standards committee agenda for the meeting to be held on 25 … · 2017-02-27 · sc jan 17 ai 00...

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Standards Committee Agenda for the meeting to be held on 25 January 2017 at 10.15am

1. Apologies for absence, declarations of interest and minutes of the meeting held on 28 September 2016

2. Standards and Advice Update Paper attached

3. Matters for decision:

a. Veterinary fees b. Complementary/Alternative Medicines (CAMSs) Review c. Committee Profile: Skills Matrix

Papers attached

4. Matters for report

a. Disciplinary Committee Report b. Riding Establishments Sub-Committee Report

Papers attached

5. Confidential Matters for report

a. Certification Sub Committee Report b. Recognised Veterinary Practice Sub-Committee Report c. Ethics Review Panel Report d. Pet Blood Banks

Papers attached

6. Risk and equality

Oral report

7.

Any other business and date of next meeting 26 April 2017

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Standards Committee 2017 Chairman: Mr David F Catlow BVSc MRCVS Vice-Chairman: Dr Thomas Witte BVetMed DipACVS DipECVS FHEA PhD MRCVS

Members:

Mrs Elaine Acaster OBE DipDSc Dip Dietetics

Mrs Lucy Bellwood RVN -Veterinary Nurses’ Council Representative

Mrs Jo Dyer BVSc DipM MRCVS

Professor Ewan Cameron BVMS PhD MRCVS

Ms Mandisa Greene BSc BVMS MRCVS

Dr Kate Richards BVM&S DipM MRCVS

Dr Christopher (Kit) Sturgess MA VetMB PhD CertVR DSAM CertVC MRCVS

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Meeting Standards Committee

Date 25 January 2017

Title Standards Committee Minutes

Classification Unclassified

Summary The Committee is asked to adopt the minutes of the meeting

held on 28 September 2016

Decisions required None

Attachments None

Author Vicki Price

Senior Advice Officer

[email protected] 0207 202 0303

Robert Pragnell

Standards and Advisory Manager / Solicitor

[email protected]

0207 202 0763

mailto:[email protected]


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N. B. This page is intentionally blank

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Standards Committee Minutes of the meeting held on 28 September 2016

Members: Mr David Catlow - Chairman

Mr Thomas Witte - Vice Chairman

Mrs Elaine Acaster

Mrs Lucy Bellwood - Veterinary Nurses’ Council Representative

Mrs Joanna Dyer

Professor Ewan

Cameron

Dr Mandisa Greene

Dr Katherine Richards*

Dr Christopher (Kit)

Sturgess

*absent

In attendance:

Dr Christopher Tufnell

-

President / Committee Observer

Professor Stephen

May - Junior Vice President / Committee Observer

Dr Melissa Donald - Council Member / Committee Observer

Mrs Julie Dugmore - Head of Veterinary Nursing / Committee Observer

Mrs Eleanor Ferguson - Acting Registrar / Head of Professional Conduct

Ms Laura McClintock - Standards and Advisory Manager / Solicitor

Mrs Vicki Price - Senior Advice Officer

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Welcome, Apologies and Declarations of Interest

1. The Chairman welcomed everyone to the meeting. Apologies were received from Dr Kate

Richards. Written comments were received from Dr Richards and RCVS Council member Mr

Chris Barker.

2. Professor Cameron declared that in addition to be being Head of School at Glasgow he is now

Chair of the Veterinary Schools Council, and as head of a large referral hospital has a particular

interest in clinical and client records.

Minutes 3. The Committee adopted the minutes of the meeting held on 27 April 2016.

Standards and Advisory Update 4. The Committee noted the update paper and the Chair highlighted the following items:

a. Veterinary nurses and acupuncture – Meeting with the Association of British

Veterinary Acupuncturists (ABVA)

It was noted that the ABVA should not expect the College to determine the efficacy of one style of

acupuncture over another, but limit advice to what can be legally delegated in accordance with

Schedule 3. The Committee also recognised the importance of seeking appropriate opinions or

views from relevant associations or experts to inform discussions, where appropriate.

b. Ethics Review Panel (ERP) for practice-based clinical research

One member asked about the process for recruiting members of the Ethics Review Panel, noting

that a robust process is crucial to ensure that the panel establishes a strong reputation. The

Standards and Advisory Manager summarised the process followed to recruit the panel, including

strategy meetings with representatives from external bodies, and noted that this was discussed at

previous Standards Committee meetings.

c. Compulsory microchipping regulations

The Standards and Advice Team has continued to receive queries from veterinary surgeons and

veterinary nurses about how the compulsory microchipping regulations apply in practice, and that

Defra has not yet produced guidance notes on the regulations. The Committee acknowledged

that the Standards and Advice team has continued to highlight the types of questions that are

being asked to Defra, and that Defra has not indicated by when the proposed guidance might be

published.

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d. Meeting with Pet Blood Banks UK (PBB) The Chair noted that the meeting with PBB covered some interesting issues around how donor

cats might be kept in order to obtain ‘clean’ blood, that is, whether they would need to be colony

cats or indoor cats, and that anecdotally blood is being imported from overseas due to the lack of

supply. It was noted that PBB is a charity and could keep colony cats under ASPA licence as is

currently done with another organisation, however, this would raise an issue of reputation for PBB

as well as the question of whether this would amount to blood farming. The major difference for

home kept cats who are regular donors is that these cats would not be kept purely for the

purpose of blood production. However, there would still be a number of issues to consider with a

donor programme in order to remain within the boundaries of recognised veterinary practice.

One member stated that sedation of cats for blood donation carries a risk and this was a matter

PBB would need to face. The Committee also noted that the proposal raises the ethical issue of

the contradictory distinction that humans are prepared to make between non-companion animals,

who may be farmed, and companion animals, who may not. Further updates will be provided to

Standards Committee at the next meeting. One member asked for a sense of the scale of the

PBB programme to be included.

Action: Standards and Advice Team

(e) The use of prosthetic eyes

The Committee noted that the Science Advisory Panel has been asked to look at the evidence

relating to the implantation of prosthetic eyes in dogs so that the Committee can consider the

matter further in due course.

(f) Practice Standards Update

The Committee noted the update. There has been good feedback from practices on the testing of

the new IT system; however, there are a number of technical issues that require further work

before completion.

Matters for decision Veterinary fees 5. The Committee was asked to consider whether any amendments or additions might be made to

Chapter 9 of the Supporting Guidance – ‘Practice information, fees and animal insurance’, to

encourage veterinary surgeons to better communicate on the issue of fees and to better educate

members of the public about the value of veterinary care. The Committee was also asked to

consider whether any other tools might assist in this regard and whether there is anything the

College could do more generally, such as producing fees related case studies.

6. On the issue of the College’s jurisdiction in relation to fees, the Acting Registrar advised that there

are a number of issues that make it difficult to take enforcement action. These include the difficulty

of reaching the required standard of proof, the difficulty in demanding the disclosure of business

records, and that high prices can often be justified on the basis that they subsidise other areas of

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the business, such as out of hours care. The difficulty of enforcement was underlined by the fact

that the Disciplinary Committee has only considered one fees related case (the Bailey case), in

which it did not find that the fees charged were so extreme as to constitute disgraceful conduct in

a professional respect. The Committee recognised the limited value of including a provision in the

Supporting Guidance, which is impossible to enforce.

7. There was some discussion of the College’s power to establish a fee framework or structure. One

suggested that professions do not necessarily operate in the same way as other free markets and

suggested that it might be reasonable for the College to set expectations of what level of fees

would be considered excessive or unprofessional. In response, it was suggested that the College

cannot set fees. This could be viewed as anti-competitive, and there would also be some practical

issues in regulating veterinary fees when related markets such as the medicines market, are

determined by market forces. It was noted that the Competition and Markets Authority (CMA) has

a role to play in looking at whether market position is being abused by dominant entities. It was

also noted that matters such as the number of veterinary surgeons and nurses, veterinary

practices and veterinary education providers are determined by the open market, not the College,

and that the College simply sets standards.

8. The Committee acknowledged that there is a need to better communicate to clients the value of

veterinary services, and to challenge the perception that veterinary practices are making large

profits. The Committee noted that some work is being done on how veterinary practices work out

their fees as part of the Vet Futures project. One member suggested that it would be useful to do

some economic testing to gather data on the extent to which fees influences client choice of

veterinary practice.

9. The Committee agreed that the existing professional obligations of veterinary surgeons and

veterinary nurses to communicate fees to clients and to gain informed consent in relation to fees

should be emphasised, to more effectively set client expectations around veterinary fees. In

particular, it was agreed that the Supporting Guidance should be strengthened to place further

emphasis on providing accurate initial fee estimates and accurate estimates for different stages of

treatment; on explaining the cost of out of hours care; and on providing detailed practice fee

information such as leaflets.


Clinical and client records 10. The Committee was asked to consider proposed amendments to Supporting Guidance Chapters 5

and 13 to address a number of issues relating to clinical records currently affecting the profession.

This included new guidance on dealing with amendments or additions to records; dealing with

factual inaccuracies and client disputes; access to and provision of records; and retention and

storage of records. The Committee acknowledged that the Veterinary Defence Society (VDS) had

seen the proposed amendments and felt that they made good sense.

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11. In relation to Chapter 13 – ‘Client and clinical records’, the Committee discussed the amendments

proposed by the Standards and Advice Team and suggested some minor changes to them. The

changes include specifying that not only relevant clinical information but also information in the

interests of the treatment of the patient should be provided to colleagues taking a case over, and

updating the discussion of ownership of diagnostic images to reflect that these are no longer

generally provided to clients in the form of physical images following consultation with the VDS.

12. In relation to Chapter 5 – ‘Communication between professional colleagues’, the Committee

approved the amendments to the guidance proposed by the Standards and Advice Team.


Telemedicine consultation

13. Standards Committee has committed to running a consultation process on telemedicine, with the

purpose of gathering feedback from the profession and the public to assist in developing an

appropriate regulatory framework for telemedicine services. The Committee was asked to

consider the draft consultation outline and questionnaire and to provide feedback on these.

14. The Chair explained there are two streams of work relating to telemedicine. Operational Board has

asked Standards Committee to focus on issues relating to telemedicine, and wider issues related

to the development of technology will be considered as part of the College’s strategic work.

15. The Chair put forward two key questions for consideration by the Committee in relation to the

consultation:

(1) What do we need to know / what questions should we ask?

(2) Who should we ask?

16. The Committee agreed that what is meant by telemedicine should be clearly defined and that the

definition should be capable of encompassing new technologies. It was also agreed that a

distinction should be made between primary clinician-client telemedicine and inter-professional

telemedicine, and that the key question will be who is the orchestrator of the care.

17. The Committee considered that rather than look at each type of telemedicine or technology, the

focus should be on who is responsible for care. It was noted that it will be difficult to regulate

overseas providers, and as Adam Little suggested, the College could invite providers to be

regulated and make this attractive or risk becoming irrelevant.

18. The Committee discussed the issue of limited service providers and whether the regulatory

framework might be softened to give space for new models to enter the market. Comparisons

were raised with limited service provides currently operating in the veterinary sector, and triage

advice services currently operating in the human healthcare sector. It was suggested that having

one person in charge would address many of the welfare issues posed by these models, and

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therefore future regulation should focus on relationships rather than physical assessment, but that

it may be difficult to enforce a requirement to act as primary clinician if no-one takes responsibility.

19. In relation to the questionnaire, it was agreed that the questions should be revised to higher level

and more principles based questions, rather than technology or condition based questions, and to

cover a broader range of services, including primary, limited and out of hours services, to ensure

that the conversation about broader issues than technology could be captured.

20. The paperwork will be revised in line with the Committee’s suggestions and will be circulated to

Standards Committee for further consideration before the consultation is launched.


Feline renal transplants 21. In April 2016 Standards Committee approved new guidance on feline renal transplantation

procedures, following consideration of evidence presented by the Science Advisory Panel as well

as input from RCVS Council. The guidance reflects the Committee’s view that it is only ethically

and legally acceptable to transplant a kidney from a dead animal, and that living and pre-

euthanasia cats (defined as animals under terminal anaesthesia before undergoing euthanasia for

an unrelated condition) are not acceptable transplant animals.

22. The new guidance was subsequently reported to RCVS Council in June 2016 and overall there

was no objection to this. However, one Council member suggested that requirements relating to

the expertise of veterinary surgeons carrying out transplantation procedures and aftercare of the

recipient, which were addressed in the previous guidance, had been omitted from the new

guidance. Accordingly, the Chair agreed to take these points back to Standards Committee for

further discussion.

23. The Committee discussed whether the additional text was too prescriptive and whether this

specific treatment scenario needed to be addressed in the Supporting Guidance. While the

Committee recognised that the guidance does not generally cover specific treatment scenarios,

the Committee concluded that given the careful ethical consideration that has been given to this

particular procedure, it was appropriate to provide specific guidance addressing the issue of

recipient welfare.

24. The Committee approved the suggested additional text proposed by the Standards and Advice

Team with some minor amendments. The Chair will present the revised text to RCVS Council

once the required amendments have been made.


Matters for report:

a. Disciplinary Committee Report

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The Committee noted the report.

The Acting Registrar also reported that on 22 September 2016, the Disciplinary Committee had

found three heads of charge proved against Mr Rahul Chandulal Shah in respect of his care for a

six year old dog called Shadow and subsequent dealings with Shadow’s owner.

One member asked for clarification on when matters are dealt with under the Health Protocol.

The Acting Registrar discussed the procedure, including that it is the Preliminary Investigation

Committee that decides whether a case should be referred to the Disciplinary Committee or RVN

Disciplinary Committee for a formal hearing or whether it would be more appropriate to take a

medical approach to the case.

b. Riding Establishments Sub-Committee Report

The Committee noted the report. The Standards and Advisory manager reported that there has

been no further feedback from Defra to date about the review of animal licensing legislation.

The President noted that responsibility for training of riding establishment inspectors was formerly

shared between the College and the British Veterinary Association (BVA), and that the College

has now taken responsibility for the training, which makes a highly valuable contribution to the

welfare of animals in facilitating low cost inspections of premises by veterinary surgeons.

Confidential matters for report: 25. The Committee considered the following confidential matters for report:

a. Certification Sub-Committee Report

The Committee noted the report and recognised the important role of this Sub-Committee in

providing advice and guidance to veterinary surgeons involved in Government export work.

b. Recognised Veterinary Practice Sub-Committee Report

The Committee noted the report as well as the involvement of the RVP Sub-Committee with the

Ethics Review Panel. The Committee also noted that the work of the RVP Sub-Committee is

increasing.

Any other business

26. The Committee considered the following items:

a. Skills matrix for Committee members The Committee discussed the proposal to move towards a skills matrix approach to the

appointment of committee members, and to widen the pool of potential committee members to

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ensure that agreed skills gaps can be filled and that committees members have a broad mix of

experience and perspectives. The Committee also considered the draft skills matrix circulated by

the President.

Overall, the Committee considered that the starting point should be to identify what skills are

desirable for Standards Committee members. It was generally agreed that soft skills such as

diplomacy are important, and that technical skills are less important as technical experts can be

engaged as consultants. It was also agreed that representation of a broad coverage of areas of

practice and types of practice would be useful, for example, covering small and large animal and

general, referral and corporate practice, and that thought should be given to succession planning.

b. Practice poster on the veterinary / client partnership

The Committee was asked to consider a proposed practice poster outlining mutual

responsibilities in the veterinary professional / client relationship, aimed at promoting the value of

veterinary care and clarifying mutual expectations. The draft poster was developed following an

approach to the College by Arlo Guthrie, editor of vetsurgeon.org, after a veterinary surgeon

shared a similar poster they had seen in a French veterinary practice on the forum. The

Committee strongly supported the poster, and made some minor suggestions for how it might be

improved.

Risk and equality

27. The Committee identified the telemedicine project as clearly carrying some risk given that there

are many unknowns in this area, and agreed that the Committee should remain alert to these

potential risks in the course of the project and in the future.

Date of the next meeting

28. The date of the next meeting is 25 January 2017.

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Meeting

Standards Committee

Date

25 January 2017

Title

Standards and Advice Update

Classification

Unclassified

Summary Standards Committee is asked to note this brief update on a

number of ongoing matters dealt with by the Standards and

Advice Team from the date of the last meeting on 28

September 2016.


Attachments Annex A: Standards and Advice Team Review of the Year

Author Vicki Price

Senior Advice Officer

020 7202 0303

[email protected]

Robert Pragnell

Standards and Advice Manager / Solicitor

020 7202 0763

[email protected]



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Standards and Advice Update (September 2016 to January 2017)

Below is a brief report updating the Standards Committee on a number of ongoing matters dealt with

by the Standards and Advice Team from the date of the last meeting on 28 September 2016:

Veterinary medicines Meeting with the Veterinary Medicines Directorate (VMD)

1. Staff of the College met with the VMD at their headquarters on 29 November in relation to a wide

number of issues. The VMD provided an update on the proposed EU Regulations on veterinary

medicinal products. They continue to attend regular meetings, and drafting is now at the second

of three read-throughs after three years. Proposals to limit internet sales to non-prescription

products only, and to limit who may make a prescription to veterinarians one were specifically

noted. It was accepted that the impact of the proposals would depend on the ongoing relationship

with the EU. VMD gave assurances that they would remain engaged with the RCVS on the issue

and continue to represent the interests of the UK and object to certain proposals.

2. The VMD noted that Brexit had meant resources had been rededicated, many new legislation

projects were on hold and there remained a lot of work to be done. There was a review of the

inspection data and discussion of how further alignment could be achieved to ensure consistency

in approach. In particular, the issue of secure medicine cabinets was discussed and the VMD

position was queried as to whether they required cabinets not deemed sufficiently secure to be

replaced and if so in what timeframe. A joint inspection had previously been agreed but had not

been achievable since the previous meeting due to calendar constraints, but was hoped to take

place over the next year.

3. Witnessed destruction, consistent date labelling and use of medicines beyond the legal timeframe

was noted. It was not felt that most instances of non compliance indicated anything more than

either poor application of the law, eg not recording the date of first opening, or a reluctance to

waste expensive unused medicines. The pharmaceutical manufacturers were reported to be

considering supplying smaller measurements for some of the more significant

medicines/controlled drugs, commercially the pharmaceutical companies are not necessarily

motivated to do so. The VMD favoured such a move and had made this clear to the

manufacturers but felt there needed to be more pressure from the profession to secure a change.

4. There was a wider discussion of the problem of practices not updating their records and securing

medicines in the name of veterinary surgeons who have moved on. This again was deemed to be

less about intentional deception to secure medicines and more about poor business processes. In

most cases the named veterinary surgeon would not be aware that their name was still being

used. The RCVS agreed to consider what if any action could be taken to address this.

Meeting with the Competition and Markets Authority (CMA) 5. On 23 November, staff of the Standards and Advice Team met with representatives of the CMA in

order to update them on actions that the College has taken over the last year and is proposing to

take in relation to fair trading requirements. At the previous meeting the CMA had expressed

concerns about fair trading and prescriptions including limited awareness of the option of

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purchasing medicines online or other than from the prescribing veterinary surgeon’s practice. We

updated the CMA on actions taken to increase public awareness including the appearance of

Bradley Viner on the BBC 1 television show Rip Off Britain in which he made it clear that clients of

veterinary surgeons have the option of buying medications from the practice or seeking a

prescription to enable them buy them online or from other pharmacies. It had been agreed at the

previous meeting that an article would be included in the RCVS News reminding the profession of

its obligations relating to fair trading and prescriptions and a copy was provided.

6. There was a wider discussion of the type of advice calls received from the public pertaining to

advertising, estimates, insurance and price structures. The CMA were directed to the work being

undertaken by Vet Futures, proposed changes to chapter 9 of the guidance in relation to fees and

the practice poster on the relationship between the veterinary surgeon and client.

7. The CMA stated that they had no significant issues to raise with the RCVS and that in the absence

of any reason to do so there was no appetite at the CMA to take any action to review the current

position. The CMA is otherwise engaged in reviews of other areas and it was deemed very

unlikely that there would be any changes that will impact specifically on the RCVS. It was agreed

that the current arrangement of an annual meeting should continue and the next meeting was

tacitly agreed for November 2017. Practice Standards Update (report from Gemma Kingswell)

8. As reported at the last meeting of the Standards Committee, the response to the new scheme has

been very positive. At present 3102 practices, which equates to 58.6% of eligible practices, are

part of PSS and the popularity of the scheme continues to grow. This is demonstrated by the

number of new applications received between 1 October 2016 and 31 December 2016, which was

twice the number of applications received in the equivalent period the previous year.

9. Interest in the new PSS awards, which allow practices to achieve recognition in a particular area,

remains high. As of 4 January 2017, 121 applications for awards had been received in total and at

present, 46 practices have achieved 78 awards. Encouragingly, the feedback received by the PSS

team regarding the awards application process suggests that they are an effective way of

encouraging practices to strive for improvement.

10. In terms of the PSS modules, there have been no amendments to the requirements since the last

meeting of the Standards Committee. However at the Practice Standards Group meeting on 28

September 2016, it was agreed that the following should be added to the guidance notes for point

8.2.9 in Module 8 (in-patients): “The environment should be as calm and quiet as possible. Noise

producing equipment should be located as far from animals as possible and the frequency of its

use should be taken into account.”

11. As the Standards Committee will be aware, it was hoped that we would be in a position to launch

the new PSS IT system, ‘Stanley’, by the end of 2016. However, after a further period of user

testing, additional issues were discovered and it was agreed that it would not be appropriate to

launch the system to practices at this time. At present, Stanley is subject to further development

work to remedy these issues and it is hoped that we will be able to embark on a final round of user

testing at the end of May 2017. The IT Project Board continues to have oversight of this project.

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Ethics Review Panel (ERP) for practice-based clinical research 12. Since the Ethics Review Panel (ERP) began accepting applications for review on 1 August 2016,

five applications have been received. All of these applications were assessed by the full Panel at

its meeting of 6 January 2017. None of the applications have been rejected, but only one of them

has been approved without any corrections. Further details are included in the Ethics Review

Panel Report, listed at Agenda Item 5(c).

Tail Docking in Scotland

13. The Scottish Government is currently considering a legislative change to permit tail docking of

working Spaniels and Hunt Point Retrievers. Currently, the Animal Health and Welfare (Scotland)

Act 2006 prohibits the mutilation of animals, and there are no exemptions in any regulations for

non-therapeutic tail docking. It is also an offence to take a dog from Scotland for the purpose of

having its tail docked.

14. Following a consultation in early 2016, the Scottish Government has announced that the law will be

changed. If changed in line with the consultation proposal, the amendment would bring Scotland

into line with England, Wales and Northern Ireland, where specific legislative exemptions apply to

allow tail docking of working dogs of specific breeds for animal welfare reasons. Under the

proposal, the Scottish exemption would apply only to Spaniels and Hunt Point Retrievers, and

would allow only the last third of the tail to be removed (as opposed to no restriction on whether the

whole or part of the tail is removed in the other jurisdictions). For the exemption to apply, a

veterinary surgeon would need to be presented with sufficient evidence that the dog will be used

for work, and be satisfied that the pain of docking is outweighed by possible avoidance of more

serious injuries in later life.

15. Draft regulations have not yet been prepared. We have asked that the College be provided with a

copy of the draft regulations when they are ready, so that we can influence the final wording and

ensure that they are clear. When the new regulations have been approved, we will need to update

the discussion of tail docking legislation in the supporting guidance, and so this may be added to

the April meeting agenda if the regulations have been finalised by that time.

Compulsory microchipping regulations

16. At the start of 2016, Standards Committee approved guidance for veterinary surgeons and

veterinary nurses on the new compulsory microchipping regulations. In September, we advised

that we have continued to pass on to DEFRA typical queries that we receive from practitioners and

members of the public as to how the regulations should be applied in practice, and had indicated to

DEFRA that clear and succinct guidance on these matters would be appreciated by practitioners.

17. DEFRA have since advised us that they do not intend to publish any guidance on the regulations,

as they are unable to add new documents to the Gov.uk website. However, they are currently

drafting a Guidance Note which will be available for circulation to interested parties. In relation to

the Certificate of exemption, DEFRA have indicated that they do not intend to update it to address

deficiencies we had identified (such as omission of a date of certification, a lack of guidance on

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how to complete the description section, and the declaration referring only to the vet having

examined ‘the dog’, rather than ‘the dog being described’), and that it will continue to be accessible

only via the BVA website rather than directly via the DEFRA website.

18. DEFRA have also answered some of the specific interpretation questions that we put to them,

including in relation to microchipping of aggressive dogs and application of the health exemption in

this context, microchipping by RVNs, retention of Certificates of exemption, and the obligation of

breeders to have pups microchipped prior to sale. The Standards and Advice team will consider

whether the guidance on microchipping should be updated in light of the Guidance Note (once

finalised) and the specific responses that have been received from DEFRA, and will put any

proposed amendments to the Committee for approval.

Telemedicine consultation

19. In September, the Committee considered the launch of a consultation process on telemedicine,

with the purpose of gathering feedback from the profession and the public to assist in developing

an appropriate regulatory framework for telemedicine services. The Committee discussed the aims

of the consultation process and highlighted some key issues, including the question of who is

ultimately responsible for care, the regulation of limited and overseas service providers seeking to

utilise new technologies, and potential risks and animal welfare issues arising out of the use of new

technologies.

20. The Committee provided feedback on the draft consultation outline and questionnaire. In relation to

the questionnaire, it was agreed that the questions should be revised to higher level and more

principles based questions, rather than technology or condition based questions, and to cover a

broader range of services, including primary, limited and out of hours services, to ensure that the

conversation about broader issues than technology can be captured.

21. Following the September meeting, the paperwork was revised in response to the Committee’s

suggestions, and having regard to further input that was sought from David Catlow and Adam Little.

The consultation documents were then recirculated to the Committee for comment over the

Christmas and new year period via email. Detailed feedback has been provided by the Committee,

and at the time of drafting this report, the consultation documents are in the process of being

revised in consideration of this feedback. It is hoped that by the time of the January meeting or

shortly thereafter, a prototype of the online survey will be ready for consideration by the Committee,

prior to the consultation being launched in the first quarter of 2017.

Standards and Advice Team – Review of the Year

22. Each year, the Standards and Advice Team provide the Committee with a report on the work they

have undertaken over the course of the year, including the work carried out on behalf of the

Standards Committee. A copy of the report for 2016 is attached at Annex A.

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Standards & Advice Team

Review of the year

January to December 2016

Report of the work undertaken by the Advice Team in 2016, including the work carried out on behalf of the Standards Committee

Standards & Advice Team (current) Robert Pragnell, Standards & Advisory Manager

Vicki Price, Senior Advice Officer

Natalie Heppenstall, Standards & Advisory Officer

Beth Jinks, Standards & Advisory Officer

Standards & Advice Team (at start of 2016) Laura McClintock, Standards & Advisory Manager (until Oct 2016)

Rebecca Rafferty, Senior Advice Officer (on maternity leave from Aug 2016)

Natalie Heppenstall, Standards & Advisory Officer



1.1 The Advice Team is responsible for responding to enquiries about the standards expected of

veterinary surgeons and veterinary nurses. Often, those making enquiries will have read the

Codes of Professional Conduct and Supporting Guidance, but are seeking further advice on how

the standards apply in practice or to a particular or difficult set of facts or circumstances. When

responding, the aims of the Advice Team are as follows:

a. To provide clear, concise and consistent advice to help veterinary surgeons and veterinary

nurses understand their professional responsibilities;

b. To provide the advice necessary to support compliance with professional responsibilities and

to ensure that the advice can be relied on;

c. To offer suggestions about how professional responsibilities can be applied in practice while

at the same time recognising the limitations of the advice and the need for individuals to

exercise professional judgement at all times;

d. To distinguish clearly between professional requirements, legal requirements and suggested

good practice;

e. To facilitate appropriate veterinary experts to help inform the advice given where necessary

and to seek input from others such as Subject Boards, Committees, Sub Committees, VN

Council or RCVS Council;

f. To consider the impact of any advice or guidance so that it does not impose any unnecessary

burdens;

g. To create an environment where veterinary surgeons and veterinary nurses have confidence

in the advice they receive and feel able to seek advice without fear of triggering enforcement

action;

h. To provide advice in plain English and without using legal language;

i. To help the public understand what they can expect from their veterinary surgeons and

veterinary nurses;

j. To explain to the public how they can raise concerns if unhappy or unsatisfied or have

concerns about a potential fitness to practise or conduct issue;

k. To explain the areas on which the RCVS is not in a position to offer advice and the reasons

for this. For example, purely legal matters such as employment law, maternity rights, or

contractual or civil disputes;

l. To comply with RCVS service standards and department standards when responding to

enquiries; and

m. To direct enquirers to other source relevant sources of support and guidance, for example,

the Citizens Advice Bureau, the British Veterinary Association Legal Advice Line, other

representative organisations and professional indemnity insurers.

1.2 We also work in accordance with an Advice Risk Register, which deals with risks in the

context of the provision of advice and guidance and how these risks are properly managed

and controlled.

Work stream 1: Providing advice to the public and profession



Advice statistics

1.3 Below are some statistics relating to the total numbers of written enquiries and telephone calls

handled in 2016 (figures for the previous 6 years have been included for comparison

reasons). The RCVS Annual Report published on our website already includes the total

advice per category (e.g. consent, client confidentiality, fees and related matters, euthanasia,

medicines etc) so the information has not been duplicated here.

Table A: Written enquiries (handled by the Advice Team)

Year

Total number of written advice requests handled by the Advice Team

2010 1360

2011 1750

2012 1796

2013 1697

2014 1990

2015 1803

2016 1877

Table B: Telephone enquiries (handled by the Advice Team and the Professional Conduct Department)

Year

Total number of calls (relating to advice and concerns)

2010 7544

2011 8000

2012 7319

2013 6702

2014 7502

2015 7666

2016 9329



Feedback on our advice

1.4 Generally, the feedback on our advice is positive. We continue to receive a steady stream of

unprompted thank you letters and emails.

1.5 Last year, the Advice Team received 235 unprompted thank you letters and emails. The

figure remained similar this year at 216. Below are examples of some of the comments

received from the public, profession and others on our advice:

“Thank you so much! Very clear guidance!” (veterinary surgeon)

“Thanks, as always, for your prompt and clear advice. I had suspected as much, but thought it was worth checking!” (veterinary surgeon)

“Many thanks, that's really interesting, and gives me very useful context. Much appreciated.” (member of the public)

“Thank you very much for your very clear advice. I will discuss it with my colleagues who I'm sure will be equally grateful for the clarity here.” (referral veterinary surgeon)

“Thank you very much for your very thorough response. It does help tremendously and fits entirely with what we had thought, which makes me feel more confident with our limits we have imposed.” (veterinary surgeon) “Thank you for your genteel and friendly advice (are you the velvet glove around the iron fist of the RCVS?).” (veterinary surgeon)

“This is perfect. Thank you so much. This is all that I need.” (veterinary surgeon)

“Thank you so much for your advice and for being so kind. It was a great relief to talk to you!” (veterinary surgeon)

“Thank you so much - you are an angel.” (member of the public)

“Thank you so much for your thorough response this has been incredibly insightful!” (human medic)

“Thank you for a VERY concise & clear answer .... not the one I wanted but clear Hahaha” (veterinary surgeon)

“Thank you so much for this huge effort.” (member of the public)

“Thank you so much for this - this is extremely helpful, and cannot thank you more for how speedy you’ve been!” (TV producer)

“This is very helpful and accurately reflects my thoughts and current practice - so that is excellent!” (referral veterinary surgeon)

“That's brilliant, it's clear how to proceed now. Thanks very much for all your help with this!” (veterinary surgeon)



“Thank you very much for taking the time to explain everything to me so clearly. It is very much appreciated. Your response has answered my query and I will look into the Supporting Guidance chapters regarding referrals more closely” (veterinary surgeon)

“Many thanks for your comprehensive advice, it is broadly in line with what I was expecting which is gratifying.” (veterinary surgeon)

“Now I can reassure him that I have sought guidance from the RCVS with an independent view. So thank you again for that.” (veterinary nurse)

“Thanks so much. That all makes sense to me.” (VMD staff member)

“This is super useful and just what I was after. I really appreciate your help.” (Environmental health officer)



2.1 The Advice Team manages the work of the Standards Committee, which is responsible for

publishing the Codes of Professional Conduct and Supporting Guidance. This includes identifying

areas where new or revised advice may be required and drafting guidance for Committee or

Council approval and dealing with policy issues relating to professional standards.

2.2 There is no doubt that proper regulation through standards and guidance protects the public and

helps to maintain public confidence in the veterinary profession. The Advice Team do this by

providing a clear framework that professionals should meet when providing veterinary care via the

Codes and Supporting Guidance. The standards and guidance should help professionals to

understand their obligations and support compliance. The standards and guidance should also

meet the needs of relevant stakeholders and help the public understand what to expect and when

to raise concerns when these have not been followed.

2.3 To further ensure proper regulation through standards and guidance, the team has also sought to

comply with the key principles outlined in the Standards of Good Regulation (2010) produced by

the Professional Standards Authority for Health and Social Care, which scrutinises and oversees

the work of the UK’s nine health and social care regulatory bodies. The PSA Standards form the

basis of performance reviews and describe the outcomes of good regulation for each of the

regulators’ functions. Although the RCVS is not scrutinised or reviewed by the PSA, their

standards of good regulation are relevant to the work we do under the umbrella of the Standards

Committee and as such, we have taken on board the core principles when carrying out our work.

2.4 Similarly, the team has also taken on board the principles and concepts of good regulation

identified in the Regulators’ Code, which came into statutory effect on 6 April 2014 under the

Legislative and Regulatory Reform Act 2006, replacing the Regulators’ Compliance Code. This

Code provides a clear, flexible and principles-based framework for how regulators should engage

with those they regulate and regulators should have regard to the Code when setting standards or

giving guidance which will guide the regulatory activities. The Code applies to nearly all non-

economic UK regulators for example the Care Quality Commission, Competition and Markets

Authority, Natural England and the Environment Agency. Again, the RCVS is not included in the

statutory list, but we have chosen to reflect some of the key principles identified in the Code as

they are relevant to the work we do.

2.5 Both the Standards of Good Regulation (2010) and the Regulators Code (2014) highlight key

principles and concepts which we have incorporated in to our work over the last year, for

example:

a) ensuring that standards and guidance reflect up-to-date practice and legislation;

b) ensuring clear standards and guidance to assist those we regulate to understand their

responsibilities;

c) ensuring clear standards and guidance to help the public understand what to expect and

when to raise concerns when these have not been followed;

Work stream 2: Standards Committee



d) taking account of stakeholders’ views and experiences, external events, developments

across the UK, European and international regulation and learning from other areas of

regulators’ work;

e) publishing the standards and guidance is accessible formats and in plain English; and

f) creating mechanisms for inviting and receiving customer feedback.

Recap on 2016 Code and Supporting Guidance updates

2.6 Over the course of the year, the Advice Team has worked on the following areas under the

umbrella of the Standards Committee, many of which led to Code or Supporting Guidance updates:

Referrals – changes to the Code detailing the need to be transparent when reporting back to

the primary veterinary surgeon about who dealt with the case. Additional information on factors

to take into account when referring, when a veterinary surgeon can choose not to support a

referral, and transparency around incentives;

Suspected illegal imports – new supporting guidance about what to do when presented with a

suspected illegal import;

Lay staff – new supporting guidance on how a veterinary surgeon should approach delegation

to lay staff including examples of what lay staff should not do;

Microchipping – Updates to the existing guidance, including guidance on regional-specific

legislation;

Veterinary care – chapter rewritten in its entirety to provide more comprehensive guidance,

including on hospitalisation, transfer, continuity of care, discharge and links to information on

mutilations and permitted procedures;

Antimicrobial resistance – updated guidance with reference to BEVA/BSAVA/VMD position

statements;

Fair trading requirements – new guidance on recommendation of retailers and providing

information to clients;

Consent – new guidance on implied consent to transfer clinical records to a superseding vet

practice;

Clinical records – new guidance on dealing with factual inaccuracies and amendments,

retention and storage or clinical records, access to clinical records; and

Feline renal transplantation – new/re-written guidance following a comprehensive review, in

conjunction with the RCVS Science Advisory Panel, of the subject



3.1 The Advice Team is responsible for managing the work of the Sub-Committees reporting to the

Standards Committee. This includes:

Certification Sub-Committee: The team deals with all enquiries relating to certification. This

includes identifying queries for referral to the Sub Committee, preparing summaries, researching

any relevant legislation and guidance, collating Committee views and drafting a final response.

The team also ensures liaison with the UK Export Certification Partnership group, APHA and

Defra and prepares regular reports on certification work for the Standards Committee.

Recognised Veterinary Practice Sub-Committee: The team manages the work of the RVP

Sub Committee and acts as the point of contact between the enquirer and the Committee. This

includes summarising the request, gathering any documentation such as study outlines and

research material, collating views and drafting the final response. Often, these enquiries are

complex and the Committee will ask the Advice Team to liaise with the applicant, the VMD or

Home Office to ensure all relevant information is available. This year, the Advice Team has

drafted responses to complex applications such as studies on rumen fistula in cattle, canine

obesity and genetics, simulated TB testing and IVDD screening in dachshunds. The numbers of

study proposals handled by the team has been fairly consistent over the past three years:

Year Total number of RVP applications

2014 15

2015 25

2016 15

Riding Establishments Sub-Committee: Since the RCVS’ takeover of the administration of

the Riding Establishments Inspectorate in 2014, the team has been kept busy with managing

the Sub-Committee, reviewing policy and organising/delivering the annual courses for

inspectors. The team’s activities in this area have included: o Responding to queries from veterinary surgeons, riding establishments and local

authorities; o Liaising with equine associations and dealing with issues raised over the course of the

year; o Reviewing amendments and finalising the new guidance on the Riding Establishments

Acts; o Organising and attending the annual training courses for Riding Establishments

Inspectors; o Delivering sessions at the annual training courses; o Assisting the Communications Team with the drafting of the Riding Establishments

Newsletter (REIN).

Work stream 3: Sub-Committees



Ethics Review Panel: Whilst technically not a Sub-Committee, the Ethics Review Panel (ERP)

is at present reporting to the Standards Committee. The ERP became active on 1 August 2016

– initially for a year’s trial - following a report into practice-based research undertaken by a joint

RCVS-BVA working party, and the Panel is intended to provide a mechanism of ethics review

for those veterinary surgeons and veterinary nurses who would not normally have access to it

(i.e. outside the contexts of academia or industry) and who are seeking to undertake research

projects of their own. The Panel has had 5 applications for ethics review at the time of writing.

The team’s activities in relation to this area of work have included:

o Responding to queries and applications from veterinary surgeons;

o Assisting in recruitment of the Panel;

o Organising and attending the Panel training day;

o Delivering presentations at the training day;

o Drafting terms of reference and guidance documents for applicants;

o Assisting the Communications Team in promoting the work of the Panel.



4.1 This year, the Advice Team has been involved in a number of wider policy issues which fall under

the umbrella of the Standards Committee. Often, this work will involve arranging and attending

meetings with the Chair of Standards Committee and other RCVS representatives and carrying out

associated work. These matters will be reported to Standards Committee at various times throughout

the year. Some examples of the wider issues handled by the Advice Team in 2016 include:

Insurance matters – in conjunction with the Chief Investigator, Advice Team members have

attended meetings with IFED (Insurance Fraud Enforcement Department) of the City of

London Police and the ABI (the Association of British Insurers) to discuss matters pertaining

to veterinary insurance fraud, how it can be reported and how practitioners can avoid being

subject to allegations of such; Pet blood banks – attending meetings and providing advice to Pet Blood Banks UK in

relation to their proposal to establish a feline blood bank, including facilitating a meeting with

PBB, VMD and the Home Office and providing advice on a proposed pilot project plan;

Overseas veterinary surgeons – working with the RCVS Education Department to take a

position on whether overseas veterinary surgeons providing opinions to UK laboratories

would need to be registered with the RCVS as UK Practising;

Telemedicine – Advice Team members have been involved in the preparation of detailed

background materials for the Committee and the drafting of consultation documents for the

proposed consultation on telemedicine, with input from the Director of Leadership and

Innovation and the Communications team.

Work stream 4: Other policy matters



5.1 The Advice team assists the Chief Investigator with concerns relating to illegal practice raised by

the public, members of the profession and, to a lesser extent, whistleblowers.

5.2 ‘Bogus vets’ tends to be an all-inclusive term for a variety of potential offenders. Generally

speaking, it refers to anyone holding themselves out to be a veterinary surgeon or veterinary

nurse, whilst not being appropriately registered with the RCVS. It could also relate to a qualified

veterinary surgeon or veterinary nurse, who has been removed or suspended from the Register

for disciplinary reasons, but who continues to practise. Or, it could be someone who has not

successfully completed a recognised veterinary degree, but nevertheless has undertaken some

veterinary training and seeks to practise in the UK. Most worrying, it is when someone with no

veterinary education and training holds out as a qualified professional, be that through offering

veterinary diagnoses or advice based on a diagnosis, undertaking veterinary medical or even

surgical procedures, or illegally buying or supplying veterinary medicines.

5.3 The RCVS has jurisdiction only over its registered members and has no statutory powers to

prosecute offences under the Veterinary Surgeons Act. But, while we have no powers to deal

with these matters directly, we endeavour to work around this. The RCVS could potentially

undertake a private prosecution, but generally we work alongside appropriate enforcement

agencies to investigate allegations relating to unqualified persons. The RCVS has fostered strong

working relationships with a variety of enforcement agencies across the UK, including Police and

Trading Standards.

5.4 The RCVS view is that illegal practice is a serious matter that can compromise animal welfare and

public safety. In the first instance, bogus vets should be reported to the police as it is a criminal

matter, although the local Trading Standards Office should also be informed. Once a case has

been reported, we will often then liaise with the relevant authorities, advising on what comprises

an act of veterinary surgery and confirming whether or not an individual is on the Register.

Assistance from the RCVS can also help to add credence to individuals’ complaints and help

speed up investigations. We actively provide names and details of staff in the department, who

are able to assist with these matters.

5.5 Title misuse is another area where the RCVS may become involved. This includes unqualified

persons holding themselves out as veterinary surgeons; previous registrants continuing to use the

title without appropriate registration with the RCVS; or, overseas or unregistered veterinary

surgeons practising abroad while using the MRCVS title. In the first instance, the RCVS will send

a ‘cease and desist’ letter to the individual concerned. This is the first step in tackling title misuse,

but a failure to respond to the letter or continued and persistent title misuse will generally result in

the authorities being notified.

5.6 In the past few years, we have worked with the enforcement agencies to secure a number of

successful prosecutions. This has included formal police cautions, conditional discharges and

Work stream 5: Breaches of the Veterinary Surgeons Act



custodial sentences. Prosecutions have included an 18 month imprisonment for breaches of the

Act and fraud offences; eight month sentence suspended for two years, 180 compulsory unpaid

work and 12-month community order for false representation as a qualified veterinary nurse and

theft; and a six-month sentence suspended, for two years, 200 hours community service, £1,000

compensation and five-year ban from owning and caring for animals for fraud, breaches of Act

and cruelty.

5.7 Below are some examples of the types of matters that we have assisted with over the course of

2016. This is not the full list, but gives a flavour of the types of issues arising in connection with

the Veterinary Surgeons Act:

a) Sent a cease and desist warning letter to a non-veterinary surgeon Equine Dental Technician

(EDT), regarding use of RCVS logo on his professional website;

b) Sent a cease and desist letter to a non-veterinary surgeon owned equine website business

regarding use of the RCVS Coat of Arms on its website;

c) Investigated concerns about a Facebook blog of an EDT claiming to carry out Category 3

extraction;

d) Investigated concerns about the way an equine dental technician was describing himself and his

qualifications on his professional website and warned the individual about making misleading

claims about RCVS approval;

e) Investigated concerns about non-veterinary surgeons (animal rescue centre) supplying POM-V

medications to the public;

f) Investigated concerns raised by a member of the public of a potential bogus veterinary surgeon

commenting on a social media website – this is an ongoing investigation to establish sufficient

evidence to report the matter to police;

g) Referred case to VMD regarding lay darters, which was subsequently referred to DEFRA

Investigation Services;

h) Provided statements to various enforcement agencies, for example the City of London Police,

the National Fraud Intelligence Bureau and Trading Standards to assist with investigations

concerning fraud and identity theft of a veterinary surgeon;

i) Liaising with police forces (CDLOs) and the VMD regarding reported veterinary surgery

burglaries; and

j) Assisted VMD with investigation and visit of premises where breaches of the VMRs were

evident.



6.1 The Advice Team regularly assists other teams, departments and committees with issues and

projects arising during the year. In 2016 some examples included:

a) Working with the Communications Team to draft articles for RCVS News and News Extra. The

RCVS News Extra feature consisting of case studies from the Standards & Advice team was

particularly well-received and had excellent feedback from the profession. This year we have

covered various topics in news articles including (but not limited to) ethics review; the new

microchipping legislation; delegating to unqualified members of staff; dealing with suspected

illegal imports; fair trading; telemedicine; referrals and incentives; feline renal transplantation

and veterinary fees. We have also liaised with public affairs staff in the Communications team to

gain clarification from DEFRA on a number of issues arising from the introduction of new

microchipping legislation.

b) The Veterinary Nursing Department regularly consults the Advice Team on registrations queries

and where they have concerns about bogus practitioners or those practising without proper

registration. We also assist colleagues in veterinary nursing with multiple queries about

individuals holding out as veterinary nurses without proper qualification or other general

enquiries about what veterinary nurses can do under Schedule 3 of Veterinary Surgeons Act.

c) We assist the Education Department with queries relating to advanced practitioners and

specialists, specifically advertising professional titles. This year, we have mostly been involved

with contacting veterinary surgeons who are misusing the term ‘specialist’ – intentionally or

accidentally – and ensuring that they cease to do so.

d) We also provide advice to the PSS Team on matters of professional conduct, particularly in

relation to the content of the Practice Standards Manuals, and general queries about the

standards expected of individual veterinary surgeons and veterinary nurses.

e) In addition, we assist the Registration Department with enquiries about whether an individual

requires RCVS registration as well as queries about disclosing convictions, cautions or adverse

findings as part of the registration or renewal processes. The Registration Department also

assists the team with registering new Riding Establishment Inspector applicants and enrolling

inspectors onto the annual course.

f) Finally, we provide training to various groups throughout the year, including Professional

Conduct staff but also the Disciplinary and Preliminary Investigation Committees on the Codes

of Professional Conduct and the Supporting Guidance. This includes giving presentations, as

well as discussion sessions, throughout the course of the year.

Work stream 6: Inter-departmental advice

SC Jan 17 AI 03(a)

SC Jan 17 AI 03(a) Classification: Unclassified Page 1 / 5

Meeting

Standards Committee

Date

25 January 2017

Title

Veterinary fees

Classification

Unclassified

Summary

This paper proposes amendments to Supporting Guidance Chapter 9 to strengthen advice on effective communication and gaining informed consent in relation to veterinary fees.

Decisions required

To approve amendments to Supporting Guidance Chapter 9

Attachments

Annex A: Draft revised guidance Annex B: Current Chapter 9 Annex C: Paper on Veterinary Fees provided to the Committee September 2016 Annex D: Chartered Trading Standards Institute’s Guidance for Traders on Pricing Practices

Author

Vicki Price Senior Advice Officer 0207 202 0303 [email protected]


SC Jan 17 AI 03(a)



SC Jan 17 AI 03(a)


Veterinary fees

Background

1. At its meeting in September 2016, the Standards Committee was asked to provide ideas for

amendments / additions to improve Supporting Guidance Chapter 9 – ‘Practice information, fees

and animal insurance’. Chapter 9 of the supporting guidance is attached in full at Annex B.

2. A review of Chapter 9 was considered timely as part of the rolling review of the supporting

guidance, and in light of commitments regarding veterinary fees made as part of the Vet Futures

Project. In particular, Action M of the Vet Futures Action Plan refers to ‘Communicating veterinary

fees and values (develop communications materials to explain veterinary fees and value to the

general public)’.

3. The paper on veterinary fees provided to the Committee in September 2016 (attached in full at

Annex C) summarised issues arising in the course of the Vet Futures Project in relation to

veterinary fees, existing Code obligations and supporting guidance, and difficulties that the

College faces in determining that the fees charged in any particular case are so extreme as to

constitute disgraceful conduct in a professional respect, with reference to the only case that the

RCVS Disciplinary Committee has ever considered in which the level of fees charged by a

veterinary surgeon was relevant (RCVS vs Mr David John Bailey MRCVS).

4. It continues to be the case that the issue of veterinary fees gives rise to a steady, but fairly small,

number of formal concerns to the College. Since the start of September, 30 cases have been

registered that have fees as their primary motivator, although this includes enquiries and so is not

necessarily representative of matters that the College is actually investigating. It should also be

borne in mind that the concerns form specifically states that we cannot decide fee issues, so most

people raise another issue at the same time.

5. Common recurring themes that arise in these concerns include the following:

a lack of informed consent

failing to provide accurate estimates / wildly exceeding estimates. It seems a number of

vets have a box on the consent form for the estimate to be included and signed to by the

client, but do not use it

communication issues (e.g. unclear communication, failing to update client)

fees and charges not being displayed in the practice

a lack of transparency in the context of insurance claims, e.g. failing to notify clients how

much a vet is claiming on their behalf, so they do not know when their limit is reached

being asked to pay up front, especially for out-of-hours cover

over-treating

not being provided with invoice breakdowns

a perception of signing a blank cheque

6. The Standards and Advice Team also responds to regular enquiries, most commonly from

members of the public, about veterinary surgeons’ and veterinary nurses’ responsibilities around

veterinary fees. Based on a search of the ‘Prof Con’ system of 340 of the advice files completed

between July 2016 and January 2017, we estimate that around 8% of the advice files handled by

SC Jan 17 AI 03(a)


the team were primarily concerned with fees. We also receive a regular stream of phone calls from

members of the public on this issue.

7. Some of the most common themes and queries raised on a regular basis include:

a lack of informed consent / charges not fully explained e.g. ‘When I left the surgery I was asked to pay the bill with no explanation of why it was

so much more, I am not happy with the hidden charges – what are my rights?’

querying charges for prescriptions and medicines e.g. ‘After a short appointment I was charged £125 for allergy tablets and cotton wipes. I

have found the drugs online, they were marked up by 150% - I’m disgusted.’

e.g. ‘I queried my bill after I noticed there were fees for two prescriptions, when both items

were prescribed at the same consultation. Is this law or just a business practice?’

lack of awareness of ability to obtain medicines elsewhere ability to end client relationship if fees remain unpaid

e.g. ‘I have a payment plan with my vet but missed the last payment. Now they have said

they will not provide any more treatment for my dog – can they do this?’

being asked to pay up front / refusal to treat if payment not made e.g. ‘I did not have enough money on me, so the vet took back the medication until I paid

the rest. I was in shock they did not put my dog’s health first, what is your advice?’.

querying charges for follow up appointments / re-examination

September 2016 meeting 8. The Committee was asked to consider whether any amendments or additions could be made to

Chapter 9 to help veterinary surgeons and veterinary nurses manage client expectations in

relation to veterinary fees, with a view to reducing the number of concerns the College receives

and helping animal owners see the value in veterinary care.

9. The Committee was also asked to consider whether there is anything the College more generally

could do, perhaps beyond the remit of the Standards Committee, such as publishing case studies

based on typical concerns related to fees, and to consider how we communicate the limits of the

College’s jurisdiction with regards to the level of veterinary fees.

10. The Committee acknowledged that there is a need to better communicate to clients the value of

veterinary services, and to challenge the perception that veterinary practices are making large

profits.

11. The Committee agreed that the existing professional obligations of veterinary surgeons and

veterinary nurses to communicate fees to clients and to gain informed consent in relation to

veterinary fees should be emphasised, to more effectively set client expectations around

veterinary fees. In particular, it was agreed that the supporting guidance should be strengthened

to place further emphasis on providing accurate initial fee estimates and accurate estimates for

different stages of treatment; on explaining the cost of out of hours care; and on providing detailed

practice fee information such as leaflets.

12. In relation to how we communicate the limits of the College’s jurisdiction over the level of fees

charged by veterinary practices, the Committee recognised the limited value of including a

SC Jan 17 AI 03(a)


statement in the supporting guidance that the College does have jurisdiction if the level of fees is

so extreme as to constitute disgraceful conduct in a professional respect, when this is very difficult

to enforce.

Matters for decision

13. The Committee is asked to consider and approve the proposed amendments to Supporting Guidance Chapter 9 at Annex A.

14. The Committee is also asked to indicate whether it agrees to the publication of case studies

similar to those published by the Standards and Advice team in 2016, based on common fee

related issues that can escalate into concerns.

SC Jan 17 AI 03(a) Annex A

SC Jan 17 AI 03(a) Annex A Classification: Unclassified Page 1 / 5

9. Practice information, fees and animal insurance Existing guidance in grey Suggested new guidance in red Suggested deleted text in strikethrough Practice information 9.1 Under EU Directive 2006/123/EC, service providers, which include veterinary surgeons, must give clients relevant information, such as their contact details, the details of their regulator and the details of their insurer. 9.2 In addition, and in accordance with the following guidance, Vveterinary practices should provide clients, particularly those new to the practice, with comprehensive written information on the nature and scope of the practice's services, including:

a. the provision, initial cost and location of the out-of-hours emergency service; b. information on the care of in-patients; c. the practice's complaints handling policy, and could also provide full terms and conditions of

business, to include for example: i. surgery opening times ii. whether open or by appointment iii. fee or charging structures iv. procedures for second opinions and referrals v. use of client data vi. access to and ownership of records

Freedom of choice 9.3 Veterinary surgeons should not obstruct a client from changing to another veterinary practice, or discourage a client from seeking a second opinion. 9.4 If a client's consent is in any way limited or qualified or specifically withheld, veterinary surgeons should accept that their own preference for a certain course of action cannot override the client's specific wishes, other than on exceptional welfare grounds.

Fees 9.5 A veterinary surgeon is entitled to charge a fee for the provision of services. There are no statutory charges and fees are essentially a matter for negotiation between veterinary surgeon and client. 9.6 The RCVS has no specific jurisdiction under the Veterinary Surgeons Act 1966 over the level of fees charged by veterinary practices., unless they are so extreme as to constitute disgraceful conduct in a professional respect. [At the last meeting the Committee discussed deleting this text due to difficulty of enforcement – does the Committee now approve deletion of the strikethrough text?] 9.7 Fees may vary between practices and may be a factor in choosing a practice, as well as the practice's facilities and services, for example, what sort of arrangements are in place for 'out-of-hours' emergency calls (eg are emergency consultations at the practice premises, or by another practice at another location). It may be helpful to explain to clients factors that influence the determination of fee levels, eg the time and skill involved in treating a case, staff training and education costs, the cost of diagnostic facilities, equipment, medicines and materials, and the cost of building, vehicle and other running costs.



9.8 Veterinary surgeons should be open and honest about fees for veterinary treatment, and should give clients clear and easy to understand information about fees in a variety of ways. Clients should be given the fee information they need so as to be in a position to give informed consent to treatment. Clients should not have to ask for this information. The higher the fee, the greater is the necessity for transparency in the giving of detailed information to the client. 9.9 Comprehensive written information on the practice’s fee or charging structures and the initial cost of the out-of-hours emergency service should be provided at the outset of the professional relationship. Veterinary surgeons should use all available means to provide this information, including practice leaflets, client letters, notices or posters displayed in the practice, the practice website and social media. Updates on the practice’s fee or charging structures should be provided on a regular basis, and where there is any significant change, clients should be informed as soon as possible. (Communication and consent) Giving estimates 9.10 Discussion should take place with the client covering a range of reasonable treatment options and prognoses, and the likely charges. If the animal is covered by pet insurance, it is in the interests of both veterinary surgeon and client to confirm the extent of the cover under the policy, including any limitations on cost or any exclusions which would apply to the treatment proposed. 9.11 Veterinary surgeons should give clients a realistic initial estimate of the anticipated cost of veterinary treatment. The initial estimate should:

a. cover all likely charges, including ancillary or associated charges, such as those for medicines/anaesthetics, diagnostic tests, pre- or post-operative care, follow up or routine visits and should include VAT;

b. include a clear warning that additional charges may arise, eg if the treatment plan changes or complications occur;

c. be provided before treatment is commenced and be the subject of clear client consent, except where delay would compromise animal welfare;

d. preferably be provided in writing, especially where treatment involves surgery, general anaesthetic, intensive care or hospitalisation.

9.12 Veterinary surgeons should include the overall any estimated charge or fee on a consent form. 9.13 Veterinary surgeons should clearly inform clients that due to the unpredictable nature of clinical work, and variations in the way that each individual animal may react to treatment, treatment plans and the initial estimate may change. If a quote is given, it may be binding in law. 9.14 Estimated costs should be kept under review during the course of treatment. If it becomes evident that the initial estimate or a limit set by the client is likely to be exceeded, the client should be contacted as soon as it is practicable to do so and informed, and their additional consent obtained. This should be recorded in writing by the veterinary surgeon.

Discounts on veterinary fees 9.15 Veterinary practices have the commercial freedom to offer discounts on their fees on terms set by them. This might include discounts for members of staff, discounts for early settlement and discounts for certain clients e.g. students, pensioners etc. Discounts generally are acceptable, but it is never acceptable to present a client with inflated fees so as to create the fiction of a discount. 9.16 Discounts should be up front and transparent for all parties liable for payment of an account. Where there is an arrangement that more than one party is liable for payment of an account (eg insurance companies where client pays the excess), it is not reasonable to apply a retrospective discount for the benefit of one party only. (Fair-trading requirements)

http://www.rcvs.org.uk/advice-and-guidance/code-of-professional-conduct-for-veterinary-surgeons/supporting-guidance/fair-trading-requirements/



Invoices 9.17 All invoices should be itemised showing the amounts relating to goods including individual relevant medicinal products and services provided by the practice. Fees for outside services and any charge for additional administration or other costs to the practice in arranging such services should also be shown separately. (Fair-trading requirements)

Re-direction to charities 9.18 Where a client cannot afford to pay the fee for veterinary treatment, the veterinary surgeon may wish to discuss the availability of charitable services or assistance with the client. 9.19 All charities have a duty to apply their funds to make the best possible use of their resources. Clients should contact the charity to confirm their eligibility for assistance. The veterinary surgeon should ensure that the animal's condition is stabilised so that the animal is fit to travel to the charity, and provide details of the animal's condition, and any treatment already given, to the charity. 9.20 If the client is not eligible for the charitable assistance and no other form of financial assistance can be found, euthanasia may have to be considered on economic grounds.

Securing payment for veterinary services 9.21 A client is the person who requests veterinary attention for an animal and veterinary surgeons and veterinary nurses may charge the client for the veterinary service provided. Where the owner is not the client (assuming there is an owner) it should be borne in mind that they may not have had an opportunity to consent to treatment. 9.22 Veterinary surgeons are entitled to ask for payment of fees up front and in full. Veterinary surgeons may also ask the client to pay a deposit prior to the commencement of treatment and to pay any remaining fee at a later point in time, eg at the completion of treatment or on discharge. 9.23 Veterinary surgeons are not under any obligation to offer clients a payment plan, but may do so if they wish. A payment plan may amount to a credit agreement. Firms that offer credit agreements may need to be registered with or authorised by the Financial Conduct Authority (FCA) as a consumer credit provider. Veterinary practices should seek advice from the FCA or obtain independent legal advice in relation to whether they need to be registered or authorised.

Unpaid bills and fee disputes 9.24 Where the fee remains unpaid, a veterinary surgeon is entitled to place the matter in the hands of a debt collection agency or to institute civil proceedings. 9.25 In the case of persistently slow payers and bad debtors, it is acceptable to give them notice in writing (preferably by recorded delivery) that veterinary services will be no longer provided. 9.26 In the event of a fee dispute, whether a client must pay a bill is a matter to be resolved between the parties or by the civil courts, therefore, in most cases, disputes about the level of veterinary surgeons’ fees fall outside the jurisdiction of the RCVS. 9.27 Irrespective of payment, a veterinary surgeon on duty should not unreasonably refuse to provide first aid and pain relief for any animal of a species treated by the practice, or to facilitate the provision of first aid and pain relief for all other species.

Holding an animal against unpaid fees




9.28 Although veterinary surgeons do have a right in law to hold an animal until outstanding fees are paid, the RCVS believes that it is not in the interests of the animal so to do, and can lead to the practice incurring additional costs which may not be recoverable.

Prescriptions 9.29 Veterinary surgeons may make a reasonable charge for written prescriptions. (Prescriptions for POM-V medicines may be issued only for animals under the care of the prescribing veterinary surgeon and following his or her clinical assessment of the animals.) Clients should be informed of any significant changes to the practice’s charges for prescriptions or medicines. 9.30 Clients may obtain relevant veterinary medicinal products from the veterinary surgeon, or may ask for a prescription and obtain medicines from another veterinary surgeon or pharmacy. Veterinary surgeons may wish to direct clients who are considering obtaining medicines from an online retailer to the Veterinary Medicines Directorate’s Accredited Internet Retailer Scheme (AIRS). See https://www.gov.uk/government/publications/accredited-internet-retailer-scheme-airs. 9.31 The Supply of Relevant Veterinary Medicinal Products Order came into force on 31 October 2005 and is enforced by the Competition and Markets Authority. It implements recommendations from the Competition Commission and provides that veterinary surgeons must not discriminate between clients who are supplied with a prescription and those who are not, in relation to fees charged for other goods or services. (Fair-trading requirements)

Advertising and competition issues 9.32 All advertising and publicity in relation to practice information and fees should comply with the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code), see http://www.cap.org.uk/Advertising-Codes/Non-Broadcast.aspx. Any advertising or publicity should be professional, accurate and truthful. In relation to fees, the Chartered Trading Standards Institute’s Guidance for Traders on Pricing Practices should also be taken into account, see https://www.businesscompanion.info/sites/default/files/Guidance-for-Traders-on-Pricing-Practices-2016.pdf. A price comparison may be made between the price of a product or service provide by a practice against the same product or service offered by a competitor, but the basis for the comparison should be made clear, and the comparison should not be false or mislead the consumer.

9.33 It would be unethical for a veterinary surgeon or group of veterinary surgeons to enter into any agreement that has the effect of fixing fees. The Competition Act 1998 prohibits anti-competitive agreements between businesses, meaning businesses must not agree to fix prices or terms of trade, and must not agree price rises with competitors.

(Advertising and publicity)

EU Directive 2006/123/EC on the provision of services 9.16 The EU Directive on services requires that service providers, which include veterinary surgeons, must give clients relevant information, such as their contact details, the details of their regulator and the details of their insurer. Certain information must be provided on request, such as the price of a service or, if an exact price cannot be given, the method for calculating the price.

Animal insurance 9.34 An animal insurance policy is a contract between the animal owner (the client/policy holder) and the insurer and as such the only person that has the right to submit a claim under the policy is the client / policyholder. The veterinary surgeon may invoice the insurer for the submitted claim when authorised to do so by the client/policyholder. The veterinary surgeon’s role is to provide factual information to support the claim, and/or invoices if authorised. Animal insurance schemes rely on the integrity of the veterinary surgeon, who has a responsibility to both the client and insurance company.

https://www.gov.uk/government/publications/accredited-internet-retailer-scheme-airs


http://www.cap.org.uk/Advertising-Codes/Non-Broadcast.aspx

https://www.businesscompanion.info/sites/default/files/Guidance-for-Traders-on-Pricing-Practices-2016.pdf

https://www.businesscompanion.info/sites/default/files/Guidance-for-Traders-on-Pricing-Practices-2016.pdf

http://www.rcvs.org.uk/advice-and-guidance/code-of-professional-conduct-for-veterinary-surgeons/supporting-guidance/advertising-and-publicity/



9.35 Veterinary surgeons must act with integrity in all dealings with an animal insurance policy. They must complete claim forms carefully and honestly. A veterinary surgeon who acts dishonestly or fraudulently may be liable to criminal investigation and/or disciplinary action. 9.36 The existence of animal insurance is no excuse for charging inflated fees or any other activity which enables a veterinary surgeon or veterinary nurse to profit dishonestly or fraudulently. When completing the insurance claim form, the veterinary surgeon should include the amounts actually paid or, in the case of direct claims, the amounts actually charged, with any additional or administrative charges shown separately. In the interests of transparency, any discounts that have been or will be applied should be accounted for on any paperwork sent to the insurer. Any material fact that might cause the insurance company to increase the premium or decline a claim must be disclosed. Failure to complete claim forms in this way may raise suspicions of dishonesty or fraud, and may result in a complaint being made to the police and/or RCVS. A veterinary surgeon in any doubt as to how to complete a particular claim form accurately should, wherever possible, discuss this with the insurance company. 9.37 In cases where the veterinary surgeon is treating an animal with a long-term or ongoing health condition under an animal insurance policy, the practice of asking clients to pre-sign blank claim forms for subsequent completion and submission by the veterinary surgeon may expose the veterinary surgeon to suspicions of dishonesty or fraud. If the veterinary surgeon adopts this method, or indeed in any situation where the veterinary surgeon will send the claim directly to the insurance company, it is good practice to send a copy of the completed claim form to the client before submission so that they can check the details of the claim. In the reverse situation, where the client submits the claim form directly to the insurance company, it is advisable for the veterinary surgeon to keep a copy of what they send to the client so that there is a record in the event of any subsequent queries. Additionally, veterinary surgeons should not sign blank insurance claim forms. 9.38 Particular care should be taken when the veterinary surgeon is treating their own animal, or an animal belonging to a family member or a close friend, and that animal is covered by an animal insurance policy. Generally, such conflicts of interest should be avoided. For that reason, it is advisable to get another veterinary surgeon to complete, sign and submit the claim form, wherever possible. Where this is not possible, the veterinary surgeon should state on the form the ownership of the animal. 9.39 Animal insurance may enable relevant veterinary investigations or treatment to be carried out in circumstances where fees might otherwise be unaffordable for the animal owner. A veterinary surgeon should, however, ensure that the investigation or treatment is appropriate and is in the animal’s best interests. 9.40 Veterinary surgeons and veterinary nurses should not be seen to favour any particular insurer, unless they are registered with the Financial Conduct Authority or formally linked with a registered insurer. If a practice wishes to display promotional material, it is prudent to display a range so as to avoid any implication of bias, financial advice, or brokering. If any commission may be paid to the veterinary surgeon, veterinary nurse or support staff in the event that a particular policy is taken out, this should be disclosed.

9. Practice information, fees and animal insurance Updated 15 June 2016

Practice information

9.1 Veterinary practices should provide clients, particularly those new to the practice, with comprehensive written information on the nature and scope of the practice's services, including:

a. the provision, initial cost and location of the out-of-hours emergency service; b. information on the care of in-patients; c. the practice's complaints handling policy, and could also provide full terms and conditions of

business, to include for example: i. surgery opening times ii. whether open or by appointment iii. fee or charging structures iv. procedures for second opinions and referrals v. use of client data vi. access to and ownership of records

Freedom of choice

9.2 Veterinary surgeons should not obstruct a client from changing to another veterinary practice, or discourage a client from seeking a second opinion.

9.3 If a client's consent is in any way limited or qualified or specifically withheld, veterinary surgeons should accept that their own preference for a certain course of action cannot override the client's specific wishes, other than on exceptional welfare grounds.

Fees

9.4 The RCVS has no specific jurisdiction under the Veterinary Surgeons Act 1966 over the level of fees charged by veterinary practices, unless they are so extreme as to constitute disgraceful conduct in a professional respect. There are no statutory charges and fees are essentially a matter for negotiation between veterinary surgeon and client.

9.5 Fees may vary between practices and may be a factor in choosing a practice, as well as the practice's facilities and services, for example, what sort of arrangements are in place for 'out-of-hours' emergency calls (eg are emergency consultations at the practice premises, or by another practice at another location).

9.6 Veterinary surgeons should include any estimated charge or fee on a consent form. In the event of a fee dispute, whether a client must pay a bill is a matter to be resolved between the parties or by the civil courts, therefore, in most cases, disputes about the level of veterinary surgeons’ fees fall outside the jurisdiction of the RCVS.

Invoices

9.7 All invoices should be itemised showing the amounts relating to goods including individual relevant medicinal products and services provided by the practice. Fees for outside services and any charge for additional administration or other costs to the practice in arranging such services should also be shown separately.

(Fair-trading requirements)

Unpaid bills

9.8 A veterinary surgeon is entitled to charge a fee for the provision of services and, where the fee remains unpaid, to place the matter in the hands of a debt collection agency or to institute civil proceedings.

9.9 In the case of persistently slow payers and bad debtors, it is acceptable to give them notice in writing (preferably by recorded delivery) that veterinary services will be no longer provided.

Holding an animal against unpaid fees

9.10 Although veterinary surgeons do have a right in law to hold an animal until outstanding fees are paid, the RCVS believes that it is not in the interests of the animal so to do, and can lead to the practice incurring additional costs which may not be recoverable.

Prescriptions

9.11 Veterinary surgeons may make a reasonable charge for written prescriptions. (Prescriptions for POM-V medicines may be issued only for animals under the care of the prescribing veterinary surgeon and following his or her clinical assessment of the animals.)

9.12 The Supply of Relevant Veterinary Medicinal Products Order came into force on 31 October 2005 and is enforced by the Competition and Markets Authority. It implements recommendations from the Competition Commission and provides that veterinary surgeons must not discriminate between clients who are supplied with a prescription and those who are not, in relation to fees charged for other goods or services.

Re-direction to charities

9.13 All charities have a duty to apply their funds to make the best possible use of their resources. Clients should contact the charity to confirm their eligibility for assistance. The veterinary surgeon should ensure that the animal's condition is stabilised so that the animal is fit to travel to the charity, and provide details of the animal's condition, and any treatment already given, to the charity.

9.14 If the client is not eligible for the charitable assistance and no other form of financial assistance can be found, euthanasia may have to be considered on economic grounds.


Securing payment for veterinary services

9.15 A client is the person who requests veterinary attention for an animal and veterinary surgeons and veterinary nurses may charge the client for the veterinary service provided. Where the owner is not the client (assuming there is an owner) it should be borne in mind that they may not have had an opportunity to consent to treatment.

EU Directive 2006/123/EC on the provision of services

9.16 The EU Directive on services requires that service providers, which include veterinary surgeons, must give clients relevant information, such as their contact details, the details of their regulator and the details of their insurer. Certain information must be provided on request, such as the price of a service or, if an exact price cannot be given, the method for calculating the price.

Animal insurance

9.17 An animal insurance policy is a contract between the animal owner (the client/policy holder) and the insurer and as such the only person that has the right to submit a claim under the policy is the client / policyholder. The veterinary surgeon may invoice the insurer for the submitted claim when authorised to do so by the client/policyholder. The veterinary surgeon’s role is to provide factual information to support the claim, and/or invoices if authorised. Animal insurance schemes rely on the integrity of the veterinary surgeon, who has a responsibility to both the client and insurance company.

9.18 Veterinary surgeons must act with integrity in all dealings with an animal insurance policy. They must complete claim forms carefully and honestly. A veterinary surgeon who acts dishonestly or fraudulently may be liable to criminal investigation and/or disciplinary action.

9.19 The existence of animal insurance is no excuse for charging inflated fees or any other activity which enables a veterinary surgeon or veterinary nurse to profit dishonestly or fraudulently. When completing the insurance claim form, the veterinary surgeon should include the amounts actually paid or, in the case of direct claims, the amounts actually charged, with any additional or administrative charges shown separately. In the interests of transparency, any discounts that have been or will be applied should be accounted for on any paperwork sent to the insurer. Any material fact that might cause the insurance company to increase the premium or decline a claim must be disclosed. Failure to complete claim forms in this way may raise suspicions of dishonesty or fraud, and may result in a complaint being made to the police and/or RCVS. A veterinary surgeon in any doubt as to how to complete a particular claim form accurately should, wherever possible, discuss this with the insurance company.

9.20 In cases where the veterinary surgeon is treating an animal with a long-term or ongoing health condition under an animal insurance policy, the practice of asking clients to pre-sign blank claim forms for subsequent completion and submission by the veterinary surgeon may expose the veterinary surgeon to suspicions of dishonesty or fraud. If the veterinary surgeon adopts this method, or indeed in any situation where the veterinary surgeon will send the claim directly to the insurance company, it is good practice to send a copy of the completed claim form to the client before submission so that they can check the details of the claim. In the reverse situation, where the client submits the claim form directly to the insurance company, it is advisable for the veterinary surgeon to keep a copy of what they send to the client so that there is a record in the event of any subsequent queries. Additionally, veterinary surgeons should not sign blank insurance claim forms.

9.21 Particular care should be taken when the veterinary surgeon is treating their own animal, or an animal belonging to a family member or a close friend, and that animal is covered by an animal insurance policy. Generally, such conflicts of interest should be avoided. For that reason, it is

advisable to get another veterinary surgeon to complete, sign and submit the claim form, wherever possible. Where this is not possible, the veterinary surgeon should state on the form the ownership of the animal.

9.22 Animal insurance may enable relevant veterinary investigations or treatment to be carried out in circumstances where fees might otherwise be unaffordable for the animal owner. A veterinary surgeon should, however, ensure that the investigation or treatment is appropriate and is in the animal’s best interests.

9.23 Veterinary surgeons and veterinary nurses should not be seen to favour any particular insurer, unless they are registered with the Financial Conduct Authority or formally linked with a registered insurer. If a practice wishes to display promotional material, it is prudent to display a range so as to avoid any implication of bias, financial advice, or brokering. If any commission may be paid to the veterinary surgeon, veterinary nurse or support staff in the event that a particular policy is taken out, this should be disclosed.

Discounts on veterinary fees

9.24 Veterinary practices have the commercial freedom to offer discounts on their fees on terms set by them. This might include discounts for members of staff, discounts for early settlement and discounts for certain clients e.g. students, pensioners etc. Discounts generally are acceptable, but it is never acceptable to present a client with inflated fees so as to create the fiction of a discount.

SC Jan 17 AI 03(a) Annex C


Date 28 September 2016

Title Veterinary fees


Summary As part of the rolling review of the supporting guidance, the

Committee is asked to review chapter 9 – ‘practice information,

fees and animal insurance’. Additionally, it is a good time to

review this chapter in light of the Vet Futures Action Plan, which

makes a number of commitments regarding veterinary fees.

Decisions required To provide ideas for amendments / additions which could

improve chapter 9 of the supporting guidance, with particular

regard to the commitments of the Vet Futures Action Plan and

the themes highlighted in this paper.

Attachments Annex A: Chapter 9 of the supporting guidance (‘practice

information, fees and animal insurance’)

Annex B: BVA client leaflet – The cost of veterinary care explained

Author Rebecca Rafferty

Senior Advice Officer (Solicitor)

0207 227 3503

[email protected]



SC Jan 17 AI 03(a) Annex C Classification: Unclassified Page 2 / 5




Veterinary fees

Background

1. The Standards Committee undertakes a rolling review of the supporting guidance and on this

occasion is asked to consider chapter 9 – ‘practice information, fees and animal insurance’. The

issue of veterinary fees in particular has been considered as part of the Vet Futures project, and

various commitments have been made in this regard.

Vet Futures

2. The Vet Futures project is now at the ‘Action Plan’ stage and one of the actions (Action M) is:

Communicating veterinary fees and values (develop communications materials to explain veterinary fees and value to the general public)

3. The Vet Futures project and report1 that informed the Action Plan

2 commissioned some focus

groups, and pet owners expressed that they thought veterinary services were expensive and they

would welcome greater transparency about costs – including displaying prices for a wider range of

products / services in waiting rooms and standardised pricing.

4. The Committee will recall its discussions at its ‘away day’ in September 2016 which also fed into

the Vet Futures Action Plan. There was a general feeling that improving public understanding of

costs would be a positive step and would also help promote the value of veterinary care. It was

also acknowledged that there can be unfair comparisons between the costs of veterinary care and

the system within the NHS.

Concerns about veterinary fees 5. We receive a steady but fairly small number of concerns that are primarily about veterinary fees.

There are, however, a number of recurring themes that give rise to such concerns, including:

Lack of informed consent

Communication issues e.g. unclear communication, failing to update client

Fees and charges not displayed in the practice

Transparency (general)

Transparency (related to insurance claims)

Estimates being exceeded

Being asked for payment up front / in full

Over-treating

Not being provided with a breakdown of an invoice

The perception of signing a blank cheque

1 Vet Futures – Taking charge of our future: A vision for the veterinary profession for 2030 2 Vet Futures – Action Plan 2016-2020 – Taking charge; taking action

http://www.vetfutures.org.uk/download/reports/Vet%20Futures%20report.pdf

http://www.vetfutures.org.uk/download/publications/vet%20futures%20report%202016(5).pdf



Existing Code obligations and supporting guidance

6. The Code states:

2.3 Veterinary surgeons must provide appropriate information to clients about the practice, including the costs of services and medicines.

7. Chapter 9 of the supporting guidance (attached in full at Annex A) expands on this obligation with

some guidance but also makes various statements that we rely on quite frequently when advising

members of the public about the realities of veterinary fees.

8. In light of the commitments of the Vet Futures Action Plan and the commonly-occurring concerns,

the Committee is asked to consider whether any additions can be made to chapter 9 to encourage

veterinary surgeons to communicate better on issues of fees and to better educate members of

the public. The Vet Futures Action Plan is specifically envisaging a reduction in complaints to the

RCVS about veterinary fees.

9. The Committee is also asked to consider how we communicate the limits of the College’s

jurisdiction with regards to the level of veterinary fees. From time to time we may receive a

concern that simply alleges that the fees charged were excessive or exorbitant. The chapter 9

guidance currently states:

The RCVS has no specific jurisdiction under the Veterinary Surgeons Act 1966 over the level of fees charged by veterinary practices, unless they are so extreme as to constitute disgraceful conduct in a professional respect.

10. The College has never determined that the fees in a particular case were ‘so extreme’ and we

have to be mindful that we must not do anything that can be adjudged anti-competitive. The

problem with determining fees of a certain level as extreme may well lead us down the path of

setting maximum fees, and this could be dangerous territory. There are other practical issues that

would make this difficult, if not impossible, for example: how do you prove, with evidence, that fees

are extreme; what objective criteria can be applied; how do we allow for geographical variations; is

it fair to consider one fee or a set of fees in isolation or do we have to take account of a practice’s

entire fee regime etc.

11. There has only ever been one case considered by the RCVS Disciplinary Committee relating to

the level of fees charged by a veterinary surgeon. This was the case of Mr Bailey.

RCVS vs Mr John David Bailey MRCVS

12. Concerns were raised by an insurance company, that found that Mr Bailey’s charges were

consistently higher than they expected, such that all new claims from Ambivet were scrutinised by

their veterinary advisor.

13. One of the charges considered by the Disciplinary Committee was that Mr Bailey charged fees for

the supply and/or administration of POM-V medicines so high that they brought, or were liable to

bring, the profession into disrepute. Mr Bailey charged a flat mark-up on POM-V medicines of at



least 200%. There were additional charges for syringes, needles and then an injection or

dispensing fee.

14. The insurance company and their underwriters investigated the fees charged and considered that

Mr Bailey charged fees that were significantly higher than in comparable practices in Derbyshire

and North London, and by comparison with figures from the average taken from the top fifty

referral practices. Mr Bailey’s practice was not a veterinary hospital or referral practice.

15. The Disciplinary Committee considered that Mr Bailey’s fees and prices were at the top of the

range, taking into account evidence submitted by both parties about fees and prices charged in

different areas of the country. They noted that at one stage the mark-ups on POM-V medicines

were increased but then dropped again due to a loss of clients. They considered that this

demonstrated the effect of market forces.

16. The Committee acknowledged that the traditional approach of the College has been to say that

fees are an entirely commercial matter for negotiation between the veterinary surgeon and client.

However, the College has also said that where fees are high they may in some cases be so

extreme as to constitute disgraceful conduct.

17. The Disciplinary Committee considered that it was neither possible nor desirable to seek to specify

a level of mark-up on POM-V medicines which might bring the profession into disrepute and

constitute disgraceful conduct, as every case must depend on its own facts. In this particular

case, the Disciplinary Committee did not find that Mr Bailey’s prices were so high as to constitute

disgraceful conduct in a professional respect. Nevertheless, the Disciplinary Committee

considered it essential to comment that the higher the fee, the greater the necessity for

transparency in the giving of detailed information to the client. The Disciplinary Committee

recognised that market forces will regulate prices, but only if the necessary information is freely

available to clients to enable them to make informed choices.

Next steps 18. The Committee is asked to consider whether we can do more via the supporting guidance to help

veterinary surgeons and veterinary nurses manage client expectations with regards to veterinary

fees. If we could do this, we may reduce the number of concerns the College receives about

veterinary fees and help animal owners see the value in veterinary care. The Committee is asked

to make suggestions that can be taken away and developed, to be considered again at its next

meeting in January. The Committee may wish to take inspiration from the BVA client leaflet – The cost of veterinary care explained, which is attached at Annex B.

19. The Committee is also asked to consider any other tools that might assist in this regard and

whether there is anything the College more generally could do, perhaps beyond the remit of the

Standards Committee. For example, the Committee is aware of the positive feedback that the

advice case studies generated and perhaps a similar exercise with an emphasis on fees would be

beneficial. Case studies based on typical concerns might be more valuable than advice-based

case studies as these could demonstrate to the profession the common issues that can escalate

into concerns and how easily better communication could have avoided the issue arising in the

first place. Any recommendations in this regard could be fed to the Head of Professional Conduct

and the team that handles concerns. Likewise, any other suggestions can be reported accordingly.

www.tradingstandards.uk

GUIDANC£for trADErsoN prICING prACtICEs

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for trADErsGUIDANC£

oN prICING prACtICEs

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Introduction

Relevant legislation

Glossary

The regulatory framework

Professional diligence

Vulnerable consumers

General requirements

Banned practices

Price promotions

Is your pricing practice unfair?

Getting it wrong

Does your promotion contain false information?

Is your pricing practice deceptive even if it is factually accurate?

Have you told consumers what they need to know?

Use of additional text

Using reference prices

• After-promotion price

• Introductory price

• Recommended retail price (RRP)

• Comparison to a competitor’s price

• Comparison with prices in different circumstances

Time limited offers

Volume offers

Use of ‘free’

Additional charges

• Compulsory charges that are fixed • Compulsory charges that may vary

• Optional charges

‘Up to’ and ‘from’ claims

Subscriptions

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5

6

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9

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1

This guidance has been produced by the Chartered Trading Standards Institute at the request of the Department

of Business, Energy and Industrial Strategy (BEIS) and the Consumer Protection Partnership.1 It replaces the 2010

Pricing Practices Guide, produced by the then Department for Business, Innovation and Skills (BIS), which is now

withdrawn.

This guidance is designed to provide helpful common sense advice to traders about pricing practices. It provides

an overview of consumer protection laws that relate to pricing and associated practices for traders. Anyone who

regularly sells or engages in the process of selling products or services is likely to be regarded as a trader. All traders

must comply with these laws when they sell any goods or provide commercial services to consumers within the

United Kingdom. UK law applies to websites located outside the UK if they are offering products or services for sale

to UK consumers.

The guidance covers all consumer goods and services, from restaurants to hairdressers, including estate

agents, banking, airlines, car retailers, supermarkets, furniture retailers, etc. It applies to all platforms used for

business-to-consumer commercial practices, including all distance contracts (online, by telephone, etc) and any other

medium used to sell to consumers. This guidance focuses on the obligations required by the Consumer Protection

from Unfair Trading Regulations 2008 (the Regulations). It does not cover all legislation that applies to traders, nor

does it cover business-to-business transactions. It is not possible to identify every fair or unfair pricing practice

and consequently the guidance focuses on the main areas of concern highlighted during the consultation process.

The legislation in this area avoids prescriptive rules and focuses on general principles of fair dealing. The guiding

principle is that traders have the responsibility for ensuring that their pricing practices do not mislead consumers.

Regulators may refer to the guidance when making enforcement decisions about a trader’s pricing practices. This

guidance is not statutory guidance and a court is not bound to accept it. The decision whether any particular pricing

practice is unlawful remains to be judged by all of the relevant circumstances. Only a court can determine whether a

trader has breached the law in a specific case.

The guidance provides examples of good practice to assist fair-dealing traders in assessing their pricing practices.

It indicates, with examples, behaviour which is generally likely to comply with the law, as well as providing examples

of behaviour which may not. Adherence to these recommendations will not, of itself, ensure that an act or omission

complies with the Regulations; the circumstances of each particular case will always need to be considered. Equally,

a departure from these recommendations will not necessarily mean that the pricing practice is unfair. Each trader is

responsible for ensuring compliance with the Regulations and will need to consider how it ensures it has the right

level of resource and expertise available to achieve this. You may wish to seek legal advice or contact your local

trading standards service.2

If you have any comments or observations about any aspect of the guidance please contact CTSI

at [email protected]. Feedback will be taken into consideration in future reviews of the guidance.

1 The CPP was formed in April 2012. More information at https://www.gov.uk/government/publications/consumer-protection-partnership-update-report-2016-

to-2018

2 www.tradingstandards.uk/tssearch

INTRODUCTION

http://www.tradingstandards.uk/tssearch

http://www.tradingstandards.uk/advice/businessadvicets.cfm

2

The most important legislation in this area is the Consumer Protection from Unfair Trading Regulations 2008 (referred

to in this guidance as ‘the Regulations’), which prohibit traders from engaging in unfair commercial practices with

consumers. The Regulations implement the Unfair Commercial Practices Directive in the United Kingdom.3

The Regulations prohibit pricing practices that are false or misleading, such that the average consumer might take

a different transactional decision (for definitions see the glossary). A pricing practice may be unfair if it, or its overall presentation, is likely to deceive consumers, even if the information contained is factually correct.

The Regulations are broad and likely to cover all forms of representation made about the price, or price promotion,

of a product (goods and services) sold by traders to consumers. In particular, there is specific reference in the Regulations to:

• the price of a product

• the manner in which the price is calculated

• the existence of a specific price advantage4

The Regulations also prohibit misleading omissions. Information that is material to a consumer must not be omitted,

hidden or presented in a manner which is unclear, unintelligible, ambiguous or untimely.

The Regulations impose a general obligation on traders not to contravene the requirements of professional diligence,

which are defined by reference to the standard of skill and care that is commensurate with honest market practice or the general principle of good faith (see page 5 for more details).

Other legislation

The Price Marking Order 2004 requires traders to indicate the price, quantity and unit price of specified products, primarily foodstuffs.

There are additionally specific information requirements for traders in relation to on-premises, off-premises and distance contracts.5

There are also sector specific rules on price indications in relation to, for example, consumer credit6 and package

travel.7

Visit www.businesscompanion.info for advice and guidance on these requirements.

3 Directive 2005/29/EC of the European Parliament and of the Council concerning unfair business-to-consumer commercial practices

4 Consumer Protection from Unfair Trading Regulations 2008, regulation 5(4)

5 Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013

6 Consumer Credit Act 1974

7 Package Travel, Package Holidays and Package Tours Regulations 1992

RELEVANT LEGISLATION



3

This glossary contains explanations or words and expressions as they are used in this guidance.

Defined in regulation 2 (2)-(6) of the Regulations.

The material characteristics of an average consumer should be considered ‘including his being reasonably well informed, reasonably observant and circumspect.’ European

case law suggests that social, cultural and linguistic factors should also be taken into

account.

Where the commercial practice is directed to a particular group of consumers, or a

particular group that is vulnerable to the practice, ‘average consumer’ refers to the

average member of that group.

See page 5 for further explanation.

Any act, omission, course of conduct, representation or commercial communication

(including advertising and marketing) by a trader, which is directly connected with the

promotion, sale or supply of a product to or from consumers, whether occurring before,

during or after a commercial transaction (if any) in relation to a product.

An individual acting for purposes that are wholly or mainly outside that individual’s

business.

The information that the average consumer needs, according to the context, to take an

informed transactional decision. It also includes certain information required to be given

to consumers as a consequence of European consumer legislation.

Defined widely to include goods, services, digital content, immovable property, rights and obligations or the demand of payment from a consumer in settlement of a liability.

The standard of special skill and care which a trader may reasonably be expected

to exercise towards consumers which is commensurate with either (a) honest market

practice in the trader’s field of activity or (b) the general principle of good faith in the trader’s field of activity.

Price promotions that aim to demonstrate good value by referring to another price

that is typically higher.

A person acting for purposes relating to that person’s business, whether acting

personally or through another person acting in the trader’s name or on the trader’s

behalf.

Average consumer

Commercial practice

Consumer

Material information

Product

Professional diligence

Reference price

Trader

GLOSSARy

4

Transactional decision Any decision taken by a consumer, whether it is to act or refrain from acting,

concerning:

(a) whether, how and on what terms to purchase, make payment in whole or part for,

retain or dispose of a product; or

(b) whether, how and on what terms to exercise a contractual right in relation

to a product.

‘Transactional decision’ covers a wide range of decisions that have been or may be

taken by consumers before, during or after a contract is formed.

This guidance uses ‘take a different decision’ as short-hand for a transactional

decision that an average consumer would not have taken otherwise.

See page 9 for further explanation.

Trading standards services in England, Wales and Scotland and the Northern Ireland trading standards service

enforce the Regulations.

The Competition and Markets Authority also enforces the Regulations.

The Advertising Standards Authority - UK Code of Non-broadcast Advertising and Direct & Promotional Marketing

(CAP Code) and the UK Code of Broadcast Advertising (BCAP Code) are advertising codes for advertisers, agencies

and media which are designed to address misleading, harmful or offensive advertising. The Codes must be followed

by all advertisers, agencies and media. The Codes are enforced by the Advertising Standards Authority, considered

an established means8 for gaining compliance with the Regulations, who can take steps to remove or have amended

any ads that breach these rules.

ThE REGULATORy fRAmEwORk




5

The Regulations require traders to ensure that consumers are not treated unfairly, by reference to the standard of an

average consumer. However, it is important to understand that the characteristics of the average consumer may include

vulnerability.

You need to take special care if you are targeting a price promotion at particular groups of consumers who may be

vulnerable - for example, on the grounds of age, credulity or mental or physical infirmity. Vulnerability is also situational; consumers may be vulnerable for a short period because of a personal situation, such as bereavement or debt. You have

a legal obligation to ensure that all such vulnerable groups are fairly treated.11

Examples:

• wheelchair users may be vulnerable to pricing practices in relation to holiday destinations that claim ease

of access

• the elderly may be more vulnerable to pricing practices in relation to security systems

• children may be vulnerable to advertisements in relation to toys


10 Consumer Protection from Unfair Trading Regulations 2008, regulation 17: The trader took ‘all reasonable precautions and exercised all due diligence to avoid

the commission of such an offence’

11 For further guidance on these concepts refer to OFT 1008 Guidance on the UK Regulations (May 2008) implementing the Unfair Commercial Practices Directive

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/284442/oft1008.pdf

The Regulations require that traders behave professionally and responsibly in the pricing of their products. You are

expected to formulate pricing practices in accordance with honest market practice and the general principles of good faith

in your field of activity. This obligation is derived both from the prohibition against contravening professional diligence9

and also the due diligence10 defence that applies to the criminal offences of engaging in misleading acts or omissions.

What amounts to the exercise of due diligence in relation to a pricing practice will depend on all of the relevant

circumstances. No prescriptive rule can be stated about what is sufficient in every case.

However, if your pricing practice is challenged, the following may be important to regulators:

• evidence of how your price promotions are communicated to consumers: on price labels, signs and notices; oral

representations; in publications such as newspapers, magazines, flyers, etc; radio and television advertisements; social media and electronic media, such as websites, SMS text messaging, emails and apps; and in any other

documentary or electronic advertisements

• any terms and conditions of the pricing practice and how these were communicated to consumers

• evidence of the stock and availability of a product during a price promotion. Retain records of your prices, stock

and sales histories whilst the promotional and non-promotional prices were charged, with relevant dates, locations,

websites, etc and sales volumes at the promotional and non-promotional prices

• where a comparison has been made against a competitor, record the competitor’s pricing fairly, including evidence

(if appropriate) that you have compared like with like - for example, website screenshots to demonstrate the product,

price and period over which a competitor has offered a product. See pages 18-19 for more guidance

pROfESSIONAL DILIGENCE

VULNERAbLE CONSUmERS

6

There are certain general requirements that a trader should consider when pricing products for sale. In addition to the

Regulations, overlapping obligations can be found in the Consumer Contracts (Information, Cancellation and Additional

Charges) Regulations 201312 and the Price Marking Order 2004.13 Visit www.businesscompanion.info for advice and

guidance on these requirements.

These general requirements apply to all of your pricing practices and should be read in conjunction with the rest of this

guidance.

DO indicate the total price of the product inclusive of taxes when you invite consumers to purchase it.14 If the nature of

the product means that the price cannot reasonably be calculated in advance, indicate how the price will be calculated

- for example, fabric on a roll is priced by the metre.

DO provide all additional freight, delivery and postal charges in or with the price.15 If those charges cannot reasonably

be calculated in advance, tell consumers that they may be payable - for example, ‘Delivery charges apply and vary

according to destination’.

DO include all compulsory fees and charges in the price.16

DO show unit prices where required by the Price Marking Order 2004.17

DON’T charge consumers a fee for using a credit card or debit card that exceeds your own cost for providing that

method of payment.18

DON’T use a default option (such as a pre-ticked box on a website) in order to obtain a consumer’s consent to

an additional fee or charge.19

Delivery ChargesUp to £7.99£8.00 to £24.99£25.00 to £39.99£40.00 to £54.99£55.00 to £64.99£65.00 to £89.99£90.00 to £149.99£150.00 to £199.99£200 and over

£0.95£2.95£4.50£6.00£7.50£9.00£12.00£17.00£25.00

12 Implementing in part the Consumer Rights Directive 2011/83/EC

13 Implementing the Price Indications Directive 98/6/EC

14 Consumer Protection from Unfair Trading Regulations 2008, regulation 6(4)(d); Consumer Contracts (Information, Cancellation and Additional Charges)

Regulations 2013, Schedule 1(c) & Schedule 2(f); Price Marking Order 2004, article 4(1) and (2)

15 Consumer Protection from Unfair Trading Regulations 2008 6(4)(e); Consumer Contracts (Information, Cancellation and Additional Charges)

Regulations 2013 Schedule 1(d) & Schedule 2(g); Price Marking Order 2004, article 7(3)

16 Consumer Protection from Unfair Trading Regulations 2008, regulations 5 and 6

17 Price Marking Order 2004 (see www.businesscompanion.info/en/quick-guides/pricing-and-payment/price-marking-of-goods-for-retail-sale)

18 Consumer Rights (Payment Surcharges) Regulations 2012, regulation 4 (certain agreements are excluded from this obligation)

19 Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, regulation 40

GENERAL REqUIREmENTS



7

20 Consumer Protection from Unfair Trading Regulations 2008, regulation 5(2)(a)

DON’T use statements such as ‘all’ or ‘everything’ unless the statement applies to all of the products described, to

everything in the store or in that category.20

DO remember that perishable products - for example, food near to its ‘best before’ or ‘use by’ date or other products

that are deteriorating, such as plants - can be reduced in price without referring to the guidance in relation to reference

prices on page 14.

REDUCED

was £0.75pNOw £0.38p

ALL ONLINEORDERS

10%Off

8

Certain practices are banned and are considered to be unfair and unlawful in all circumstances.21

DON’T advertise products or services at a specific price if you have reason to believe that they will not be available in reasonable quantities at that price for a reasonable period without making this clear in the promotion.22

DON’T advertise a product at an attractive price to encourage interest and then discourage its purchase in order to

persuade the consumer to switch to something different - for example, by demonstrating a defective sample or by

refusing to show the product, take an order or deliver the product within a reasonable time.23

DON’T falsely state that a product will only be available at a particular price or available on particular terms for a very

limited amount of time in order to persuade the consumer to make an immediate decision and deny them the time or

opportunity to make an informed choice.24

DON’T claim that you are about to cease trading or move premises when you are not.25

DON’T describe a product as ‘free’ or similar if the consumer has to pay any more than the unavoidable cost

of responding to your offer, collecting the product or paying for delivery.26

See page 22 for more guidance on the use of ‘free’.

21 Consumer Protection from Unfair Trading Regulations 2008, Schedule 1

22 Consumer Protection from Unfair Trading Regulations 2008, Schedule 1 paragraph 5 (bait advertising)

23 Consumer Protection from Unfair Trading Regulations 2008, Schedule 1 paragraph 6 (bait and switch)

24 Consumer Protection from Unfair Trading Regulations 2008, Schedule 1 paragraph 7



fINAlwEEkEND

to sAvE

SALE7-DAy SALE

limited availability

sale ends midnight

tuesday

bANNED pRACTICES



9

This guidance is designed to provide helpful common sense advice to traders about pricing practices that regulators

are likely to consider fair or unfair.

If you wish to promote your products by making claims in relation to price you should spend time and effort ensuring

that the claim is transparent and not unfair. The guiding principle is that the promotion should not, in any way, mislead,

deceive or take advantage of consumers. Consumers should be able to have confidence that they can rely on the information that you provide when making their decision to purchase.

The average consumer is described in the Regulations as having the characteristics of being ‘reasonably well informed, reasonably observant and circumspect’. However, even well-informed, observant and circumspect

consumers can be deceived by unfair and misleading practices.

The Regulations do not just apply to the decision to purchase a product. They extend to other transactional decisions,

such as the decisions a consumer makes about payment terms or the exercise of other contractual rights. This may

also include decisions that do not have a direct financial consequence, such as entering a shop.27 You should consider

the impact that any pricing promotion might have on all of the decisions that consumers may take.

Consider:

• who is the promotion aimed at?

• what will that person understand it to mean?

• is that different to the actual position?

27 Trento Sviluppo srl and Centrale Adriatica Soc. Coop arl C-281/12, [2014] CTLC 326

For each pricing promotion, you should ask yourself:

• is any information (however it is given) false?

• even if the information is factually correct, will it, or the way in which it is presented, deceive or be likely

to deceive?

• is information that a consumer needs to know omitted, hidden, or given in a manner that is unclear,

unintelligible, ambiguous or untimely?

If any of your answers are ‘Yes’, or if you have any doubts, you should change your pricing promotion.

pRICE pROmOTIONS

IS yOUR pRICING pRACTICE UNfAIR?

10

It is important for traders to get pricing right. Getting it wrong could:

• create the illusion of savings that do not exist or have been exaggerated

• generate confusion amongst consumers

• generate legal claims for compensation

• cause civil enforcement action to be taken by regulators

• result in a complaint to the Advertising Standards Authority

• cause criminal enforcement action, fines and negative media exposure

• generate adverse publicity by consumers sharing negative stories about price promotions in the press

or social media

Your price promotion should not contain false information about the price, ‘the manner in which price is calculated’ or the ‘existence of a specific price advantage’.28

The following are examples of practices that may breach this requirement:

• advertising a price promotion for a product that is not in fact available at the advertised price

• comparing your current price to a reference price that is not genuine. (See page 14 for further guidance

on reference pricing)

• comparing your own price to the higher price of a competitor or to a recommended retail price (RRP)

but presenting the higher price as your own previous price

• excluding a compulsory charge from your headline price. (See page 24 for further guidance on additional charges)

• claiming a discount that is not in fact given to the consumer - for example, ‘10% off all main courses’ where

the price is not adjusted accordingly at the till

• claiming a discount for all of your products when all products are not in fact included in the offer - for example,

‘10% off all package holidays booked before end of September’ when holidays to Spain are excluded

28 Consumer Protection from Unfair Trading Regulations 2008, regulation 5 (4)(g) & (h)

GETTING IT wRONG

DOES yOUR pROmOTION CONTAIN fALSE INfORmATION?



11

The Regulations prohibit misleading omissions. Therefore it is important that you do not mislead consumers

by leaving out important information or presenting it in a way that hides or disguises it.

Your pricing practice can therefore be considered unfair if:

• it omits material information

• it hides material information

• it provides material information in a manner which is unclear, unintelligible, ambiguous or untimely

and it causes or is likely to cause the average consumer to take a different decision

The Regulations define material information as ‘The information which the average consumer needs, according to the context, to take an informed transactional decision’.

29 For more advice on volume offers, see page 21

30 For more advice on comparing your prices to other trader’s prices, see pages 18 & 19

Consumers must be able to trust the information you have provided them with. Your pricing practice must not contain

information that might deceive consumers or that is presented in such a way that might deceive consumers, even if

the information is factually accurate.

Care should be taken to ensure that better-value

offers based on size are not unfair because smaller

packs offering the same or better value can also

be purchased from you.29

If you become aware that your competitor has

lowered their selling price but you take no steps

to withdraw or amend the pricing practice you

may allow the promotion to become unfair.30

OUR pRICE

£10<Competitor> price

£20

bIGGER pACk - bETTER VALUE

claim on packaging

IS yOUR pRICING pRACTICE DECEpTIVE EVEN If IT IS fACTUALLy ACCURATE?

hAVE yOU TOLD CONSUmERS whAT ThEy NEED TO kNOw?

12

You must ensure that the presentation of your offer is transparent and clear. You should consider how consumers are

likely to understand it, having regard to its overall presentation.

In particular, you should consider the prominence and clarity of any additional text in comparison to the headline text

or main message.

You should ensure that the headline or prominent message is truthful, clear and consistent with other information you

provide. It should not need explanatory text to make it comply, particularly if that text is not prominent.

Consider how the offer is expressed - a simple offer can be communicated in straightforward terms using direct

language. If your offer is more complex you should take care to ensure that it is presented in a way that consumers

will fully understand.

Additional information should not contradict the headline claim. It must be given in a clear, intelligible, unambiguous

and timely manner. Including material information in the small print in a manner that is not clear and prominent may

mean that you do not meet that requirement.

Material information might be:

• qualifying statements - for example, ‘Wednesdays from 6pm’

• important conditions of the offer - for example, ‘minimum two dinners’

• relevant exclusions - for example, ‘set menu only’

fAb fRIENDSmIDwEEk TREAT2 COURSES £203 COURSES £23

wednesdays from 6pmMinimum two dinners, set menu only

hEADLINE TExT

SUb hEADING

SmALL pRINT

USE Of ADDITIONAL TExT



13

If you operate a website or use other digital communication, you should use technology so that information

is communicated to consumers in a way that is transparent and timely. Additional text that is likely to make a

difference to the consumer’s decision should be prominent and close to the price, headline or main message.

You should not delay telling consumers about additional charges or other material information when it is possible

to do so from the outset.

It may amount to an unfair practice if your technology requires that consumers take extra steps, such as clicking

on a link or scrolling down a page, to obtain material information, such as additional costs. You should consider

carefully whether it is possible to provide consumers with material information about the price and additional

costs without the need to visit other webpages or to follow links.

For more information on the use of additional text see the Committee of Advertising Practice

guidance Qualification claims

https://www.cap.org.uk/Advice-Training-on-the-rules/Help-Notes/Qualification



14

Reference pricing refers to price promotions which aim to demonstrate good value by referring to another,

typically higher, price.

Four examples of reference pricing are:

• ‘was/now’ prices, which compare an advertised price to a price the trader has previously charged

for the product

• after-promotion prices or introductory prices, which compare the current advertised price to a price

the trader intends to charge in the future

• recommended retail prices (RRPs), which compare an advertised price to a price recommended

by the manufacturer or supplier

• external reference prices, which compare an advertised price to a price charged by another trader

for the same product

Including a reference price in an offer can create a point which consumers use as a base for estimating the value

of the product and might reduce the effort consumers put into shopping around and comparing prices. It follows

that reference pricing calls for a high level of trust and integrity. It is unlikely that consumers will have made a

record of the reference prices in order to determine for themselves whether the claimed price reduction is genuine.

USING REfERENCE pRICES



15

Any specific price advantage claimed must not be misleading or unfair.31 It is important to be clear and not to make

unfair price comparisons. If your proposed pricing practice explicitly or by implication indicates a saving against

another price you must be able to satisfy yourself that the quoted saving is genuine and is therefore not unfair.

Ask yourself whether the average consumer would think that it is a fair comparison.

Below is a non-exhaustive list of issues that should be considered when determining whether a price reduction

is genuine.

1. How long was the product on sale at the higher price compared to the period for which the price comparison

is made?

2. How many, where and what type of outlets will the price comparison be used in compared to those at which

the product was on sale at the higher price?

3. How recently was the higher price offered compared to when the price comparison is being made?

4. Where products are only in demand for short periods each year, are you making price comparisons with

out-of-season reference prices?

5. Were significant sales made at the higher price prior to the price comparison being made or was there any reasonable expectation that consumers would purchase the product at the higher price?

31 Consumer Protection from Unfair Trading Regulations 2008, regulation 5(4)(h)

SALEwAs

Now

16

more likely to complyIssues to be considered Less likely to comply

1. How long was the product on sale at the higher price compared to the period for which the price comparison is made?

2. How many, where and what type of outlets will the price comparison be used in compared to those at which the product was on sale at the higher price?

3. How recently was the higher price offered compared to when the price comparison is being made?

4. Where products are only in demand for short periods each year, are you making price comparisons with out-of-season reference prices?

5. Were significant sales made at the higher price prior to the price comparison being made or was there any reasonable expectation that consumers would purchase the product at the higher price?

The price comparison is made for a period

that is the same or shorter than the period

during which the higher price was offered.

The retailer makes a price comparison

against a reference price that has been

offered in the same store as the price

comparison is made.

A travel agent refers to a selling price that

was charged less than two months ago with

no intervening prices and therefore gives

a genuine indication of the current value of

the holiday.

An online trader reduces its prices in order

to generate sales where demand has fallen

away when the sales season for a product

has passed.

The retailer can provide evidence to show

significant sales at the higher price or that this was a realistic selling price for the

product.

The price comparison is made for

a materially longer period than

the higher price was offered.

A retailer charges £3 in store A

and £2 in store B and then claims

‘Was £3 now £1.50’ in store B,

referring to a reference price in a

store where that price was never

charged.

A website refers to previous

selling prices that were charged

many months ago and therefore

no longer represent a genuine

indication of the current value

of the item.

A trader offers the product at a

higher price when the product is

out-of-season and then lowers

the price in time for the expected

product demand.

A retailer repeatedly uses a

reference price knowing that

it had not previously sold a

significant number of units at that price.



17

It is important that price comparisons are genuine. Examples of price comparisons that may not be genuine include:

1. During the period that the product was sold at the higher price, different types of discount were offered

- for example, multi-buy.

2. The higher price is not the last price that the product was sold at - for example, there have been intervening prices.

3. A series of price claims made against a reference price, where each subsequent claim does not offer

a greater discount.

Examples of price comparisonsthat may not be genuine more likely to comply Less likely to comply

1. During the period that the product was sold at the higher price, different types of discount were offered - for example, multibuy.

2. The higher price is not the last price that the product was sold at - for example, there have been intervening prices.

3. A series of price claims are made against a reference price, where each subsequent claim does not offer a greater discount.

An online retailer offers a product for

sale with the price claim of ‘Was £500

now £350’ for a month. For the preceding

month the product was priced at £500

with no price promotions or other price

reductions.

A sofa is offered for sale at £500

immediately before the price promotion

‘Was £500 now £350’ is advertised.

A coat is offered at ‘Was £150 now £99’,

then a further reduction is made and the

item is advertised as ‘Was £150 was £99

now half price £75’.

An online retailer offers a product

for sale with the price claim of

‘Was £500 now £350’ for a month.

For the preceding month the

product was priced at £500 with a

volume promotion operating at the

same time - ‘Buy 2 get 10% off’.

A sofa is offered at £500 then

reduced to £350 with no claim of

saving. A number of weeks later

the product is labelled as ‘Was

£500 now £350’.

A coat is offered at ‘Was £150

now half price £75’; subsequently

the same item is advertised as

‘Was £150 now £99’.

18

After-promotion price

You can make a comparison against a price that you will subsequently charge for a product. However, this type

of pricing practice is likely to be considered unfair if the price is not subsequently increased to the advertised

after-promotion price at the end of the promotional period or the reference price did not meet the guidance starting

on page 14.

Introductory price

Traders must consider carefully the use of ‘new’ or ‘introductory price’ in price promotions. You should assess what

consumers in your particular sector would consider as new and therefore how long the claim can be made before the

new or introductory price becomes the normal selling price. The claim ‘new’ could be used for a longer period where

the product is rarely purchased, compared to a regularly purchased product.

This type of pricing practice is likely to be considered unfair if the price of the product is not in fact increased at the

end of the promotional period.

Recommended retail price (RRP)

A recommended retail price (RRP) is a price that a manufacturer or supplier has independently recommended. The

use of RRPs is contentious and there have been calls to prohibit the practice completely. Traders must take extra

care when using RRPs to ensure that they do not mislead consumers.

When making comparisons to an RRP, you should clearly and prominently tell consumers that the higher price is

an RRP, rather than a price that you have charged. The initials RRP have historically been used in the UK and their

meaning is likely to be understood by most consumers. You should avoid using other abbreviations unless you can

be sure that consumers will have a clear understanding of their meaning in the context of the sale.

An RRP must not be false; it must not be created purely in order to present the appearance of a discount. An RRP

must represent a genuine selling price. You should not recommend your own RRP or influence the price at which your third party supplier or manufacturer sets the RRP.

Traders using RRPs should consider obtaining substantiation from their suppliers or manufacturers that the RRP

represents a genuine selling price. The use of RRPs as a reference price without such substantiation leaves the

business open to the risk that the RRP is not genuine and may be considered misleading.

Further guidance on the use of RRPs is available from the Committee of Advertising Practice: ‘marketers should be aware that while it is acceptable for them to quote RRPs if they are genuine, such price comparisons are likely to mislead if the RRP differs significantly from the price at which the product or service is generally sold.’

Comparison to a competitor’s price

Comparisons that you make to a competitor’s price must comply with both the requirements of the Regulations and the

Business Protection from Misleading Marketing Regulations 2008. The price comparison must not be false or mislead

consumers and they must be told any material information in a way that is clear, transparent and timely.

A fair comparison may be made between the price of a product you sell against the same product being sold by a

competitor. Such comparisons can be helpful to consumers who are looking for the best price for that item or service.

https://www.cap.org.uk/Advice-Training-on-the-rules/Advice-Online-Database/Recommended-Retail-Prices.aspx#.WEFfGH0aySV



19

You can also make comparisons with products which, whilst not identical, meet the same needs or are intended for the

same purpose. You should set out any material differences between your product and the competitor’s product clearly

and transparently. This is unlikely to be achieved if material differences are not a prominent part of the presentation

of the price comparison to consumers. You should not selectively focus on element(s) of a competitor’s price that are

unrepresentative and give an overall impression that is misleading.

The basis of any comparison you make against your competitor should be objective rather than subjective. The

comparison must objectively compare one or more material, relevant, verifiable and representative features of the product. You should consider providing simple mechanisms through which a consumer can verify the comparison,

such as online, by email, telephone or in writing.

If you operate in a particularly price-sensitive sector, where prices frequently change, you should take care to ensure

that your price comparison does not become misleading because your competitor’s price has changed. You should

monitor the position and take prompt action to withdraw claims if necessary.

You must not compare the price of your product against the price of a product with a designation of origin - for example

a Cornish pasty32 - unless your product has the same designation of origin.33

If you wish to make a comparison based on prices in specific locations, care needs to be taken to establish whether there are local price variations. If the prices you wish to use are based on information made available centrally by your

competitor - for example, online - you should check for local variations.

You should not make general claims that give the overall impression that all of your products are cheaper, if that is only

true for selected items. If you make a claim that your prices are generally lower, you should explain why it is a fair and

suitable comparison - for example, by telling consumers the basket of products chosen is based on a typical weekly shop.

It is important that you keep clear documentary records of any price comparisons that you have made against a

competitor’s price. You should identify your competitor, their product and the circumstances in which they offered the

product at the price you are comparing against. In some instances, it may also be important to provide technical

evidence to demonstrate that your product is not materially different.

In making a price comparison to the price of a competitor you must observe the following rules:

• you must not deliberately mislead consumers into believing that your product is made by a particular

manufacturer, when it is not34

• you must not create confusion between you and your competitor

• you must not create confusion between your products’ trademarks, trade names, other distinguishing marks

and those of your competitor

• you must not discredit or denigrate the trademark, trade name or other distinguishing mark, goods, services,

activities or circumstances of a competitor

• you must not take unfair advantage of the reputation of a trade mark, trade name or distinguishing mark

of a competitor or of the designation of origin of competing products

• you must not present products as imitations or replicas of products bearing a protected mark or trade name

32 Council Regulation (EC) No 510/2006 on the protection of geographical indications and designations of origin for agricultural products and

foodstuffs: Cornish Pasty 2007

33 Business Protection from Misleading Marketing Regulations 2008, regulation 4(g)


For more information about comparing to a competitor’s price see the Committee of Advertising Practice

guidance Retailers’ price comparisons


https://www.cap.org.uk/Advice-Training-on-the-rules/Help-Notes/Retailers-Price-Comparisons

https://www.cap.org.uk/Advice-Training-on-the-rules/Help-Notes/Retailers-Price-Comparisons

20


Examples of pricing practices more likely to comply Less likely to comply

Comparing pricing models that are not like-for-like

Comparing products in different conditions

The website claims ‘Save 50% on airport

parking’ and also states ‘when you

book in advance, compared to the turn

up and pay price’ in a clear, intelligible,

unambiguous and timely manner.

A car retailer advertises the price of a

second-hand car and claims a saving

against a higher price that was the price

of the car when new. The origin of the

higher price is clearly stated alongside

the savings claim.

The website claims ‘Save 50%

on airport parking’ with no further

details of the basis of the claim

of 50% savings.

A car retailer advertises the price

of a second-hand car and claims

a saving against a higher price

that was the price of the car

when new. This information is

not provided.

Comparison with prices in different circumstances

It may be possible to make a fair price comparison against the price of a product that has been sold in different

circumstances. However, it is very important that any material differences in the circumstances are communicated to

consumers in a way that is transparent, fair and prominent. Features that differentiate the circumstances must be clear

and not hidden in the small print. Any material information must be provided in a clear, intelligible, unambiguous and

timely manner.

The comparison must be readily understandable and relevant to the consumer it is directed towards. The differences

between the circumstances must still allow for a fair comparison to be made. The overall impression given to

consumers must not be misleading even if the information provided is correct.

Additional text (refer to guidance starting on page 12) may be useful to ensure that the pricing practice can be clearly

understood by the average consumer, as long as it is provided in a clear, intelligible, unambiguous and timely manner.

It is a breach of the Regulations to deprive consumers of sufficient opportunity or time to make an informed choice by falsely stating that a product is only available on those terms for a very limited time.35 It is particularly important

that traders do not contravene this provision where a consumer is likely to feel under pressure because of the

circumstances of a sale, such as a sale made in a consumer’s home.

Where a product will genuinely only be available on particular terms for a limited time, and consumers need to act

quickly to take advantage of the offer, the date the offer ends is very likely to be material information. Therefore it

should be provided in a manner that is clear, intelligible, unambiguous and timely.

Once the end date for any pricing promotion has been published (for example, in store, in press, TV advertising or

online), any change to the end date is likely to be scrutinised carefully by regulators to assess whether the originally

publicised time limit was genuine. You should avoid changing the end date unless circumstances arise that could not

be reasonably foreseen at the time that the price promotion commenced.

If there is any delay between a consumer ordering a product and receiving it, you should make clear whether the price

promotion applies if the time limit expires after a consumer has ordered the product, but before the delivery

of goods or commencement of a service.

TImE LImITED OffERS



21

Volume offers are price promotions that aim to demonstrate good value by reference to the volume, weight

or amount of the product purchased, or the purchase of a combination of different products.

Examples of volume offers include:

Multi-buys - where the consumer gets a discount by purchasing

more than one unit of a product, such as:

• buy one get one free

• three for the price of two

• two for £3

Combination offers - where a discount is given when the consumer

purchases a specified combination or basket of products, such as:

• meal deal: sandwich, drink and crisps for £5

Linked offers - where the consumer is offered a free or discounted

product for purchasing another product, such as:

• half price MOT with your car service

Extra for the same price - where the consumer is given more for

the same price, such as:

• 50% extra free

• bigger pack - better value

You should not use this type of price promotion unless the consumer is genuinely getting better value because

of the offer. Care must be taken to ensure that any volume offer is not made to be unfair because better value was

being offered before the volume promotion or for the same product elsewhere in your business.

The risk of these price promotions being unfair is increased if they are not easy to understand. You must ensure that

the price promotion provides all of the material information that the consumer needs to understand it and that this

information is provided in a clear, intelligible, unambiguous and timely manner. You should not take advantage of

the fact that many consumers will not calculate for themselves whether your price promotion actually offers better

value - for example, the price of a combination offer should be cheaper than the total cost

of buying the same items separately.

Pre-printed value claims on pack such as ‘Bigger pack - better value’ should be objectively accurate and justifiable.

bUy ONE

GET ONE fREE

on all clothing

bUy oNE MAINCoUrsE gEt ONE

hALf pRIcE

mEAL DEALINCLUDES SANDwICh,

CRISpS AND DRINk

£2.95

VOLUmE OffERS

22

You must not use the term ‘free’, or similar phrases, unless the consumer pays nothing other than the unavoidable

cost of responding to the commercial practice and collecting or paying for delivery of the item.36

In promotions where an item is described as ‘free’ traders should be able to show:

• that the free item is genuinely additional to or separable from what is being sold

• if the consumer complies with the terms of the promotion, the free item will be supplied alongside what

the consumer is paying for

• the stand-alone price of what is being sold is clear and is the same with or without the free item

Receiving the free product can be conditional on the purchase of a product provided this is made clear - for example:

• the claim ‘Free wallchart when you buy Thursday’s paper’ is legitimate if the paper is sold without

a wallchart on other days for the same price

• a claim of ‘Free travel insurance for customers who book their holiday online’ is legitimate if customers

who book the same journey by telephone are offered the same price but not offered free insurance

The item must, however, be truly free. The cost of the free item should not be recovered by reducing quality or

composition or inflating the price of the product that is to be paid for. You should not describe a part of any package as ‘free’ if it is already included in the package price.

You should not exaggerate the value of any free product or service to persuade consumers to make qualifying

purchases.

36 Consumer Protection from Unfair Trading Regulations 2008, Schedule 1, paragraph 20

fREETOyGIVEAwAy! Sample!fREEfREE fREE

GIfT

USE Of ‘fREE’



23

You should not describe a service as free if it is not free for consumers that choose not to enter into an agreement

with you after receiving the service - for example, you should not use the terms ‘free valuation’ or ‘free call-out’ if

there is a one-off charge for a consumer who decides not to proceed with a subsequent purchase or agreement.

For more information on the use of ‘free’ see the Committee of Advertising Practice guidance Free claims

fREE vAlUAtIoN

https://www.cap.org.uk/~/media/Files/CAP/Help%20notes%20new/Guidance_use_of_free.ashx

https://www.cap.org.uk/Advice-Training-on-the-rules/Help-Notes/Guidance-on-Free-claims

24

Delivery ChargesUp to £7.99£8.00 to £24.99£25.00 to £39.99£40.00 to £54.99£55.00 to £64.99£65.00 to £89.99£90.00 to £149.99£150.00 to £199.99£200 and over

£0.95£2.95£4.50£6.00£7.50£9.00£12.00£17.00£25.00

This section contains further detailed guidance on additional charges and should be read in conjunction with the

general requirements.

Examples of additional charges are:

• fixed compulsory charges, which all consumers have to pay

• charges for a component of the product or service that is compulsory but where there is a range of possible

charges for that compulsory component

• additional charges for an optional product or service

Compulsory charges that are fixed

Additional charges should be included in the up-front price if they are compulsory. A failure to include compulsory

charges in the up-front price may breach the Regulations.

Examples of compulsory charges are:

• a non-optional administration fee that must be paid for a service

• a set cover charge at a restaurant

• mandatory insurance cover required for hiring a car

Compulsory charges that may vary

Compulsory charges may vary in accordance with the consumer’s choices or circumstances. Even if the charge may

vary, it is still compulsory if the consumer must always pay something extra for it - for example, a delivery charge

might depend on the consumer’s location or the size/weight of the product.

Where a compulsory charge may vary, you should alert consumers to the charge at the outset. You should give

information about how it will be calculated in a clear, intelligible, unambiguous and timely manner while still allowing

the total cost to be easily and readily calculated by the average consumer as soon as possible.

ADDITIONAL ChARGES



25

Care should be taken that general notices such as ‘Up to half price sale’ or ‘From 50% off’ are not misleading; they

must reflect the reality of the offer. You should only make such a claim if the maximum reduction quoted applies to a significant proportion of the range of products that are included in the promotion. A prominent general claim of a maximum discount such as this should represent the true overall picture of the price promotion. The ‘up to’ and ‘from’

claims are essential to the understanding of the pricing practice so should be shown clearly and prominently.

Off50 %Up TO

Examples of compulsory charges that vary:

• a charge for a component part of bespoke furniture that may vary according to the material used,

such as the fabric chosen

• a charge for delivery that is compulsory but varies according to location

Optional charges

It is not necessary to include an optional charge within the up-front price. However, the charge must be genuinely

optional. Charges that are, in reality, an unavoidable part of the main purchase are not optional. You should ask the

question whether the average consumer would consider ‘optional’ to be a fair description of the charge. Where a

charge is optional, it should still be presented to the consumer clearly.

Examples of optional charges:

• when booking a flight, a charge for hiring a car at the destination

• when buying a product, a charge for gift wrapping

‘Up TO’ & ‘fROm’ CLAImS

26

If your agreement with a consumer requires that repeat payments are made, such as a monthly subscription, the

extent of the consumer’s financial commitment should be set out clearly and prominently from the outset, and the consumer’s express consent to these additional payments secured before they are charged. You should not mislead

consumers about the extent of their future commitment in order to secure an agreement. If you initially offer a product

that is free or heavily discounted, you must inform consumers clearly and prominently of any additional payment

obligations that will be incurred, including the duration of any contract.

Published by the Chartered Trading Standards Institute


Copyright 2016 Chartered Trading Standards Institute

SUbSCRIpTIONS

SC Jan 17 AI 03b

SC Jan 17 AI 03b – CAMs Review Unclassified Page 1 / 5



Title Complementary/Alternative Medicines (CAMs) Review


Summary The paper is intended for discussion purposes and, although not

comprising an exhaustive list, sets out a range of ‘positions’ from a range

of organisations about the use, effect and regulatory stance taken on the

use of CAMs.

Decisions required To review the current position and consider:

What (if any) further information the Committee wishes to obtain?

To what extent (if at all) the Committee wishes to amend the current

Code of Professional Conduct/Supplementary Guidance, with

reference to the provision of complementary and alternative

medicines/services and advertising of and claims made for such

products and services?

Attachments Annex A: Current RCVS statement on homeopathy;

Annex B: Extracts from the Code of Professional Conduct and Supporting

Guidance: 1.3 / 2 / 19.22 / 23;

Annex C: Up to date guidance and recommendations from the Advertising

Standards Authority (ASA) on the restrictions on advertising and marketing

of homeopathic products;

Annex D: Homeopathy – what’s being said by others;

Annex E: Article – Evidence–based Complementary and Alternative

Veterinary medicines – a contradiction in terms? (2010);

Annex F: Report of Science Advisory Panel 2016;

Annex G: Recent review paper published in the Veterinary Record 17

December 2016 (page 628) entitled: ‘Efficacy of homeopathy in livestock

according to peer-reviewed publications from 1981 – 2014’;

SC Jan 17 AI 03b


Annex H: VMD – Guidance on the operation of the use of unauthorised

medicines (the cascade);

Annex I: Media bundle;

Annex J: Extract from home page of the British Association of

Homeopathic Veterinary Surgeons (BAHVS) (see links embedded in the

site).

Author Eleanor Ferguson

Registrar/Director of Legal Services

020 7202 0718

[email protected]


SC Jan 17 AI 03b


Background 1. The debate about the role and use of Complementary and Alternative Medicines (CAMs) (of

which homeopathy is one), has been ongoing for some time, with considerable strength of feeling

on both ‘sides’ of the argument.

2. However, the debate crystallised somewhat in recent times, with the ‘removal’ of homeopathic

treatments from the NHS, and calls within the veterinary sector for a ‘ban’ on homeopathy –

initially in a recent petition with over 3,000 signatures [see: https://www.change.org/p/the-royal-

college-of-veterinary-surgeons-a-call-to-ban-veterinary-surgeons-from-prescribing-homeopathy-

as-a-treatment-for-animals ]. At the same time, however, there has been a ‘counter’ petition with

over 6,000 signatures supportive of homeopathy [see: https://www.change.org/p/british-

veterinary-prove-homeopathy-is-worth-keeping-for-our-pets ].

Current position 3. The RCVS position has remained static for some time. See Annex A for full details. Below sets

out the text of the recent letter to Danny Chambers in response to the “anti” – homeopathy

petition:

“As the regulator of the veterinary profession we place an emphasis on the importance of evidence-based veterinary medicine. We therefore recommend that there should therefore be a cautious approach to homeopathy for animals and that normal evidential standards should be applied to complementary treatments. We believe it is also essential that such treatments, until they can be proved, are complementary rather than ‘alternative’ and that they are therefore used alongside conventional treatment.

However, whatever views there may be within the veterinary profession, it is clear that there is a demand from some clients for complementary therapies for their animals. It is better that they should seek advice from a veterinary surgeon – who is qualified to make a diagnosis, and can be held to account for the treatment given – rather than turning to a practitioner who does not have veterinary training.

Furthermore, homeopathy is currently accepted by society and recognised by UK medicines legislation and does not, in itself, cause harm to animals. While this is the case it is difficult to envisage any justification for banning a small number of veterinary surgeons from practising homeopathy.”

4. It should be noted that although excluded from NHS funding, homeopathy and other CAMs have

not been ‘banned’ as such and there remains a demand for it within society at large. It should be

also be noted that there are a considerable number of homeopathic remedies that have a

marketing authorisation and are licensed for animal use by the VMD, and therefore authorised for

veterinary use, see link for those grandfathered in, as on the market before 1st January 1994. A

very much smaller list (@10) has received subsequent authorisation. To be marketed a

veterinary homeopathic remedy must either be registered or specially prepared for a specific

animal.

https://www.change.org/p/the-royal-college-of-veterinary-surgeons-a-call-to-ban-veterinary-surgeons-from-prescribing-homeopathy-as-a-treatment-for-animals



https://www.change.org/p/british-veterinary-prove-homeopathy-is-worth-keeping-for-our-pets

https://www.change.org/p/british-veterinary-prove-homeopathy-is-worth-keeping-for-our-pets

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/499695/_750047_Veterinary_homeopathic_remedies_eligible_for__Grandfather_Rights.XLS

SC Jan 17 AI 03b


5. Purely from a ‘medicines’ perspective, it would appear that authorised homeopathic remedies

may be used quite legitimately as a first option for animal treatment, otherwise use would be

under the cascade (see for reference Annex H: re: use of unauthorised medicines / under the Cascade).

6. As regards claims made about products/advertising, the recent changes in guidance issued by

the ASA (via the Committee of Advertising Practice (CAP)) are significant and far reaching and

have come about as a result of the withdrawal of homeopathy from the NHS. Although primarily

targeted at ‘human’ homeopathy, the ASA guidelines would seem to apply in equal measure to

veterinary services.

7. As regards to licensed/authorised products, the guidance allows whatever claims are on the

product label/pack to be reproduced. Otherwise, it would seem to permit registered practitioners

(as distinct from someone that had no qualifications, and not backed via a formal system of

regulation) to make claims about treating conditions only if there is ‘robust clinical evidence’ to

support the claims made.

8. There is no precise definition of what ‘robust’ evidence is, and in particular whether it is limited to

the six categories generally recognised in Cochrane. In descending order these are:

Grading of evidence – 6 levels

Ia: systematic review or meta-analysis of randomised controlled trials (RCTs);

Ib: at least one RCT;

IIa: at least one well-designed controlled study without randomisation;

IIb: at least one well-designed quasi-experimental study, such as a cohort study;

III: well-designed non-experimental descriptive studies, such as comparative studies,

correlation studies, case-control studies and case series;

IV: expert committee reports, opinions and/or clinical experience of respected authorities.

9. The guidance however does helpfully state:

“To date the ASA has not seen persuasive evidence to support claims that homeopathy can treat, cure or relieve specific conditions or symptoms. We understand this is in line with other authoritative reviews of evidence. We therefore advise homeopathic marketers to avoid making specific claims of efficacy for treatments where robust evidence is not held to substantiate them.”

10. Furthermore, in its section headed ‘the need for evidence’, it states:

“Objective claims must be backed by evidence, if relevant, consisting of trials conducted on people. If relevant the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of available scientific evidence.”

They make it clear that testimonials from clients alone will not be sufficient.

SC Jan 17 AI 03b


11. Attached Annex D: What’s being done by others? For reference, this sets out the current

published approach and views in a variety of spheres, veterinary and otherwise, in the UK and

abroad. Notably the robust position stated in the NHS guidance (25) in Annex C is not reflected in

terms in the GMC guidance; though some mention is made with reference to unlicensed

medicines, (15) and with reference to prescribing generally (17) where it is stated that effective

treatments should be based on the ‘best available evidence’. Likewise, GMC guidance in relation

to advertising is fairly muted, referring to making sure information published is “factual and can be checked and does not exploit patients vulnerability or lack of medicine knowledge.” Position

statements by Associations tend to be more strident than those of regulators and there seems to

be a focus on the provision of information to clients / customers to ensure informed choice.

Going forward 12. Until the recent changes in the position of the ASA following on from the removal of homeopathy

from the NHS, there have been considerable barriers to any changes to the previously stated

RCVS position / guidance.

13. With these in place, however, and short of a ‘ban’, there would seem to be scope to expand the

current RCVS Code of Professional Conduct / guidance in a number of respects – regarding

consent / information to clients about products / advertising and claims about products, to allow

an informed choice to be made.

14. The Article referred to at Annex E sets out an analysis as at 2010 of the data available on CAM in

human and veterinary medicine concluding that little rigorous research data concerning efficacy

has been published. This is echoed in the information referred to at Annex F.

15. The Committee is asked to review the current position and consider:

What (if any) further information it wishes to obtain?

To what extent (if at all) it wishes to amend the current Code of Professional

Conduct/Supplementary Guidance with reference to the provision of complementary and

alternative medicines/services and advertising of and claims made for such products and

services?

SC Jan 17 AI 03b An A

SC Jan 17 AI 03b An B

Extracts from the Code of Professional Conduct and Supporting Guidance

1. Referrals and second opinions

When to refer 1.3 Veterinary surgeons should recognise when a case or a treatment option is outside their area of

competence and be prepared to refer it to a colleague, organisation or institution, whom they are

satisfied is competent to carry out the investigations or treatment involved.

2. Veterinary care

Introduction 2.1 The Codes of Professional Conduct state that veterinary surgeons and veterinary nursesmust

provide veterinary care and veterinary nursing care that is appropriate and adequate.

2.2 Veterinary surgeons and veterinary nurses are personally accountable for their

professionalpractice and must always be prepared to justify their decisions and actions. When

providingcare, veterinary surgeons and veterinary nurses should:

a. take all reasonable care in using their professional skills to treat animals;

b. ensure that a range of reasonable treatment options are offered and explained, including

prognoses and possible side effects;

c. make decisions on treatment regimes based first and foremost on animal health and welfare

considerations, but also the needs and circumstances of the client;

d. recognise the need, in some cases, to balance what treatment might be necessary,

appropriate or possible against the circumstances, wishes and financial considerations of the

client*;

e. obtain the client's consent to treatment unless delay would adversely affect the animal's

welfare (to give informed consent, clients must be aware of risks) (see Supporting Guidance

Chapter 11);

f. consider the welfare implications of any surgical or other procedure and advise or act

appropriately;

g. provide an environment in which animals are subjected to minimum stress and provided with

optimal care;

h. ensure a hygienic and safe environment;

i. where possible, check that the care or treatment provided for each animal is compatible with

any other treatments the animal is receiving (it is recognised that it may not be possible to do

so in emergency situations);


j. keep within their own areas of competence, save for the requirement to provide emergency

first aid;

k. consult suitably trained colleagues, either within or outside the practice, when novel or

unfamiliar procedures might be under consideration or undertaken;

l. facilitate a client’s request for a referral or second opinion and recognise when a case or a

treatment option is outside their area of competence (see Supporting Guidance Chapter 1);

m. comply with animal welfare legislation and relevant Codes of Practice in the jurisdiction(s) in

which they practise;

n. comply with relevant legislation, guidance and Codes of Practice if involved in research or

teaching (see Supporting Guidance Chapters 24 and 25)

o. be familiar with any special rules or requirements of the particular industry in which they

practise, for example, the meat hygiene industry or animals used in sport; and

p. keep their skills and knowledge up to date.

*There may be additional considerations for owners of animals kept for commercial or

production purposes. Whatever the circumstances, the overriding priority is to ensure that

animal health and welfare is not compromised.

Communicating investigations and treatment options to the client 2.3 Having reached a provisional diagnosis, taking into account the animal’s age, the extent of any

injury and disease and the likely quality of life after treatment, veterinary surgeons should make a

full and realistic assessment of the prognosis and the options for treatment or euthanasia and

communicate this to the client.

2.4 Veterinary surgeons and veterinary nurses should use language appropriate for the client and

explain any clinical or technical terminology that may not be understood (see Supporting

Guidance Chapter 11 Communication and Consent).

19. Treatment of animals by unqualified persons

Other complementary therapy 19.22 It is illegal, in terms of the Veterinary Surgeons Act 1966, for non-veterinary surgeons,

however qualified in the human field, to treat animals. All forms of complementary therapy

that involve acts or the practise of veterinary surgery must be undertaken by a veterinary

surgeon, subject to any exemption in the Act. At the same time, it is incumbent on veterinary

surgeons offering any complementary therapy to ensure that they are adequately trained in its

application.


23. Advertising and publicity

Complying with UK advertising codes 23.2 All publicity should comply with the UK Code of Non-broadcast Advertising, Sales Promotion

and Direct Marketing (CAP Code) which is enforced by the Advertising Standards Authority,

see http://www.cap.org.uk/Advertising-Codes/Non-Broadcast.aspx

23.3 Veterinary surgeons and veterinary nurses planning to conduct a direct marketing campaign

should comply with all relevant data protection legislation. Advice and guidance can be

sought from the Information Commissioner's Office and there is useful information on

database practice at section 10 of the CAP Code.

23.4 Veterinary surgeons and veterinary nurses planning to produce advertisements or publicity

which make claims of superiority or other comparisons with competitors should have

particular regard to section 3 of the CAP Code so as to ensure they do not mislead the public

or be accused of so doing.

23.5 Concerns about particular advertisements and publicity should generally be raised with the

Advertising Standards Authority in the first instance (or the Information Commissioner's Office

where the concerns relate to the use of personal data).

http://www.cap.org.uk/Advertising-Codes/Non-Broadcast.aspx

http://ico.org.uk/

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SC Jan 17 AI 03b An C

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SC Jan 17 AI 03b An D

SC Jan 17 AI 03b An E

Veterinary Homeopathy1. Homeopathy is a complementary or alternative medicine based on the use of highly diluted

substances which practitioners claim can cause the body to heal itself, and is therefore used in anattempt to treat a wide range of conditions. In reference to human medicine, a 2010 House ofCommons Science and Technology Committee report on homeopathy stated that homeopathictreatments perform no better than placebos.

2. The use of veterinary homeopathy in veterinary medicine is highly controversial. Proponents ofhomeopathy point to case reports, non-randomised comparative studies and randomisedcontrolled trials (RCTs) that are perceived to be positive. Critics emphasise the improbableefficacy of very highly diluted medicines, and conclude that the research evidence in homeopathycannot plausibly contain positive findings. However, up until recently, neither side of theargument had been able to call upon the true and full nature of the clinical research evidence asno systematic review of RCTs in veterinary homeopathy had been conducted.

3. In 2014 the first systematic review of randomised controlled trials of veterinary homeopathy(annex 1) was carried out by Robert Mathie, research development adviser for the BritishHomeopathic Association (BHA), and Jürgen Clausen from the Carstens Foundation in Germany.Using the standard criteria defined by the Cochrane Collaboration, the review sought to assessthe risk of bias and to quantify the effect size of homeopathic intervention compared with placebofor each eligible peer-reviewed trial. The authors found 18 peer-reviewed placebo-controlledRCTs of veterinary homeopathy that were eligible for detailed assessment. These RCTs weredisparate in nature, representing four species and 11 different medical conditions. Of these, twowere judged to comprise reliable evidence and be free from vested interest: homeopathy for theprevention of diarrhoea in piglets was shown to be effective; individualised homeopathic treatmentof mastitis in cattle was shown to be ineffective. The remaining studies had unclear or high risk ofbias. The shortcomings of the remaining papers were concerned particularly with randomisation,allocation concealment, blinding and source of funding and these failings were likely contributoryto the highly variable results provided by these trials.

4. The mixed findings from the only two reliable placebo-controlled RCTs prevent any conclusionsabout the efficacy of any particular homeopathic treatment or the impact of individualisedhomeopathic intervention on any given medical condition in animals. Given this, there is a clearneed for new and higher quality research.

5. The same researchers have recently completed a full meta-analysis of the same 18 trials and thiswill be submitted for publication shortly. They are also working on a systematic review of non-placebo-controlled RCTs in veterinary homeopathy.

SAP Apr 16 AI 05

SC Jan 17 AI 03b An F

October 18, 2014 | Veterinary Record | 373

Res

earchResearch

Veterinary homeopathy: systematic review of medical conditions studied by randomised placebo-controlled trialsRobert T. Mathie, Jürgen Clausen

A systematic review of randomised controlled trials (RCTs) of veterinary homeopathy has not previously been undertaken. Using Cochrane methods, this review aims to assess risk of bias and to quantify the effect size of homeopathic intervention compared with placebo for each eligible peer-reviewed trial. Judgement in seven assessment domains enabled a trial’s risk of bias to be designated as low, unclear or high. A trial was judged to comprise reliable evidence if its risk of bias was low or was unclear in specified domains. A trial was considered to be free of vested interest if it was not funded by a homeopathic pharmacy. The 18 eligible RCTs were disparate in nature, representing four species and 11 different medical conditions. Reliable evidence, free from vested interest, was identified in two trials: homeopathic Coli had a prophylactic effect on porcine diarrhoea (odds ratio 3.89, 95 per cent confidence interval [CI], 1.19 to 12.68, P=0.02); and individualised homeopathic treatment did not have a more beneficial effect on bovine mastitis than placebo intervention (standardised mean difference -0.31, 95 per cent CI, -0.97 to 0.34, P=0.35). Mixed findings from the only two placebo-controlled RCTs that had suitably reliable evidence precluded generalisable conclusionsabout the efficacy of any particular homeopathic medicine or the impact of individualisedhomeopathic intervention on any given medical condition in animals.

Robert T. Mathie, PhD, British Homeopathic Association, Hahnemann House, 29 Park Street West, Luton LU1 3BE, UKJürgen Clausen, PhD, Karl und Veronica Carstens-Stiftung, Am Deimelsberg 36, D-45276 Essen, Germany

E-mail for correspondence: [email protected]

Provenance: not commissioned; externally peer reviewed

Accepted for publication June 21, 2014

Veterinary Record (2014) doi: 10.1136/vr.101767

HomeopatHy is a system of medicine that uses specific preparations of substances whose effects, when administered to healthy subjects, correspond to the manifestations of the disorder (symptoms, clinical signs, pathological states) in the individual patient. Homeopathic prescribing is thus normally based on the individual’s ‘totality of symptoms’ (Swayne 2000).

In (rightly) extolling the importance of placebo-controlled clini-cal trial design in evidence-based veterinary medicine, overall and Dunham (2009) make a key comment about the application of the scientific method in the particular case of homeopathy: ‘If homeopa-thy [wishes] to be considered by scientists, [it] must be shown to be valid using methods that science uses to evaluate all treatment modali-ties’. this systematic review directly addresses this issue by examin-ing the evidence available in randomised placebo-controlled trials of veterinary homeopathy, using established systematic review methods.

the use of homeopathy in veterinary medicine is highly con-troversial, with strong viewpoints expressed on each side of the argument (Baker and others 2005, Hektoen 2005). on the one side,

Review

homeopathy’s proponents point to case reports, non-randomised com-parative studies and randomised controlled trials (RCts) that are per-ceived to be positive; on the other side, critics highlight the improbable efficacy of very highly diluted medicines, with the conclusion that the research evidence in homeopathy cannot plausibly contain positive findings. Nevertheless, many homeopathic medicines are not in this ‘ultra-molecular’ range (Rutten and others 2013), and the plausibility argument is being approached directly in new research on nanoparti-cles (Bell and Schwartz 2013) and other physicochemical properties of dilutions (see Hill and others 2009). moreover, neither side of the argument has been in a position to know the true and full nature of the clinical research evidence as, until now, no systematic review of RCts in veterinary homeopathy has been conducted.

a previous systematic search of the published RCts in veteri-nary homeopathy by the current authors identified 38 peer-reviewed papers that were regarded as potentially eligible for detailed systematic review (mathie and others 2012b). Such in-depth reviews can inform the debate surrounding the effectiveness of veterinary homeopa-thy in general or the efficacy of its medicines for particular medical conditions.

In taking forward the first phase of this in-depth review pro-gramme, the approach continued to reflect the above literature analy-sis, and three principal attributes of research design or intervention were distinguished: (a) controlled by placebo versus controlled by other than placebo; (b) individualised homeopathy versus non-indi-vidualised homeopathy; and (c) treatment versus prophylaxis. this review reports findings from an appraisal of placebo-controlled, peer-reviewed trials of veterinary homeopathy (individualised or non-indi-vidualised, treatment or prophylaxis).

For each eligible RCt, the aim was to assess the risk of bias (Higgins and altman 2011), together with the direction, statistical sig-

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nificance and effect size of home-opathy or placebo on the main outcome measure. For groupings of RCts per medical condition, we aimed to determine pooled effect size by meta-analysis and, by reflecting study quality criti-cally in our approach, to deter-mine if (and which) homeopathic interventions were more benefi-cial than placebo, and for which particular medical condition(s). practical and reporting standards for systematic reviews set by the pRISma Group (moher and others 2009) were adhered to throughout.

MethodsData sourcesall randomised and controlled trials that assessed a homeopathic intervention, in any species except people, were eligible for review according to the inclusion/exc lus ion cr i te r ia out l ined previously (mathie and others 2012b).

the following electronic databases were searched, up to and including march 2011 (dur-ing peer review, the systematic literature search was updated up to the end of December 2013): ameD, CINaHL, CeNtRaL (Cochrane), embase, Hom-Inform, HomVetCR (Carstens-Stiftung), LILaCS, pubmed, Science Citation Index and Scopus. the literature search strategy has been described in detail elsewhere (mathie and others 2012b).

Identifying papers for full data extractioneighteen papers were identified as satisfying the key acceptance criteria: substantive report of clinical treatment or prophylaxis trial in veterinary homeopathic medicine; randomised; controlled by placebo; and published in a peer-reviewed journal (mathie and others 2012b).

Rtm screened and categorised each of the 18 potentially relevant papers to assess their eligibility for full data extraction. JC indepen-dently appraised these decisions. any differences of opinion were resolved by consensus discussion.

exclusion criteria before data were extracted:n Research using radionically prepared ‘homeopathic’ medicines; n Intervention tested was homeopathy combined with other (complementary or conventional) medicine or therapy.

Fig 1 illustrates the pRISma flowchart, which focuses solely on previously identified placebo-controlled trials (mathie and others 2012b). RCts controlled by a comparator other than placebo are the subject of a separate review. the 18 RCts included in this systematic review comprised 12 treatment trials and six prophylaxis trials.

Data extraction and managementBecause it is recognised that contacting the original authors of trials may lead to overly positive answers (Higgins and altman 2011), the authors of eligible RCt papers were not approached for clarification on unclear or missing facets of any of their methods or results; however, original authors’ references to their previously published study methods were eligible for follow-up and taken into account as appropriate. For each of two assessors working independently, relevant data were extracted and then recorded using a standardised data collection format (microsoft excel; microsoft).

None of the 18 papers report-ed more than one RCt. For a paper reporting an RCt that involved more than two groups of subjects, the authors focused data extraction on only one pair of groups as follows: treatment in preference to prophylaxis; and placebo control in preference to other-than-placebo control.

For studies that comprised more than one homeopathy group, the total sample size (and associated outcomes) cited reflected the total number of sub-jects in the homeopathy groups combined (Higgins and others 2011). this was the approach in all cases, that is, where the same homeopathic medicine was used, and with the same timing of administration, but with different potencies; where the same home-opathic medicine and potency were used, but with different tim-ings of administration; and where a different homeopathic medicine was used.

Assessment of risk of biasIn eligible trials, and using the standard criteria defined by the Cochrane Collaboration (Higgins

and altman 2011), extraction of information enabled appraisal of freedom from risk of bias. there were three options when assessing the trials: ‘yes’ (low risk of bias), ‘unclear’ (uncertain risk of bias) or ‘no’ (high risk of bias).

this approach applied to each of seven assessment domains:

n I – method used to generate the random sequence; n II – method of allocation concealment used to implement the random sequence; n IIIa – Blinding of trial personnel, including animal owner as appropriate; n IIIB – Blinding of outcome assessors; n IV – Whether all randomised patients were completely accounted for in the analysis; n V – evidence of selective outcome reporting;n VI – evidence of other bias, such as extreme data imbalance at baseline.

For the domain relating to whether all randomised patients were accounted for in the analysis, unless there was indication to the con-trary, a trial was regarded as being at high risk of bias if there was greater than 20 per cent participant attrition rate, and irrespective of whether intention-to-treat analysis had been carried out on the data.

For the domain relating to evidence of selective outcome report-ing, judgement was based on reported outcomes and not on a com-parison with an original trial protocol (as none exists in the public domain for RCts of veterinary homeopathy) but rather on a compari-son with the details given in the materials and methods section in the original paper.

the two assessors’ judgements were mutually scrutinised and compared, with discrepancies between them resolved by consensus discussion, with the aim of producing summary of findings tabula-tions to characterise all eligible trials.

Using the Cochrane approach, each trial was designated as one of the following: at low risk of bias (free of bias in all seven standard domains of assessment); at uncertain risk of bias (unclear judgement of bias for one or more domains, and no evident risk of bias in any

18 records

* Treatment – 12 RCTs * Prophylaxis – six RCTs

A01. Hektoen # A02. Werner A03. Andersson # A04. Cracknell A05. de Verdier # A06: Fidelak A07. Hielm-‐Björkman A08. Holmes # A09. Kayne A10. Searcy A11. Wolter A28. Williamson

A22. Albrecht A23. Arlt A24. Camerlink A25. Danieli # A26. Guajardo-‐Bernal # A27. Soto

Fig 1: PRiSMA flowchart illustrating records of randomised placebo-controlled trials eligible for inclusion in the systematic review

* RCTs are numbered as per a previous paper published by theauthors (Mathie and others [2012b]). Publication details of each RCT may be found in the reference list# Trial with continuous measure as main outcome (unmarked trials have a dichotomous measure as the main outcome)

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domain); or at high risk of bias (evident risk of bias for one or more domain) (Higgins and altman 2011).

For each trial that was not found to be at high risk of bias (that is, it did not attain a ‘no’ response for any domain), the evidence was seen as reliable if it was assessed to be free of bias in each of four domains: randomisation; blinding of trial personnel; blinding of out-come assessors; and patients accounted for in analysis. these criteria for ‘reliable evidence’ are analogous to those used by Shang and others (2005) in their designation of ‘trials of higher methodological qual-ity’. according to these criteria, the latter group included adequacy of allocation concealment (domain II) but excluded completeness of data analysis (equivalent to domain IV). In the veterinary trial context, domain IV was regarded in this study as a more relevant arbiter of reli-able evidence than domain II.

For each trial (for the purposes of risk-of-bias assessment and for assessment of treatment effect), the main outcome measure was iden-tified using a refinement of the approaches adopted by Linde and oth-ers (1997) and by Shang and others (2005). the main outcome meas-ure of each trial was based on a hierarchical ranking order (consistent with the World Health organization [WHo 2002] classification sys-tem for levels of functioning linked to health condition):

n mortality;n morbidity;

– treatment failure;– pathology; symptoms of disease;

n Health impairment (loss/abnormality of function, including apparent presence of pain);n Limitation of activity (disability, ill health);n Surrogate outcome (for example, blood test data).

In cases where, according to the judgement of the reviewers, there were two or more outcome measures of equal greatest importance within the above hierarchy, the designated ‘main outcome measure’ was selected randomly from those two or more options by tossing coins or rolling dice.

the single endpoint (measured from the start of the intervention) associated with the designated main outcome measure was taken as the last follow-up at which data were reported for that outcome. the exceptions to this were two ‘semi-crossover’ trials (Hektoen and oth-ers 2004, Werner and others 2010), for which the single endpoint was taken at seven days after treatment commenced and before any cross-over. a semi-crossover study design is one in which patients defined as non-responders after a pre-defined period of time are re-randomised to another arm of the trial.

Summary effect measures for main outcomeFor each eligible trial, effect size was taken to be the difference between the homeopathy and the placebo groups at the predetermined endpoint of the trial as follows (mathie and others 2013):

n For dichotomous measures: odds ratio (oR) with 95 per cent confidence interval (CI);n For continuous measures: standardised mean difference (SmD), with 95 per cent CI.

For a trial in which the selected dichotomous measure was pre-sented solely as percentage data (tabulated or graphed) per group, the categorical data required for analysis were calculated from the availa-ble published information. For a trial in which the selected continuous measure was presented as a mean, but without an associated standard deviation (sd), Cochrane-recognised methods were used to calculate or estimate sd per group (Higgins and Deeks 2011).

If the original paper did not provide adequate information on the designated main outcome measure to enable data extraction, that tri-al’s outcome was classified as ‘not estimable’ and a further potentially estimable outcome was not sought.

mean effect size was interpreted as follows: an SmD of less than 0.40 was considered ‘small’; an SmD of 0.40 to 0.70 (inclusive) was considered ‘moderate’; and an SmD of more than 0.70 was considered

‘large’ (Schünemann and others 2011). Using the standard formula to convert SmD approximately to oR (Schünemann and others 2011), the corresponding effect size thresholds were calculated as: an oR of less than 2.10 was considered to be ‘small’; an oR of 2.10 to 3.60 (inclusive) was considered to be ‘moderate’; and an oR of over 3.60 was considered to be ‘large’.

Under the separate group headings of individualised homeopathy and non-individualised homeopathy, and for each of any subcatego-ries in which there was more than one RCt paper with extractable data, the authors aimed to determine summary statistics, using meta-analytical methods, for the following:

n Disease-specific prophylactic effects per species;n Disease-specific treatment effects per species.

all calculations and analyses were performed using Review manager 5.2 (Cochrane). Given the anticipated heterogeneous data for intervention effects, the random effects (rather than fixed effects) model was planned for each meta-analysis (Deeks and others 2011). For each meta-analysis, the need to merge dichotomous and continuously variable data, using the Cochrane-recognised method, as required, to re-express SmD in terms of oR, was also anticipated (Schünemann and others 2011).

Reflecting overall study qualitythe main focus was on the data extracted from trials that were not designated to be at high risk of bias, and especially those that were deemed to contain reliable evidence.

the focus for primary conclusions was trials with reliable evi-dence that were also not explicitly funded, directly or indirectly, by a homeopathic pharmacy (that is, there was no overt vested interest in the trial’s findings).

Direction of effect of treatment/prophylaxis per trialFor a conclusion that homeopathic intervention impacted on health outcome (that is, statistical significance favouring homeopathy, at p≤0.05), the following were required:

n Dichotomous measure (oR): lower 95 per cent confidence limit of 1 or more;n Continuous measure (SmD): relevant 95 per cent confidence limit of less than or equal to 0 or more than or equal to 0, depending on the direction of the hypothesis favouring homeopathy.

ResultsDemographic detailstable 1 provides details of each of the 18 eligible trials: (i) individualised homeopathy/treatment (two trials); (ii) non-individualised homeopathy/treatment (10 trials); and (iii) non-individualised homeopathy/prophylaxis (six trials). Data presented include: medical condition, species, nature of the homeopathic intervention, and trial setting. the tabulation also includes details of the RCt’s source of funding, together with the associated freedom from vested interest: only one trial (Holmes and others 2005) was deemed to be clearly free of such vested interest.

the trials were clinically extremely diverse. In the 18 eligible stud-ies, four different species are represented: cattle (10 trials); dogs (two trials); goats (one trial); and pigs (five trials). eleven different medical conditions are represented.

table 2 details sample sizes, designated main outcome measures, and trial endpoints of the included trials. table 2 also accounts for three trials for which data were not extractable for analysis. Diversity was again apparent, with large variations in sample sizes, main out-come measures and the timing of the trial endpoint.

Risk of biastable 3 details risk-of-bias judgements per trial.

Some of the papers were written to such a poor standard that risk-of-bias assessments were not straightforward. However, consensus discussion always resolved the matter. only one trial had a low risk

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Table 1: Details of 18 placebo-controlled randomised controlled trials

Condition Species Trial First authorPublication year

Homeopathic medicine

Level of dilution* Setting Funding

Free from vested interest Notes

Individualised homeopathy/treatment

Mastitis Cattle A01 Hektoen 2004 Individualised Not stated 39 dairy herds in eastern Norway

Government Unclear Semi-crossover trial

A02 Werner 2010 Individualised Mostly D6 or D12

One organic and three conventional dairy herds in Germany

Government; charity

Unclear Semi-crossover trial

Non-individualised homeopathy/treatment

Diarrhoea Cattle A05 de Verdier 2003 Podophyllum D30 12 dairy herds in Sweden

Charity; remedies were gifts from HPC

No

A09 Kayne 1994 Arsenicum album 30C Unstated number of cattle farms in Scotland

Remedies were gifts from HPC

No

Fear of firework noises

Dogs A04 Cracknell 2008 Fixed formulation of five remedies

6C, 30C Dogs whose owners replied to national advertising in the UK

HPC No

Induction of farrowing

Pigs A11 Wolter 1966 Caulophyllum D30 At least 23 pig herds in Germany


No

Infertility Cattle A06 Fidelak 2007 Three different complex preparations of over 20 remedies

D1 to D10 One organic dairy herd in Germany

None stated Unclear

A28 Williamson 1995 Sepia (24 to 48 hours and 14 days postpartum)

200C One dairy herd in Scotland


No RCT of homeopathy (group 1) v homeopathy (group 2) v untreated controls v placebo

Mastitis Cattle A03 Andersson 1997 Six different remedies

D2 to D12 12 dairy herds in Germany

European Union, remedies were gift from HPC

No

A08 Holmes 2005 Mastitis nosode 30C One dairy herd in England

Charity Yes

A10 Searcy 1995 Complex of three remedies

200C One dairy herd in Mexico

None stated Unclear

Osteoarthritis Dogs A07 Hielm-Björkman

2009 Complex of 14 remedies

D2 to D8 Dogs screened via owner-completed telephone interview in Finland

Charities; drug industry; remedies were gifts from HPC

No RCT of homeopathy v placebo v NSAID

Non-individualised homeopathy/prophylaxis

Endometritis Cattle A23 Arlt 2009 Either two or three different remedies, taken consecutively

Not stated One dairy herd in Germany

HPC No RCT of homeopathy (group 1) v homeopathy (group 2) v placebo

Diarrhoea Pigs A24 Camerlink 2010 Coli 30K One commercial pig farm in the Netherlands

None stated Unclear Treated sows and evaluated piglet litters

Growth rate Pigs A26 Guajardo-Bernal

1996 Sulphur 201C One university pig unit in Mexico

None stated Unclear

Infectious diseases (respiratory)

Pigs A22 Albrecht 1999 Complex of five remedies

D1 to D4 One intensive pig farm in Germany

Charity; HPC No RCT of homeopathy v placebo v antibiotics

Metabolic disturbance postpartum

Goats A25 Danieli 2009 Echinacea purpurea

30C One commercial goat farm in Italy

None stated Unclear RCT of homeopathy v placebo v anti-ketogenic v anti-ketogenic+ homeopathy

Reproductive performance

Pigs A27 Soto 2010 Avena sativa and/or Pulsatilla nigricans

6C One commercial pig farm in Brazil

None stated Unclear RCT of each of three homeopathic remedies v placebo

HPC Homeopathic pharmacy company, RCT Randomised controlled trial. *Note on homeopathic dilutions: The number refers to the number of successive serial dilutions to which the starting material has been subjected. The letter refers to the scale on which the dilution has been carried out: the letter D denotes the decimal method of dilution (that is, one part of liquid is added to nine parts of purified water, ethanol, glycerol or lactose); the letter C indicates the centesimal method (one part added to 99 parts of diluent). In the Korsakovian method (denoted K), a single piece of glassware is used; this is emptied and refilled, the liquid adhering to the walls of the vessel in which it is diluted. In homeopathic dilutions above 12C/D24 (10-24 molar) – beyond Avogadro’s constant, 6.02 x 1023 mol-1 – there are, in theory, no material traces of the original substance; such dilutions are known as ‘ultra-molecular’

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Table 2: Sample sizes and outcomes

Trial n start (h)

n start (p)

n start (total)

n end (h)

n end (p)

n end (total)

Attrition (per cent)

Main outcome

Problem with main outcome?

Main outcome used for data extraction

Endpoint Notes


A01 21 16 37 21 16 37 0.0 Acute mastitis score

No (though sd calculated from 95 per cent CI data, using t-distribution)

Acute mastitis score

Seven days

A02 58 43 101 58 43 101 0.0 Totally cured quarters

No Totally cured quarters

Seven days n=number of udder quarters


A05 24 24 48 24 20 44 8.3 Duration of diarrhoea

Yes: sds not given, but common sd calculated from CI data (assuming 95% CI)

Duration of diarrhoea

Up to eight days

A09 6 10 16 6 9 15 6.3 Animals with 'pasty' stools

No Animals with 'pasty' stools

48 hours Authors did not carry out formal statistical analysis of data

A04 35 40 75 34 38 72 4.0 Improved (that is reduced) fear response

No Improved (that is reduced) fear response

Four weeks

A11 18 23 41 18 23 41 0.0 Presence of uterine contraction

No Presence of uterine contraction

20 minutes after treatment

Contractions after birth of first piglet. n=1 excluded from homeopathy group (repeat measurement of placebo group animal)

A06 76 70 146 58 56 114 21.9 Gestating cows

No Gestating cows

200 days post-partum

A28 60 30 90 50 26 76 15.6 Held to first service

No (original percentage data used for calculation of odds ratios)

Held to first service

Not stated n for homeopathy is total for two homeopathically treated groups. It was assumed that a total of 120 cows were randomised to four equal groups

A03 Data not given

Data not given

416 Data not given

Data not given

306 26.4 Bacterial cell counts

Yes, data not given None usable 37 days n reflects number of quarters, not number of animals

A08 76 76 152 68 67 135 11.2 Somatic cell counts (only outcome recorded)

Yes, sd not available (logarithmic data)

None usable 28 days

A10 52 52 104 51 52 103 1.0 Unaffected quarters

No Unaffected quarters

30 days n=number of udder quarters. Unaffected quarters identified by CMT

A07 17 17 34 14 15 29 14.7 Improved mobility index

No Improved mobility index

Eight weeks Assumes that total n=51 was divided equally into three groups


A23 417 200 617 417 200 617 0.0 Absence of endometritis

No Absence of endometritis

21 to 27 days

A24 26 26 52 24 26 50 3.8 Absence of diarrhoea

No Absence of diarrhoea per litter

One week The sows were treated. n=number of litters

A26 39 40 79 39 40 79 0.0 Piglets' final bodyweight

Yes: sd not given, but common sd calculated from conservative P=0.049

Piglets' final bodyweight

30 days

A22 480 480 960 480 480 960 0.0 Absence of respiratory tract disease

No Absence of respiratory tract disease

11 days

A25 Not stated

Not stated

19 Not stated

Not stated

19 0.0 Plasma glucose

Yes, data not given None usable Three weeks after parturition

Assumes that half of the 38 randomised animals received homeopathy or placebo. 'Main outcome' decided on coin toss

A27 94 31 125 94 31 125 0.0 Parturition No Parturition Not stated Sperm was treated

CI Confidence interval, CMT California mastitis test, h Homeopathy group(s), n Number, p Placebo group(s), sd Standard deviation

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Table 3: Risk-of-bias judgements made in the 18 placebo-controlled RCTs

TrialI. Sequence generation

II. Allocation concealment

IIIA. Blinding: personnel

IIIB. Blinding: outcome assessors

IV. Complete outcome

dataV. Outcome reporting

VI. Free of other bias

(excl. funding)

Number of domains for which Cochrane criteria

fulfilled

Risk of bias (excluding assessment of vested interest)

Trial with reliable evidence

Y U N


A01 Y Y Y Y Y Y Y 7 0 0 Low Yes

A02 Y U N N Y Y U 3 2 2 High No


A05 U U Y Y U N N 2 3 2 High No

A09 U U Y Y Y Y N 4 2 1 High No

A04 Y Y Y Y Y Y U 6 1 0 Unclear Yes

A11 N N Y Y Y Y N 4 0 3 High No

A06 N N Y U N Y U 2 2 3 High No

A28 U U N U U Y U 1 5 1 High No

A03 U U U U N N N 0 4 3 High No

A08 Y U Y Y U Y Y 5 2 0 Unclear No

A10 U N U U Y Y Y 3 3 1 High No

A07 Y U Y Y U Y Y 5 2 0 Unclear No


A23 N N Y Y Y Y Y 5 0 2 High No

A24 Y U Y Y Y Y Y 6 1 0 Unclear Yes

A26 U U Y Y U Y Y 4 3 0 Unclear No

A22 Y U N N U Y N 2 2 3 High No

A25 U U N U U Y U 1 5 1 High No

A27 U U Y Y Y Y Y 5 2 0 Unclear No

Criteria fulfilled for domains Y Yes, U Unclear, N No

of bias; six trials had uncertain risk of bias; and the remaining 11 trials were judged to be at high risk of bias, some of them failing the assess-ment criteria in more than one domain.

of the seven trials not deemed to be at high risk of bias, four of them failed to meet the criteria for reliable evidence. these were Holmes and others (2005), Hielm-Björkman and others (2009), Guajardo-Bernal and others (1996) and Soto and others (2010). one of the three remaining (reliable) trials had potential vested interest due to funding source (Cracknell and mills 2008) and so was not reflected in the primary conclusions.

Considering the assessments overall, high risk of bias was evident across all domains (table 3). Domains IIIa (personnel blinding) and domain VI (other biases, which most frequently were connected with extreme data imbalances) were at high risk of bias particularly fre-quently. For randomisation (domain I), only seven of the 18 trials had low risk of bias. a problem that was frequently encountered was the lack of detail or clarity provided in the original papers; allocation con-cealment (domain II) was associated with the greatest rate of uncer-tainty in assessment.

Trials at low/uncertain risk of biasthe summary statistics for each of the seven RCts that were assessed to be at low/uncertain risk of bias are presented in table 4. the direction of effect was towards homeopathy in each of the six trials from which data could be extracted. the seventh trial in this category (Holmes and others 2005) contained logarithmic data. Due to the diversity of medical conditions, species and types of homeopathic intervention displayed in these six trials, and the fact that analysis was limited to data from trials at low/unclear risk of bias, it was not considered appropriate to carry out meta-analysis on disease-specific treatment or prophylaxis.

Trials designated as having reliable evidence and being free of vested interestonly two trials were considered to have reliable evidence and contributed to the primary conclusions (that is, low/uncertain risk of bias overall, with low risk of bias for each of Cochrane domains I, IIIa, IIIB and IV, and also without overt vested interest due to funding source); these were Hektoen and others (2004) and Camerlink and others (2010). an additional facet of study design should be noted in each case: the Hektoen RCt was a semi-crossover trial, whose data were extracted for the precrossover timepoint; and the Camerlink RCt involved treating sows but evaluating piglets.

these two trials analysed different medical conditions, species and categories of intervention, and so a meta-analysis was not appropriate.

as displayed in table 4, the Hektoen trial (a01) showed a non-significant treatment effect in cattle with mastitis (SmD –0.31, 95 per cent CI –0.97 to 0.34, p=0.35), while the Camerlink trial (a24) showed a statistically significant effect in the prophylaxis of diarrhoea in piglets (oR 3.89, 95 per cent CI 1.19 to 12.68, p=0.02).

Trials at high risk of biasthe 11 trials that were judged to be at high risk of bias are presented in table 5. the direction of effect was towards homeopathy in five trials (three statistically significantly, though highly variable and imprecise in the magnitude of effect size) and towards placebo in four (none statistically significantly). Data were not extractable from the remaining two trials.

Discussionalthough six trials with extractable data were judged to be at low/unclear risk of bias, their diverse characteristics prevented the

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Table 4: Trials at low or unclear risk of bias

Trial Condition SpeciesOutcome measure Data extracted

Summary effect

measureEffect size

(95 per cent CI)Direction of

effect P value

Homeopathy Placebo


A01 Mastitis Cattle Acute mastitis

score

Mean, 12.2, sd 4.72, n=21

Mean 13.7, sd 4.60,n=16

SMD -0.31 (-0.97, 0.34)

Homeopathy 0.35


A04 Fear of firework noises

Dogs Improved (that is

reduced) fear response

25 of 34 26 of 38 OR 1.28 (0.46, 3.57)

Homeopathy 0.63

A08 Mastitis Cattle None usable X X X X X X

A07 Osteoarthritis Dogs Improved mobility index

10 of 14 4 of 15 OR 6.88 (1.35, 35.06)

Homeopathy 0.02


A24 Diarrhoea Pigs Absence of diarrhoea per

litter

17 of 24 10 of 26 OR 3.89 (1.19, 12.68)

Homeopathy 0.02

A26 Growth rate Pigs Piglets' final body weight

Mean 9.4, sd 2.66, n=39 Mean, 8.2, sd 2.66, n=40 SMD 0.45 (0.00, 0.89) Homeopathy 0.05

A27 Reproductive performance

Pigs Parturition 69 of 94 22 of 31 OR 1.13 (0.46, 2.78) Homeopathy 0.79

CI Confidence interval, OR Odds ratio, sd Standard deviation, SMD Standardised mean differenceBold text indicates trials deemed reliable; Italic text indicates trials with a potential risk of bias due to funding source (see also Table 1)

Table 5: Trials at high risk of bias

Trial Condition Species Outcome measure Data extracted

Summary effect measure

Effect size(95 per cent CI)

Direction of effect P value

Homeopathy Placebo


A02 Mastitis Cattle Totally cured quarters 8 of 58 4 of 43 OR 1.56 (0.44, 5.56) Homeopathy 0.49


A05 Diarrhoea Cattle Duration of diarrhoea (days)

Mean 3.1, sd 1.72, n=24

Mean 2.9, sd 1.72, n=20

SMD 0.11 (-0.48, 0.71) Placebo 0.71

A09Animals with ‘pasty’ stools 5 of 6 8 of 9 OR 0.63 (0.03, 12.41) Placebo 0.76

A11 Induction of farrowing Pigs Presence of uterine contraction

14 of 18 0 of 23 OR 151.4 (7.58, 3024) Homeopathy 0.001

A06 Infertility Cattle Gestating cows 49 of 58 47 of 56 OR 1.04 (0.38, 2.85) Homeopathy 0.94

A28 Held to first service 20 of 50 11 of 26 OR 0.91 (0.35, 2.38) Placebo 0.85

A03 Mastitis Cattle None usable X X X X X X

A10 Unaffected quarters 34 of 51 15 of 52 OR 4.93 (2.14, 11.38) Homeopathy 0.0002


A23 Endometritis Cattle Absence of endometritis 231 of 417 126 of 200 OR 0.73 (0.52, 1.03) Placebo 0.07

A22 Infectious diseases (respiratory)

Pigs Absence of respiratory tract disease

436 of 480 411/480 OR 1.66 (1.11, 2.49) Homeopathy 0.01

A25 Metabolic disturbance postpartum

Goats None usable X X X X X X

CI Confidence interval, OR Odds ratio, sd Standard deviation, SMD Standardised mean difference. Italic text indicates trials with a potential risk of bias due to funding source (see also Table 1)

application of meta-analytical methods to examine disease-specific effects. each of these six trials had a direction of treatment effect towards homeopathy, three of them significantly (p≤0.05). However, such ‘vote counting’ masks a lack of robustness in the data, the small sample size per trial contributing to a wide confidence interval with lower limit approaching null effect. a meta-analysis of all six trials together (irrespective of species, medical condition, outcome measure or type of homeopathic intervention), following the combined analytical approach reported by Linde and others (1997) and Shang and others (2005), was outside the scope of the current review.

Sensitivity analyses on relevant groups of trials, reflecting the full range of risk of bias across all 18 RCts, is the subject of a separate paper (mathie and Clausen, in press).

only two trials did not have high risk of bias and contained reli-able evidence that was free from vested interest; the disparate nature of these trials again prevented meta-analysis. It is the evidence separately from those two trials, therefore, that forms the basis of the primary conclusions of this review: Hektoen and others (2004) (individualised treatment using unspecified homeopathic potencies of acute bovine mastitis); and Camerlink and others (2010) (prophylaxis of porcine

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diarrhoea with an ultra-dilution of the homeopathic preparation Coli).Camerlink reported a large, though imprecise, effect size that was

statistically significant, in favour of homeopathy; the smaller effect size reported by Hektoen was not statistically significant. the idi-osyncrasies of study design in these two trials (indirect treatment of piglets via the sow; semi-crossover RCt) should also be noted. From the only two trials that inform the primary conclusions, therefore, there is modest evidence that homeopathic Coli has a prophylactic effect on porcine diarrhoea and that individualised homeopathy is not more beneficial than placebo in the treatment of bovine mastitis. It is not possible to generalise from these two divergent findings to other medical targets of veterinary homeopathic treatment or prophylaxis, for which there is no reliable (or any) research evidence.

the authors are confident that the risk-of-bias assessment approach was fair and rigorous, always erring on the side of stringen-cy. Indeed, the definition of an RCt with reliable evidence closely approximates that used by Shang and others (2005) to designate a trial of ‘higher methodological quality’; moreover, source of research funding (vested interest) was also taken into account as a matter of key importance in these assessments. Given that the 18 eligible trials were published in peer-reviewed journals – arguably therefore repre-senting the ‘best’ of such RCt research in veterinary homeopathy – the inability of our findings to yield broader-based conclusions may disappoint homeopathy’s advocates and critics alike. Neither gloomnor glee is indicated here for either side of the polarised argument:matters will be settled only in the event of more and much better-quality research. Similar cautionary notes about the limited qualityand clarity of the available evidence in homeopathy were applied ina recent Cochrane review – involving one of the current authors – ofhomeopathic oscillococcinum for influenza in humans (mathie andothers 2012a).

Shortcomings of the papers included in this review were con-cerned particularly with randomisation, allocation concealment, blinding and source of funding. Such failings were undoubtedly con-tributory to the extraordinarily variable results provided by the 11 tri-als that were assessed to be at high risk of bias. a further problem was the unclear original reporting of the key data, particularly for standard deviation of a continuous measure: in such cases, the use of recognised Cochrane methods to calculate or estimate the sd enabled the other-wise unusable findings of some trials to be included in the data pres-entation (see tables 2, 4 and 5). Deficiencies in RCts of conventional veterinary medicine are also well recognised, including the potential relationship between funding source and positive outcome reporting (Wareham and others 2013).

the use of a single, hierarchy-based, outcome measure per trial harmonises with the method adopted in major systematic reviews of homeopathy RCts in humans (Linde and others 1997, Shang and others 2005), as well as in the authors’ own study protocol for meta-analysis of RCts in human homeopathy (mathie and others 2013) and in quality assessment of RCts in conventional medicine (Hartling and others 2009). Some commentators have previously expressed concern that trials in homeopathy often use irrelevant or subjective outcomes (merrell and Shalts 2002). None of the main outcome measures used in this analysis can be regarded as clinically irrelevant: only two (fear response to fireworks [Cracknell and mills 2008] and ‘pasty’ stools [Kayne and Rafferty 1994]) can be regarded as subjective. outcome measures that can be regarded as surrogate only featured in trials whose data proved to be not extractable for analysis (andersson and others 1997, Holmes and others 2005, Danieli and others 2009). It was noteworthy that 16 of the 18 RCts assessed here did not designate a ‘main’ or ‘primary’ outcome meas-ure and this concern corresponded with the absence of a prospective power calculation to determine the appropriate sample size of trials.

the deficient nature of the current RCt literature in veterinary homeopathy indicates a clear need for further primary research investigation, whether in the context of individualised or non-indi-vidualised veterinary prescribing. New research of this nature can be informed by research-targeted observational studies on the out-comes of homeopathic treatment in cats, dogs and horses (mathie and others 2010a, b). Naturally, such RCts should be independently funded and strive for reliable evidence, and they should also optimise

the model validity of the homeopathic intervention as state-of-the-art (mathie and others 2012c). an updated search of peer-reviewed RCts published since an original literature analysis in 2011 revealed only one new placebo-controlled trial (Notz and Hässig 2013). While this means that this systematic review is barely compromised by the absence of up-to-date findings, it also illustrates the near-static nature of this field of research. the authors are currently progressing a sepa-rate systematic review of veterinary RCts in which the control group was a comparator other than placebo.

although few in number (as well as deficient in quality), the preponderance of homeopathy RCts in livestock might reflect the needs of the organic farming community, especially in the european Union (ImpRo 2012). the very small number of homeopathy RCts in companion animals might reflect the difficulty of recruiting suffi-cient numbers of subjects for individualised treatment or prophylaxis, which necessitates long consultation times with each animal and its owner. the dearth of RCts in individualised homeopathy per se is consistent with this conjecture.

ConclusionsFrom 18 RCts in total, low or unclear risk of bias was ascribed to seven diverse trials, two of which were judged to contain reliable evidence and were free of vested interest due to funding source. mixed findings in these two trials preclude generalisable conclusions about efficacy of a particular homeopathic medicine or the impact of individualised homeopathic intervention in any given medical condition in animals. there is an obvious need for new and higher quality research.

Acknowledgementsthe authors would like to thank elizabeth Baitson (British Homeopathic association) for statistical support and Daniela Hacke (Karl und Veronica Carstens-Stiftung) for library assistance.

Conflict of interest statementas a research physiologist (Rtm) and a biologist (JC), each of us is employed by a homeopathy charity to clarify and extend an evidence base in homeopathy. We have applied the normal high standards of scientific method in the conduct of the work and of complete and transparent reporting in the write-up of the paper.

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Annex for Standards Committee

Homeopathy: overview of recent media and social media coverage

The launch of Danny Chambers’ change.org petition calling upon the College to ban veterinary

surgeons being allowed to prescribe homeopathic treatments at the end of 2015 has, to some extent,

reignited the debate about the efficacy of homeopathic treatments and the professionalism of those

veterinary surgeons who use them.

The debate has been carried out both through ‘traditional’ media platforms such as newspapers and

online news websites as well as on social media.

Herewith is a brief overview of both the ‘traditional’ media coverage and some of the social media

debates from the beginning of 2016 onwards.


TRADITIONAL MEDIA

Farmers Weekly, 3 June 2016

A petition urging vets to ban prescribing homeopathic treatments for animals has gathered more than 2,500 signatures.

Equine vet Danny Chambers, who grew up on a dairy farm in Devon, started the petition on the change.org website.

The petition calls on the Royal College of Veterinary Surgeons (RCVS) to blacklist homeopathy from treatments vets are allowed to offer animals.

But it has received a furious backlash from homeopathy vets who support such treatments for farm animals.

Homeopathy appears to be an increasing trend in the dairy community and is an animal welfare issue. It certainly is not a good way for farmers to spend their money when milk prices are so low, Danny Chambers, equine vet

Last month, Prince Charles told a conference in London that he uses homeopathic medicines to treat the cattle and sheep on his Gloucestershire estate, Home Farm, alongside conventional medicine, to minimise dependence on antibiotics.

In an open letter, Mr Chambers tells the RCVS that homeopathic treatments “have been proven not to work”, adding that many reviews have clearly shown they have “no effect beyond the placebo effect”.

Mr Chambers said: “The biggest danger of homeopathy is not that the remedies are ineffective, but that some homeopaths are of the opinion that their therapies can substitute for genuine medical treatment.

“This is at best misleading and at worst may lead to unnecessary suffering and death.”

Mr Chambers argues that substituting homeopathic treatments for more serious diseases, such as the control of mastitis in cows, could have devastating consequences for dairy farming families if they failed to control the disease and went out of business.

Mr Chambers told Farmers Weekly: “Homeopathy appears to be an increasing trend in the dairy community and is an animal welfare issue.

“It certainly is not a good way for farmers to spend their money when milk prices are so low.”

Trendy option

According to Defra, in the UK there are about 500 farmers trained in homeopathy and 38 homeopathic vets. Meanwhile, in New Zealand, dairy giant Fonterra has reported that 3,000 of their dairy farmers are using homeopathy.

Geoff Johnson, a Somerset-based homeopathic vet with over 20 years’ experience, said: “Danny Chambers has never studied, qualified in or practiced homeopathy and knows nothing about it.

“It is quite trendy in the Liberal chatting classes to attack homeopathy. But there is a lot of evidence that homeopathy is successful. It is used by millions of people in the country. It is cheap and has been demonstrated to be effective. It is also getting increasingly popular.”


But John Blackwell, senior vice president of the British Veterinary Association, said the association could not endorse the use of homeopathic remedies, or any products making therapeutic claims, which have no proven efficacy.

“The consequence could be serious animal health and welfare detriment because of the lack of therapeutic effect, which would be counterproductive to best animal health and welfare,” he added.

“As with any disease that requires treatment using licensed veterinary medicines, that use must be science- and evidence-based.”


Daily Mail, 8 July 2016

Homeopathy for your pet? That's barking, warn vets: More than 2,500 use letter to demand alternative medicine is blacklisted

Homeopathy with pets is practised by about 50 vets in the UK

But more than 2500 vets and animal lover have called for a ban

Critics say homeopathy is dangerous, if used instead of proven medicines

By Fiona Macrae Science Editor

Published: 00:46, 8 July 2016 | Updated: 09:44, 8 July 2016

The homeopathic treatment of pets is unethical, potentially deadly and should be banned, vets have said.

More than 2,500 vets, veterinary nurses, scientists and animal lovers have written to the Royal College of Veterinary Surgeons urging it to blacklist the alternative medicine.

Popular with people who prefer natural and alternative therapies, homeopathy is also practised by some 50 vets in the UK.

Fully-qualified veterinary surgeons, they offer homeopathic treatments as well as conventional ones.

The discipline claims to prevent and treat diseases using diluted forms of plants, herbs and minerals.

It is based on the principle that an illness can be treated by substances that produce similar symptoms. For example, it is claimed onions, which make eyes itchy and tearful, can be used to relieve the symptoms of hay fever.

Believers include Prince Charles, who just last month revealed he uses homeopathic remedies on his cows and sheep.

http://www.dailymail.co.uk/home/search.html?s=&authornamef=Fiona+Macrae+Science+Editor


But scientists argue the 'cures' are so diluted they are unlikely to contain any of the original substance.

They also warn that homeopathy can be dangerous, if used in place of conventional medicines that have proven benefits.

In his letter to the veterinary regulator, the RCVS, Devon vet Danny Chambers states: 'The health of animals is totally in the hands of those charged with their care.

'It is unethical to inflict ineffective alternatives on creatures that have no choice in the matter.

'It is unfair to misuse an owner's often limited financial resources on a 'treatment' that does nothing but offer false hope.'

Dr Chambers, who specialises in equine medicine, started the petition after having to put down several animals that could have been successfully treated with conventional medicine, had it been prescribed on time.

These include a horse that was given homeopathic medicine for Cushing's disease, a hormonal condition which can be treated with drugs.

The horse went onto develop a foot condition that was so severe it had to be put down.

Dr Chambers said: 'How was that owner meant to know that the advice they'd received from a qualified vet was so dangerously wrong?

'It shouldn't be on the owner to determine if their vet's advice is correct or not – it's for the RCVS to make sure that vets are providing advice consistent with what we know to be safe and effective.'

Michael Marshall, project director of the Good Thinking Society, a charity which fights pseudoscience, said: 'Vets are enormously qualified professionals who by and large do a great job, but unfortunately it's clear that a minority are still willing to prescribe treatments that have been comprehensively shown to be entirely ineffective.

'While it's undoubtedly the case that vets who use homeopathic treatments do so with the best of intentions, that unfortunately doesn't change the fact that these treatments are at best a waste of time and money, and at worst they represent a genuine threat to the wellbeing of the animal.'


The RCVS said homeopathic treatments should be used with caution and given alongside conventional treatments, rather than instead of them.

However, a ban is unlikely.

A spokesman said: 'Whatever views there may be within the veterinary profession, it is clear that there is a demand from some clients for complementary therapies for their animals.

'It is better that they should seek advice from a veterinary surgeon - who is qualified to make a diagnosis, and can be held to account for the treatment given - rather than turning to a practitioner who does not have veterinary training.

'Furthermore, homeopathy is currently accepted by society and recognised by UK medicines legislation and does not, in itself, cause harm to animals.

'While this is the case, it is difficult to envisage any justification for banning a small number of veterinary surgeons from practising homeopathy.

'We appreciate there are strong views about these issues on both sides of the argument and are grateful for the opportunity that this petition affords us to hear the latest views of both animal owners and the veterinary profession.'


BBC Radio 4 Today, 8 July 2016

Discussing homeopathy on BBC Radio's Today Programme Danny Chambers

Tavistock, United Kingdom

8 Jul 2016 — The last 6 minutes of the Today Programme featured a discussion the the petition to stop vets from using homeopathy. 2 hours 54 minutes in

08/07/2016, Today - BBC Radio 4

Scientists are developing genetically engineered mice to be ultrasensitive to specific smells, paving

the way for animals that are...

http://www.bbc.co.uk


BBC News Online, 8 July 2016

Vets: Ban the use of homeopathy in animals By Helen Briggs BBC News

About 1,000 of the UK's vets have signed a petition calling for a ban on homeopathy being prescribed to animals.

The petition calls on the Royal College of Veterinary Surgeons to stop vets from offering homeopathy on animal welfare grounds.

But the veterinary regulator says "it is difficult to envisage any justification" for a ban.

About one in seven practices offers some form of complementary therapy.

Figures suggest about 500 farmers and 40 vets are trained in homeopathy.

Danny Chambers, the Devon vet who started the petition on Change.org, said it had been signed by more than 1,000 British vets as well as others from around the world.

There are some 22,000 vets in the UK.

"We think vets these days should be offering 21st Century medicine," he told BBC News.

"It's been shown that homeopathy doesn't work, so it probably shouldn't be offered any more even if it is offered with good intentions."

According to Mr Chambers, prescribing homeopathy is an animal welfare issue and fails to meet the standard required for scientific veterinary practice.

"A veterinary surgeon should have an accredited degree from an accredited university, and they shouldn't be using treatments that have been disproven," he said.

"Animal welfare undoubtedly suffers if people give homeopathy instead of proper treatment."

The Royal College of Veterinary Surgeons, which regulates the veterinary profession, says it recommends "a cautious approach to homeopathy for animals".

In response to the petition - due to be submitted on Friday - it said given demand for complementary therapies it was better clients sought advice from a veterinary surgeon - who was qualified to make a diagnosis, and could be held to account for the treatment given - rather than turning to a practitioner with no veterinary training.

The statement added: "Furthermore, homeopathy is currently accepted by society and recognised by UK medicines legislation, and does not, in itself, cause harm to animals.

"While this is the case, it is difficult to envisage any justification for banning a small number of veterinary surgeons from practising homeopathy."



Homeopathy

Homeopathy is based on the use of highly diluted substances, which practitioners say can cause the body to heal itself.

A 2010 House of Commons Science and Technology Committee report on homeopathy said the remedies performed no better than placebos and that the principles on which homeopathy was based were "scientifically implausible".

According to NHS guidelines, there "is no good-quality evidence that homeopathy is effective as a treatment for any health condition".

Supporters of homeopathy in animals say that the evidence base supporting the effectiveness of the therapy is growing.

Source: Homeopathy - NHS Choices

Mark Elliott is a qualified vet and veterinary homeopath in West Sussex and a past president of the British Association of Homeopathic Vets.

He told BBC News: "As a veterinary surgeon, my role and what I am charged to do by my clients is to do the best I can for my patients.

"And if that involves using homeopathy to achieve a benefit for that patient - having seen literally thousands upon thousands of cases over my career respond well - then that to me is actually a critical appraisal of the evidence that's in front of my eyes."

He added: "If you have qualified, regulated people who understand the medical processes of the day and can objectively assess the case and determine which is the treatment for that particular case, is that not a better thing?"

"Because if you ban homeopathy through veterinary surgeons, it will only go underground."

Organic farming

Homeopathy is sometimes used by organic farmers, such as for cows with mastitis.

In May, Prince Charles, speaking at a summit on antibiotic resistance, said he was successfully using homeopathy on animals at his organic farm.

The organic food charity, the Soil Association, said the use of homeopathy was an individual decision for farmers and not mandatory for organic status.

"For all complementary therapies, our standards specify that they are used with professional veterinary guidance and provided that their healing effect works for the species and condition you are treating," said policy director, Peter Melchett.

http://www.publications.parliament.uk/pa/cm200910/cmselect/cmsctech/45/4502.htm

http://www.nhs.uk/Conditions/Homeopathy/Pages/Introduction.aspx


Veterinary Record,


The Pet Site, 8 August 2016

Should Pet Owners Adopt Homeopathy? 09 August 2016

Homeopathic treatments are currently approved by the Royal College of Veterinarians (RCVS), but a new petition by vet Danny Chambers aims to ban their use, due to fears that such remedies don’t really work, and instead may lead to undue suffering to the animals treated with them.

At the time of writing, his petition had gained more than 3,000 signatures, over 1,100 of which are from practising vets. But which side of the debate should you believe?

What is Homeopathy?

Homeopathy is a complementary or “alternative” medicine, based around the central principle that “like cures like”. Practitioners of homeopathy believe that a substance that causes certain symptoms can also help to remove those symptoms, if it is diluted to extremely low levels before it is administered.

Does Homeopathy Work?

The big point of contention in the debate over homeopathic medicine is whether or not it actually works, and it is on this point that the two sides disagree.

Mr Chambers, the instigator of the petition, said: “Homeopathy should not be confused with herbal medicine. Many herbal medicines have some merit, and it is not the same as a ‘holistic’ approach to medicine. Homeopathy is not effective.

“It is based on the premise that 'like cures like' for which there is no scientific evidence. Ingredients are then diluted to the point where not one molecule of the original substance remains.

“The theory is that extreme dilution increases the effect of the remedy. Homeopaths believe that water has a memory of what was once dissolved in it, and that this somehow has healing properties.”

Mr Chambers has spent three years writing letters and debating the issue of homeopathy in the Veterinary Times. He says he has become increasingly frustrated, after seeing that some animals may legally be given an ineffective alternative therapy, instead of an appropriate medicine that could help them.

Are There Any Benefits?

Despite Mr Chambers’s insistence that homeopathic treatments are not just useless, but actually harmful to people’s pets, there are a number of vets who disagree with him.

In a statement about the petition, the British Association of Homeopathic Veterinary Surgeons (BAHVS), said: “The whole premise of this campaign is based on the blatant misrepresentation that homeopathic medicines are ‘only water’. This is plainly not true. A


global initiative of over 100 researchers from a mutiplicity of disciplines – the Group Recherche sur l’Iinfinitessimal (GIRI) - has been studying solutions described as ‘ultra-dilutionse’ for 30 years. They have observed unequivocal evidence of their bioactivity.

“The foundation of the campaign is therefore untenable from a scientific point of view. It is nonsense to suggest that homeopathy has been proven to be ineffective. There is a wealth of scientific papers demonstrating the beneficial effect of homeopathy, in humans and in animals.

“Among them are a clinical audit published in the Veterinary Record, and the most recent meta-analysis in homeopathy, published in 2014 in the peer-reviewed journal Systematic

Review, which concluded there was a significant treatment effect beyond placebo.”

However, it is important to note that the GIRI is a group specifically set up to prove that homeopathy works, and is therefore not a scientific research group in the strictest sense of the term.

Additionally, a 2010 House of Commons Science and Technology Committee report on homeopathy, found that homeopathic remedies perform no better than placebos, and that the principles on which homeopathy are based are “scientifically implausible”.

While it is true that the negative conclusions from the House of Commons evidence check in 2010 have been somewhat discredited – because only three members of the committee voted in favour of the report – neither is it true that homeopathy has been conclusively proven to work.

Currently, the National Institute of Health and Care Excellence (NICE) does not approve homeopathic treatments for use on the NHS, and any placebo affect that may be observed in humans due to the belief that they will get better, can evidently not be the case in animals, who do not have a concept of medicine.

Despite conflicting claims from both sides, it is still the case that the RCVS currently allows the use of homeopathic treatment for animals.

In a statement about the petition, the RCVS said: “As the regulator of the veterinary profession, we emphasise the importance of evidence-based veterinary medicine. We recommend that there should therefore be a cautious approach to homeopathy for animals and that normal evidential standards be applied to complementary treatments.

“We believe it is also essential that such treatments, until they can be proved, are complementary rather than ‘alternative,’ and that they are therefore used alongside conventional treatment.”

The crux of Mr Chambers’s argument, however, is that this may not always be the case when vets prescribe homeopathy. He argues that he has seen instances in which dogs and horses suffering from Cushing’s disease were ineffectually treated with homeopathy alone, leading to undue suffering that could have been prevented if a conventional medicinal treatment had been administered.


He said: “If you give homeopathy instead of conventional medicine then you are withholding treatment. This means it is an animal welfare issue and is a disservice to the owners.

“Animals and children have no choice in treatment so we should offer them medicine that definitely works. If adult humans want to ignore medical advice and choose something that has been proven not to work, that is their decision, but they shouldn’t inflict that on children or animals.

“Sometimes owners try homeopathy if their animal is terminally ill because they do not want to euthanise. This is understandable, but in reality it gives owners false hope, wastes their money, and prolongs suffering unnecessarily.”

What Does This Mean for Your Pets?

RCVS said it appreciates there are strong views about these issues on both sides of the argument, but that they are grateful for the opportunity this petition affords them to hear the latest views of both animal owners and the veterinary profession.

They also say that homeopathy “does not, in itself, cause harm to animals”, but when it is used as an alternative to conventional medicine, this may be a different matter.

For now, homeopathy is still licensed for use, but the advice for pet owners from the RCVS is that homeopathy should only be used alongside conventional medicine, and not simply as a replacement for more evidence-based treatments.


Vetsurgeon.org, 30 September 2016

CVS muddled over homeopathy

Arlo Guthrie 30 Sep 2016 7:22 AM

The RCVS has responded to a petition from Danny Chambers MRCVS and 1,100 of its members which called for veterinary surgeons to be banned from prescribing homeopathic treatments to animals. In a letter to Danny, RCVS President Christopher Tufnell wrote:

"As the regulator of the veterinary profession, we place an emphasis on the importance of evidence-based veterinary medicine. We therefore recommend that there should be a cautious approach to homeopathy for animals and that normal evidential standards should be applied to complementary treatments."

Danny said: "A cautious approach? What, like this claim by the BAHVS that homeopathy cures cancer?. Or would you say that this claim on national TV represents a cautious approach?

"Talking about homeopathy and normal evidential standards in the same breath is oxymoronic. If you apply normal evidential standards to homeopathy, it is completely ineffective and should not therefore be used in animals."

Mr Tufnell wrote: "We believe it is also essential that such treatments, until they can be proved, are complementary rather than 'alternative' and that they are therefore used alongside conventional treatment."

Danny said: "This argument makes sense whilst evidence-gathering for new treatment modalities. Homeopathy, however, has been with us since 1796. In that time, there has been no good evidence that homeopathy is effective for any condition. Against that, we now have the benefit of an increasing body of meta analyses that show it isn’t. How much more evidence does the RCVS require?"

Mr Tufnell wrote: "Whatever views there may be within the veterinary profession, it is clear that there is a demand from some clients for complementary therapies for their animals."

Danny said: "That may be true, but client demand is not an argument for prescribing medicines shown not to work. Nor should ill-informed client demand trump animal welfare"

Mr Tufnell added: "It is better that they [clients] should seek advice from a veterinary surgeon - who is qualified to make a diagnosis, and can be held to account for the treatment given - rather than turning to a practitioner who does not have veterinary training."

Danny said: "It makes no difference to the animal's suffering whether effective treatment is withheld by a layperson or a qualified vet. At what point do we trust the clinical judgement of vets who subscribe to this magical thinking? In the case of hyperthyroidism in a cat, at

https://www.vetsurgeon.org/members/Editor/default.aspx



http://www.bahvs.com/cured-cases/


http://www.bbc.co.uk/news/science-environment-36748693

https://www.vetsurgeon.org/microsites/private/rational-medicine/p/veterinary-homeopathy-research.aspx



https://www.vetsurgeon.org/members/Editor/default.aspx


what point do we trust them to start giving proper treatment? Maybe when the T4 levels reach a certain number? Or when renal failure kicks in? Or when the cat loses a certain percentage of its body weight?"

Finally, Mr Tufnell wrote: "homeopathy is currently accepted by society and recognised by UK medicines legislation and does not, in itself, cause harm to animals."

Danny said: "I'm not sure how it is possible to claim homeopathy is 'accepted by society'. What constitutes 'societal acceptance'? The NHS says that: 'The ideas that underpin homeopathy are not accepted by mainstream science, and are not consistent with long-accepted principles on the way that the physical world works'; the Australian Government says: 'Homeopathy should not be used to treat health conditions that are chronic, serious, or could become serious.' Clearly homeopathy is far from being accepted by society.

"Even if it was, the argument that we should prescribe medicines because they are 'societally accepted' is no different to the argument that we should do so because there is 'consumer demand.' Both are plainly wrong. Presumably the RCVS wouldn't approve of veterinary surgeons prescribing antibiotics just because there is 'consumer demand', or because they are 'societally accepted'.

As to the veterinary medicines regulations, homeopathic remedies were ‘grandfathered’ and have not had to prove efficacy to become authorised. So their recognition by UK medicines legislation is meaningless.

"Lastly, homeopathy does, in itself, cause harm to animals when given ahead of, or in place of proven treatments."

At the same time as Danny was running his petition for banning homeopathy, the Campaign For Rational Veterinary Medicine has been running a petition which instead asks that the RCVS takes steps to allow animal owners to make a more informed decision, thereby limiting the harm that homeopathy causes animals.

This petition, which is for the veterinary profession only, has so far gathered over 400 signatures, and the campaign organisers are now inviting anyone who signed the petition to ban homeopathy to consider signing this one as a pragmatic alternative.




https://www.nhmrc.gov.au/_files_nhmrc/publications/attachments/cam02_nhmrc_statement_homeopathy.pdf

https://www.nhmrc.gov.au/_files_nhmrc/publications/attachments/cam02_nhmrc_statement_homeopathy.pdf

https://www.vetsurgeon.org/microsites/private/rational-medicine/p/veterinary-homeopathy-petition.aspx




Daily Mail, 16 December 2016

How alternative medicine cured our precious pets: These doting owners swear homeopathy, reiki and aromatherapy transformed the lives of their pets. Sceptical? Read their stories and judge for yourself By Helen Carroll for the Daily Mail

When Ruth Owen was given the devastating news that her beloved miniature bull terrier had a deadly cancerous growth in her stomach, she prepared herself for a sad goodbye.

The vet gave her dog just months to live but suggested that while chemotherapy and steroids couldn’t cure the small cell lymphoma, they could buy Ruth a little more time with her pet Dorothy, then 11, which she had taken in as a rescue puppy a decade earlier.

However, Ruth decided that she could not put her adored dog through the agonising side-effects of the drugs.

Instead, the 54-year-old, from Newton Abbot, Devon, opted to try homeopathy in the hope of making Dorothy more comfortable during her final days.

Astonishingly given the lack of scientific weight behind homeopathy’s claims, Ruth found a Cambridge University-trained veterinary surgeon, Geoff Johnson, who offers only alternative therapies at his Somerset practice.

While other veterinary practices have banned homeopathy on the grounds that it is ineffective — and this week a study concluded claims that animals benefit from homeopathy are based on unreliable evidence — Geoff has worked on hundreds of animals homeopathically since gaining a second degree in the subject from Oxford University 12 years ago.

‘The only thing I knew about it was that it purports to do no harm, so I took Dorothy along for a consultation,’ says Ruth.

http://www.dailymail.co.uk/home/search.html?s=&authornamef=Helen+Carroll+for+the+Daily+Mail


‘As well as having a very distended stomach, she also had terrible sickness and diarrhoea, and no energy, and I hoped homeopathy might ease her symptoms.’

Following an hour-long assessment, Dorothy was prescribed a thrice-daily drop of Gadolinium arsenate, derived from metal and salt and one of around 4,000 homeopathic remedies, diluted in 100ml of water.

The consultation and prescription cost £100 in total.

After a week, Ruth insists, Dorothy’s stomach was no longer swollen and within three weeks her symptoms had cleared and she appeared to be back to full health.

She had been suffering for three months before treatment and, as it was the only change that Ruth introduced, she is convinced homeopathy cured her precious pet.

Ruth continued the treatment for a further eight months, and then Dorothy continued receiving just one 2ml dose a week.

Despite having been given just months to live, she remained fit and well for another three years before dying aged 14 — not of cancer, but a stroke.

Ruth says: ‘I believe that, thanks to homeopathy, I got three more wonderful years with Dorothy.

'They were years in which she didn’t have to suffer the dreadful side-effects of steroids and chemotherapy.

‘She was 14 when she passed away, due to a stroke, no doubt the result of her advanced years, but she was fit and healthy right up until the end.

'The expected lifespan for a miniature bull terrier is just 11 or 12 years, so I feel extremely fortunate that homeopathy helped Dorothy beat cancer and gave her a new lease of life.’

Understandably, though, many were dubious about Dorothy’s apparently miraculous recovery.

‘Some people I’ve told have said, “She couldn’t have had cancer, it will have been a wrong diagnosis”, but it showed up on X-rays, in blood tests and biopsies,’ says Ruth.


She admits she didn’t have Dorothy X-rayed after the homeopathy to see if the tumour in her stomach had changed size, but says: ‘My message to doubters is, if homeopathy didn’t cure it, where did the mass go?’

However, even Ruth has been forced to admit that homeopathy carries no guarantees.

She returned to Geoff Johnson when her crossbreed dog Kevin developed a skin rash last year and says: ‘He tried three different treatments on him, none of which worked, so in the end I went to my regular vet who prescribed a steroid cream, which cleared the rash.

‘So, obviously, homeopathy doesn’t work for everything.’

Vet Geoff, 53, first became interested in animal homeopathy 21 years ago after being successfully treated for hay fever by a professional homeopath, and is in no doubt that the remedy he prescribed shrank Dorothy’s tumour.

He explains that homeopathy is not used to cure specific conditions, but triggers an individual’s body into being able to heal itself.

So, the key is finding out as much about the person, or animal, as possible — taking into account temperament, medical history, sleeping and eating — before selecting a remedy for them.

‘Conventional medicine has a very important role and, if my child had meningitis, I would ensure they were on a penicillin drip in a hospital in no time,’ says Geoff.

‘But in the case of Dorothy, and many others, there was no medical cure so we used homeopathy to help her body heal itself.

‘I understand why some people question its efficacy because the mechanism is totally different to conventional medicine, but I would tell them, “Come and look at the animals I’ve treated successfully.” ’

However, homeopathy is deeply controversial among Geoff’s colleagues in the veterinary world.

In a report published this week, scientists from the University of Kassel, in Germany, assessed studies published between 1981 and 2014 and found none of the clinical trials that claim to show effectiveness have been repeated under comparable conditions, meaning results are unproven.


Devon vet Danny Chambers has drawn up a petition asking the Royal College of Veterinary Surgeons to introduce rules preventing the use of homeopathy by vets.

It has attracted 2,500 signatures, including those of 1,100 vets, veterinary nurses and scientists.

He says: ‘I have seen cases of animals who have had to be put to sleep because homeopathy has been used instead of a conventional treatment, which could have worked.’

He adds: ‘I’ve seen this with a dog who had Cushing’s disease, a hormonal condition which could have been treated effectively with drugs, but the owners chose instead to use homeopathy.

‘Another was a cat with hyperthyroidism, which could have easily been treated with medicine.

‘Even if a vet is giving homeopathic remedies alongside conventional treatment, although it won’t harm the animal, it legitimises a treatment that doesn’t warrant it and owners are being charged for things that just do not work.’

However, the British Association of Homeopathic Veterinary Surgeons disputes the claims that there is no proof the treatment works, and the RCVS says it would be difficult to ban vets from offering it.

Most studies have concluded that there is no evidence of the medicinal effect of homeopathy, whether practised on humans or animals.

A 2010 House of Commons Science and Technology Committee report stated that homeopathic remedies work no better than placebos and that the principles on which it is based are ‘scientifically implausible’, a view shared by England’s Chief Medical Officer, Prof Dame Sally Davies.

Nevertheless, more and more owners are giving their pets alternative therapies and homeopathy has many advocates, including Prince Charles, who last month revealed that he uses homeopathic remedies on his cows and sheep.

Homeopathy is currently practised by some 50 qualified vets.


And it’s far from the only complementary therapy that owners rely on when their animals become sick.

Gemma Cook’s strawberry roan horse Derby has had a stiff hind left leg for years and, as physiotherapy has been unable to cure it, she turned to reiki.

With its roots in Japanese culture, reiki healing is based on the theory that humans, and animals, have seven major chakras — centres of energy — in their bodies and when one or more of these becomes unbalanced, the body and mind suffer.

Another owner at the stables where Gemma keeps Derby, near her home in Kent, employed a reiki healer to treat her horse for cellulitis, a bacterial infection of the soft connective tissues, in one of its hind legs, and recommended the therapy.

‘Derby was very highly strung and so, as well as her physical symptoms, I thought the reiki might help calm her,’ says Gemma, 34, who works in advertising sales.

‘We’ve had quite a few falls over the 17 years I’ve had her, usually because she’s refused to jump, which may be partly due to her stiff leg.

‘But it’s made us both a bit nervous and wary. Derby could be naughty, biting and pushing me out of the way too.’

A month ago, reiki practitioner Sarah Adams began visiting Derby at her stables and, standing a little distance from the horse, ‘allowed the energy to flow’ between them.

After three hour-long sessions to help rebalance her chakras, monthly follow-up appointments have been recommended, at a cost of £35 each.

‘I don’t have to place my hands on the animal,’ says Sarah. ‘It’s a natural healing therapy and the energy needed to rebalance the chakras flows from me to them.

‘After the first session she was more flexible and mobile and less stressed, and much better still after the third.’

Gemma also believes that Derby is happier and more relaxed as a result of the treatment.


She says: ‘When I ride her I can feel that the stiffness in her leg has eased, so we both feel a lot more relaxed.

‘In fact, she felt so different beneath me that I had to ask one of the stable girls to check if she looked OK.

‘She’s also more laid back and doesn’t get uptight when I leave her.

‘Friends who are sceptical about alternative therapies look at me as if I’m crazy and say, “Why on earth would you pay for reiki for a horse?”

'But I want Derby to be happy, and I’m pretty open-minded, so willing to give things a try.’

Emma Saville was close to the end of her tether, after consulting her vet about methods to stop her cat urinating and defecating all over the family home in Chelmsford, Essex, by the time she tried aromatherapy.

Annie, a fluffy, long-haired black and white moggy, was three when Emma rescued her three years ago.

She and her daughters Ava, now nine, and Neve, seven, were advised to keep Annie indoors for the first eight weeks, until she became acclimatised.

During that time Annie used a litter tray. However, once it was time for her to venture outside, where she was expected to go to the toilet, she refused and, avoiding her tray, used carpets indoors instead.

‘I took her to the vet, who said she was clearly stressed and anxious and consequently marking her territory,’ recalls Emma.

‘It was a huge headache for me because, with young children to protect, I was forever having to check the corners of rooms and clean up the mess Annie left.’

Emma discovered that, when Annie was rescued by the RSPCA in Colchester, she had been a stray and recently given birth to a litter of kittens, who were found lying dead around her.

Convinced this was at the root of Annie’s distress, Emma did some online searches and came across animal aromatherapist Caroline Thomas, who charges £45 for an initial consultation.


Caroline explained that cats have an advanced olfactory system and are therefore very sensitive to smells.

But, while aromatherapy can help, the essential oils must be heavily diluted and carefully administered to cats, as they lack an enzyme important in breaking down the oils.

‘Having heard Annie’s story, I decided to try her with three different oils — yarrow, which is useful in helping with emotional trauma; carrot seed, which we use for abandonment; and angelica essential, which is for traumas suffered in early life,’ says Caroline.

‘We believe that aromatherapy helps with stress by balancing the body and connecting to the brain’s limbic system, which deals with emotions.’

Caroline left the bottles — each costing £15 and containing one drop of essential oil in 25ml of carrier oils — with Emma and told her to take off the lids each day and let Annie choose which ones she wanted to sniff.

‘Somehow it seemed to quell her anxiety and, after a week, she stopped using our home as a toilet and happily went outside instead,’ says Emma.

With figures showing one of the main reasons four in ten pet insurance claims are rejected is the growing number looking to be reimbursed for treatments such as acupuncture and hydrotherapy, it seems Ruth, Gemma and Emma are far from alone in seeking alternative solutions.

Vet Danny Chambers, however, continues to urge caution.

‘People who use alternative medicines on their pets, instead of seeking proper veterinary advice, can unwittingly allow their animals to be sicker for longer,’ he warns.

Read more: http://www.dailymail.co.uk/femail/article-4039160/How-alternative-medicine-cured-precious-pets-doting-owners-swear-homeopathy-reiki-aromatherapy-transformed-lives-pets-Sceptical-Read-stories-judge-yourself.html#ixzz4UzvJ2YAI Follow us: @MailOnline on Twitter | DailyMail on Facebook

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Letter to Veterinary Record from Campaign for Rational Veterinary Medicine ref homeopathy (note: as of 10.01.17 this has not been published)

Professional standards and the practice of homeopathy

WE were pleased to read in the November 2016 RCVS News that the Standards

Committee is to review the RCVS’s guidance on complementary and alternative

medicine (CAM). CAM encompasses a wide range of therapies, some more evidence

based and rational than others. One of the least rational, and with good evidence of

lack of efficacy, is homeopathy.

Homeopathy is a system of magical thinking – the unproven dictum of ‘like cures like’

is a textbook example of sympathetic magic, as practiced by many cultures over the

millennia (Fraser 1922). Homeopaths treat their patients with pseudoscientific magic

rituals. The rituals consist of the use of information both relevant and incidental to the

patient’s illness to select – by means of an arbitrary system of rules – substances that

have no medical relevance to that illness, then grinding-up the substances in water or

alcohol (‘trituration’) to create a ‘mother tincture’ that is serially diluted and agitated

(‘succussed’) to invoke an imagined supernatural healing energy (homeopaths call the

process of trituration, serial dilution and succussion ‘potentisation’) they believe is

transmitted in their remedies and cures their patients. This system was invented by

one man in the 1790s, before Darwin, Pasteur, Virchow, Koch and the modern scientific

understanding of biology and pathology. There is no rational, plausible basis in science

and reality for such behaviour or claims, and systematic reviews and meta-analyses of

the highest-quality controlled trials yet carried out have shown homeopathic remedies

to be ineffective, despite homeopaths’ reports of consistently high efficacy in their

practices.

Yet another review of clinical trials of homeopathy has just been published (Doehring

& Sundrum 2016) showing that there is insufficient evidence to support the use of

homeopathy, in this case – despite over 50 published trials – to replace or reduce use of

antibiotics for farm livestock; a use actively promoted by the organic farming

movement. To date, despite over 200 years of practice and hundreds of trials, there is

still no good-quality evidence that homeopathy is effective to treat any one condition in

humans or animals.


Homeopathic remedies themselves do no harm, but homeopathy potentially harms

animals in two ways. First, vets and owners use ineffective treatments on patients

rather than proven effective treatments. Second, by inducing caregiver placebo effects

in owners, causing them to believe their animals are improved when they are not.

Veterinary homeopaths practice mysticism, not medicine, on animals that – unlike

humans – cannot provide informed consent and cannot benefit from the undoubted

‘counselling/psychotherapeutic’ aspects of homeopathic consults or the placebo effects

they induce in human patients. For many years, the RCVS has regarded this practice of

mysticism and pseudoscientific ritual by veterinary professionals as acceptable therapy,

and that position was explicitly re-affirmed in July 2016 (Viner 2016).

Because the evidence has shown that homeopathic remedies are ineffective, because

the rationale for homeopathy is based on mystical thinking, and because the practice of

homeopathy consists of the use of pseudoscientific rituals to invoke imagined

supernatural healing energies, we believe it to be both irresponsible and unethical for

veterinary professionals to treat animals with homeopathy.

The practice of homeopathy cuts to the very core of professional regulation.

Veterinary surgeons have the right, and privilege, to treat animals with great – though

not unlimited – clinical freedom. However, with that right comes the responsibility to

act rationally and in accordance with the available evidence when diagnosing and

treating the animals under our care (and when communicating with the public about

what vets do). The practice of homeopathy is systematically arbitrary, systematically

irrational and proven to be ineffective and, therefore, reneges on that responsibility,

resulting in potential or actual harm to patients by veterinary professionals and a

lowering of the standards of our profession.

We, therefore, regard the RCVS’s current position as a clear failure of the profession’s

regulator in their duty to uphold the clinical standards of practicing veterinary

surgeons. We respectfully ask the Standards Committee, as part of their review of the

RCVS’s guidance on CAM therapies, to consider why the RCVS regards the use of

mysticism, pseudoscience and magic ritual by veterinary professionals, to treat patients,

as acceptable veterinary practice.

Martin Whitehead, Danny Chambers, Niall Taylor, Mike Jessop, Alex Gough, Martin Atkinson, Phil

Hyde, Brennen McKenzie and Arlo Guthrie.


The Campaign for Rational Veterinary Medicine

www.vetsurgeon.org/microsites/private/rational-medicine/

References

Fraser, J.G. (1922) The Golden Bough: A Study in Magic and Religion. MacMillan. Chapter 3.

Doehring, C. & Sundrum, A. (2016) Efficacy of homeopathy in livestock according to peer-reviewed

publications from 1981 to 2014. Veterinary Record, 179(24):628

Viner, B. (2016) Homeopathy and cancer. Veterinary Record 179(3):79.

http://www.vetsurgeon.org/microsites/private/rational-medicine/


Letter to the Vet Times from the Campaign for Rational Veterinary Medicine ref homeopathy (as of 10.01.17 this letter has not been published)

Homeopathy consists of mysticism and magic ritual

The RCVS Standards Committee has announced it is to review the College’s guidance on

homeopathy and other alternative and complementary veterinary medicines and therapies (‘RCVS to

review guidance on alternative therapy’, Jan 4 issue). It is, therefore, an opportune time to draw

attention to some recent public pronouncements of prominent UK veterinary homeopaths.

Geoff Johnson MRCVS, one of the UK’s most senior veterinary homeopaths, claims, on the British

Association of Homeopathic Veterinary Surgeon’s website (http://www.bahvs.com/cured-cases/) to

cure – “successfully treat and resolve” – cancer in dogs using homeopathy. This claim was also made

in the National press, including in the Daily Telegraph in June 2016 (Knapton 2016) and BBC2’s

Victoria Derbyshire Show (July 8th 2016: http://www.bbc.co.uk/programmes/p040ty7g). In

December, he made a similar claim in the Daily Mail (Carroll 2016) about a dog with cancer – that he

successfully used homeopathy to “help her body heal itself”.

Geoff Johnson is also a teacher at the School of Homeopathy. This quote, on the School of

Homeopathy’s website (http://www.homeopathyschool.com/the-school/faculty/teachers/) provides

insight into how Mr Johnson selects the remedies he uses to treat illnesses: "Homeopathy is simple.

All you have to do in your consultation is perceive something from nature in your patient. You can

hear it in their story, see it in their actions, and sometimes you witness it appearing in the space

between you and them. That is the remedy they need, and if it is the right one, wonderful things can

occur after you give it. This extraordinary phenomena is something a homeopath can witness every

day. Homeopathy not only connects you to your patient, but to nature too."

Two other UK veterinary homeopaths have recently claimed in the veterinary press that, unlike

conventional medicine, homeopathy operates outside the material world:

From Wendy McGrandles MRCVS article ‘Integrating holistic and conventional veterinary

practice’ in the September 2016 Veterinary Business Journal: “Conventional thinking is based in the

material world, with most treatments and current research being centred around the genes and

biochemical pathways that are altered in the expression of disease. Homeopathic thinking is

different and is based in the dynamic world, with treatment based on symptom expression of the

whole individual with symptoms and material changes being a consequence of dynamic disturbance


http://www.bbc.co.uk/programmes/p040ty7g

http://www.homeopathyschool.com/the-school/faculty/teachers/


and not a cause of disease.” Ms McGrandles does not specify what – or where – this ‘dynamic

world’ is.

From Peter Gregory MRCVS, Veterinary Dean of the Faculty of Homeopathy, in a letter in the

Veterinary Times (October 11, 2016 issue): “…homeopathic medicines do not operate on the

material plane; hence, to understand their effects requires a shift to an electromagnetic paradigm.”

Given that electromagnetism is a fundamental part of the material world, which consists of atoms

held together by electromagnetism, it is not clear where Mr Gregory thinks homeopathy operates.

Homeopathy is a system of mystical thinking that involves the practice of pseudoscientific rituals

(using the clinical findings and patients’ history, along with incidental information, to select, by

means of an arbitrary system of rules, substances with no medical relevance to the patients’ illness,

then grinding-up those substances in water or alcohol, then serially diluting and shaking the

suspensions/solutions that result) to call forth imagined supernatural healing energies. For many

years, despite repeated concerns expressed by members of the profession, the RCVS has regarded

this practice of mysticism and pseudoscientific ritual by veterinary professionals as acceptable

therapy, and that position was explicitly re-affirmed in July 2016 (Viner 2016).

Despite 200 years of practice and hundreds of clinical trials, there is still no good-quality evidence

that homeopathy is an effective (beyond placebo) treatment for any one condition in any species.

So, why does the RCVS – with their remit to maintain clinical standards in the profession and protect

animals and owners from poor-quality treatment – approve the practice of mysticism and magic

rituals by veterinary surgeons acting in their professional capacity? Is it possible that the College,

even now, does not realise that homeopathy consists of mysticism and pseudoscientific rituals? Or

does the College know that, yet regard the use of magic ritual to invoke imagined supernatural

healing energies to be acceptable veterinary practice?

Hopefully, when undertaking its review, the RCVS Standards Committee will consider whether

the use by veterinary professionals of mysticism and magic ritual to treat their patients can still be

regarded as acceptable practice in the 21st century.

Martin Whitehead, Danny Chambers, Niall Taylor, Mike Jessop, Alex Gough, Martin Atkinson, Phil

Hyde, Brennen McKenzie and Arlo Guthrie.

The Campaign for Rational Veterinary Medicine

www.vetsurgeon.org/microsites/private/rational-medicine/

http://www.vetsurgeon.org/microsites/private/rational-medicine/


References

Carroll, H. (2016) How alternative medicine cured our precious pets: These doting owners

swear homeopathy, reiki and aromatherapy transformed the lives of their pets. Sceptical?

Read their stories and judge for yourself. http://www.dailymail.co.uk/femail/article-

4039160/How-alternative-medicine-cured-precious-pets-doting-owners-swear-

homeopathy-reiki-aromatherapy-transformed-lives-pets-Sceptical-Read-stories-judge-

yourself.html. Accessed December 16, 2016

Knapton, S. (2016) Homeopathy can kill pets and should be banned, say vets.

http://www.telegraph.co.uk/science/2016/06/24/homeopathy-can-kill-pets-and-should-be-

banned-say-vets/?WTmcid=tmgoff_soc_spf_fb&WT.mc_id=sf29586103. Accessed July 11,

2016

Viner, B. (2016) Homeopathy and cancer. Veterinary Record 179(3):79.

http://www.dailymail.co.uk/femail/article-4039160/How-alternative-medicine-cured-precious-pets-doting-owners-swear-homeopathy-reiki-aromatherapy-transformed-lives-pets-Sceptical-Read-stories-judge-yourself.html




http://www.telegraph.co.uk/science/2016/06/24/homeopathy-can-kill-pets-and-should-be-banned-say-vets/?WTmcid=tmgoff_soc_spf_fb&WT.mc_id=sf29586103

http://www.telegraph.co.uk/science/2016/06/24/homeopathy-can-kill-pets-and-should-be-banned-say-vets/?WTmcid=tmgoff_soc_spf_fb&WT.mc_id=sf29586103


SOCIAL MEDIA

Danny Chambers’ change.org petition – at time of closure 3,364 people had supported the petition

A call to ban veterinary surgeons from prescribing homeopathy as a treatment for animals

Danny Chambers Tavistock, United Kingdom

Please sign and share this petition if you want to prevent homeopathic treatments being prescribed to animals.

The following is an open letter to the Royal College of Veterinary Surgeons to ask them to blacklist homeopathy from the treatments veterinary surgeons are allowed to offer animals and their owners. We believe that the current position of allowing veterinary surgeons to prescribe homeopathic treatments, which have been proven not to work, is both an animal welfare issue and fails to meet the standard required for scientific veterinary practice. This is a disservice to the animals and their owners.

An open letter to the RCVS regarding veterinary homeopathy:

Many systematic reviews and meta-analyses have proved conclusively that homeopathic treatments have no effect beyond the placebo effect, the Cochrane review in 2010 being a notable one (1),(2),(3). The House of Commons Science and Technology Committee

https://www.change.org/u/90038766






concluded that the NHS should not waste public money and risk lives by funding homeopathic treatments which have been clearly proven to have no effect beyond the placebo effect. (4)

It could be argued that as homeopathy has no effect beyond placebo, the use of it is not a cause for concern. However we believe the use of homeopathic remedies by veterinary surgeons is potentially dangerous for several reasons.

The biggest danger of homeopathy is not that the remedies are ineffective, but that some

homeopaths are of the opinion that their therapies can substitute for genuine medical

treatment. This is at best misleading, and at worst may lead to unnecessary suffering and death.

At what level of significance does homeopathy become a concern to the profession? If veterinary homeopaths wish to believe that their treatments have quickened the resolution of ringworm on a dog then no one would begrudge them that. However, substituting effective and appropriate treatment with homeopathy for more serious diseases such as hyperthyroidism in a cat could result in a personal tragedy for the owner of a much loved companion animal. Similarly, it would be devastating for a family dairy farm that went out of business because the homeopathic treatments failed to control a mastitis problem.

We believe homeopaths are acting with good intentions. We have no doubt that the majority of them are very sincere in their beliefs, but if they are not capable of assessing the evidence for themselves then it must fall to a third party to prevent them from promoting these beliefs on the public who, rightfully, put their faith in the medical knowledge that the letters MRCVS after a name implies. Members of the public put their trust in veterinary surgeons because they assume that their medical knowledge and training was gained during an accredited degree at an accredited university. They do not assume that they will be offered the

veterinary surgeon's personal beliefs in therapies that have absolutely no basis in science.

We are not advocating that that every single treatment administered by veterinary surgeons must have a proven and extensive evidence base. Indeed, it is possible that almost half of the treatments provided by the NHS are of unknown efficacy (5). However, there is normally a logical clinical reasoning behind many of our mainstream treatments as opposed to homeopathic remedies which have been shown to have no rational basis in medicine whatsoever.

We would argue that permitting veterinary surgeons to prescribe homeopathic remedies is severely contrary to the public and animal health interest. In our opinion, homeopaths should

not be able to use their membership of the RCVS to promote either the validity of the

treatment or the fee for it. Where do we draw the line for what members of the RCVS are allowed to offer clients? If we genuinely believe it will help, can we offer crystal healing, reiki or psychic healing? All recommended under our professional opinions as members of the RCVS? Can we use our standing as veterinary surgeons to charge fees for and add legitimacy to these 'services'? So why do homeopaths with their equally unproven evidence base somehow come under exemption from this? Is it appropriate for an RCVS approved practice to be allowed to offer homeopathy as a service?

Given the current RCVS promotion of evidence based medicine there seems to be a contradiction when encouraging vets to gain accredited and rigorous postgraduate


qualifications, yet also permitting homeopaths to place their various homeopathic 'qualifications' along side their MRCVS suffix. Although within the veterinary profession we understand the difference between various certificates and diplomas, many members of the general public will simply be impressed by the number of 'letters after the name'. Allowing the VetMFHom to be alongside MRCVS bestows upon it a status it does not deserve. We firmly believe being a MRCVS should differentiate us from all the various unlicensed healers. Should they wish to, adult humans have the right to decide that they want to ignore scientific wisdom and elect for unproven or dangerous alternatives. The health of animals is

totally in the hands of the humans charged with their care, so it would appear to be unethical

to withhold mainstream medicine and inflict alternatives on creatures that have no choice in

the matter.

We are aware that an open letter of the same sentiment was written to the RCVS back in 2006. However, with the recent decision by the government to hold a consultation into 'blacklisting' homeopathy on the NHS, would it not be wonderful for the veterinary profession to show its commitment to evidence based medicine by leading the way in taking a definitive, firm stance on this matter?

To summarise, we believe the RCVS should not allow members to prescribe homeopathy because:

it is an animal welfare issue it undermines public confidence in mainstream medicine it would further differentiate veterinary surgeons from unlicensed healers it devalues conventional treatments it devalues conventional qualifications it would allow the veterinary profession to take the lead, forging the way for our

human medical counterparts to do the same.

References:

1) Ernst, E. (2010). "Homeopathy: What does the "best" evidence tell us?". Medical Journal of Australia 192 (8): 458–460.

2) Milazzo, S; Russell, N; Ernst, E (2006), "Efficacy of homeopathic therapy in cancer treatment", European Journal of Cancer 42

(3): 282–9 3) Shang, Aijing; Huwiler-Müntener, Karin; Nartey, Linda; Jüni, Peter; Dörig, Stephan; Sterne, Jonathan AC; Pewsner, Daniel; Egger, Matthias (2005), "Are the clinical effects of homeopathy placebo effects? Comparative study of placebo-controlled trials of homeopathy and allopathy", The Lancet 366(9487): 726–732

4) Evidence check: Homeopathy, House of Commons Science and Technology Committee, 20 October 2009, parliament.uk 5) Clinical Evidence. How much do we know?http://clinicalevidence.bmj.com/ceweb/about/knowledge.jsp

Link to petition: https://www.change.org/p/the-royal-college-of-veterinary-surgeons-a-call-to-ban-veterinary-surgeons-from-prescribing-homeopathy-as-a-treatment-for-animals

http://clinicalevidence.bmj.com/ceweb/about/knowledge.jsp


change.org petition started by member of the public in support of homeopathy – as of 6 January 2017 this has been signed by 6,833 people

Prove Homeopathy is worth keeping for our pets

Pamela Taylor INVERNESS, United Kingdom There is currently a petition to ban homeopathic vets from practising and the use of homeopathy for our pets. I, myself have used and seen fantastic results through homeopathy and believe there is a massive place in the welfare and health of our animals for homeopathy. Please help show your belief and support by signing this petition and stop this ban on an amazing natural source which should be encouraged NOT prevented. Link to petition: https://www.change.org/p/british-veterinary-prove-homeopathy-is-worth-keeping-for-our-pets







Selection of Twitter comments on the issues (NOTE: all tweets included are publicly-available and have been picked up by our social media monitoring software)

Tweet from: Honest Homeopathy

23 April 2016 | 13:42:42 | Honest Homeopathy | Twitter

This is an illegal statement in human healthcare. Animals deserve better @RCVS_UK

#homeopathy #homeopathic https://twitter.com/vincethevet/status/723840153576452096

Tweet from: Max Sang

08 July 2016 | 07:48:06 | Max Sang | Twitter

Shocking response from @RCVS_UK >> Vets: Ban the use of homeopathy in animals -


Tweet from: Sarah Ryan

11 July 2016 | 08:59:48 | Sarah Ryan | Twitter

Royal College of Veterinary Surgeons won't protect from #homeopathy #sCAMs & @BBCNews

do balance wrong AGAIN #ten23 http://www.bbc.co.uk/news/science-environment-36734179

Tweet from: Elen Sentier

13 July 2016 | 11:21:38 | Elen Sentier | Twitter

Good ... In a statement, the Royal College of Veterinary Surgeons said “… homeopathy is

currently accepted by... http://fb.me/JiQPHMM6

Tweet from: DisabledAnimalsClub

29 July 2016 | 17:47:45 | DisabledAnimalsClub | Twitter

The @RCVS_UK response to this is quite unbelievable. Homeopathy is quackery.

https://twitter.com/A_Kelly_ISPCA/status/759067038543409152

Tweet from: (((Alan Henness)))

30 September 2016 | 19:58:13 | (((Alan Henness))) | Twitter

http://twitter.com/HonestHomeo/statuses/723854610289573888

http://www.twitter.com/HonestHomeo

http://www.twitter.com/

https://twitter.com/vincethevet/status/723840153576452096

http://twitter.com/max_sang/statuses/751306849337696256

http://www.twitter.com/max_sang



http://twitter.com/Geekazoid/statuses/752412057606160384

http://www.twitter.com/Geekazoid



http://twitter.com/elensentier/statuses/753172528982585344

http://www.twitter.com/elensentier


http://fb.me/JiQPHMM6

http://twitter.com/disabledanimals/statuses/759067904923033604

http://www.twitter.com/disabledanimals


https://twitter.com/A_Kelly_ISPCA/status/759067038543409152

http://twitter.com/zeno001/statuses/781931173069090817

http://www.twitter.com/zeno001



What a stunningly inept response from @RCVS_UK RCVS muddled over homeopathy:

https://www.vetsurgeon.org/news/b/veterinary_news/archive/2016/09/30/140108.aspx

#homeopathy

Tweet from: Andy Lewis

30 September 2016 | 20:15:44 | Andy Lewis | Twitter

In their reluctance to tackle quackery in their midst, the @RCVS_UK become a threat to animal

welfare. http://qako.me/2dBQIKI

Tweet from: Laura Thomason

01 November 2016 | 10:12:49 | Laura Thomason | Twitter

Meanwhile, the BAHVS claims homeopathy is effective to treat cancer.

http://www.bahvs.com/cured-cases/ cc @RCVS_UK

https://twitter.com/DannyVet/status/793392842379030528

Tweet from: Laura Thomason

12 December 2016 | 18:49:24 | Laura Thomason | Twitter

Vets who prescribe #homeopathy mislead public, put animals at risk & embarrass the veterinary

profession… https://twitter.com/i/web/status/808383265925197824

Tweet from: UK Homeopathy Regs

12 December 2016 | 18:45:28 | UK Homeopathy Regs | Twitter

VMD need to crack down on homeopathic remedies as well if it is to work.


Danny Chambers @DannyVet 12 Dec 2016

Why the @RCVS_UK soft position on #homeopathy must be changed: "...being well-intentioned and deluded is no substitute for being right."

https://www.vetsurgeon.org/news/b/veterinary_news/archive/2016/09/30/140108.aspx

http://twitter.com/lecanardnoir/statuses/781935579034423296

http://www.twitter.com/lecanardnoir


http://qako.me/2dBQIKI

http://twitter.com/LauraThomason_/statuses/793395363365478400

http://www.twitter.com/LauraThomason_




http://twitter.com/LauraThomason_/statuses/808383265925197824

http://www.twitter.com/LauraThomason_


https://twitter.com/i/web/status/808383265925197824

http://twitter.com/UKHomeopathyReg/statuses/808382276635656192

http://www.twitter.com/UKHomeopathyReg



https://twitter.com/DannyVet

https://twitter.com/DannyVet

https://twitter.com/RCVS_UK

https://twitter.com/hashtag/homeopathy?src=hash


@DannyVet: Is this the "cautious approach to #homeopathy" the @RCVS_UK currently

recommends? Claiming cure of cancer in papers http://www.dailymail.co.uk/femail/article-

4039160/How-alternative-medicine-cured-precious-pets-doting-owners-swear-homeopathy-reiki-

aromatherapy-transformed-lives-pets-Sceptical-Read-stories-judge-yourself.html

Tweet from: Colin Mackay �

29 December 2016 | 20:14:29 | Colin Mackay � | Twitter

RT @LauraThomason_: Having a vet agree that a homeopathic “vaccine” is OK will not make it

work, @DirectLine_UK cc @RCVS_UK

https://twitter.com/DirectLine_UK/status/813686837931835392

Morag@DrMoragKerr Dec 29, 2016 @lecanardnoir @RCVS_UK It's long past time vets were prohibited from touting these unlicensed products. 2

Morag@DrMoragKerr Dec 29, 2016 @RCVS_UK @lecanardnoir That's an appalling abrogation of responsibility. Where in the cascade do content-free preparations sit? 3

fermi@fermi239 Dec 29, 2016 .@RCVS_UK @lecanardnoir So the standards you claim to 'uphold' are double ones 1

Les Rose@Majikthyse Dec 29, 2016 @lecanardnoir @RCVS_UK Nor will it do its job and regulate vets who use magic medicine. 1

Andy Lewis@lecanardnoir Dec 29, 2016




http://twitter.com/ColinMackay/statuses/814565271432261632

http://www.twitter.com/ColinMackay


https://twitter.com/DirectLine_UK/status/813686837931835392

https://twitter.com/DrMoragKerr/status/814434776312594432

https://twitter.com/DrMoragKerr/status/814434317891989505

https://twitter.com/fermi239/status/814433884653887488

https://twitter.com/Majikthyse/status/814433509142044676

https://twitter.com/lecanardnoir/status/814431506034790400


So, to make clear. The @RCVS_UK will not issue guidelines to insurers to help prevent the cruel use of homeopathic nosodes on animals. RCVS @RCVS_UK @lecanardnoir As the regulator of veterinary professions we've no remit over terms & conditions of commercial pet insurance companies 1/2

Roy Alexander FRAS@Roy_Astro Dec 29, 2016 .@RCVS_UK @lecanardnoir if your code includes homeopathy then you support & encourage the torture of animals. Fix it.

Morag@lecanardnoir @RCVS_UK It's long past time vets were prohibited from touting these unlicensed products. 8d

Morag@RCVS_UK @lecanardnoir That's an appalling abrogation of responsibility. Where in the cascade do content-free preparations sit? 8d

RCVS@lecanardnoir 2/2 Clinical decisions on care & treatment are a matter for vets who must comply with our Code and all relevant legislation 8d

Andy LewisHi @RCVS_UK. Can you supply @DirectLine_UK with a statement that homeopathy/nosodes are no substitute for vaccination? If not, why not?

https://twitter.com/Roy_Astro/status/814443823283732480

SC Jan 17 AI 03b An J

British Association of Homeopathic Veterinary Surgeons (BAHVS) website: www.bahvs.com

Home Page

Webinars

Webinars

Webinars

http://www.bahvs.com/

http://www.bahvs.com/event/spring-day-meeting-4th-march-2017/

http://www.homeopathycongress.eu/2016/index.php/accommodation

http://www.bahvs.com/?p=35


Webinars

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News :How homeopathy might work

Find a Vet

Events

Research Project & Recruitment Application Form

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Snooks 2

What Happens when you visit a homeopath

Snooks 2


http://www.bahvs.com/news/

http://www.bahvs.com/find-a-vet/

http://www.bahvs.com/events/

http://www.bahvs.com/osteosarcoma-research-project-summary/

https://youtu.be/Fn-U7cE8y90

https://youtu.be/kirfmCIVB-g


Snooks 2


;

Archives

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Upcoming Events

1. SPRING DAY MEETING 4th March 2017

March 4 @ 9:30 am - 5:00 pm

2. Conference 2017

October 13 @ 8:00 am - October 15 @ 5:00 pm

View All Events

BAHVS MEMBERS ONLY BLUESKY FORUM

If you would like to join our forum please email [email protected] to get added as a

member

BAHVS

http://www.bahvs.com/2015/06/

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http://www.bahvs.com/events/


https://youtu.be/e2QWLBfdP6o

SC Jan 17 AI 03(c) SC Jan 17 AI 03(c)

SC Jan 17 AI 03(c) Classification: Unclassified Page 1 / 4

Page 1 / 4

Meeting

Standards Committee

Date

25 January 2017

Title

Future Committee Selection

Classification

Unclassified

Summary

Following on from the paper considered by the Committee at its

September meeting this paper considers what skills and

expertise are essential, desirable or not required to enable it to

meet future challenges.

Decisions required

The Committee is asked to identify and classify skills as

summarised above.

Attachments

Annex A: Committee profiles and appointment process paper

(Standards Paper September 2016)

Annex B: Draft skills matrix

Author

Robert Pragnell

Standards and Advice Manager / Solicitor

020 7202 0763

[email protected]




Page 2 / 4

N.B. This page is intentionally blank



Page 3 / 4

Introduction

1. At its meeting on 10 November 2016 the Committee considered a paper on the future profile

of RCVS committees. The paper was a part of the wider work being undertaken to modernise

the Colleges governance structure by ensuring that those who serve on its committees have

the necessary skills and knowledge required to meet the challenges of regulating and

supporting a modern veterinary profession.

2. The document reviewed was a first draft in response to the College Presidents endorsement

of a skills matrix approach to guide the appointment of Committee members. The proposals

included were previously discussed at the Operational Board at its meeting on 15 September

and by both Standards and Education Committees at their meetings on 28 September and 5

October respectively. The Committee was asked to consider the proposed skills matrix,

suggest any amendments and consider where gaps exist the best way of securing the

necessary skills or expertise.

3. The minutes recorded that the:

‘...the Committee considered t hat the starting point should be to identify what skills are desirable for Standards Committee members. It was generally agreed that soft skills such as diplomacy are important, and that technical skills are less important as technical experts can be engaged as consultants. It was also agreed that representation of a broad coverage of areas of practice and types of practice would be useful, for example, covering small and large animal and general referral and corporate practice, and that thought should be given to succession planning.’

4. This paper reflects the Committees position and seeks further guidance as to what skills and

experience are deemed to be essential, desirable or not required for the future.

Proposed Approach

5. The previous paper discussed the wider rationale for the need to review to modernise the

appointment process for Committees. The Committee supported the move towards

expanding the pool of potential Committee members and co-opting expertise as required. A

copy of the Council paper considered by the Committee at its September meeting is attached

at annex A.

Professional Diversity

6. It was the view that while the Committee should include a broad cross section of expertise

and skills this should not be at the expense of the Committee representing, to the greatest

extent possible, all areas of practice. Table one proposes a list of practice areas and the

Committee is asked to assess them as essential, desirable or not required. The Committee

are invited provide a view as to whether the areas identified in table 1 represent the right

areas of practice and if not suggest alternative areas.



Page 4 / 4

RCVS Knowledge and Relevant Subject Matter

7. While it was accepted as desirable to have those with specific expertise, experience or

knowledge on the Committee it was agreed that if specific expertise were to be required the

Committee should co-opt members of the Council and College. Table 2 identifies a number

of areas of knowledge and experience in areas deemed relevant to the work of the

Committee. The Committee are asked to consider the identified areas and assess them

accordingly.

Soft Skills

8. The Committee previously indicated its support for a the move to greater assessment of

evidence of transferable ‘soft skills’ as a part of the selection process. A number of skills

areas have been identified as desirable for committees and these have been included in table

3 bellow. This table also includes the Nolan Principles and the RCVS Principles of operation

adopted in 2011. A commitment to the RCVS Principles is by default required by all members

of Committees. The Committee are asked to consider the identified skills and assess them

accordingly.

Decision required

9. To assess the ‘skill set ‘necessary for the Committee and (1) to consider the tables annexed

and decide and if any areas require amendment or addition; and (2) to identify and classify

skills accordingly.

SC Jan 17 AI 3(c) Annex A

SC Jan 17 AI 03(c) Annex A Classification: Unclassified Page 1 / 4


Date 28 September 2016

Title Committee profiles and appointment process


Summary The President is keen to move towards a skills matrix approach

to guide the appointment of committee members. This paper

makes proposals for such an approach, which was discussed

by Operational Board at its meeting on 15 September. The

Board broadly supported the overall approach, although it was

keen to ensure that committees retain sufficient breadth of

experience and made the point that there will always be a need

to understand the background of any potential members. The

matrix should be seen as a guide, not a ‘straightjacket’.

Standards Committee is asked to consider the proposals, the

skills matrix and any gaps in membership and provide comment

in order to inform a final version of the proposal to be agreed by

Council in November (Education Committee will also be asked

to consider this paper).

Decisions required Standards Committee is invited to:

consider and comment on the proposals;

comment on the proposed skills matrix and suggest any

amendments;

consider where gaps exist and the best way of filling these,

e.g. by appointment of new members or by co-opting

relevant expertise, taking into account the need for some

continuity of membership, in order to ensure that sufficient

‘corporate memory’ is retained.

Attachments Annex A: Draft Skills Matrix

Author Chris Warman Head of Education 020 7202 0732 [email protected]




Future skills profile of RCVS Committees Introduction

1. It has long been usual practice for most RCVS committees to be predominantly comprised of

Council members, although some sub-committees do have a wider membership, with

appointments being made on the basis of particular skills and knowledge.

2. With future changes to the governance structure of the RCVS, moving towards a smaller Council,

and also the need to ensure that committee members have the skills and knowledge that the RCVS

needs to deliver on its strategy, both now and in the future, there is a need to consider the skills

mix that is required by each committee and the way in which committee members are appointed.

3. The President is keen to move towards a skills matrix approach to guide the appointment of

committee members. This paper makes proposals which were considered by Operational Board at

its meeting on 15 September and now need to be discussed by both Standards and Education

Committees, with a view to producing a final version of the proposal to be agreed by Council in

November.

Skills required by each committee

4. The attached annex provides a first draft of a skills matrix as a starting point for discussion for

Standards Committee and Education Committee. Whilst there is likely to be some commonality of

requirement across both committees, it is also likely that there will be differences in emphasis and

priority and it is important that each committee has the right mix of skills to fulfil their specific remits.

5. Each individual committee is invited to discuss the knowledge and skills mix that it needs and then

identify any gaps that it feels it has. This should not be seen as a ‘one-off’ exercise: the skills matrix

will need to be checked at least annually to ensure that the right expertise is available for the work

being undertaken.

Appointing committee members

6. Once a skills matrix has been agreed and each committee has set its priorities within this,

appropriate members will need to be appointed to fill any gaps. As mentioned above, traditionally,

committees have been drawn largely from the membership of Council. Whilst it makes sense that

Council members with appropriate skills should continue to Chair and/or serve on RCVS

committees, the recent thinking that not every Council member needs to do so seems sound and

should continue. This will allow an appropriate balance between the objectivity of Council as a final

arbiter and decision-maker on many issues and coherence in thinking throughout the committee

structure as a whole.

7. It is also suggested that the annual round of Presidential appointments to committees is not best

practice in governance terms and will become increasingly difficult to sustain as Council reduces its

numbers over the next few years.

8. In order to ensure that the College has access to the expertise it needs to meet the challenges of

the future, there is a real need to widen the pool of potential committee members and begin to

bring in ‘new blood’: as mentioned above, some sub-committees have made appointments based

on agreed skills gaps and have consequently brought in members with wider experience and

different perspectives, which has greatly enhanced the quality of debate and decision-making.



9. It is suggested that:

where skills/knowledge gaps exist, committee vacancies should be advertised more widely

and appointments made on the basis of application rather than nomination

consideration be given to including non-veterinary professionals as committee members,

provided that they have the right skill-set

consideration be given to greater use of co-opted, non-voting members with particular

expertise for limited time periods, which would allow access to appropriate knowledge without

the need to increase committee size or lose continuity of committee membership.

Next steps

10. This paper has been discussed by Operational Board, which broadly supported the overall

approach, although it was keen to ensure that committees retain sufficient breadth of experience

and made the point that there will always be a need to understand the background of any potential

members. It is important that the matrix is seen as a guide and not a ‘straightjacket’.

11. Standards Committee is invited to:

consider and comment on the proposals;

comment on the proposed skills matrix and suggest any amendments;

consider where gaps exist and the best way of filling these, e.g. by appointment of new

members or by co-opting relevant expertise, taking into account the need for some continuity

of membership, in order to ensure that sufficient ‘corporate memory’ is retained.



NB This page is intentionally blank

SC Jan 17 AI 03(c) Annex B

SC Jan 17 AI 03(c) Annex B Classification: Unclassified Page 1 / 4

Annex B – Draft Skills Matrix

Table 1

Professional Diversity Essential Desirable Not Required

Small animal, farm or equine

First opinion practice

Referral/ surgical practice

Newly qualified

Veterinary Nurse

Research or academia experience

Significant experience of business and leadership in veterinary profession

Regional experience (England, Scotland, Wales and Northern Ireland)

Advanced practitioner

Exotic Animal/ Wildlife Medicine

Table 2

RCVS Knowledge and Relevant Subject Matter Essential Desirable Not Required

Regulatory experience or demonstrable knowledge of regulating professionals

Knowledge/ experience of Sub-Committee areas including: certification, riding establishments, ethics review and recognised veterinary practice

Able to demonstrate a sound understanding of the role of the College specifically in setting standards and the maintenance of guidance

Familiarity with and commitment to the RCVS Code and Guidance

Understanding of and stated commitment to the upholding of the Standards Committee terms of reference

Recognises the wider stakeholder groups involved in the work of the Standards Committee including the general public

Able to demonstrate that they are aware of issues impacting on the veterinary profession including proposed and existing legislation and practice matters

Willing to act as an ambassador for the Committee and profession

Experience at board level

Awareness of and commitment to the Colleges stated core principles and values



Table 3

Desirable Soft Skills/ Abilities – Standards Essential Desirable Not Required

Team working

able to work effectively with anyone with different skill sets, personalities, work styles, or motivation level to achieve a better team result

Communication skills

the ability to communicate effectively in all formats

Effective listening skills

able and willing to listen and consider all issues and views in order to facilitate a positive dialogue in any media format

Interpersonal skills

demonstrable ability to engage and work with people diplomatically and positively, including those with strong views to achieve a required outcome

Critical/ strategic thinking skills

able to the bigger picture and potential long term impact of decisions

Analytical skills

able to absorb and assess large amounts of material in various formats to enable them to make a positive contribution to a discussion

Independence

independence of thought and action. Able to make positive contribution to the Committee and College irrespective of personal or professional interests

Awareness

recognises diversity of thought and belief and able to act as an advocate for the interests of all members of the profession and public

Judgement

understanding of the importance of making reasoned structured decisions

Customer Service

experience of dealing with the public and/ or an understanding of the client/ professional relationship

RCVS Principles

awareness of and commitment to the principles upon which the RCVS works:



1. Fairness – to regulate the veterinary profession fairly and impartially managing the link

between the profession and the public while maintaining the trust of both. The RCVS is acts without fear or favour

2. Openness – the activities of the RCVS are open to the public and to public scrutiny

3. Understanding – the RCVS demonstrates a clear understanding of its scope of operation and is committed to enhancing its understanding of the needs of all stakeholders

4. Forward thinking – looking to the future to ensure that the veterinary profession, and the College itself, remains fit for purpose, and that veterinary standards move with the times

5. Accountable – the RCVS is accountable for its actions and decisions

6. Consistency – to ensure that the RCVS is maintains and applies the standards of the profession consistently at all times.

Nolan Principles

aware of and agrees to abide by all of the 7 Nolan Principles of Public Life:

1. Selflessness - Holders of public office should act solely in terms of the public interest.

2. Integrity - Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships

3. Objectivity - Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.

4. Accountability - Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.



5. Openness - Holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.

6. Honesty - Holders of public office should be truthful.

7. Leadership - Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs.

SC Jan 17 AI 04(a)




Title Disciplinary Committee Report


Summary Update of Disciplinary Committee since the last meeting of the

Standards Committee on 28 September 2016


Attachments None

Author Chloe Newbold

Clerk to the Disciplinary Committee

020 7202 0729

[email protected]


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Report of Disciplinary Committee hearings since the Standards Committee meeting on 28 September 2016

Background

1. Since the last meeting of the Standard’s Committee on 28 September 2016, the Disciplinary

Committee (‘the Committee’) has met on five occasions; the Veterinary Nurses’ Disciplinary

Committee (‘VN DC’) has met once.

Hearings

Mr Rahul Shah

2. On 19 September, the Committee met for four days to hear allegations against Mr Rahul Shah

and his treatment of a client’s dog, Shadow.

3. The allegations against Mr Shah included that he:

a. failed to provide Shadow with adequate or appropriate care in that he discharged

Shadow when he was not in a fit state to be so discharged;

b. failed to advise that Shadow should receive veterinary attention as a matter of

urgency;

c. failed to ensure that his clients were fully informed as to out of hours care for Shadow.

4. The full details of the Charges can be found on our website: http://www.rcvs.org.uk/document-

library/shah-rahul-chandulal-september-2016-charges/

5. On decision of the facts of the case, the Committee found all heads of charges proved.

Further in its findings on disgraceful conduct the Committee stated ‘”It...accepts that Mr. Shah was acting in good faith at all times and doing what he thought was best but that is no answer to a charge of serious professional misconduct when his best falls far short of that which is expected...and it therefore finds he conducted himself disgracefully in a professional respect.”

6. By way of sanction, the Committee reprimanded Mr Shah for his actions and urged him in the

strongest possible terms to ensure that his future conduct by way of training and support

systems within his practice are such as to avoid any possibility of a future incident such as this

occurring in order to ensure animal welfare and public confidence in the veterinary profession.

Mr Nigel Charles Hough

7. The Committee reconvened on 30 September 2016 to hear the remainder of the Inquiry

hearing into Mr Hough and his treatment of his client’s dog, Mya. This hearing had been

adjourned on 17 May 2016 due to lack of time.

http://www.rcvs.org.uk/document-library/shah-rahul-chandulal-september-2016-charges/

http://www.rcvs.org.uk/document-library/shah-rahul-chandulal-september-2016-charges/

SC Sept 16 AI 04(a)


8. The allegations against Mr Hough include failing to communicate effectively with the owners,

speaking disparagingly of his colleagues at another veterinary practice and deciding on

treatment for Mya that was not clinically justified. The full details of the charges are available

on the RCVS website at: http://www.rcvs.org.uk/document-library/hough-nigel-charles-may-

2016-charges/

9. At the initial hearing in May, the Committee had found Charges A3 (ii), A4 (iii), B (iii), B (iv)

proved. Namely that Mr Hough had failed to provide and ensure adequate overnight care for

Mya; it was inappropriate and unreasonable to plan for the wound management to be

undertaken by Mya’s owners following the second procedure; and he had failed to provide

information about post-operative care and out of hours cover. Charge C (in its entirety), in

relation to speaking disparagingly about his colleagues, had been admitted and found proved.

10. Of the proved charges, the Committee found that Mr Hough had been guilty of disgraceful

conduct in a professional respect in relation to Charges A3 (ii), B1 (iii) and C. Their full

decision on disgraceful conduct can be found here: http://www.rcvs.org.uk/document-

library/hough-nigel-charles-september-2016-findings-on-disgraceful/

11. In summing up their decision on sanction, the Committee noted that they were pleased with

the evidence adduced in mitigation which included an impressive list of testimonials, Mr

Hough’s implementation of new protocols at his practice; and both character and professional

references supporting his clinical expertise and surgical skills; and decided a reprimand was

the proportionate sanction in this case.

Roger Sidney Meacock

12. Between 17 and 18 October, the Committee met to hear an Inquiry into Mr Roger Meacock.

The allegations raised against Mr Meacock related to his website and statements that were

deemed to be misleading; and therefore likely to bring the profession into disrepute.

13. The full charges are available on the RCVS website: http://www.rcvs.org.uk/document-

library/meacock-roger-sidney-october-2016-charges/

14. On the second day, the College applied for an adjournment of proceedings indefinitely on the

basis that Mr Meacock had voluntarily entered into undertakings with the College to amend

the contents of his website in such a manner as to make it compliant with the matters to which

the College took exception.

15. In granting the application, the Committee stated: "The Committee...grants the application and adjourns this hearing generally. The Committee is conscious however that even in the event of a finding of fact adverse to Mr. Meacock the longest period of time for which judgement could be postponed in the event of undertakings being imposed is two years. The Committee would therefore urge the College to consider this period as the longest possible before discontinuing these proceedings in the event of Mr. Meacock’s continued compliance...’.

http://www.rcvs.org.uk/document-library/hough-nigel-charles-may-2016-charges/

http://www.rcvs.org.uk/document-library/hough-nigel-charles-may-2016-charges/

http://www.rcvs.org.uk/document-library/hough-nigel-charles-september-2016-findings-on-disgraceful/

http://www.rcvs.org.uk/document-library/hough-nigel-charles-september-2016-findings-on-disgraceful/

http://www.rcvs.org.uk/document-library/meacock-roger-sidney-october-2016-charges/

http://www.rcvs.org.uk/document-library/meacock-roger-sidney-october-2016-charges/

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16. The Committee’s full decision on the application for adjournment can be found at:

http://www.rcvs.org.uk/document-library/meacock-roger-sidney-october-2016-decision-of-

disciplinary/

Ian Beveridge

17. On 01 November 2016, the Committee met to hear an application for restoration to the RCVS

Register from Mr Ian Beveridge.

18. On 24 May 2013, Mr Beveridge had faced a number of allegations from the College including

failing to treat his client’s with courtesy and respect; failure to treat a client’s dog as an

emergency patient; and failure to undertake any or any adequate investigations into patients

under his care. The Committee found Mr Beveridge guilty of disgraceful conduct in a

professional respect and directed the Registrar to remove his name from the Register stating

that ‘his behaviour subsequently demonstrates a complete failure of insight on his part into his misconduct’ and were of the view that he posed a risk to animals committed to his care.

19. On 15 June 2015, the Applicant made an application for restoration to the Register. The

application was adjourned as evidence had been served few days prior to the hearing

concerning allegations that the applicant had ordered prescription only drugs when

unauthorised to do so and the Committee decided that it was in the applicant’s interests and

the interests of justice generally for time to be given for the applicant to respond to those

allegations.

20. On 20 November 2015, the Committee met to hear the adjourned application for restoration to

the Register. The Committee took into account the factors required when governing

restoration applications and decided, based on their concerns over the applicant’s efforts in

respect of continuing professional development and the unauthorised ordering of drugs, that

Mr Beveridge’s application for restoration should be dismissed.

21. At the hearing, Mr Beveridge gave oral evidence and provided the Committee with a

comprehensive bundle of information that referred to each of the factors outlined in the

Disciplinary Committee Procedure Guidance (the ‘Guidance’) at paragraph 70. In their

decision, the Committee stated that they accepted ‘the Applicant was sincere in the sentiments that he expressed in his written statement, and showed insight into his previous conduct and behaviour’.

22. The Committee decided to restore Mr Beveridge to the Register stating:

‘It is the judgement of the Committee that the conduct which resulted in the Applicant’s name being removed from the Register is unlikely to be repeated. The Applicant has satisfied the Committee that he is fit to be restored to the Register of Veterinary Surgeons.’

http://www.rcvs.org.uk/document-library/meacock-roger-sidney-october-2016-decision-of-disciplinary/

http://www.rcvs.org.uk/document-library/meacock-roger-sidney-october-2016-decision-of-disciplinary/

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23. With reference to the concerns of the Committee at the previous application for restoration,

the Committee stated that there is no evidence of any adverse conduct on the part of the

Applicant in relation to the illegal purchase of veterinary medicines; and, with regards to

continuing professional development (‘CPD’) the Applicant has produced evidence of CPD

activity and now realises its importance. They continued to add that ‘Whilst the Committee accepts that the Applicant has made considerable progress in this regard, it emphasises that this is but the start of a process that must continue until the Applicant retires from professional work’.

24. The full decision can be found on the website here: http://www.rcvs.org.uk/document-

library/beveridge-ian-november-2016-decision-on-restoration-application/

Dr Amir Kashiv

25. On 05 December 2016, the Committee met for six days to hear an Inquiry into Dr Kashiv and

his treatment of his client’s dog, Tanzy.

26. The Committee found proved Charges 1 (b), 2 (a), 2 (c) and 2 (d); 3 and 4. These include a

failure to communicate certain options with the client; a failure to discuss alternative treatment

options with his client; discharging Tanzy when she was not in a fit state to be so; and failing

to keep sufficiently clear and/or detailed and/or accurate clinical records.

27. You can find the full charges on the RCVS website: http://www.rcvs.org.uk/document-

library/kashiv-amir-december-2016-amended-charges/

28. It was found that Dr Kashiv was guilty of disgraceful conduct in a professional respect in

relation to charges 1, 2 and 3. However, they did not take the view that Charge 4 amounted to

disgraceful conduct stating:

‘The individual and cumulative effect of the admissions and findings, as recognised on behalf of Mr Kashiv, amount to disgraceful conduct in a professional respect. The Committee has concluded that Mr Kashiv’s inadequate recordkeeping, as he acknowledged, fell short of the standards to be expected, but not so far short so as to amount to disgraceful conduct.’

29. On consideration of sanction the Committee stated: ‘Mr Kashiv is a dedicated veterinary surgeon, as evidenced by the large number of testimonials, and that he provides a valuable service to the community, particularly with rescue animals. The Committee has been shown three protocols and procedures that have been initiated since this incident, which demonstrate a degree of insight. Nevertheless, the Committee considers that there were a number of fundamental failings in Mr Kashiv’s clinical competence which require to be addressed’

http://www.rcvs.org.uk/document-library/beveridge-ian-november-2016-decision-on-restoration-application/

http://www.rcvs.org.uk/document-library/beveridge-ian-november-2016-decision-on-restoration-application/

http://www.rcvs.org.uk/document-library/kashiv-amir-december-2016-amended-charges/

http://www.rcvs.org.uk/document-library/kashiv-amir-december-2016-amended-charges/

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Samantha Giles RVN

30. The VN DC met on 15 and 16 December to consider an allegation against Miss Samantha

Giles RVN. The allegation was that between 1 August 2012 and 21 June 2016, Miss Giles

failed to respond adequately or at all to reasonable requests from the Royal College of

Veterinary Surgeons to provide information with regards to CPD.

31. From the outset, Miss Giles accepted the facts of the case and the Committee concluded that

she was guilty of disgraceful conduct in a professional respect stating:

‘Your Regulatory body is dependent on all veterinary nurses to respond promptly and truthfully to all reasonable requests made of them for evidence that they have so complied with their continuous training obligations. Without such co-operation the policing of the system cannot work. That is what we consider to be the gravamen of your failures.’ ‘We consider that you have no legitimate excuse for not complying with those reasonable requests which were made of you by the College or at least some of them…Accordingly, given the importance of compliance with the Code requirements for CPD training and prompt and truthful responses to the reasonable requests for confirmation of your compliance therewith, we have no hesitation in arriving at the conclusion that your admitted conduct amounts to disgraceful conduct in a professional respect.’

32. On deciding sanction, the Committee stated:

‘It is a matter of great importance that your regulatory body should be able to ascertain whether or not you have complied with your CPD obligations. It is a matter of great importance precisely because members of the public need to be able to repose confidence in the fact that all veterinary nurses have met these training obligations and that their animals can be left safely in the custody and care of those who hold themselves out as properly qualified, experienced and up-to-date practitioners.’ ‘In the result that mitigation has persuaded us that we would be acting consistently with our public duty by imposing a period of suspension of 2 months. ‘In imposing that sanction we have noted the evidence as to your professional competence and your other professional qualities. The Committee trusts, therefore, that once you have served your period of suspension you will return to the profession which you say you love.’

33. The full findings can be found on the RCVS website: http://www.rcvs.org.uk/document-

library/giles-samantha-december-2016-findings-on-sanction/

Upcoming Hearings

34. There are currently three Inquiry hearings listed before the Committee on the following dates:

03-11 January 2017

http://www.rcvs.org.uk/document-library/giles-samantha-december-2016-findings-on-sanction/

http://www.rcvs.org.uk/document-library/giles-samantha-december-2016-findings-on-sanction/

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23-27 January 2017

06-31 March 2017

35. In addition to the cases already listed, one further case has been referred to the Committee for

Inquiry. The Clerk will list this case as soon as possible

36. There is currently one Inquiry hearing listed before the Veterinary Nurse Disciplinary

Committee on the following dates:

06-15 February 2017

37. At present, there are no other cases that have been referred to the VN DC.

Appeals

38. No appeals have been heard since the last Standards Committee meeting.

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Title Riding Establishments Sub-Committee Report


Summary Standards Committee is asked to note this brief update on the

work of the Riding Establishments Sub-Committee.


Attachments None

Author Natalie Heppenstall

Standards & Advisory Officer

020 7202 0757

[email protected]


SC Jan 17 AI 04(b)



SC Jan 17 AI 04(b)


Riding Establishments Sub-Committee Report

Annual meeting

Morning session

1. The annual general meeting of the Riding Establishments Sub-Committee was held at

Belgravia House on 24 November 2016. As has been the norm for the last few years, the

morning session is a closed AGM for the Sub-Committee and the afternoon session is a

discussion to which key stakeholders/interested parties are invited.

2. In the morning session, the Sub-Committee made the decision to finalise and publish the

revised guidance on the application of the Riding Establishments Acts and a revised

inspectors’ form (following a number of minor typographical amendments). The amendments

have been made and the guidance will be published in late January and advertised in the next

edition of the Sub-Committee’s newsletter for inspectors, REIN.

3. Feedback was provided to the Sub-Committee from the annual inspectors’ courses, which

was overwhelmingly positive. The Advice Team had had heavy involvement in modernising

and refreshing the content of the inspectors’ courses, and designing training materials in

conjunction with the Sub-Committee so that the courses had more of an interactive and

practical focus. The Sub-Committee took the view that a similar structure should be adopted

for the 2017 courses, which are to be held in June and July.

4. The Sub-Committee also conducted an audit of inspectors’ reports and found the majority

sampled to be of high quality.

5. Tenure of Committee members was also discussed as the majority of the Sub-Committee had

been in post for a long time before the administration of the Riding Establishments

Inspectorate had been taken back in house by the RCVS. It was agreed that once suitable

replacements could be found for the longest-serving members, they would be replaced, but

only one at a time to preserve an appropriate level of knowledge and experience on the Sub-

Committee.

Afternoon session 4. Representatives from the British Horse Society, the Donkey Sanctuary, APSPH (the

Association of Polo Schools and Pony Hirers) and KBIS Equine Insurance were present at the

afternoon session.

5. A number of issues relating to inspection of riding establishments were discussed, including

problems arising with miscommunication and lack of support for inspectors from local

authorities, jurisdictional problems in relation to multi-site trekking centres and the current

difficulties facing the insurance of riding schools.

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Update on DEFRA licensing review

6. Charlotte Carne of DEFRA had attended the 2015 RESC Sub-Committee meeting to

provide information on the proposed DEFRA review of animal establishments licences and

advised the Sub-Committee that they were looking to bring all four animal establishment

licensing schemes under one licence, with separate standards for each.

7. Ms Carne was unable to attend the 2016 meeting but advised by email that little progress had

been made since the 2015 meeting and that DEFRA’s plans remained the same and they

were in the process of analysing responses to a consultation they had put forward. It was

agreed that the Sub-Committee would be provided with an update once the consultation

analysis was complete.

Advice queries 8. The Advice Team have been dealing with multiple queries in relation to riding establishments

over the course of 2016 from inspectors, establishment owners and members of the public.

Topics have included:

a. Whether there are recommended fees for veterinary inspections;

b. Requirements around provisional licences;

c. Biennial inspections of riding establishments;

d. Trail riding issues, including bio-security measures;

e. Whether licences are required for centres offering horsemanship and horse agility courses;

f. Retiring veterinary surgeons (who continuing to do limited work) conducting inspections;

g. Whether the Acts apply to driving horses;

h. Dealing with horses being used on a trial basis in an establishments;

i. Dealing with new horses introduced to the establishment between inspections

j. Occasional hire of polo ponies;

k. Interim measures to assist a veterinary inspector with short-term health issues affecting ability

to conduct the clinical parts of the inspection;

l. Dealing with horses with impaired or limited vision; and

m. Whether licenses are required for a community farm, with limited riding taking place.

standards committee agenda for the meeting to be held on 25 … · 2017-02-27 · sc jan 17 ai 00...

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