What we stand for

At CEBCoM, we're committed to bringing together the Complementary Medicine community and the best healthcare evidence on all matters related to Complementary Medicine and Integrative Medicine.

We will support the best in CM research, the best education of CM Practitioners, and the best use of evidence by those practitioners because we believe it will provide the best health for everyone.

We love our gadgets, and believe they are the ideal way to gather and deliver information right now. We are building evidence, and that requires open and wide communications. We will listen, and reflect what you tell us back to our community.

There are enemies of Complementary Medicine. And while we intend to keep an eye on them, we believe that moving positively forward with bringing CM into the mainstream will see them wither and fade.

Still, we don't mind a fight if that's what's needed ;)


Background for TGA survey

We're interested in your vote in this survey. Yes, we're demanding! We want you to read and know what Proposals 5 and 6 of the TGA Impact Statement (pages 42 to 45) are, so I have summarised this below. We are mainly interested in the Proposal 6, related to information on healthcare products to naturopaths, herbalists and other healthcare practitioners who have not yet achived national registration.

To answer the survey, you may need to know that:

  1. Many healthcare practitioners are registered nationally with AHPRA - the Australian Health Practitioner Regulation Agency. Naturopaths, western herbalists and homoeopaths are not.
  2. Proposals 5 and 6 separate health practitioners nationally registered from those who are not, and proposes different rules for each on advertising and education
  3. Proposal 5 Option 2 would limit the use of "higher risk medical devices", including some "in vitro diagnostic devices", because there is "need for involvement of a healthcare practitioner to ensure safe use of the product". This would presumably be a AHPRA registered healthcare practitioner, plausibly removing naturopaths, herbalists and homoeopaths from using some diagnostic devices.
  4. Proposal 6 Option 2 on advertising directed to health professionals again seeks to treat naturopaths, herbalists and homoeopaths as if they are the equivalent of the untrained general public, and would have the effect of them being unable to maintain their education and knowledge on healthcare products, and this would severely reduce their ability to advise their clients on quality healthcare.
  5. Option 1 on both proposals leaves the status quo, with naturopaths, herbalists and homoeopaths continuing as valuable and up-to-date health care practitioners in Australia.
  6. There is an option for submission of another Option - an "Option 3" - which we are recommending.


YES, we at CEBCoM DO believe that all healthcare practitioner bodies need to move into the national independent regulatory model, and to break the shackles of the peak bodies who serve their own interests rather than the long-tem interests of their members. 

But the deadline of one year is almost impossible, even for peak bodies committed to national registration.

That's why we propose an "Option 3" for both of these proposals - a moritorium for 5 years while the peak bodies of natural therapists move to AHPRA regulation and registration within within that 5 year period.

Enough from us - give us your opinion in this survey. We have put our option 3 in, but you can add your own, and we will take that view forward in our submission to the TGA.




TGA Deadline extended

The TGA has extended the deadline for submissions on the impact statement by one week, from 12th to 19th July, allowing a reasonable timeframe for consumers and practitioners to respond to the Proposals.

We urge you to READ the relevant sections (page 42-45) of this document, and use this coversheet in your submission. All the details you need for making a submission (and make it YOURS, not a pro-forma) can be found here on the TGA website.

What we are aiming to do is to ensure that fully trained naturopaths, herbalists and homoeopaths are able to continue to receive information and training on medical devices and complementary healthcare products, and use their expertise to inform and aid their clients. YES, these groups do need to move on to a Naional Registration model, and we should support those groups such as ARONAH who are doing this.

But for now, stopping a process with no benefits for health consumers is a priority.


Responding to the TGA "Impact Statement"

We want you all to know about this TGA regulation impact statement, and we are devoting our FoCM App exclusively to this process until the deadline for submissions on 19th July. We have a very limited period of time to approach the TGA with input on the potential negative consequences of the proposed changes, principally The Option 2 of Proposals 5 and 6 on page 42-45 of this document.

Read our take on the details of this proposed change in regulations here. If you're as concerned as we are, take our survey on your response to the TGA Options, and we will use these results to inform our own submission.

Option 2 of the Proposals seek to limit the types of "advertising" on medical devices and therapeutic products to homoeopaths, western herbalists and naturopath to advertising available to the general public. The TGA separates these practitioners, who have not become part of the national registration process in Australia, from those others such as doctors, chiropractors, osteopaths and traditional Chinese medicine practitioners who are on the national registration program. 



One of us (MD) was president of the Natural Healthcare Alliance  (NHCA) In Mid-2000 period for about five years. He and a group of other dedicated practitioners worked hard to moving natural health care into the medical mainstream, and identified the necessity for joining in a national registration process is essential for the ongoing relevance and survival of natural health care practitioners in Australia.

Certain large groups representing natural healthcare practitioners, principally ATMS and ANTA,  resisted the process which ultimately led to the disbanding of the NHCA four years ago.

Since that time, critics of complementary medicine such as the Friends of Science in Medicine have been chipping away the gains made during those five years, attacking education and research in complementary medicine, and pressuring universities to drop courses that they regarded as "unscientific". 

Our concern is that these TGA proposals are the "thin edge of the wedge", and that once advertising is limited to these professional groups, they will be unable to participate in quality ongoing educational programs, and will be unable to maintain their professional development, and relevance to the community in health care in Australia.

Groups such as ARONAH (The Australian Register of Naturopath and Herbalists) have arisen to represent the interests of the many naturopath and herbalists who do see national registration as a valuable attainment, and one which protects not only the public, but the profession itself.

The Centre for Evidence-Based Complementary Medicine supports ARONAH in this endeavour,  and we are looking at ways of contributing materially to their process.

This is not a single battle, and whether or not the TGA makes changes to the advertising regulations will not in the long-term impact the uptake of complementary medicine and natural Healthcare by consumers.

We professionals need to get on board with issues of accountability, educational quality, evidence-informed practice, and effective healthcare delivery to a public that increasingly sees natural healthcare is the first option in prevention and health care.


We urge naturopaths, herbalists, homoeopaths and other natural health modalities not nationally registered to express their concerns and provide input to the TGA before 5PM Friday 19 July 2013 (it was extended a week after pressure). Electronic submissions in MS-Word format are preferred and should be emailed to Details of how to do this can be found at this TGA page.



About CEBCoM

CEBCoM is short for the Centre for Evidence-based Complementary Medicine. We are a group of three Australian medical practitioners with over 100 years of combined experience in Complementary Medicine (CM) and Integrative Medicine (IM).
We are Dr Joachim Fluhrer, Dr Mark Donohoe and Dr Emmanual Varipatis.You can find out more about us on our CEBCoM website.
CM is often termed Complementary and Alternative Medicine (CAM) outside Australia. We believe the term, "alternative" can be divisive and worsen the plight of health consumers who feel the need to chose between two "alternatives". We see Western Orthodox Medicine and CM currently as separate, but moving towards a more "integrated" model of healthcare in which all health modalities and practitioners receive education in the history and philosophy of traditional and modern healthcare systems and cultures, then move into healthcare in their chosen areas with full awareness of and respect for their healthcare colleagues. 
The best outcome would be a seamless, affordable and sustainable healthcare system from conception to the grave, with a much greater focus on prevention and early, simple intervention, achieving the dual outcomes of a long and healthy life.
The three doctors who run CEBCoM come from a background of primary care practice, so we are well aware of the limitations of double-blind trials and meta-analyses in their conversion to useful outcomes for health consumers. 
Some years back, we decided that all health care should be backed by appropriate evidence. We realised that the level of evidence required for chemotherapy drugs was very different to that required for, say, chamomile tea before bedtime. We need to assemble the evidence appropriate to the modality, product, procedure or advice. Overdoing the evidence can make simple and safe interventions unaffordable, as trials and research cost a lot of money. But a bias of evidence or a lack of evidence can be very dangerous as well, as we now know from HRT and Vioxx disasters on the medical side.
The job, as we see it, is to put medicine back where it works best - in disease diagnosis and treatment - and identify those low cost, safe and simpler prevention and early intervention which have been the strength of Complementary Medicine for centuries.



"FoCM"? Please explain!

CEBCoM established the Friends of Complementary Medicine (FoCM) and the upcoming App to achieve three main goals:

1. To provide a simple and beautiful presentation of the news about Complementary Medicine and the evidence which is building to support its safety and benefits;

2. To provide a focal point for a community to come together to contribute and chatter and gossip about this news, provide new leads and ideas, and have some fun; and

3. to identify the threats to CM, identify those involved, and protect CM education, research and practices against unreasonable attack

FoCM is NOT a club or a society. It is a community of you and your colleagues, with a simple sign-on process within this App allowing you to put your name to what you believe about CM, and stand together as a group to protect CM through its growing phase. 
We need the best educated practitioners we can manage, and the best quality CM research in our Universities to define what works and what does not. What is harmless and what may be harmful. 
And we need this so that we and our children can enjoy a better healthcare system in the future than the one currently dominated by failing hospital systems and unsustainable growth of pharmaceuticals and medical high technology.
So, if you believe as we do that CM is important, and needs to be available for all Australians as part of an integrated healthcare system, we urge you to download the App once it is released, sign up and contribute to the CM community through the App.
You and your iPad or iPhone can make a real difference to the healthcare of the future in this country.