Medical Board of Australia Public Consultation – Open for Submissions

Medical Board of Australia’s public consultation on
“Guidelines for registered practitioners –
Complementary and unconventional medicine and emerging treatments”

The Medical Board of Australia (MBA) is currently undertaking public consultation on its proposed new medical guidelines, called “Guidelines for registered medical practitioners – Complementary and unconventional medicine and emerging treatments”. These guidelines aim to strengthen the regulation of doctors who prescribe complementary or unconventional medicine (including unconventional off-label prescribing and long term antibiotics), as well as emerging treatments. To read the guidelines and discussion paper, click the link in this paragraph.

Whilst these guidelines are not about ME/CFS directly, they will impact the ME/CFS community. For an illness like ME/CFS, for which conventional medicine has very little to offer, and for which there is little published evidence for even well-recognised ME/CFS treatments, many treatments which ME/CFS patients access through their doctor will be covered by these guidelines.

The MBA is asking the public to choose between two options:

Option 1: Retain the status quo of providing general guidance about the Board’s expectations of medical practitioners who provide complementary and unconventional medicine and emerging treatments via the Board’s approved code of conduct.

Option 2: Strengthen current guidance for medical practitioners who provide complementary and unconventional medicine and emerging treatments through practice-specific guidelines that clearly articulate the Board’s expectations of all medical practitioners and supplement the Board’s Good medical practice: A code of conduct for doctors in Australia.

Emerge Australia recommends Option 1

Emerge Australia believes that the proposed guidelines have been insufficiently justified and will likely result in unintended consequences for patients’ ability to access care, and recommends that the Board retains the existing guidelines.

Making a Submission

The consultation process is open to anyone to submit feedback on the guidelines. The deadline has been extended and will now close on 30 June 2019. We encourage members of the ME/CFS community to submit even brief feedback on this important document and have prepared this short guide to help anyone who would like to do so.

To make a submission, send an email to and include ‘Public consultation on complementary and unconventional medicine and emerging treatments’ as the subject.

Key points to make in support of Option 1

It’s not essential to make all of these points. Make as many or as few as you feel comfortable with. Even a very brief single paragraph submission will be helpful. Do not name your doctor in your submission.

  1. Tell your story about benefit you receive from complementary or unconventional medicine, or emerging treatment (CUMET) prescribed by a doctor.
    These guidelines arose from a desire by the MBA to protect patients from harm. However, they have overlooked the many patients who benefit from CUMET and how vital these treatments may be for their wellbeing.
    Focus your story only on those treatments which are prescribed by a doctor. Describe how you benefit. Some examples of relevant treatments covered by the guidelines include vitamin injections or infusions, supplements, unconventional off-label prescribing (like low dose naltrexone), long term antibiotics, or herbal treatments or acupuncture prescribed by a doctor.
  2. The need for these guidelines has been insufficiently justified.
    The existing guidelines cover all the issues which the MBA identified as needing to be addressed. The MBA also provided examples of complaints which have been upheld against doctors practising CUMET, suggesting that the existing guidelines are providing sufficient protection for the public.
  3. The proposed guidelines are likely to have unintended consequences which will impact the ability of patients to access appropriate care, and impact patients’ freedom of choice.
    We believe these guidelines will disproportionally affect people with illnesses like ME/CFS, for which there are no safe evidence-based treatments and for which conventional medicine has little to offer. We are concerned that these guidelines will increase the burden on those doctors practising CUMET, and may discourage doctors from practising in this way, or increase patient costs of accessing these treatments, which is likely to result in increased harm to patients.
    We are especially concerned about patients having reduced access to helpful treatments, and losing freedom of choice in their care. We also believe that it is better for patients to access treatments through doctors, a profession which is already well-regulated, than turning to other health professionals who will be less well-regulated and could therefore pose greater risk of harm to patients.
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