umbrella of DSHEA, whether additional information about the
toxicity, the risk, the drug interactions, all of that information should now be
included, not making the kind of claim for efficacy stuff which is clearly
prohibited under DSHEA, but in the spirit of protecting the public, that we
would recommend a consideration of that kind of information in the package
insert.
I didn't hear people against that, but I just wonder if we could kind of
get more clarity on that point.
MR. CHAPPELL:
Well, at the present time, it is against the law.
MR. DeVRIES:
I understand that.
DR. FINS:
But we are here to recommend modification or reconsideration, again,
trying within the spirit of the existing law, within the spirit of DSHEA, FDA
might be able to make, not a statutory change, but a regulatory interpretation
in the context of what is going on here.
DR. GROFT:
When you get into your work in different areas, I think it is an area
that we need to explore further, and I am never hesitant, and I think it is
within our mandate that was provided in the Executive Order, for us to make
administrative and legislative recommendations on what we feel is necessary to
improve the access and delivery of CAM products and services.
To me, I think it is just something we have to look at in greater detail,
and if the Commission feels that some changes are necessary, I think we have to
be willing to go ahead and make those changes and recommendations to whoever is
appropriate.
DR. GORDON:
Thank you.
Yes, I feel the mandate is not only there in terms of safety issues,
Tieraona, I feel the mandate is also, is it possible to provide information if
there is a meta-analysis of studies on St. John's wort; is there some way that
we can make a recommendation that that information be made available.
DR. LOW DOG:
What I think we would like to do is we would like to separate that
recommendation into probably two parts, to two, one really looking at benefit
and claim information, and the other looking at potential interaction and side
effects, and we will work on that.
DR. GORDON:
Joe, go ahead.
DR. PIZZORNO:
I would like to second the issue about more appropriate language for
making claims, because my concern is without being able to make appropriate
claims, such as when there really is clinical evidence, that without being able
to make claims, you kind of open up the door to anything being claimed, but if
you have a good quality claim opportunity on the label of practice materials,
then, people know they can write on this and they don't have to believe or
consider the other stuff.
DR. GORDON:
David.
DR. BRESLER:
Just a point of information. Can a label refer people to an information
source, can a label refer people to a book, an article, or an Internet site?
DR. GORDON:
I think that what we need to do is explore all those questions. Again, we are
taking this very seriously, as we should, but I think Steve's point is well
taken, we can make recommendations.
Our job is to help the public be better informed and use these products
safely and appropriately, and so I think we are in a position where we can make
recommendations.
The question is what kind of recommendations and how we should make
them.
DR. GROFT:
Just to bring up to date a little bit, one of the comments that were made
when we received the Interim Progress Report we submitted for approval, one of
the comments that came back from the FDA was the suggestion that perhaps we need
to be more aggressive in recommending that or encouraging how we want to word
it, that sponsors move products to a New Drug Application stage that Tom
mentioned, as far as only then, to me, is adequate information really available,
that is looked at, is reviewed, peer reviewed, and then said this is the current
state of knowledge.
But I think realistically, we are now in the Internet age, and
information that years ago you only could go find way deep in the literature, is
not up front on page 1. I think we have got to look at how people are
retrieving information. We have heard how people are retrieving
it.
I think we need to be rather aggressive in our stance of what we are
saying that people need. I think that is realistic for us to do, as
well.
DR. GORDON:
So, this is an issue we really want, you take back, consider, listen, and
all those who are interested in this group, please be in touch with Tieraona and
David, and help them work on this issue.
Let's move along. Nos. 15, 16, and 17, we changed "purity" to
"quality" and "safety," and there was general agreement about that. There was general
agreement about the recommendations although there was some concern on No. 17
whether, if No. 16 were enacted, if GMPs were actually put forward, whether we
needed to mandate the domestic surveillance, as well as international. So, maybe you can
just bring that piece of it back.
No. 18.
There was concern with the FDA, that on the advisory board, there be the
kind of clinical expertise that is necessary to help evaluate some of these
approaches.
There was agreement about the recommendation as a whole.
That was the only area where there was an additional feeling that it
would be helpful, since there already is an advisory board, we don't need to
make that recommendation, but that clinical expertise be included on the
advisory board.
That is the recommendations, and it is time for lunch.
MS. AXELROD:
There is another part to that last one, that Wayne had wanted the staff
part to be deleted, the adequate staff part.
DR. GORDON:
Right.
DR. WARREN:
When we start talking about the labeling of these dietary supplements and
all their possible interactions with drugs, I was just kind of tipping the scale
to one side.
Shouldn't methotrexate have a label on it that says don't use it in
combination with B complex vitamins.
DR. GORDON:
Good point.
Let's talk a little about that as a new issue, and then we can report
back to this group.
Let's bring that up again, if we can bring that up on Saturday. Thank you.
DR. GROFT:
I would just like to remind you that after these recommendations are
formulated here on the next three days, we are going to meet with the federal
agencies involved and others to talk about what the Commission is thinking and
to get their input into where things are currently and how might they be
changed.
I think there are a number of federal agencies that would like to see
changes, but until you get a legislative approach, things can't change because
of the requirements.
We will be doing some follow up on this meeting aggressively with the
federal agencies.
DR. GORDON:
This is great.
Thank you everybody for being really on time.
[Applause.]
MS. CHANG:
Lunch is in Conference Room A, which is across the hall and down a
bit. This room
will be closed during our lunch break, so, visitors, you will have to go
outside. You
can leave your books and everything on the table, and we will reconvene at
1:30.
[A lunch recess was taken at 12:30 p.m.]
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