A. Introduction As a result of increasing interest in and use of Traditional, Complementary, and Alternative Medicine (TCAM) therapies in medical practices and as a necessary function of its duty to protect the public interest, the UAE Ministry of Health requires all TCAM physicians and practitioners to comply with professional, ethical and practice standards, and act as responsible agents for their patients.
The following guidelines assists in educating and regulating: (1) TCAM practitioners who may work independently and (2) Those TCAM practitioners who co-manage patients with licensed Medical practitioners in clinics or polyclinics and hospitals
This document focuses on encouraging the medical community to adopt consistent standards, ensuring the public health and safety by facilitating the proper and effective use of TCAM treatments, while educating physicians on the adequate safeguards needed to assure these services are provided within the bounds of acceptable professional practice
B. Licensing: In exercising its licensing authority the Ministry of Health has the inherent power to determine precisely the qualifications a TCAM applicant must possess. It may investigate educational credentials, professional competence, and moral character. The applicant bears the burden to prove his fulfillment of all requirements for licensure.
The practice of medicine consists of the ethical application of a body of knowledge, principles and methods known as medical science and that these objective standards are the basis of medical licensure for physicians and TCAM practitioners. Therefore no person shall practice TCAM in the UAE without first being licensed by the Ministry of Health. Successfully passing TCAM qualifying examination is a precondition for evaluation and grant of TCAM practice license.
Following is a list of M.O.H recognized TCAM specialties: Herbal Medicine Traditional Islamic Medicine (Unani) Traditional Chinese Medicine Traditional Indian Medicine (Ayurveda and Siddha) Homeopathic Medicine Naturopathy Chiropractic Medicine Osteopathy
D. Eligible qualifications for TCAM Examinations: 1. Examples of Masters level Courses (Usually 2 years Post Graduation): Member of Faculty of Homeopathy (M. F. Hom. from Faculty of Homeopathy, UK) or equivalent Doctor of Medicine in Homeopathy (MD in Homeopathy) or equivalent Doctor of Medicine in Ayurvedic Medicine (MD in Ayurvedic Medicine) or equivalent Doctor of Medicine in Unani Medicine (MD in Unani Medicine) or equivalent Doctor of Medicine in Traditional Chinese Medicine (MD or Masters in TCM)
2. Examples of Bachelor level Courses (Usually 4 to 5 ½ Years College Level Education): Doctor of Chiropractic Medicine (DC) or equivalent Doctor of Naturopathy (ND) or equivalent Bachelor of Naturopathy and Yogic Sciences (BNYS) Bachelor in Homeopathic Medicine and Surgery (BHMS) Bachelor in Ayurvedic Medicine and Surgery (BAMS) Bachelor in Siddha Medicine and Surgery (BSMS) Bachelor in Unani Medicine and Surgery (BUMS) Bachelor in Osteopathy Bachelor in Traditional Chinese Medicine
3. Examples of Diploma Level Courses (Usually 3 to 4 years College Level Education): Diploma in Naturopathy Diploma in Homeopathy Diploma in Osteopathy Diploma in Acupuncture Diploma in Herbal Medicine Practice Category: The educational qualifications, depth and field of experience, and results of the TCAM examinations and recommendations from examination board would be considered for evaluating the candidates and the category for their practice. The evaluation committee may permit the following two categories of TCAM practice privileges on the licenses: 1. Independent TCAM practice category: Usually TCAM practitioners, who have basic medical degrees or MD level qualifications in TCAM specialties or those who have extensive proven experience and/or as per recommendations of the examination board, may be awarded independent TCAM practice. These practitioners may start their own clinics or treatment centers and may employ other supporting staff like nurses, technicians and even other TCAM specialists, as per their needs and requirements. 2. Under Clinic License category: These practitioners would be permitted to work only in an established polyclinic or clinic where a licensed Medical General Practitioner is on duty. Based on the policy or decision of the management of the clinic, these TCAM practitioners may see patients directly or after referral from the resident Medical G.P. Good TCAM care 1.Physicians, indeed all health-care professionals, have a duty not only to avoid harm but also a positive duty to do good— that is, to act in the patient’s best interest[s]. This duty of beneficence takes precedence over any self-interest. Furthermore, patients have a right to seek any kind of care for their health problems. It is recognized that a full and frank discussion of the risks and benefits of all medical practices is in the patient’s best interest. 2.There are varying degrees of potential patient harm that can result from either conventional medical practices or TCAM: 3.Economic harm, which results in monetary loss but presents no health hazard; 4.Indirect harm, which results in a delay of appropriate treatment, or in unreasonable expectations that discourage patients and their families from accepting and dealing effectively with their medical conditions; 5.Direct harm, which results in adverse patient outcome. TCAM practitioners are responsible for practicing good medicine by complying with professional standards and regulatory mandates. In consideration of the above potential harms, the Ministry of Health will evaluate whether or not a TCAM practitioner is practicing appropriate practice by considering the following practice criteria.
Is the licensed TCAM practitioner using a treatment that is: Effective and safe? (Having adequate scientific evidence of efficacy and/or safety or greater safety than other established treatment models for the same condition) Effective, but with some real or potential danger? (Having evidence of efficacy, but also of adverse side effects) Inadequately studied, but safe? (Having insufficient evidence of clinical efficacy, but reasonable evidence to suggest relative safety) Ineffective and dangerous? (Proven to be ineffective or unsafe through controlled trials or documented evidence or as measured by a risk/benefit assessment)
Good TCAM care must include: An adequate assessment of the patient’s condition, based on history, clinical sign and symptoms and if necessary an appropriate examination
1) Evaluation of Patient Prior to offering any TCAM treatments, the TCAM practitioners shall conduct an appropriate medical history and physical examination of the patient as well as an appropriate review of the patient’s medical records. This evaluation shall include, but not be limited to, conventional methods of diagnosis and may include other methods of diagnosis as long as the methodology utilized for diagnosis is based upon the same standards of safety and reliability as conventional methods, and shall be documented in the patient’s medical record.
2) Documentation of Medical Records The TCAM practitioners should keep accurate and complete records to include: (a) The medical history and physical examination; (b) Diagnostic, therapeutic and laboratory results; (c) Results of evaluations, consultations and referrals; (d) Treatment objectives; (e) Discussion of risks and benefits; (f) Appropriate informed consent; (g) Treatments; (h) Medications (including date, type, dosage and quantity prescribed); (i) Instructions and agreements; (j) Periodic reviews Records should remain current and be maintained in an accessible manner, and readily available for review. 3) Treatment Plan The TCAM practitioner may offer the patient TCAM treatment pursuant to a documented treatment plan tailored to the individual needs of the patient by which treatment progress or success can be evaluated with stated objectives, such as pain relief and/or improved physical and/or psychosocial function. Such a documented treatment plan shall consider pertinent medical history, previous medical records and physical examination, as well as the need for further testing, consultations, referrals, or the use of other treatment modalities. The treatment offered should: i) Have a favorable risk/benefit ratio compared to other treatments for the same condition; ii) Be based upon a reasonable expectation that it will result in a favorable patient outcome, including preventive practices; iii) Be based upon the expectation that a greater benefit will be achieved than that, which can be expected with no treatment. 4) Consultations and/or referral to M.O.H licensed Medical General Practitioners and Specialists The TCAM practitioners may refer patients as necessary for additional evaluation and treatment in order to achieve treatment objectives. However, the Medical G.P or Specialist is responsible for monitoring the results and should schedule periodic reviews to ensure progress is being achieved. 5) Clinical Investigations As expected of those physicians using conventional medical practices, physicians providing TCAM therapies while engaged in the clinical investigation of new drugs and procedures are obligated to maintain their ethical and professional responsibilities. Investigators shall be expected to conform to the following ethical standards: i) Clinical investigations should be part of a systematic program competently designed, under accepted standards of scientific research, to produce data, which are scientifically valid and significant. ii) A clinical investigator should demonstrate the same concern and caution for the welfare, safety, and comfort of the patient involved as is required of a physician who is furnishing medical care to a patient independent of any clinical investigation. iii) Furthermore, investigators shall abide by all M.O.H. guidelines and safeguards, to ensure the risks to the patient are as low as possible and are worth any potential benefits. In providing TCAM therapies, practitioners must: 1) Recognize and work within the limits of their professional competence 2) Be willing to consult allopathic and alternative medicine colleagues 3) Be competent when making diagnosis and when giving or arranging treatment 4) Keep clear, accurate and contemporaneous patient records which report the relevant clinical findings, the decisions made, the information given to patients and any drugs, regimen or treatment prescribed. 5) Keep colleagues well informed when sharing the care of patients 6) Pay due regard to efficacy and use of resources 7) Prescribe only the treatment, drugs or appliances that serve the patient’s needs. G. Prohibitions and restrictions: TCAM practitioners are prohibited from: i. Carrying out procedures not related to their specialty, including performing operations ii. Administering injections, parenteral solutions and vaccinations iii. Practicing midwifery iv. Withdrawing blood v. Claiming or offering to treat cancer vi. Treating infectious, communicable diseases vii. Performing internal examinations viii. Prescribing controlled medicines or drugs such as “Prescription Only” medications ix. Sale of medicines, goods, or health related products from their clinics or treatment centers. Grounds for discipline These may include the following: i. Advertising that is false or misleading or that claims the cure of any condition or disease ii. Alcohol or drug dependency iii. Fraudulent procurement of a license iv. Failure to cooperate with a medical licensing committee investigation v. Participation or involvement in a criminal abortion vi. Sexual advances toward or involvement with patients vii. Sales of medical certificates viii. Charging a patient for services not rendered ix. False or inaccurate patient records x. Improperly prescribing, administering or dispensing controlled substances xi. Diverting or giving away controlled substances xii. Transmission of disease by improper sterilization procedures xiii. Weight control therapy abuse xiv. Patient neglect and abandonment xv. Failure to comply with a patient’s request to furnish a health record or report required by law. xvi. Unprofessional or dishonorable conduct or gross misconduct xvii. Gross or repeated malpractice or the failure to practice TCAM at a level of care, skill, and treatment which is recognized and acceptable xviii. Exercising influence on a patient in such a manner as to exploit the patient for financial gain of the TCAM practitioner or of a third party which shall include, but not limited to, the promotion or sale of services, goods or appliances. xix. Splitting fees, or promising to pay a portion of a fee or a commission, or accepting a rebate xx. Directly or indirectly engaging in threatening, dishonest, or misleading fee collection techniques xxi. Failure to comply with legal requirement, such as reporting venereal and infectious disease, birth registration, and suspicious death or injury xxii. Permitting, aiding, or abetting unlicensed personnel to perform medical procedures normally restricted to a licensed practitioner xxiii. Conviction of a crime xxiv. Any other act the Ministry of Health by rule may define. TCAM practitioners who do not possess basic medical degree (MBBS, MD, etc.) are prohibited from claiming to be or leading people to understand that they are an allopathic, or conventional medical doctor. TCAM practitioners are also prohibited to prevent any person from being treated by an allopathic physician or improperly influencing any person to abstain from such treatment. References and other sources: i) Federation of State Medical Boards, USA: Guidelines for the use of Complementary and Alternative Therapies in Medical Practice. ii) Legal Medicine, Fourth Edition, American College of Legal Medicine iii) Legal Status of Traditional Medicine and Complementary / Alternative Medicine, WHO iv) Complementary Medicine, New Approach to Good Practice, British Medical Association v) Overview of Legislative Development Concerning Alternative Health Care in the United States, A Research Project of the Fetzer Institute, by David M. Sale, J.D., LL.M. vi) Alternative Medicine, Expanding Medical Horizons, N.I.H, Bethesda, USA vii) Complementary Therapies for Pharmacists, by Steven B Kayne
Compiled and edited by the Office of TCAM, Federal Ministry of Health, UAE For suggestions and comments: Email: email@example.com