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NCH Submits Comments on NCCIH's Draft Strategic Plan

April 18, 2016
Over the past year, the National Center for Complementary and Integrative Health (NCCIH) has been working to update its strategic plan. The new strategic plan will set the stage for NCCIH's research priority setting over the next 5 years. To develop this plan, NCCIH has assessed developments in science, medicine, and health care and requested input from varied stakeholders, including researchers, health professional organizations, the public, and our advisory council.
 
NCCIH recently posted a draft of this strategic plan and invited comments from key stakeholders, included NCH. Below are the comments submitted by NCH Board Member, Tina Quirk, on behalf of NCH:
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April 15, 2016
 
The National Center for Homeopathy, a non-profit, consumer-based organization, appreciates the opportunity to comment on the 2016 NCCIH Strategic Plan. Homeopathy is a complete system of alternative medicine that treats both acute and chronic illness, as well prevents disease and promotes health. The National Center for Homeopathy educates consumers, plays an important role in the continuing education of practitioners, and is dedicated to making homeopathy more accessible to the public. We inform legislators and work to secure homeopathy’s place in the U.S health care system while ensuring that homeopathy is accurately represented in the media. Each of the 2016 Strategic Plan’s Objectives and Strategies has ramifications for homeopathy, which we note below:
 
Objective 1: Advance Fundamental Science and Methods Development
The National Center for Homeopathy is disappointed to see the continuing application of a very narrow perspective on the approach to research in the complementary and integrated health arena. Searching for the mechanism of action, a scientifically-driven focus can prove elusive for many complementary health approaches. In fact, widely-used drugs and treatments have been and are still being used without knowledge of how they work. Years of research have yet to reveal the basic mechanism of homeopathy, yet homeopathy is the second-most widely used alternative health system in the world.  
 
Recently, Dr. Luc Montagnier confirmed the capability of water to hold and transfer energetic information.  Another recent study of the behavior of nanoparticles has opened the door to understanding the action of homeopathic preparations (Dr. Iris Bell).  Additionally, many randomized controlled trials have shown effectiveness of homeopathy for a variety of conditions.  With its safety record, ease of use, and scarcity of side effects, homeopathy’s effect on health benefits, resiliency, and well-being should be a research priority. And in these studies, the research design must be both scientifically rigorous and appropriate to the integrity of homeopathic principles and practice.
 
Objective 2: Improve Care for Hard-to-Manage Symptoms
With the prevalence of opioid overuse and misuse, it is essential to explore alternative strategies for chronic pain (as noted in the NCCIH strategies).  Homeopathy should be in focus for its effectiveness in reducing pain both acutely and in chronic conditions, along with its lack of serious side effects.  Homeopathy should also be researched for treating anxiety and depression.  Currently research into homeopathic treatment of depression is being conducted in the UK.   
 
Comparative effectiveness studies are most appropriate for homeopathy and other complementary and integrative approaches and the results are easy to apply in “real world” settings.
 
Objective 3: Foster Health Promotion and Disease Prevention
We want to commend NCCIH for expanding its focus to include wellness and health promotion, which is a step toward shifting away from the disease management paradigm in a more positive direction.  However, we do think it would be more helpful to change the terminology in Objective 3 to eliminate the reference to “disease” altogether and focus on health and wellness, which is more positive and encompasses a more proactive approach to health.  
 
While resiliency is the research outcome recommended by NCCIH, we suggest that a systems approach be used in any research design.  This is substantiated by the observation in the Strategic Plan that complementary health approaches are used more often for wellness goals than for treating a specific illness.  Wellness is the result of complex, interactional processes in the organism and needs to be approached from a “whole person” view.  Homeopath and researcher, Dr. Iris Bell, has presented a complex adaptive systems approach that is most appropriate for research in homeopathy. ("A complex systems science perspective for whole systems of complementary and alternative medicine research." Forschende Komplementarmedizin 19(1) 7-14. doi: 10.1159/000335181) 
 
Although we believe that exploring the demographics and behaviors of users of complementary and integrative practices is an important goal, we disagree with using this information to target and influence adherence to conventional practices, such as standardized immunizations and medical screenings.  It is our opinion that this is not the most optimum use of the data.  Individuals should be well-informed to make their own decisions about practices that enhance their health. The Strategic Plan states that this group of users is healthier, with healthier behaviors.  If research shows improved resilience to infection and disease for those who use complementary and integrative practices, then investigation into the need for standardized mass immunizations and screening procedures should be undertaken. This research may identify a more individualized and targeted use for these mass procedures.
 
NCH is also pleased to see strategies that are inclusive of vulnerable and underserved populations and that move away from a clinic-based system.  However, it is important to ensure that health and wellness programs are culturally sensitive and tailored to reach and effectively communicate to a range of diverse populations.  Cultural sensitivity encompasses more than just making sure programs and materials are in languages understood by participants.  It also means meeting people where they are both physically and philosophically.  Homeopathy is particularly suited for these groups, as it does not need extensive laboratory or diagnostic tools and is low-cost.
 
Objective 4: Enhance the Complementary and Integrative Health Research Workforce
Researchers must be knowledgeable about the modality they are researching.  However, most homeopaths are not researchers.  Therefore, collaboration between experienced researchers and experienced homeopaths is the best solution for rigorous and useable research.
 
Objective 5: Disseminate Objective Evidence-based Information on Complementary and Integrative Health Interventions
Research results should be disseminated to all health care providers and they should be encouraged to refer patients to appropriate integrative health care practitioners. All professionals related to health care should be educated on integrative health approaches, such as homeopathy.  In addition consumers and policymakers should familiarize themselves on integrative approaches in order to be able to make and support policy decisions.  The National Center for Homeopathy, a primary education source for consumers in the US, has informative videos and articles available through its website and webinars.  (www.nationalcenterforhomeopathy.org)
 
Respectfully submitted on behalf of the National Center for Homeopathy,
Tina Quirk, RN, MS, CCH (Certified Classical Homeopath)
Board Member, National Center for Homeopathy