Organizations on NCCAM’s Strategic Plan: IHPC, ACCAHC, AHMA, AANP, IAYT, NCH, AANMC and MTF

Summary: That NCCAM’s 2011-2015 strategic plan is critically important to the future of the integrative practice field is clear from this set of stakeholder responses. Together, these 8 organizations represent over 360,000 licensed practitioners: Integrated Healthcare Policy Consortium, Academic Consortium for Complementary and Alternative Health Care, American Holistic Medical Association, Association of Accredited Naturopathic Medical Colleges, International Association of Yoga Therapists, Massage Therapy Foundation, National Center for Homeopathy and American Association of Naturopathic Physicians. (The two consortia represent 22 separate partner or member organizations.) Notably, their comments are almost entirely supportive of the direction Congress mandated but in which NCCAM poorly invested under its first director. If this input is valued, NCCAM has significant stakeholder backing for complying with Congress’ real pragmatic research mandate.

Organizations on NCCAM’s Strategic Plan: IHPC, ACCAHC, AHMA, AANP, IAYT, NCH, AANMC and MTF

Summary: That NCCAM’s 2011-2015 strategic plan is critically important to the future of the integrative practice field is clear from this set of stakeholder responses. Together, these 8 organizations represent over 360,000 licensed practitioners: Integrated Healthcare Policy Consortium, Academic Consortium for Complementary and Alternative Health Care, American Holistic Medical Association, Association of Accredited Naturopathic Medical Colleges, International Association of Yoga Therapists, Massage Therapy Foundation, National Center for Homeopathy and American Association of Naturopathic Physicians. (The two consortia represent 22 separate partner or member organizations.) Notably, their comments are almost entirely supportive of the direction Congress mandated but in which NCCAM poorly invested under its first director. If this input is valued, NCCAM has significant stakeholder backing for complying with Congress’ real pragmatic research mandate. 

The direction the NIH National Center for Complementary and Alternative Medicine takes with its 2011-2015 strategic plan is the most significant decision point for the integrative practice field since complementary, alternative and integrative medicine arrived on the national scene 15 years ago. The two articles above are evidence of the importance the Integrator gives the topic. This article, with full length submissions from 8 significant organizations – one of which is a consortium of 15 national organizations and another with 7 partner organizations – provides a significant look at NCCAM’s most significant stakeholders. The submissions are from the:

• Integrated Healthcare Policy Consortium
• Academic Consortium for Complementary and Alternative Health Care
• Association of Accredited Naturopathic Medical Colleges
• International Association of Yoga Therapists
• Massage Therapy Foundation
• National Center for Homeopathy
• American Association of Naturopathic Physicians

These responses are offered in full so community leaders can see the depth of their alignment. look for your own points of continuity. I offer some brief comments at the end.

Note: I have sought the submission from a variety of organizations, including the influential Consortium of Academic Health Centers for Integrative Medicine (which was the only organization which merited NCCAM mention in the strategic planning white paper) but the response was not available prior to this publication.

1.  Integrated Healthcare Policy Consortium (IHPC)

Synopsis: Integrated Healthcare Policy Consortium (IHPC) sent
an “Alert” to their list with these key points: Now is the time for “tough love” as
NCCAM should support research that facilitates the integration
of CAM into mainstream healthcare and hasn’t been; promotes more licensed
complementary and alternative medicine practitioners on the NCCAM advisory
council; urges funding for pragmatic, outcomes-based research that gathers “data on
costs and other factors that payers and policymakers use when deciding
what to include in their plans.”

Dear [IHPC Alert recipient]:

NCCAM is listening…make your voice
heard!

Right
now, in the midst of Thanksgiving celebrations, we have an opportunity to
influence the direction of what is arguably the most important federal agency
for the field of integrated health care.

	NCCAM is not just supposed to support rarified reductionist science. NCCAM is supposed to support research that facilitates the integration of CAM into mainstream healthcare.

Most of
you already know what NCCAM is, but let me remind us all. The National Center
for Complementary and Alternative Medicine (NCCAM) at NIH is the ONLY Federal
body whose primary job is exploring not only the effects of complementary and
alternative medicine, but also its integration.  That is right, the
legislation that created NCCAM says explicitly that this agency is charged with
studying, “…the integration of alternative treatment, diagnostic and
prevention systems, modalities, and disciplines with the practice of
conventional medicine…and into health care delivery systems in the United
States.”  NCCAM is not just supposed to support rarified
reductionist science exploring the effect of a single herb out of a complex
formula —  NCCAM is supposed to support research that facilitates the
integration of CAM into mainstream healthcare. 

Take
action now to help them remember that charge!

At IHPC we believe that NCCAM is a vital
part of the movement for integrated, wellness-oriented healthcare. Members of
the IHPC board were instrumental in the creation of NCCAM.

Time for tough love We support NCCAM. And sometimes support takes the form of tough love, and now, while NCCAM is completing Strategic Plan it is important for us to help them fulfill their mission with some forthright advice.

Please join us by sending a letter to
NCCAM’s Director, Dr. Josie Briggs, and tell her that NCCAM needs to
fulfill its mission in two important ways – and we have
supported it ever since.  Sometimes support takes the form of tough love,
and right now, while NCCAM is completing its next 5-year Strategic Plan and is
calling for public comment it is important for us to help them fulfill their
real mission with some forthright advice.

1)  As we have told them before, NCCAM must adhere to the law that
created them and that specified that “… at least half of the members of the
advisory council who are not ex officio members shall be licensed
practitioners of one or more of the major systems with which the Center is
concerned, and at least 3 individuals representing the interests of
individual consumers of complementary and alternative medicine.” The
legislators required that NCCAM be advised not only by researchers, but mostly
by patients and providers of complementary and alternative health care. 

That was a stroke of wisdom when they wrote it, and it still is.

	NCCAM must start funding the pragmatic, outcomes-based research that gathers data on costs and other factors that payers and policymakers use.

2)  NCCAM must start funding the kind of research that will
facilitate the integration of CAM into mainstream health care delivery.
This means pragmatic, outcomes-based research that gathers data on costs and
other factors that payers and policymakers use when deciding what to include in
their plans.

Both of these issues are named in the legislation that created NCCAM 10 years
ago.  Now the legislature and you and I must hold NCCAM to their
mandate. 

Take action now – by the end of
Monday, November 30th – and send a clear message to both Dr. Briggs and to
Senator Harkin, the Chair of the Senate HELP Committee which oversees NCCAM and
its funding.

The action we take today will directly influence the direction NCCAM takes for
the next five years.  Let’s create something now that we can all be
thankful for in November of 2010, 2011, 2012, 2013 and 2014!

And thank you, for working with us on this.

Janet
Kahn, PhD

Executive Director

2.  Academic Consortium for Complementary and Alternative Health Care (ACCAHC)

Synopsis: Academic Consortium for Complementary and Alternative Health Care
(ACCAHC) – Three main points: research on whole practices; research on “costs,
cost-effectiveness, cost-offsets and cost-savings” and, third, investment in capacity in the licensed CAM fields, in “the expansion
of investment in the development of researchers who are graduates of
complementary and alternative medicine programs, particularly those who
have a continued association with the accredited CAM schools.”

Dear
Dr. Briggs and Strategic Planning Team Members:

We
are writing in response to your October 2009 solicitation of stakeholder input
on the next strategic plan for the NIH National Center for Complementary and
Alternative Medicine (NCCAM). Thank you for your preliminary work and for this
opportunity to respond.

The
12 core ACCAHC member organizations (see left column) serve the distinctly
licensed complementary and alternative healthcare disciplines of chiropractic
medicine, acupuncture and Oriental medicine, naturopathic medicine, massage
therapy and direct-entry midwifery. In addition, ACCAHC’s members include 3
organizations from non-licensed Traditional World Medicines fields of yoga and
Ayurvedic medicine that are engaging in self-regulatory efforts. The ACCAHC
disciplines provide the majority of the complementary and alternative medicine
and integrative services for consumers in the United States. Similarly, 187 of
our universities, colleges and programs are accredited through specialized U.S.
Department of Education-recognized accrediting agencies. These institutions are
the educational providers for the vast majority of future integrative practitioners.
We view ourselves as a significant NCCAM stakeholder.

We
have identified the following three areas as the top, shared priorities for
research investment across our licensed professions. We believe that investment
in these three areas will have the most potentially positive impact on US
healthcare.

We need to learn more about the real world outcomes of these disciplines in order to understand the experience of consumers and the value of these practices in healthcare delivery.

1. Research on whole practices– We need to
learn more about the real world outcomes of these disciplines in order to
understand the experience of consumers and the value of these practices in
healthcare delivery. We urge the evaluation of the effectiveness of the actual,
multi-dimensional practices of the members of these disciplines. A subset of
this exploration could include evaluating the preventive outcomes of the
clinical approaches that are a common orientation of integrative healthcare practitioners
in the ACCAHC disciplines. These whole practices frequently
include many of the lifestyle-related interventions that are recommended to
combat numerous chronic diseases.

2. Costs, cost effectiveness, cost-offsets and
cost-savings – Cost to
consumers and to third-party payers is a critical issue regarding access to
integrative healthcare/integrative medical services provided by practitioners
from the ACCAHC disciplines. Cost implications of including the services of members
of these disciplines are central components of decision-making processes for
insurers, employers, legislators and government agencies as well as administrators
and medical directors of hospitals and clinics. These stakeholders would find
significant, practical value in information on costs, and particularly
cost-offsets, as they continue to expand the integration of the services of
these licensed practitioners into payment and delivery systems.

	Insurers, employers, legislators and government agencies as well as administrators and medical directors of hospitals and clinics would find significant, practical value in information on costs, and particularly cost-offsets.

3.  Capacity – We urge the
expansion of investment in the development of researchers who are graduates of
complementary and alternative medicine programs, particularly those who have a continued
association with the accredited CAM schools. Our disciplines have gained
significant new experience from programs supported by conference grants and by the
education awards that assisted the development of evidence-based medicine
curriculum, research activity in our faculty and students, and partnerships
with conventional academic health centers. Graduates of a growing number of our
universities, schools and programs are benefitting from NCCAM’s development
awards. These have been extremely meaningful, even as NIH investment in
conventional academic health centers starting a half-century ago has
transformed those institutions. One focus of grants and awards could be on
developing expertise in methodologies and practices for evaluations in the
areas recommended in #1 and #2, above.

The
NCCAM’s 1998 mandate from Congress appears to be remarkably supportive of these
priorities. We note Congress’ prioritization of evaluation of outcomes and health
services research. Congress calls repeatedly for the evaluation of each of the licensed
CAM disciplines and, specifically, their integration with conventional medicine
and into delivery systems. The mandate urges evaluation of preventive
approaches, and also notes the importance of investment in personnel as a
necessary means to all of these ends.

A
number of healthcare trends, beyond the common interests and needs of the
ACCAHC disciplines, support these recommendations for NCCAM’s strategic plan.  Among these are an increased awareness of the
multi-factorial nature of care for costly chronic diseases, the heightened
focus on healthcare costs and the importance of comparative effectiveness
research.  In addition, the emergence of
“integrative medicine” in conventional medicine has prompted an overlapping
interest in the evaluation of whole practices, whole systems, interventions
related to wellness and healing, and factors related to their appropriate integration
with delivery systems.

The timing is auspicious for these priorities because a growing number of researchers directly related to these disciplines now have experience of the NIH culture and have participated in the NIH mission as advisers, reviewers, applicants for grants and as funded researchers.

Finally,
this timing is auspicious for these priorities because a growing number of researchers
directly related to these disciplines now have experience of the NIH culture
and have participated in the NIH mission as advisers, reviewers, applicants for
grants and as funded researchers. Researchers and institutions associated with
ACCAHC disciplines are better equipped than they were in 1998 to partner,
counsel and lead these evaluations which Congress urges. We anticipate that
such a prioritization will continue to excite increasing interest in research
endeavors among the students, faculty and clinicians from the ACCAHC disciplines.

Thank
you for this opportunity to participate. Please do not hesitate to contact us
if we can provide you with further information that will assist NIH NCCAM’s
strategic planning process.

Sincerely,

Elizabeth
A. Goldblatt, PhD, MPA/HA             David
O’Bryon, JD
ACCAHC
Chair                                            ACCAHC Vice-Chair 

3.  American Holistic Medical Association (AHMA)

Synopsis: American Holistic Medical Association (AHMA): Shift to outcomes-based research from the past; promotes name for NCCAM change to “something like” National Center for Integrative Medicine; states “fundamental
research on application of integrative holistic practices to produce
positive health outcomes” should be NCCAM’s focus; speaks to importance of use of
systems research methodologies to address systemic problem;

plus, “enhanced development of the researcher pipeline and a
focus on cost issues with respect to holistic/integrative/CAM coverage.”

Dear Dr. Briggs and NCCAM Committee:
 

We are
writing in response to your call for stakeholders in the field of CAM to
provide input regarding the next Five-year Strategic Plan for NCCAM.  We want to thank you for this consideration
and the opportunity.

The
American Holistic Medical Association has been in existence for 31 years, and
our mission and purpose continues to be the transformation of the health care
system to a more holistic, integrated and sustainable system focused on health
and wellness.  Our focus is both
holistic, in the sense of emphasizing the interconnectedness between all aspects
of one’s being, and integrative, supporting the inclusion of scientifically
sound, grounded CAM approaches to our healthcare services.  Our leaders have consisted of many of the
pioneers in the field – Norm Shealy, Bernie Siegel, Christiane Northrup – and
we remain committed to this same path of leadership.

In
recent years, we have taken the lead in establishing collaborative partnerships
within the ever-expanding arena of integrative health organizations, and we
have sought to move the integrative ball forward by broadening our membership from
a historically MD/DO organization to an inclusive membership model that
embraces all doctorate level practitioners and licensable CAM practitioners.
 

NCCAM has fallen short on some essential areas.  Research has largely along the lines of standard NIH policies or reductionism, looking for mechanisms of action, and randomized double-blind placebo-controlled trials. The very nature of integrating multiple modalities into standard medicine and then looking for long term positive results on health requires patience and a new look at outcomes research.

We are
appreciative of many of NCCAM’s efforts over the past decade, particularly in
the areas of legitimizing research in the area and providing public
information.  However, NCCAM has, in our
opinion, fallen short on some essential areas. 
First, research has largely been along the lines of standard NIH
policies or reductionism, looking for mechanisms of action, and randomized
double-blind placebo-controlled trials. Many of these policies, particularly
the research standards, are not amenable to much of what defines integrative or
holistic practice.  There are numerous
papers available to offer ways to pursue more meaningful research in
integrative medicine.  Much of this will
be in the areas of multiple holistic approaches to reach a positive measurable
endpoint, not merely just testing a single modality or agent.  Second, the public information being listed
as “complementary or alternative medicine (CAM)” is counter to our
philosophy.  We realize “CAM” is in your
title but believe it should be taken out for a better term such as National
Center for Integrative Medicine”. CAM is
a marginalizing term
put forth by standard allopathic medicine and our intent is to remove this term
in favor of integrating what works
into mainstream medicine.  The public
certainly doesn’t look at these modalities as marginal to their health and they
speak strongly with their personal income choices.

The
very nature of integrating multiple modalities into standard medicine and then
looking for long term positive results on health requires patience and a new
look at outcomes research.  Our current
healthcare system is in trouble in that we continue to apply quick fixes, at
great cost, where fundamental (but time delayed) solutions are called for.  We believe fundamental research on
application of integrative holistic practices to produce positive health
outcomes is where the basic focus of NCCAM should be.  In fact, our reading of the original mandate
from Congress supports this direction.

To that
end we would like to offer strong support for a shift toward Outcomes-Based Research.

As our
healthcare and political systems have wrestled over the last decade with the
role of CAM, much of the focus has been on research for specific therapeutic
interventions, and NCCAM’s agenda has appropriately mirrored this perspective.  However, we feel that an increased emphasis on outcomes research serves the NCCAM Congressional
mandate more directly, serves the CAM field more accurately, and serves the future of healthcare in America more
appropriately.

Currently,
we have a much stronger national discussion emerging on the links between
health outcomes and lifestyle, and we believe that outcomes research can more
appropriately address these issues.  The
current administration has championed the theme of funding “what works” as a centerpiece
of new healthcare directions, and the
data is unequivocal that the overwhelming majority of health conditions driving
healthcare dollars are primarily creations of lifestyle.  Heart disease, diabetes, pain syndromes,
respiratory disease – we all know the list. 
They have escalated in prevalence due to the skyrocketing rates of
obesity, sedentary lifestyle, lack of sleep, poor stress management tools, and
lack of support and social interconnectedness in an increasingly fragmented
world.

	Lifestyle issues are inextricably woven together, interconnected in a way that a reductionist philosophical approach simply cannot adequately address.

The current
research avenues that are philosophically and methodologically grounded in a
reductionist model serve the aspects of health and illness that the
conventional medical system addresses quite well:  trauma, emergency medicine, acute
disease.  But, lifestyle issues are
inextricably woven together, interconnected in a way that a reductionist philosophical
approach simply cannot adequately address.  
We eat poorly because we’re stressed and tired; we don’t exercise
because we’re tired and aren’t sleeping well… The problem itself is a systems problem, so the methodology to address it
must be a systems methodology.  This
is the real world of healthcare delivery that has been so systematically
de-emphasized over the past decades in the form of decreased time spent with
patients and compartmentalized sub-specialization.

You
have outlined in the 2009 NCCAM White Paper that outcomes research is indeed a
priority and suggested that one of the primary obstacles is this long-standing
emphasis on basic, reductionist biochemical research as espoused by a
significant number of voices within the NIH and the mainstream community.  We are
suggesting that a possible way out of this polar debate is a re-framing of the
argument that emphasizes the enormous contribution that outcomes research would
make toward solving the current healthcare crisis.  It should be seen as an approach that serves
not just the potential integration of CAM modalities and treatments into our
healthcare structure, but as one that directly and most appropriately addresses
the core issue already identified as
the root of the problem:  how we
systematically support and promote healthy lifestyle change.

Further,
an emphasis on outcomes-oriented research actually conforms to the original
charge given to NCCAM.  The charge to
have at least 50% of the Advisory Council consist of clinical practitioners (in
addition to consumer advocates), the listing of “Outcomes Research and
Investigations” at the very top of the activity goals, and the repeated
emphasis on “research on prevention modalities and systems” underscore the
political mandate available.

We echo the calls from other stakeholders for increased investment in researcher development via accredited CAM/Integrative training programs.

Additional
support structures for an emphasis on outcomes research would include enhanced development of the researcher
pipeline and a focus on cost issues with respect to holistic/integrative/CAM
coverage.  We echo the calls from
other stakeholders in this discussion, such as the Academic Consortium for
Complementary and Alternative Health Care (ACCAHC),
for increased investment in researcher development via accredited
CAM/Integrative training programs, as
well integrative practitioner centers, to provide additional means through
which this research can be accomplished. 

At NCCAM’s inception “integrative centers” were just organizing and
becoming functional, and organizations such as the Consortium of Academic
Health Centers for Integrative Medicine (CAHCIM) did not even exist.  There is a growing abundance of facilities
and centers for outcomes research, not to mention extensively developed systems
research approaches that can address the previously difficult barriers to
application for healthcare treatments.  This
brings up another possibility of initiating cooperative group research, modeled
after the highly successful cancer cooperative groups such as ECOG for adults
or COG for children.  Such cooperative
research in integrative medicine would accumulate numbers faster and in a more
standard fashion and allow multiple studies to proceed simultaneously.

The
cost issues relate to the research issues in a mutually supportive way.  Emphasis on outcomes research can provide the
needed data to support appropriate extension of cost coverage into the
holistic/integrative/CAM arenas,
and improvement in these cost issues in turn helps create financially
sustainable centers and programs for further research.

We
appreciate greatly the work that NCCAM is continuing to accomplish, and we are
excited about the potentials and new directions now being discussed.  We believe the current climate may provide
fertile ground for further success, and we look forward to the changes of these
coming years.

We
consider ourselves a willing collaborative partner, and if we can be of any
assistance in NCCAM’s needs and goals, please contact us.

Sincerely,

J.
David Forbes, MD
President,
American Holistic Medical Association

4.  Association of Accredited Naturopathic Medical Colleges (AANMC)

Synopsis: Association of Accredited Naturopathic Medical Colleges focused on: preventive-oriented services and complexity of
related research; research on the whole systems of treatment i9ncluding a short list of studies exemplifying the outcomes approach); research
on the cost-effectiveness of naturopathic treatments; and a request for research on naturopathic care for two specific conditions, diabetes and
oncology.

Dear
Dr. Briggs and Strategic Planning Team Members:

I
am writing on behalf of the Association of Accredited Naturopathic Medical
Colleges (AANMC) in response to your October 2009 solicitation of stakeholder
input on the next strategic plan for the NIH National
Center for Complementary
and Alternative Medicine (NCCAM). Thank you for the opportunity for input, and
the leadership that you are demonstrating in assessing and guiding research
needs within the complementary and alternative medicine field.

The medical system requires a greater focus on preventive care and the boosting of the overall level of health of American citizens.  The most effective therapies to achieve this are frequently complex to research.

The
AANMC is an organization in which membership is limited to institutions that
have been accredited by, or are in candidacy status with, the Council on
Naturopathic Medical Education, the programmatic accrediting agency recognized
by the Department of Education.  Naturopathic
medicine is a system and philosophy of medicine that has been in use for over
100 years.  Graduates of these programs have
completed four-year intensive medical training and are qualified to serve as
primary care physicians, having comparable knowledge and skills in the basic
and clinical sciences to conventional medical doctors. In addition, NDs receive
training in a variety of core treatment methods including nutrition, botanical
medicine, homeopathy, pharmacology, physical therapy, and minor office surgical
procedures.

There
is no question that the medical system requires a greater focus on preventive
care and the boosting of the overall level of health of American citizens.  The most effective therapies to achieve this
are frequently complex to research within an environment in which reductionist
techniques aimed at single agents or single treatments are easier to
study.  Nonetheless, the rigor of whole
systems methodologies have developed to where the results of these studies are
providing strong evidence for the efficacy of these approaches.  Furthermore, the outcomes data from these
studies can be used for further research on the comparative costs and benefits
of these approaches. See:

Cooley
K, Szczurko O, Perri D, Mills EJ, Bernhardt B, et al. (2009) Naturopathic
Care for Anxiety: A Randomized Controlled Trial ISRCTN78958974. PLoS ONE
4(8): e6628. doi:10.1371/journal.pone.0006628

Szczurko
O, Cooley PK,
Mills EJ, Zhou Q, Perri P, Seely D. Naturopathic Treatment of Rotator Cuff
Tendonitis Amongst Canada Post workers: A randomized controlled trial.
Arthritis Rheum. 2009 Jul 30; 61(8):1037-1045.

Szczurko
O, Cooley K, Busse JW, Seely D, Bernhardt B, Guyatt GH, Zhou Q, Mills EJ.
Naturopathic care for chronic low back pain: a randomized trial. PLoS ONE. 2007 Sep 19; 2(9):e919.

Cramer
EH, Jones P, Keenan NL, Thompson BL. Is naturopathy as effective as
conventional therapy for treatment of menopausal symptoms? J Altern
Complement Med. 2003 Aug; 9(4):529-38.

Herman
PM, Szczurko O, Cooley K, Mills EJ. Cost-effectiveness of naturopathic
care for chronic low back pain. Altern Ther Health Med. 2008 Mar-Apr; 14(2):32-9.

In
support of research of this nature, the AANMC would recommend the following
priorities:

• 	For a medical system based on expenditure, change generally only occurs where there is a financial advantage that can be gained.  Nonetheless, there is surprisingly little research assessing the economic impact of systems of treatment.

  Research on
  whole systems of treatment.  As noted
  above, the sum is frequently much greater than the parts.  However, it is not true that all whole
  systems treatment is more effective, or indeed effective at all.  Determining what should be supported requires
  high-quality outcomes based research focused on systems of treatment.

• Research on
  the cost effectiveness of naturopathic treatments.  For a medical system that is based on
  expenditure, meaningful change generally only occurs where there is a financial
  advantage that can be gained.  Nonetheless,
  at this point there is surprisingly little research assessing the economic
  impact of systems of treatment.

• Research
  related to the impact of naturopathic treatments on diabetes.

• Research
  related to the burgeoning field of naturopathic oncology.

Thank
you again for the opportunity to provide input to the development of the
strategic priorities for NCCAM.

Sincerely,

Bob
Bernhardt, BSc, Med, LLM, PhD

President

5.  International Association of Yoga Therapists (IAYT)

International Association of Yoga Therapists: specifically supports ACCAHC’s
3 recommendations; stresses “real world” priorities for research on Yoga
based upon two factors in the NCCAM solicitation (“scientific promise”
and “extent and nature of practice and use”).

Dear Dr. Briggs and the Strategic Planning Team,

We are writing in response to your solicitation of stakeholder input into Priority Setting for the next strategic plan for the NIH National Center of Complementary and Alternative Medicine. The International Association of Yoga Therapists (IAYT), with 2,300 members in the U.S. alone, serves as a professional organization for Yoga teachers and Yoga therapists worldwide. Membership has tripled since 2003. We have published the International Journal of Yoga Therapy since 1990, the only professional and scientific journal dedicated to Yoga as a healing practice. IAYT has also hosted an annual Symposium on Yoga Therapy and Research (SYTAR) since 2007, attracting an average of over 600 participants each year. We see ourselves as a significant stakeholder in NCCAM.

We note the role Yoga can play in integrative approaches to healthy lifestyle changes, including stress management.

First, we are writing in support of the top shared priorities identified by the Academic Consortium for Complementary and Alternative Health Care (ACCAHC). They apply to Yoga as well as the licensed CAM disciplines.

• Research on whole practices

• Costs, cost effectiveness, cost off-sets and cost savings
• Infrastructure and capacity – including the development of researchers in both licensed and unlicensed fields

Yoga therapy is an emerging profession in the U.S., actively engaged in the self-regulatory process. IAYT has been a member of the ACCAHC since 2006. Together with the Yoga Alliance (YA) and the National Ayurvedic Medical Association (NAMA), we are the Traditional World Medicines Group within ACCAHC.

Second, we are writing to stress the “real world” priorities for research on Yoga based upon two key factors identified in the solicitation – Scientific Promise and Extent and Nature of Practice and Use.

Scientific Promise

First, we note the role Yoga can play in integrative approaches to healthy lifestyle changes, including stress management. Perhaps the most well known example is in the work of Dean Ornish, MD, and colleagues at the Preventive Medicine Research Institute. Yoga inspired the practices for stress management – stretching, deep breathing, meditation and deep relaxation. Those lifestyle changes have been shown to reverse coronary heart disease and effect the progression of early low grade prostate cancer. (1) As Dr. Ornish recently testified, the potential for such integrated approaches for disease prevention is enormous. “Last year, $2.1 trillion were spent in this country on medical care, or 16.5% of the gross national product and 95 cents of every dollar were spent to treat disease after it had already occurred. Heart disease, diabetes, prostate cancer, breast cancer and obesity accounts for 75% of these health care costs, yet these are largely preventable and even reversible by changing diet and lifestyle.” (2)

	There are numerous opportunities for explicit uses of Yoga for mental health, cardiovascular health, musculoskeletal and neurologic disorders, coping with cancer and other life threatening diseases and much more.

Second, as presented at a recent scientific Symposium on Yoga as a Therapeutic Intervention at the May 2009, North American Research Conference on Complementary and Integrative Medicine (NARCCIM), there are numerous intriguing opportunities for explicit uses of Yoga for mental health, cardiovascular health, musculoskeletal and neurologic disorders, coping with cancer and other life threatening diseases and much more.(3) While the popular practice of Yoga has passed the “market test”, these therapeutic applications of Yoga need more research in order to gain a deeper scientific understanding and support for wider acceptance and utilization by our healthcare system.(4) There is significant interest in Yoga research. There were 100 people in the audience at that Yoga symposium at NARCCIM. At IAYT’s own annual Symposium on Yoga Therapy and Research, the research track has drawn about 50 attendees three years in a row (2007-2009), mostly Yoga researchers. In the past two conferences, over 40 research abstracts were submitted each year for oral or poster presentation. There is also widespread and growing scientific interest in meditation for health purposes. For example, note that on July 8–9, 2008, NCCAM held a 2-day workshop in Bethesda, Maryland on meditation for health purposes. It was co-sponsored by the National Cancer Institute (NCI), the National Institute on Aging (NIA), the NIH Office of Behavioral and Social Sciences (OBSSR), and the Canadian Institutes of Health Research (INMHA, ICRH). (5)

Extent and Nature of Practice and Use.

Yoga is a well known and popular CAM therapy, practiced by 6.1% of the adult population.(6) Two other classic Yogic practices are also very popular, deep breathing, at 12.7 %, and meditation at 9.4%. Moreover, these practices represent three out of four top ten CAM therapies that showed significant increases from the same study done five years earlier. (7) Yoga can be a fitness practice, a wellness practice, a therapeutic practice and/or a spiritual practice. While Yoga is not “healthcare” as conventionally viewed, the practice is used by over 15 million adults as an enjoyable and low cost means to help maintain their health and complement their healthcare. (8) As an example, we are pleased to note that pictures of individuals practicing Yoga are prominently featured on the NCCAM website.

Thank you for the opportunity to participate. Please feel free to contact us if we can provide you with further information that will assist the NIH NCCAM strategic planning process.

Sincerely,

John Kepner, MA, MBA                                      Matthew J. Taylor, PT, PhD
Executive Director                                            President, Board of Directors

1 Preventative Medicine Research Institute website. http://www.pmri.org/research.html. November, 28, 2009.

2 Dean Ornish, MD. US Senate Healthcare Reform Testimony on Integrative Care: A Pathway to a Healthier Nation. February 26, 2009. Reprinted in the International Journal of Yoga Therapy, No 19, (2009), pp 43-46.
3 Khalsa, Sat Bir Singh. Presentation at the Symposium on Research on Yoga as a Therapeutic Intervention, May 13, 2009, North American Research Conference on Complementary and Integrative Medicine.
4 Khalsa, Sat Bir Singh. “Why Do Yoga Research: Who Cares and What Good is It?” International Journal of Yoga Therapy, No 17, (2007), pp 19-20.
5 Meditation for Health Purposes Workshop — July 8–9, 2008. Executive Summary. NCCAM website, November 28, 2009.
6 Complementary and Alternative Medicine Use Among Adults and Children: United States, 2007, Barnes PM, Bloom B, Nahin R. CDC National Health Statistics Report #12, 2008.
7 Khalsa, Sat Bir Singh. Presentation at the Symposium on Research on Yoga as a Therapeutic Intervention, May 13, 2009, North American Research Conference on Complementary and Integrative Medicine.

8 Yoga Journal releases 2008 “Yoga in America” market study, Yoga Journal press release, 2/28/2008.

6.  Massage Therapy Foundation (MTF)

Synopsis: Diana Thompson, LMP, president of the Massage Therapy Foundation (MTF) responded to NCCAM via the NCCAM website. MTF is the leading research voice for the massage field and sponsors the most significant research meeting for the field. Thompson re-constructed her comments, based on the questions asked on the NCCAM site, for the Integrator. MTF made these key points: said there was a “greater and more immediate” need for outcomes research than for basic research; reductionist methods don’t capture massage as practiced; value of massage goes beyond the pain focus of interest at NCCAM; requested support to mentor massage therapists as researchers; and sought programs to help massage therapists get access to scientific evidence.

Response to NCCAM Paper One

1. NCCAM statement: Major features of
the current CAM research landscape that are important in considering future
strategic directions for NCCAM and the field of CAM research in general: 

	While basic/mechanics studies contribute to the body of knowledge, there is a greater and more immediate need for outcomes research.

While basic/mechanics studies are informative and contribute
to the overall body of knowledge, there is a greater and more immediate need
for outcomes research. Consumers are already using CAM therapies and while use
may shift slightly from one herb to another with more basic science
information, choices to incorporate most body-based or body-mind therapies will
continue as is. Safety is also less of a pressing issue with these modalities.
The public may benefit more from comparative, cost effectiveness, and
integrative studies. There is a need to educate the medical system on how to
refer, when to refer, and to whom and to educate the public on which therapies
may best contribute to their goals for health.

2. NCCAM statement: Particular needs
and opportunities of importance to NCCAM’s efforts in research capacity
building:

A mentorship program could be established to reward research institutions for engaging practitioners into existing research opportunities.

Professions that are not based in traditional academic
institutions do not have access to traditional research training. For example,
massage therapists seeking a PhD find themselves in programs often unrelated to
their clinical practices, such as nursing, sociology and psychology. While the
R25 offers many possibilities, a mentorship program could be established to
reward research institutions for engaging practitioners into existing research opportunities
and stimulating interest in pursuing advanced degree programs that can find a
way to fit into their professional interests.

3. NCCAM statement: Opportunities,
obstacles, and NCCAM’s future role in supporting research on approaches to
improved states of general health and well-being:

	The current reductionist method of research does not adequately address many CAM therapies, in particular, it does not represent massage therapy as practiced.

The current reductionist method of research does not
adequately address many CAM therapies, in particular, it does not represent
massage therapy as practiced. Disease is often complex, patients are often
complex, and treatment must be modified to address the needs of each
individual. In addition, rarely do patients choose one or another modality, but
rather create a palette of complementary therapies, each addressing one aspect
of their needs or building on each other to provide a desired result. Realizing
that this is an expensive proposal, perhaps NCCAM can devote funds to study
“add-ons”, for example, diet, exercise, and
massage therapy, with the hypothesis that people make better choices if
self-worth is improved. Studies on adherence or compliance could be valuable in
complex settings or in wellness and prevention studies. Massage therapy is
currently being relegated to pain management studies, a role massage plays a
part in, but there is much more that massage can contribute—to integrative
medicine, to public health, etc. Studies are demonstrating the role of massage
in relieving depression and anxiety, more so than pain, and more can be explored
in regards to the role of massage in improving self-worth, self-esteem, and people’s
ability to make healthy choices.

Response to NCCAM Paper Three

2. NCCAM statement: The major unmet
needs of health care providers in accessing, interpreting, and making use of
research evidence about CAM:

Massage therapy research is published in a myriad of
professional journals: orthopedic, neurological, and nursing to name a few,
even though there are now two publications specific to massage and bodywork
research. In addition, massage education does not take place in traditional
academic institutions, making access to these journals cost prohibitive and
nearly impossible. There could be funding to allow universities to share
database access to CAM educational institutions not already aligned with public
academic institutions.

7.  National Center for Homeopathy (NCH)

Synopsis: National Center for Homeopathy
(NCH): specific program announcement on basic, preclinical and
clinical/outcomes research on homeopathy; use of reviewers experienced
in homeopathy; scientific information about homeopathy on the NCCAM
website; opportunity to submit names for possible appointees to the
NCCAM advisory council.

Dear Dr. Briggs, members of
the Strategic Planning Team, Ms. Thompson,

As President of the National Center for Homeopathy, I am writing on
behalf of my organization, in response to your request for stakeholder input
for the 2010 strategic plan of NCCAM.

NCCAM has a Congressional mandate to identify, investigate and validate complementary and alternative treatment, diagnostic and prevention modalities, disciplines and systems.

The National
Center for Homeopathy is an open
membership organization that supports and promotes the cause of homeopathy in
the United States.
We do this through educating about homeopathy, publicizing the effectiveness
and therapeutic benefits of homeopathy and ensuring that access to homeopathic
medicines is protected. Our members are 5,000 strong and growing daily in
response to the trend toward self care using safe and effective medicines for self
limiting conditions and for primary care providers who practice prevention and
wellness in an integrative environment. Our members represent those
stakeholders whose interests echo those of the recent IOM summit attendees.
They want patient centric, individualized medicine. They want an integrative
model and they want cost effectiveness. Your recent NIH study revealed that
some $33 billion are spent out-of-pocket yearly on CAM
products, homeopathy included. The NCCAM has a Congressional mandate to identify,
investigate and validate complementary and alternative treatment, diagnostic
and prevention modalities, disciplines and systems. Homeopathy is listed on the
NCCAM website as a whole system of medicine and, in my opinion, must be a
priority consideration. The NCH has a moral mandate to ensure that our members,
consumers and practitioners are the recipients of homeopathic research and the
dissemination of educational materials based on existing research and evidence.



Our suggestions for
implementation into the 2010 Strategic Plan are as follows:

• 
  The writing of a
  specific program announcement around basic, preclinical and clinical research
  on homeopathy. For example, in basic science, methodology-oriented grant
  proposals. In clinical research, methodological approaches such as those  by Frei (pre-testing subjects and showing
  clinical responsivity before allocating subjects into double-blind placebo
  controlled trials) and Walach (open label studies to avoid entanglement,
  specific analytical approaches to differentiate active from placebo and Bell (
  psychophysiology during intervention). 
  Large scale observational studies such as those done by Claudia Witt are
  critical to showing effectiveness in the real world.  There could be a program announcement specifically
  on outcomes research with observational longitudinal design, cost effectiveness
  and safety issues as the focus. It is equally important to consider reviewers
  with scientific homeopathic background.

• 	We suggest the writing of a specific program announcement around basic, preclinical and clinical research on homeopathy.

  Public Law
  105-277, the NCCAM mandate, SEC. 485D, (b) calls for an Advisory Council
  members of whom are not ex officio “shall include practitioners licensed in one
  or more of the major systems with which the Center is concerned, and at least 3
  individuals representing the interests of individual consumers of complementary
  and alternative medicine.”  The
  membership of the National
  Center for Homeopathy is
  unique in that it includes licensed practitioners, nationally certified
  practitioners and consumers.  As such, the
  NCH would respectfully request the opportunity to submit a roster of names for
  consideration for placement on this Advisory Council.

• 
  SEC.485D, (g),
  Clearinghouse (1) DATA SYSTEM, – calls for the Director to establish a
  bibliographic system for the collection, storage, and retrieval of worldwide
  research relating to complementary and alternative treatment, diagnostic and
  prevention modalities, disciplines and systems. Such a system shall be
  regularly updated and publicly accessible.” Currently, there is no such
  information on homeopathy available although a plethora of such research does
  exist. We suggest that updating the data be a priority for the 2010 Strategic
  Plan so that consumers have access to information that both educates them and
  allows them to make informed decisions regarding their health care.

On behalf of myself and the
membership of the National
Center for Homeopathy, I
want to thank you for the opportunity to participate in the planning process.  Please be assured that we stand ready to be of
assistance to you at any time should you so require.

Respectfully submitted,

Nancy Gahles, D.C., CCH,
RSHom(NA)

President, National Center
for Homeopathy

8.  American Association of Naturopathic Physicians (AANP) 

Synopsis: American Association of Naturopathic Physicians urged: Development
and funding of outcomes-based research initiatives that demonstrate how
(primary care organized on naturopathic principles) will enable the
“transformation of our disease-based system into one that is rooted in
sustainable health and wellness;” research utilizing practice-based research
networks; inclusion of appropriately trained professionals on NCCAM’s
advisory council and in peer review; and examination of cost issues.

Introduction

While conventional medicine’s focus on treatment of disease
has produced many benefits, especially in acute and life-threatening
conditions, its effectiveness for the treatment of chronic disease or the
promotion of health is limited. This limitation has been a major cause of the
out-of-control healthcare costs plaguing the nation.

What is required is the funding of outcomes-based research initiatives that demonstrate how this care will enable the transformation of our disease-based system.

There is, at present, a severe shortage of primary care
physicians. A number of proposals have been put forth as to how to fill that
shortage and many of these are aimed at increasing the number of medical
students going in to primary care. 

However, there are also a number of proposals to utilize the skills of
other licensed healthcare practitioners to  expand access to patient-centered primary care
in both federally funded and private health care offerings—e.g., naturopathic
physicians (NDs).  What is now required
is the development and funding of outcomes-based research initiatives that
demonstrate how this care will enable the transformation of our disease-based
system into one that is rooted in sustainable health and wellness.

Naturopathic medicine is a system and philosophy of medicine
that has been in use for over 100 years. The American Association of
Naturopathic Physicians (AANP) represents licensed naturopathic physicians who
are trained at fully accredited four-year, residential medical programs.  Graduates of our medical schools serve as
primary care physicians and have the same training in the basic and clinical
sciences as conventional medical doctors. In addition, NDs receive training in
a variety of core treatment methods including nutrition, botanical medicine,
homeopathy, pharmacology, physical therapy, and minor office surgical
procedures. Some licensed naturopathic physicians are also trained in
traditional Chinese medicine, acupuncture and Ayurvedic medicine as well as
clinical specialties such as natural childbirth. Therefore, naturopathic
medicine and NDs provide the ideal laboratory to test a complement to the
present primary-care-deficient model of health care.

The Changing Role of
Natural Medicine

As NCCAM evaluates its existing strategic direction for the
next five years, it is essential to recognize the dramatically changing
landscape of the “complementary and alternative” (CAM)
world.  Terminology and practices are
shifting daily, opening new doors and breaking down barriers.  Practitioners of natural medicine and
alternative therapies continue to organize themselves professionally and
academically.  In addition, there is
growing acknowledgement and acceptance of these practices in the more
conventional environments, as is evidenced by the utilization of terminology
that includes integrative medicine and integrative health – terminology that is
utilized by conventional and non-conventional providers alike.

	How NCCAM responds to integration of ‘alternative’ and ‘conventional’ medicines stands to dramatically impact the development of a sustainable health care system.

How
the research community and NCCAM itself respond to integration of ‘alternative’
and ‘conventional’ medicines stands to dramatically impact the development of a
sustainable health care system. 

Integration holds the potential for a newly defined worldview of
wellness, increasing acceptance of treating the whole person and systemically
valuing true prevention and the body’s ability to heal at a time when chronic
disease promises to cripple our financial future.  Yet it is essential to note, research
initiatives that are successful in demonstrating effective integration of
conventional and natural medicine will require continued commitment to educational
and testing standards by the professions, and established research protocols
that recognize the underlying principles associated with each profession.  The Commonwealth Working Group on Traditional
Complementary Health Systems at the University
of Oxford, in a study of developing
countries across Asia, India
and Africa, found that successful integration of CAM
and conventional medical systems requires the professions to first
self-regulate standards of practice and training (Bodeker, 2001). 

AANP,
along with many of the other CAM professional
organizations, stand committed to establishing standards on par with that of
their allopathic counterparts.  In
addition, the study concluded that the central regulation of natural products
through good manufacturing practices and sound research is essential to effective
integration efforts (Bodeker).  Viable
pathways towards effective integration of ‘alternative’ care into the
conventional paradigm should be viewed with careful consideration.  Why?  In
China,
it was demonstrated that domination of conventional medicine can result in the
dilution of traditional philosophies and practices, compromising the quality of
education (Bodeker, 2001).  Today,
existing research initiatives fail to incorporate the relevance of philosophy
to both the practitioner and the health care outcomes of the patient – ergo,
the relationship of the naturopathic physician to his or her patient is undervalued
in the current effectiveness evaluation scales.

We strongly encourage thoughtful development of research
paradigms that are 1) outcomes-based, 2) incorporate the importance of
philosophy and education, 3) evaluate the provider/patient relationship, and 4)
serve to redefine and quantify the standard interpretation of health and
wellness programs.

NCCAM Capacity to
Conduct Effective and Representative Research

NCCAM has an enormous opportunity to meet its stated mission on the composition of the Advisory Council, availing itself of “appropriate expertise” and including accredited and licensed professions in the evaluation of alternative and complementary treatment.

The Center has an enormous opportunity over the course of
the next five years to meet its stated mission relating to 1) the composition
of the Advisory Council, 2) availing itself of “appropriate expertise” from the
CAM scientific realm, and 3) the call to include accredited and licensed
professions in the evaluation of alternative and complementary treatment.  In the naturopathic medical field alone, the
number of qualified researchers, the research programs at accredited
institutions and the number of naturopathic physicians practicing in
integrative environments has grown dramatically.  NCCAM, and the federal agencies that are best
suited to partner in CAM research initiatives,
should avail themselves of the numerous high-quality, cost-effective medical
practice patterns of highly skilled physicians and practitioners for the purpose
of conducting quality, outcomes-based research. 

Expanding NCCAM’s worldview of developing research initiatives and
private sector offerings, could significantly impact the types of projects
undertaken across federal agencies, and substantially add to the growing body
of research on outcomes and effectiveness of naturopathic treatment.

In April 2009, the AANP submitted testimony to the Federal
Coordinating Council for Comparative Effectiveness Research on its commitment
to outcomes research, the determination of best practices and the need to fund
evaluation of alternative systems of healthcare.  We specifically proposed funding of health
information technology and electronic medical records in a practice-based
research network (PBRN) containing both conventional and naturopathic medical
practices to compare “real world” effectiveness and cost-effectiveness for type
2 diabetes.  Creation of this PBRN has
been initiated, and will include collaboration with other private and public
sector research and academic institutions. 
The proposal calls first for retrospective and pilot prospective studies
to test the feasibility of protocols based on an informatics approach to
naturopathic medicine outcomes research and to characterize the populations
before going on to more definitive study. 

If there are positive results with comprehensive treatment, the
treatment and the outcomes data can be examined for factors associated with
improvement.

Comparative Effectiveness Research:  A Case Study

The initial proposal is for a study on type 2 diabetes
(T2D). T2D is epidemic and often inadequately controlled (only 37% in adequate
glycemic control) by approved treatments. 
Nearly half (47.9%) of US diabetes patients also use complementary and
alternative medicine (Garrow & Egede 2006; Yeh, Eisenberg, Davis &

Phillips, 2002). The Diabetes Prevention Program (DPP) conclusively
demonstrated that diet and lifestyle changes could prevent diabetes more
effectively in a susceptible population than metformin (58% reduction in incidence
versus 31%). The DPP lifestyle intervention used lifestyle coaches and a focus
on weight loss and exercise, and although it proved less expensive per case of
diabetes prevented than pharmacological management alone, it still presents a
substantial cost to implement. ND practices will be used to test modifications
to this model that include a primary care setting allowing diabetes prevention
to be incorporated into patients’ overall focus on health.  It may be even more effective, e.g., through
the inclusion of nutritional supplementation (Bartlett & Eperjesi, 2008;
Farvid, Jalali, Siassi & Hosseini, 2005; Bonnefont-Rousselot, 2004)), and
potentially, more cost-effective.

Diabetes is paradigmatic of endemic chronic diseases for
which NDs have specific well rationalized treatment protocols of which the
elements, individually, show promise but have not been tested in combined
practice.  This PBRN proposal can be used
to test components of primary care that can also be incorporated into
conventional practice.

Diabetes is an important chronic condition but it is only
one of many conditions toward which the informatics-based research
infrastructure that we propose can be targeted.  NCCAM funding of such systems could enable the
determination of the best approaches to general primary care/family practice,
pain, and other chronic disease conditions.

Opportunities and
Obstacles for Outcomes-Based Research

	NCCAM has not fully availed itself of the unique opportunities associated with cost-effectiveness research across the naturopathic profession.

NCCAM’s original mandate reads “the Director of the Centers
shall identify and evaluate alternative and complementary medical treatment,
diagnostic and prevention modalities in each of the disciplines and systems
which the Center is concerned, including each discipline and system in which
accreditation, national certification, or a State license is available.”  The AANP would assert that NCCAM has not
fully availed itself of the unique opportunities associated with
cost-effectiveness research across the naturopathic profession.  Federal funding for health research in many
agencies remains restricted to those professions identified in the Social
Security Act, overlooking the other primary care providers licensed in many states
across the country.  And, despite the
fact that corporations are experiencing enormous success in the implementation
of even the most basic wellness programs, Congress and many policy makers
remain unconvinced and unable to attribute savings for these programs.  Thus, federal law  and the current health insurance reform
efforts are not able to avail themselves of programs that stand at the forefront
of reducing the prevalence of chronic disease, and transformation from a
disease-based system.

Cost-effective,
Quality Outcomes

One such example of how naturopathic medicine is
transforming outcomes in the private sector exists in Vermont with the “Jump Start To Better
Health” program for employees of a statewide association.  The program uses an approach to improving
employee wellness that includes fitness and weight loss challenges, a monthly
newsletter, on-site flu immunization clinics, on-site health awareness
screenings, a smoking cessation program, online wellness center, the FirstLine
Therapy Therapeutic Lifestyle Change program, and a comprehensive incentive
program with $10,000.00 in cash prizes.

The “Jump Start To Better Health” program was designed by a
naturopathic physician, Dr. Bernie Noe. It has dramatically improved the health
of association members, and has helped cut healthcare costs. In the first two
years of the program, the occurrence of high blood pressure decreased by 49
percent, while the occurrence of high cholesterol decreased by 26 percent. The
occurrence of smoking, physical inactivity, and multiple risk factors for
cardiovascular disease, all decreased by more than ten percent. The Association
estimates that during the program’s first two years, it saved an average of
$8.20 in health care costs for every $1.00 invested in the program. This
translates into an overall savings of $1,421,000 in direct and indirect health
costs during that time period.

The naturopathic model was cost effective and had the added benefits of improving health outcomes and lowering other medical costs.

Another powerful example of the direct correlation between
patient access to a wide range of healthcare provider options and more
efficient, cost-effective healthcare has been demonstrated in a study funded by
NCCAM. In the study, Patricia Herman, ND, compared conventional and naturopathic
lower back pain treatments. Dr. Herman found that the naturopathic model of
care was less costly than conventional treatment, when accounting for
absenteeism. The naturopathic model also had the added benefits of improving
health outcomes and lowering other medical costs.

A second study by Dr. Herman, also funded by NCCAM, found
that integrative care can reduce reliance on conventional drugs in a study of
patients with eating disorders. A comparison of patients treated
conventionally, and those treated with added integrative therapies including
dietary supplements, acupuncture and massage showed that patients receiving
integrated treatments generally had decreased symptoms and reliance on
conventional medications. Two common conditions in eating disorder patients, constipation
and sleep disorder, reduced significantly. In fact, reliance on sleep
medications was reduced from 55 percent to 11 percent in the integrated patient
group. Naturopathic therapies, in place of or in conjunction with conventional
care, can provide increased health outcomes at reduced costs. NCCAM funding of
studies such as these is evidence that utilization of naturopathic expertise
can greatly ease the burden on our nation’s healthcare system.

Conclusion

In
fall, 2009, the Department of Labor issued a custom report defining the role of
a naturopathic physician to read: 

“Diagnose, treat, and
help prevent diseases using a system of practice that is based on the natural
healing capacity of individuals. May use physiological, psychological or
mechanical methods. May also use natural medicines, prescription or legend
drugs, foods, herbs, or other natural remedies. 
Sample job titles include Naturopathic Physician, Naturopathic Doctor,
Physician, and Doctor of Naturopathic Medicine. (Occupational Information
Network, 2009) “ 

The world of medicine is rapidly changing through the
promulgation of regulation, the passage of legislation and in the daily practice
of medicine itself.  Naturopathic
physicians, acupuncturists and yes, our conventional partners, the advanced
practice nurses, are a growing force in the transformation of our healthcare
system.  It is a force that is driven by
consumer experience and increased consumer demand.  It is medicine that demands increased
research.  There is enormous opportunity
in recognizing the redefinition of how primary care is provided in this
country.  Enhancing research efforts on
the work of those previously designated as alternative, and now quickly becoming
mainstream, is a precursor to true health care reform.

The AANP stands ready to support NCCAM’s efforts to enhance
infrastructure, expand research opportunities in the naturopathic field, and
advocate for funding of outcomes-based research initiatives that demonstrate
the effectiveness and sustainability of natural medicine and patient-centered
care.

Bodeker, G. (2001). Lessons on Integration from the
Developing World’s Experience. British Medical Journal, 322,
164-167. doi:10.1136/bmj.322.7279.164
 

Bonnefont-Rousselot,
D. The Role of Antioxidant Micronutrients in the Prevention of Diabetic
Complications. Treatments in Endocrinology. 3(1): 41-52, 2004.

Bartlett H, Eperjesi F. Nutritional supplementation for type
2 diabetes: a systematic review. Ophthalmic & Physiological Optics [serial
online]. November 2008;28(6):503-523.

Farvid
MS, Jalali M, Siassi F & Hosseini M. Comparison of the effects of vitamins
and/or mineral supplementation on glomerular and tubular dysfunction in type 2
diabetes. Diabetes Care. 2005 Oct;28(10):2458-64.

Garrow
D, Egede LE.  National patterns and
correlates of complementary and alternative medicine use in adults with
diabetes.  J Altern Complement Med. 2006b
Nov;12(9):895-902.

Occupational Information
Network. (2009).  29-1199.04 – Naturopathic Physicians. Retrieved November 11, 2009, from the Occupational
Information Network website: http://online.onetcenter.org/link/details/29-1199.04#Education

Yeh GY, Eisenberg DM, Davis RB, Phillips RS. Use of
complementary and alternative medicine among persons with diabetes mellitus:
results of a national survey.  Am J
Public Health. 2002 Oct;92(10):1648-52.

Comment: The connective threads here are clear: real-world, pragmatic research, attention to balance on the NCCAM advisory council, research on costs, and support of infrastructure. The outcomes arena is unanimously identified in all of these responses. Notably, this is an area Congress identified the  #1 priority as an “activity” for research, but is also a place where NCCAM has invested less than 1% of its funds. Basic research and RCTs are recognized as valuable but not recommended.

The big gap in this group, as a representative sampling, is the conventionally-based integrative medicine community. How will the influential Consortium of Academic Health Centers for Integrative Medicine weigh in? I know that the integrative practitioner subset of that community also has much use for outcomes, whole practice/whole systems rand cost-related research.

Some allied organizations are on the record as recommending outcomes and effectiveness directions. Certainly the Bravewell Collaborative has an agenda which would benefit from this funding. (In fact, shifting NCCAM’s investment to create capital to help them prove the value of integrative medicine might be viewed as the best fund-raising they could be doing right now to transform US health care.) Key entities like the Institute for Integrative Health, led by NCCAM-funded researcher Brian Berman, MD and the Samueli Institute, led by Wayne Jonas, MD, the former director of the NCCAM predecessor, have promoted outcomes approaches. But I am not aware if they have formally submitted.

These gaps in the presentation here notwithstanding, the way I look at it, the job of NCCAM director Josephine Briggs, MD is becoming easier. It’s time for her to get it right and place NCCAM in a radical realignment with both Congress and these significant NCCAM stakeholders rather than with the reductive and basic researchers who have shaped NCCAM’s investment to date. The challenge is significant. It will take a sort of patricide to do it. But the benefits will flow to the consumers – the citizens that is – whom government agencies are supposed to serve.