Dear Members,

Homeopathic Medical Association of Canada have submitted a written submission to the Standing Committee on Social Policy who met on April 23, 2007 in Legislative Block of the Ontario Parliament Building at Queens Park at 4 pm. In short, we have demanded a separate college for homeopathy and access to all control acts under RHPA. However three other Associations were given the time to give their oral presentations in front of the Committee. The transcript of the oral presentations are enclosed below for your perusal. The bill would now be presented in the Parliament on May 7, 2007 for amendments. We are proud to inform you that the Government is seriously thinking of a separate regulatory college of Homeopathy which is a heartening news for all of us. So keeping our fingers crossed we may await for the passage of the Bill 171-Schedule P for our further announcements. .

Sincerely.

Dr. B.P.Sharma, President, Homeopathic Medical of Association.


Committee Transcripts: Standing Committee on Social Policy - April 23, 2007 - Bill 171, Health System Improvements Act, 2007.
ONTARIO HOMEOPATHIC ASSOCIATION
The Chair: The next group is the Ontario Homeopathic Association. While they’re coming forward, I’m going to suggest to the committee that where we have just a few minutes left, perhaps we’ll have just one party take the time.
Mrs. Witmer: That’s a good idea.
The Chair: I apologize for that. I started down a road I couldn’t get off of once I started.
I would also remind those who have cellphones—if you would turn them off. Perhaps you can put them on vibrate rather than ring. Heck, you might even enjoy a phone call.
Okay. The time is yours.
Ms. Maya de Szegheo-Lang: I’m Maya de Szegheo-Lang. As president, I represent members of the Ontario Homeopathic Association, referred to as OHA. With me is Mirsada Vins, head of the homeopathic department of the Ontario College of Homeopathic Medicine, referred to as OCHM. We would also like to acknowledge Ranvir Sharda, president, and members of the Homeopathic Medical Council of Canada, HMCC, who are in support of this submission.
We wish to thank the Chair and committee members for the opportunity to comment today on the regulation of homeopathy in schedule P of Bill 171.
The Ontario Homeopathic Association is a non-profit, voluntary association of highly qualified homeopaths who must adhere to a code of ethics and must meet educational and practice criteria which include specified hours of general arts and science courses, medical science courses, homeopathic instruction and clinical internship in homeopathy.
Ms. Mirsada Vins: Through review and consultation, the OHA proposes the following: With respect to the establishment of the College of Naturopaths and Homeopaths of Ontario, the OHA submits that homeopaths and naturopaths ought to be regulated under separate colleges. We acknowledge that naturopaths receive some education in homeopathic principles. It is common amongst regulated health professions for there to be some aspects of shared knowledge or practice. However, homeopathy is a distinct system of medicine with a core body of knowledge that is unique to the practice of homeopathy. A separate college would provide homeopaths with the opportunity to develop the appropriate regulatory scheme for homeopathy in Ontario.
We note that when the College of Midwives of Ontario was created, it had 67 members. In the ensuing 14 years, its membership has grown to approximately 400 members. The OHA estimates that there are currently approximately just over 500 highly qualified homeopaths in Ontario who would be eligible for membership as regulated health professionals. As well, both the OHA and the OCHM have seen an steady increase in the past 10 years in the number of persons wishing to obtain homeopathic education. This increase in interest in homeopathy has been mirrored by an increase in members of the public who wish to have access to alternative medicine. There are sufficient number of homeopaths in Ontario to warrant and support a college of homeopaths of Ontario.
We acknowledge that experience and regulation is of great assistance when developing policies, procedures and programs. We expect to consult with and draw on the expertise of the many established regulatory bodies in Ontario and include representatives from other colleges on our transitional council. In our view, such collaboration and consultation is a more beneficial approach than relying on a composite college system.
Therefore, we recommend that schedule P to Bill 171 be amended to provide for separate regulatory bodies for homeopaths and naturopaths by creating a college of homeopaths of Ontario and a college of naturopaths of Ontario.
With respect to the use of the title “doctor,” the OHA and OCHM, amongst other homeopathic groups, such as the HMCC, have worked to establish the minimum standards for theoretical and practical knowledge required to undertake the diagnosis of conditions, treat within the scope of practice and make inter-professional referrals in the best interests of patient care.
The OHA recognizes that some homeopaths in Ontario have advanced theoretical and clinical training above those minimum standards. For example, homeopaths in many jurisdictions are required to have a medical or osteopathic medicine degree in addition to postgraduate training in homeopathy. The qualifications of such homeopaths match or exceed the academic and clinical requirements for regulated health professionals in Ontario, such as chiropractors, dentists, optometrists or psychologists, who are currently entitled to use the protected title “doctor.”
The government of Ontario has already acknowledged that within a regulated health profession there are practitioners with a range of experience and training and that it is appropriate in the public interest to recognize advanced academic and clinical training with the use of the title “doctor.” For example, in the Traditional Chinese Medicine Act, 2006, all members of the College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario are provided with the restricted title “traditional Chinese medicine practitioner” or “acupuncturist.” However, the council can make regulations regulating or prohibiting the use of the title “doctor” and can prescribe a class of certificates of registration for members who use the title “doctor.”
Ms. de Szegheo-Lang: We also feel that some controlled acts belong within the scope of homeopathic practice.
Communicating a diagnosis: Diagnosis is a vital and fundamental aspect of the homeopathic system of medicine. A homeopathic diagnosis is based on a patient’s physical, mental and emotional condition, objective and subjective symptomology, history, diagnostic test results and physical exam findings. A homeopathic diagnosis is necessary to prescribe the correct homeopathic remedy and to identify and discuss treatment and conditions, including those that require urgent emergency medical attention.
Administering, by injection or inhalation, a prescribed substance: Traditionally, homeopathic medicines were administered orally or, if indicated, by inhalation. However, scientific research being conducted in a number of medical centres in Europe has established that some homeopathic medicines are more effectively administered by injection, so it is standard homeopathic practice in some jurisdictions to administer some homeopathic medicines by injection. Permitting a homeopath to perform the controlled act of administering a prescribed homeopathic substance by injection in accordance with the appropriate regulations is in the public interest. This will allow the most effective homeopathic treatment under prescribed conditions that protect the public.
Prescribing, dispensing, selling or compounding a drug as defined in subsection 117(1) of the Drug and Pharmacies Regulation Act: Most homeopathic medicines used in the practice of homeopathy in Ontario are defined as “natural health products” pursuant to the natural health products regulations made under the Food and Drugs Act. This means that they are not considered to be drugs as defined in the Drug and Pharmacies Regulation Act and homeopaths can prescribe, dispense, sell or compound them. However, there are some homeopathic medicines contained in the accepted homeopathic pharmacopoeias which are not defined as natural health products. Homeopaths in Ontario cannot legally use them in the practice of homeopathy because, absent being defined as “natural health products,” they are defined as drugs. It is a controlled act to prescribe, sell or dispense a drug.
In order to ensure that homeopaths and their patients in Ontario can benefit from the full range of homeopathic medicines in the homeopathic pharmacopoeia, homeopaths require the authority to perform the controlled act of prescribing, dispensing, selling and compounding homeopathic medicines.
Therefore, we recommend that schedule P to Bill 171 be amended to include the following: In the course of engaging in the practice of homeopathy, a member is authorized, subject to terms, conditions and limitations imposed on his or her certificate of registration, to perform the following:
(1) administering, by injection or inhalation, a prescribed homeopathic substance;
(2) communicating a homeopathic diagnosis that may be identified through an assessment that uses homeopathic techniques and includes assessing the individual’s physical, mental and emotional conditions and symptoms, and is used to prescribe the appropriate homeopathic medicine or therapy;
(3) prescribing, dispensing, selling or compounding a homeopathic medicine which is defined as a drug in subsection 117(1) of the Drug and Pharmacies Regulation Act.
We note that the council would also require the authority to make regulations concerning the three controlled acts.
Thank you for your time.
The Chair: Thank you. There’s enough time for one question. I’m making an arbitrary decision that it go to the government because they did not get in on the first rotation. Mr. Fonseca.
Mr. Fonseca: Thank you, Chair. You’re so kind.
I’d like to thank the Ontario Homeopathic Association. I’d just like to tell you that the commitment from this government is to make sure that right now there is an equal representation on the college between naturopaths and homeopaths. We are also seriously looking at separating the college.
I want to ask you a question in regard to standards in terms of education standards for a doctor. What standards are there? Is there a standard exam that all homeopaths take? Can you tell me a little bit about that?
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Ms. de Szegheo-Lang: No. As far as the Ontario Homeopathic Association, most members will have a BA coming into homeopathic study and then do what is equivalent to about a five-year university tenure in homeopathy.
Ms. Vins: We’re also working toward increasing the standards to match those that exist in other jurisdictions in the world that require medical degrees, training in the health sciences and an extensive training in homeopathy and in the clinic as well.
The Chair: We’re out of time. Thank you.