Homeopathy groups’ attack on NHMRC – the missing submission

The Australian homeopathy industry has made a submission to the Commonwealth Ombudsman regarding the NHMRC’s report on the industry. But two of the three organisations that apparently made the submission are not acknowledging that they’ve done it, and the third only makes a very brief passing reference to it. And there are even questions about the submission’s very existence.

The 2015 NHMRC report, titled “Evidence on the effectiveness of homeopathy for treating health conditions”, concluded that there are “no health conditions for which there is reliable evidence that homeopathy is effective”. The report received worldwide coverage and was seen as being very damaging to the homeopathic industry. This makes the apparent lack of interest by those organisations most affected by it surprising, intriguing and even suspicious.

Dated August 2016, the submission by Complementary Medicines Australia, the Australian Homoeopathic Association, and the Australian Traditional-Medicine Society, is that the report “is inaccurate, highly misleading to the public and unjustly damaging to the credibility of the homeopathy sector. It is therefore essential that all published documents relating to the Homeopathy Review are rescinded in their entirety.”

But for such an important response in the face of such damning criticism, it seems that the support for the submission has been diluted to almost non-existent status (or, at least as far as we can tell following a detailed search of the complainants’ publicly available online information).

To add further mystery to the issue of the missing submission, while the Ombudsman’s media office says it cannot comment on whether a submission is under review, one source within that same organisation told Australian Skeptics that no submission had been received.

Frankly we became suspicious of the claimed complaint when we noticed that Complementary Medicines Australia doesn’t include any submission to the Commonwealth Ombudsman re the NHMRC’s homeopathy report in its historical list of submissions.

In a section of the list titled “Submissions – Therapeutic Goods Administration” (although many of them are not to the TGA), it does include a submission made in August last year on “the Structural Review of NHMRC’s Grant Program”. However, this does not mention the homeopathy report, despite the apparent concurrency of the dates of the submissions.

In one other part of the list, which covers Other Submissions, it mentions a response to the NHMRC’s information paper on the effectiveness of homeopathy in the treatment of health conditions. This response was made in June 2014, more than two years before the submission under discussion.

Likewise another co-complainant, Australian Traditional-Medicine Society, does not mention the submission. It does mention the NHMRC in a press release issued in early April of this year on a pro-homeopathy film, Just One Drop. (The film covers the basic premise of homeopathy and does refer to the NHMRC report.) But the ATMS’s press release makes no mention of a submission: “The Australian Traditional-Medicine Society (ATMS), Australia’s largest national association representing professional practitioners of natural medicine, including accredited Homeopaths, anticipates that this film will open up a new conversation on Homeopathy, and particularly on the National Health and Medical Research Council (NHMRC) report into the effectiveness of Homeopathy that was released in 2015.”

Note, this release was published eight months after the supposed submission, and yet it can only bring itself to mention the 2015 report.

In fact, the only one of the three apparent co-complainants that does mention the submission is the Australian Homoeopathic Association, and even then (as far as we can find) only in its news item on the Just One Drop film. (The news item is currently unavailable.)

The film, apparently, “Exposes Australian Research Scandal” and “has brought Australia’s scientific research community under international scrutiny”: “The AHA is issuing the following media release on the occasion of the premiere of the documentary film Just One Drop in London. It marks the beginning of the AHA’s media campaign, the next step in the endeavour to have the NHMRC ‘Homeoathy [sic] Review’ rescinded, with the on-going complaint still before the Commonwealth Ombudsman. … A formal complaint against the NHMRC is now before the Australian Ombudsman detailing procedural and research flaws, conflicts of interest, and reporting inaccuracies. In an Executive Summary of the complaint it concludes the NHMRC’s findings are ‘inaccurate, highly misleading to the public and unjustly damaging to the credibility of the homeopathy sector’.”

In a footnote, it links to that executive summary, and makes the point that “AHA’s complaint to the Australian Ombudsman was submitted jointly with Complementary Medicines Australia (CMA) and the Australian Traditional-Medicine Society (ATMS)” – the two organisations that don’t mention it.

(The executive summary is the only element of the submission that is publically available. It is four pages plus a covering sheet, and basically outlines the argument supposedly developed by the three complainants.)

The AHA did issue an open letter to the NHMRC in March 2015 in response to a draft version of the report in which it criticised the methodology used, ie similar to the content of the supposed 2016 submission. The only submission it refers to in that open letter is one made in 2011.

And that’s it – the apparent total of references to the submission by its three authors is a single mention by one of them in a press release on a film.

Despite this, the supposed submission has received coverage in other places. Michael Marshall of the Merseyside Skeptics and Good Thinking Society alerted us to a piece in the UK-based medical conspiracy site What Doctors Don’t Tell You which states definitively that “the Commonwealth Ombudsman is investigating the review’s procedures”, something which is not at all confirmed. It was Marshall’s comment which set the ball rolling on this investigation.

The one organisation that does go full-bore (if you can call it that) on the submission is the Homeopathy Research Institute.

On its website under the heading “The Australian Report”, the HRI has a section titled “Complaint submitted to Commonwealth Ombudsman” in which it says “In August 2016 HRI’s in-depth scientific analysis was used as part of a submission of complaint to the Commonwealth Ombudsman brought by Complementary Medicines Australia, Australian Homeopathic Association and Australian Traditional-Medicine Society.”

It links to the executive summary.

Perhaps ironically, neither the HRI nor its contribution to the submission are mentioned in the executive summary.

It adds that “As the complaint is ongoing, our full analysis – some 60 pages – cannot be shared as yet, but HRI’s data provided details demonstrating the following scientific failures by NHMRC which necessitate retraction of the Australian Report. [It then lists a series of issues it has with the report.] … The complainants are now waiting to hear back from the Ombudsman regarding their submission. As NHMRC’s inaccurate Homeopathy Review has had a significant impact on the field of homeopathy research worldwide, HRI will share any news regarding the complaint as the case progresses.”

Those complainants waiting to hear back are the three organisations who seem to be ignoring the submission in the first place, so they may be waiting but not, apparently, with bated breath.

In a press release titled “World-renowned government research department misled scientists and the public over homeopathy” the HRI refers to “Formal complaint to Commonwealth Ombudsman details inaccuracies, mishandling of evidence, and conflicts of interest”. That, and a link to the executive summary as a footnote, are the only references to the submission.

The rest of the release looks at the NHMRC’s procedures, and the Just One Drop film. The HRI points out that it worked “with the Australian Homeopathic Association (AHA) to conduct a thorough investigation to fully uncover exactly what went on”. Note, no reference to CMA or AMTS.

So what are we to make of this silence on an important submission in response to a major and devastating report? The lack of any in-depth mention of the submission by the three co-complainants made us suspicious whether there was any serious submission at all. Certainly we are concerned that the Commonwealth Ombudsman’s office is cited in reference to a submission that none of the supposed authors of that submission apparently take seriously (if they mention it at all).

It has been suggested that perhaps the submission was sent to a different organisation, the National Health Practitioners Ombudsman, instead of the Commonwealth Ombudsman. However, a spokesman for that organisation says they have not received a complaint, that it wouldn’t have been in their area anyway, and that if they did receive anything like the NHMRC complaint they would recommend the complainant take it to the Commonwealth Ombudsman.

Overall, this process is potentially an abuse of the important role the Commonwealth Ombudsman plays, involving it in a supposed ‘scientific’ dispute between a highly respected scientific research body and organisations representing homeopathy, a proven pseudoscience, and their supposed submission.

The importance of the submission as outlined by the HRI may very well be an example of over-reach. If the submission is not of great interest to its own authors, and if it exists at all (and one contact at the Commonwealth Ombudsman said they had not received it), then it can safely be ignored by everyone else.

Maybe the three complainants do support the submission, but they certainly are not showing it. If they do have evidence of support – strong support – then Australian Skeptics would love to see it. But, in the meantime, we will treat the whole situation with a heavily diluted grain of salt.

3 thoughts on “Homeopathy groups’ attack on NHMRC – the missing submission”

  1. I think what may have happened is they wrote the submission, diluted it a few times so not even letters were left and so submitted a blank document.
    This would not be registered so noone knows about it.

  2. Whilst I don’t like the idea of going around the official spokesperson at the Ombudsman, I appreciate how fairly you’ve reported this.
    thank you,

  3. As usually, the industry of pseudoskepticism and the Marshall business take the smear and the misinformantion in their hands.

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