02 March 2015

Homeopathy Self-certification

Questions about tertiary-sector homeopathy education provider serlf-certification and TEQSA review, from the 25 February 2015 Education & Employment Legislation Estimates Committee hearing
Senator KIM CARR: Could I turn to the question of homeopathy-one of my favourite topics, as you know, Professor. I would like to deal with a specific case. I understand that Dr Ken Harvey has sought by FOI matters relating to the reaccreditation report for homeopathy offered by ParaPharm in Western Australia. Do you have any detail of that matter?
Prof. Saunders: I have some detail of that matter, yes.
KIM CARR: As I understand it, there are two degree courses offered in homeopathy, one in Western Australia by ParaPharm, and there is one on the east coast as well, is there?
Prof. Saunders: By the Australian College of Natural Medicine, yes.
Senator KIM CARR: Is it the case that the NHMRC has released a finding of the committee reviewing homeopathy which has found that there is no good evidence to actually support the discipline?
Prof. Saunders: That is correct.
Senator KIM CARR: Do take any note of that?
Prof. Saunders: Absolutely, I take note of that. It was conducted by somebody I have a great deal of respect for.
Senator KIM CARR: Who is that? Can you refresh my memory.
Prof. Saunders: Paul Glasziou, from Bond University.
Senator KIM CARR: There was no trick question there.
Prof. Saunders: It was a very thorough examination of the evidence at hand.
Senator KIM CARR: There was also a committee chaired by the Chief Medical Officer. Is that the case?
Prof. Saunders: I think that relates to something else. I think it relates to the funding of these.
Senator KIM CARR: The Review of the Australian Government Rebate on Private Health Insurance for Natural Therapies.
Prof. Saunders: Yes, that is correct.
Senator KIM CARR: Not an unrelated topic, I would have thought. I understand that the report of the committee chairman has been with the government for some while. Are you aware of that.
Prof. Saunders: No, I am not aware of the delays or whether there have been delays.
Senator KIM CARR: I understand the two homeopathy programs that I have referred to were in fact accredited by state authorities originally. Is that the case?
Prof. Saunders: Originally; that is correct, yes.
Senator KIM CARR: They are now up for reaccreditation with your agency. Is that correct?
Prof. Saunders: Yes.
Senator KIM CARR: In fact, the Western Australian course was up for reaccreditation at the end of last year-
Prof. Saunders: Yes.
Senator KIM CARR: and I understand the Sydney course-the Endeavour college course-comes up for reaccreditation in a couple of months time.
Prof. Saunders: Yes.
Senator KIM CARR: What is the process you will be using to reaccredit this particular program?
Prof. Saunders: It is the process that we would use for all course accreditations. It is a mixture of our own assessment as well as sending the courses to external experts.
Senator KIM CARR: How many external experts?
Prof. Saunders: It would depend, but in general terms we would send a course to two experts. If there is a suite of courses we might actually send it to more experts than that. Sometimes we do not use experts at all.
Senator KIM CARR: If you do not use experts at all, who does the assessment?
Prof. Saunders: We sometimes have internal expertise, the background of people within TEQSA; sometimes we are assessing the fifth course in a single field of, say, a business field and we have confidence in what the external experts have said previously.
Senator KIM CARR: Am I correct in saying that while a course is under the process of reaccreditation it is entitled to continue?
Prof. Saunders: That is correct.
Senator KIM CARR: Have you made a decision in regard to the Western Australian course?
Prof. Saunders: No, we haven't. We are in the process of making that decision, and it would not really be appropriate for me to say much more.
Senator KIM CARR: No, but you have not made it.
Prof. Saunders: We have not made a decision on that.
Senator KIM CARR: And the provider can continue while that process is underway.
Prof. Saunders: That is correct.
Senator KIM CARR: The second course-I have a date here of 2 April 2015 for reaccreditation - have you commenced the process for that?
Prof. Saunders: I would have to take that question on notice. The submission usually has to be made six months prior to the expiry of the date, so yes we would have at least received that.
Senator KIM CARR: So it is a reasonable expectation that that has commenced as well. Are there any courses in alternative therapies that you are examining at the moment?
Prof. Saunders: At the moment, we have courses from Study Group Australia. To my knowledge, that is the only other application coming from providers we have not already mentioned.
Senator KIM CARR: How many students are involved in Study Group?
Prof. Saunders: I would have to take that question on notice.
Senator KIM CARR: That is based where-in Melbourne?
Prof. Saunders: I would have to take that question on notice. I think Study Group has multiple campuses, but I will have to take that on notice.
Mr Griew: You may be interested that there are also nine complementary medicine degrees at universities.
Senator KIM CARR: Yes, there are some issues there too, I am sure. When will you get to look at those?
Prof. Saunders: If it is relevant, we will look at those at the time of reregistration.
Senator KIM CARR: Dr Ken Harvey has sought advice from you in regard to the re-accreditation report. Is that correct?
Prof. Saunders: The re-accreditation of?
Senator KIM CARR: ParaPharm in Western Australia.
Prof. Saunders: That is correct.
Senator KIM CARR: Did the document provided back to Dr Harvey under FOI include the name of the external reviewer - who, I am told, is a naturopath - used by TEQSA?
Prof. Saunders: The response to Dr Harvey had to be considered in the context that this was an application that was still under assessment. There had to be processes that were fair to the provider. There were also commercial-in-confidence considerations in that what we were considering was the intellectual property of the provider, and there were a range of other matters that had to be taken into account. So the material released to Dr Harvey was very limited.
Senator KIM CARR: How long would you sit on a report of this type?
Prof. Saunders: We do not sit on reports.
Senator KIM CARR: When was the report finalised?
Prof. Saunders: We have not finalised the report for this particular provider. As I said, this is a process that is ongoing. It would not be appropriate for me to talk about any particular stages.
Senator KIM CARR: But you did provide Dr Harvey with a document concerning the process that TEQSA was using, including the name of the external reviewer?
Prof. Saunders: Yes.
Senator KIM CARR: You have indicated that you are mindful of the NHMRC review?
Prof. Saunders: Yes.
Senator KIM CARR: Have you adopted a policy of prioritising the commercial interests of private providers over the public's right to know what the bases of accreditation decisions are?
Prof. Saunders: Absolutely not.
Senator KIM CARR: Why is that?
Prof. Saunders: We believe there needs to be a balance between considering the interests of both the provider and the public. All our FOI decisions are based on those considerations.
Senator KIM CARR: That is in regard to the FOI decision. I am asking you in regard to your accreditation process.
Prof. Saunders: We do not take commercial considerations into account at all in assessing a course or a provider. As I said, the assessment is done against the standards. The standards refer to matters to do with financial viability but not to the commercial interests of the provider.
KIM CARR: In regard to the re-accreditation of ParaPharm, why did only a single person-not a panel-undertake the review of the course?
Prof. Saunders: That relates to a technical issue with regard to the FOI request.
Senator KIM CARR: How does that work?
Prof. Saunders: We were assessing a number of courses. Dr Harvey asked for information about one course. So we gave Dr Harvey the relevant information about one particular course, but we had other people involved in the assessment of the other complementary-
Senator KIM CARR: The other things at the institution-I see. Can you indicate to me why it was that your expert witness-who I would prefer not to name at this point, but you know the person I am referring to. Is that right, Professor? You are aware of the details of that expert-
Prof. Saunders: I would have to take that on notice. I have seen the report; I just cannot carry the name of the person in my head at the moment.
Senator KIM CARR: All right. Can you indicate what was the basis of the appointment of that particular individual-who as I say, is a naturopath-to examine the operations of this particular college.
Prof. Saunders: That person would be on the TEQSA register or we would have had advice from people who were on the TEQSA register of experts as to who we might approach in this particular circumstance. Finding assessors who are experts in the field of complementary medicine is not easy. We have a range of people that we can go to. We have taken steps in the last six months to try and expand the range of people that we can choose to do those assessments, and I think I will leave it at that. If I may make a comment about the whole issue here-
Senator KIM CARR: I look forward to your comments.
Prof. Saunders: I think it is important that we separate out assessment against a set of educational standards against the recognition, registration and regulation of clinical practitioners. Unfortunately, or fortunately, TEQSA has no role to play in the latter. What we have to do is take a course and look at it from the point of view of the standards, and nowhere in the standards does it talk about the need for material or the course to be scientifically based. Nowhere does it have any content-specific standards. What it says is that the body of knowledge upon which this is drawn has to be coherent and it has to actually have scholarship associated with it, and there are other standards in there about intellectual inquiry of students and promoting those sorts of critical appraisal skills and the like. So, when we apply the standards to something like a course in homeopathy, we are not asking the question as to whether the science or the clinical outcomes of homeopathy are appropriate. What we are asking is: does this course position homeopathy in the field such that students who are studying this understand that there is a controversy and that there is strong evidence that it is in fact not an effective clinical regime? We are expecting students to understand the criticisms of homeopathy, not just simply to study in a modular sort of way the tenets of homeopathy. We would use our judgement applying those standards to the accreditation of courses like this.
Senator KIM CARR: Yes. Thank you for that. Do I take it from that there is a degree of discomfort about the way in which this now operates?
Prof. Saunders: No, I do not think there is. If there is discomfort, it would be the same discomfort about accrediting bachelors of theology. We use educational standards about the experience of the student, the coherence of the course, the build, the framework, the learning outcomes that are being achieved and whether it fits with the Australian Qualifications Framework. These are educational standards.
Senator KIM CARR: In terms of publishing the accreditation report for homeopathy, what are you doing about that? When will you be publishing this report?
Prof. Saunders: What we do is that, once we have done our assessment, we then publish the decision of the assessment. We would then be declaring whether or not the assessment has led to a reaccreditation of the course; if it is reaccredited, what are the conditions that are applied on that course; and whether the course has been accredited for a maximum period of 7 years or a shorter period of time. And there is a public notice that we always publish as a part of the national register that actually explains why we have taken those decisions.
Senator KIM CARR: Yes. Now the difficulty here is-and this particular issue has been experienced with regard to ESOS registration and it has been experienced with regard to VET registration-in this particular case, with students that are being enrolled in 2015 - given that I take it you have had this process underway for at least six months?
Prof. Saunders: Yes.
Senator KIM CARR: I take it that you must have completed your work, your-
Prof. Saunders: We are in the final stages of discussion with the provider about provisional findings, yes.
KIM CARR: So what do they do about enrolments for 2015?
Prof. Saunders: They are free to make enrolments until a decision is taken by TEQSA, and if the decision-
CHAIR: Senator Carr-
Senator KIM CARR: I will just-
CHAIR: Senator Ruston has one quick question.
Senator KIM CARR: Yes, sure. My concern, though, is that I take it you have actually decided to allow them to continue?
Prof. Saunders: No, we have not made that decision at all.
Senator KIM CARR: So what do you do with the students, then, if you choose to close them down?
Prof. Saunders: Then they have to have a planned and supervised teach-out of that. Now that would require them to transfer their students to another provider-
Senator KIM CARR: There is only one other provider.
Prof. Saunders: Yes.
CHAIR: All right, can we continue this after dinner if you have more questions for TEQSA, Senator Carr? Senator Ruston, you have a quick question?
Senator RUSTON: Just one.
CHAIR: But I will just double check. Sorry, Minister? Hello, Minister? We just have a question from Senator Ruston.
Senator Birmingham: Sorry, Chair. I was just confirming one point there with Professor Saunders about the course that Senator Carr was asking about the provider for. Being a bachelor course, it is a multi-year course. So the phase-out-type provisions that Professor Saunders was just talking about would have had to apply regardless of the timing of when a decision is made, where a decision has been made in that type of area.
Senator RUSTON: Professor Saunders, I am just wondering in the discussions about the accreditation whether there were any alternative medicine courses already being offered at public universities?
Prof. Saunders: Yes, certainly. Alternative medicine courses are offered by a number of public universities: Central Queensland University, Charles Sturt University, Macquarie University, Murdoch University, RMIT, Southern Cross University, University of New England, University of Technology Sydney and the University of Western Sydney. Chiropractic is the most common course that is being taught in the public universities, but as well as chiropractic they cover naturopathy, traditional Chinese medicine, acupuncture, osteopathy and western herbal medicine, and a couple of those public universities offer a Bachelor of Health Sciences with a generic complimentary medicine stream.
Senator RUSTON: And one assumes that the process of accreditation is exactly the same?
Prof. Saunders: They are self-accrediting institutions, so they would have put these courses through their own proper academic governance processes.