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Letters to the Editor Issue 167

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listed in letters to the editor, originally published in issue 167 - February 2010

How Regulation is Developing for Craniosacral Practitioners

by Roger James

The Craniosacral Therapy Association (CSTA)  decided almost a year ago to continue to combine its regulatory functions with its role as a professional association. The AGM in October decided to make it easier for members to register both with CSTA and with the Complementary and Natural Healthcare Council (CNHC) if they so wish. That will be possible when the CNHC opens its register to craniosacral therapists sometime in March 2010.

For most members dual registration should not be necessary, as the CSTA provides all the safeguards anyone coming to them for a treatment may need – all CSTA members are properly trained, have full insurance, and are covered by the code of ethics. Only a tiny, tiny fraction of treatments lead to any complaint – a tribute to the care and skill with which all members work and also a reflection of the fact that craniosacral therapy is a very safe activity. If anything serious happens then a client can send in an official complaint which will be rigorously investigated.

No external regulator can do any more to protect the client than the CSTA already does. That is why it is puzzling that some people are still saying that regulation by the CNHC would be better than what we have now. There is an argument that the CNHC provides more impartial regulation (the Shipman argument that a profession will look after its own no matter what crimes a member may commit) but where is the evidence that CSTA regulation is a whitewash job?

When setting up a CAM regulatory federation (what we now know as CNHC) was first mooted, a lot of sense was talked about the pros and cons of such an arrangement. One key remark was made by Maggy Wallace, now executive chair of the CNHC, in a paper she wrote about the feasibility of setting up such a federation. She wrote that there were a number of criteria which must be met by participant therapies. One of these was that:
"The profession must wish to participate in the establishment of a federal approach for complementary healthcare and must demonstrate its commitment to the concept." (Reference: Wallace – PFIH Feasibility/Implementation Study 2006)

Now what is the evidence that craniosacral therapy wishes to participate in this federal approach, which is now a reality? The CSTA conducted a ballot on this very subject 12 months ago. While a substantial minority voted for the federal model, the clear outcome of the vote was the rejection of the idea that we should register with the CNHC. The other large body of craniosacral practitioners, the Upledger-trained members of the Cranio-Sacral Society, had already made a similar decision not to have anything to do with the CNHC. That left two much smaller organisations, the craniosacral special interest group of the Chartered Society of Physiotherapists and the International Cranial Association. How far the views of their members have been tested I do not know, but they remained in the Cranial Forum which became a strongly pro-CNHC body until it rather mysteriously dissolved itself last autumn to make way for a new Cranial Forum. (Puzzled? So was I.)

Does this mean that the profession of craniosacral therapy wishes to 'participate in the establishment of a federal approach' – of course not. We fail the test proposed by Maggy Wallace and should not be involved.

But it is not just us. Before the CNHC came into being, a large section of the Reflexologists and Reiki practitioners set up a breakaway organisation, known as GRCCT (General Regulatory Council for Complementary Therapies). Recently, at least two reflexology associations have expressed strong opposition to CNHC. Do these professions 'wish to participate in the establishment of a federal approach for complementary healthcare'? Clearly not on the CNHC model anyway. There are signs too of uncertainty, to say the least, among some of the other professions expected to jump on the CNHC wagon.

Somewhere along the line, the concept of willing professions joining a federation they have decided in favour of has been lost in the heat of controversy. The picture is rather of professions being dragged kicking and screaming towards CNHC regulation by minorities of their members.

But there are other reasons why people still fight shy of the federal concept as embodied by the CNHC.

The CSTA is 'owned' by the members. They can go along to our AGM and if they can get enough support can change the rules of the Association or any aspects of its policies. It is no shame to have disagreements and come to decisions which not everybody is happy with. In fact it is healthy to have differences of opinion and thrash them out in lively debate, providing it is done with respect.

The CNHC is not owned by therapists in that sense. It is run by a board of nine non-therapists and although this board seeks advice from therapists on peripheral committees, there is no meeting you can go along to and vote for change. If you register with the CNHC you don't get to vote who those nine board members should be.

There is a part of the CNHC which is owned by the professions concerned and these are the so-called profession specific boards (PSBs). A 'cranial' PSB was set up recently so that in due course craniosacral therapists can register with CNHC if they want. But unfortunately the body that chose this profession specific board did so after both the two main CST associations I have already mentioned had withdrawn from the Forum who did the appointing. So it is hard to see how 'our' PSB is owned by the profession in any real sense.

It can't be said often enough that the CNHC is not a government body and does not speak with the authority of government. It has some government money to subsidise its operations in the early years – and that is the limit of its official standing.

In mid-January 2010 CNHC had just under 1,400 people registered with it. The therapies covered by its register are Massage, Nutritional therapy, Reflexology and Aromatherapy, together with three newcomers: Shiatsu, Alexander and Yoga.  Others, including craniosacral therapy will follow in due course. Now the therapists who have registered with the CNHC represent only a small fraction of those who could do so. The biggest take-up is by Massage therapists, but less than 9% of those eligible have chosen the CNHC so far, and this part of the register has been open since January 2009. The Nutritional therapy part of the register has also been open for most of 2009 and only has just over 160 registered, around 10% of those eligible. (This is based on the total numbers in each therapy who would be eligible to register, taken from rather approximate estimates quoted in the 2006 Wallace paper already cited.)

Why the small numbers? One obvious factor is that the whole thing is voluntary. These therapies are not like Osteopathy and Chiropractic which are regulated by Act of Parliament. No-one need register with the CNHC unless it suits them. (Exactly the same thing is true of the CSTA of course.)

Another important factor is the existence of the breakaway GRCCT which has attracted large numbers of Reflexologists, Reiki practitioners and others. As of last autumn it had over 7,000 people on its register.

Not only that, but some professional associations apart from those in Craniosacral therapy have set their face against CNHC. There are around 100 associations in the 11 therapies that started along the CNHC road, so knowing what they are all doing is not easy. What is certain is that the formation of CNHC has sparked discord in nearly every therapy.

Interesting that those who first advocated a federal CAM regulator insisted that this should be a slow, measured process designed to take all those involved along with it at a pace they felt comfortable with. The fact that this has not happened suggests to me that the CNHC was started in a hurry and what should have taken years to come to fruition was done in a year or two, with the unhappy results we see.

Whether the CNHC will succeed we shall have to see. I said at the Craniosacral Therapy Association AGM that it was a failing organisation and would have to cease trading if the government money runs out in a couple of years and they have too few registrants to break even. Someone loudly objected that I could not know if this would happen, and this is very true – hecklers often speak the truth. We shall see.

But there is something else to mention, which is how CNHC goes about its business. It is, remember, just a Regulator. Its job is to make sure that the public are protected when they go to a therapist for treatment. This includes making sure that practitioners are properly trained. What one would expect, therefore, is that people wanting to register would send to the CNHC details of their qualifications, proof of insurance and so on.

But, here a surprise awaits us. The CNHC have set up a scheme under which it is professional associations which verify therapists' qualifications. That is what the sometimes heated discussion at The CSTA AGM was about, because we were told we had to join the new Forum being set up for Craniosacral therapy in order to be able to verify members' qualifications should they wish to register with us and the CNHC. The AGM agreed to this. There is an alternative and very expensive option to apply direct to the CNHC, but this is designed for those with no formal qualifications or coming from overseas.

But there is something odd here. A well-established organisation called the Federation of Holistic Therapists says on its website that it will verify the qualifications of non-members for a fee of £15. This involves providing proof of qualification but also getting a character reference. But isn't this checking of qualifications what the regulator itself should be doing? How safe is this for the client picking a therapist off a list? Is not our system, where we know that each and every member has gone through a rigorous training at a college we know, infinitely safer? (We have a few members who have come in via the associate member route but these too are rigorously checked to see if their training has been up to our standard.)

Now it gets tricky, but it is really important to try to understand what follows. At the AGM I described the CNHC verification system as Byzantine. Lisa McCaul, CNHC administration officer, has helpfully explained this part of it to me, and I have not changed my mind about my description. This is what can happen when the CNHC register is open to craniosacral therapists:

If a professional association (PA) belongs to the Cranial Forum and has an agreement with the CNHC, then any Craniosacral therapist can apply to any PA in the Cranial Forum which has such an agreement and ask them to verify his qualifications. He can do this even if he belongs to some other association which may not itself belong to the Forum. In other words his qualifications can be verified by a body that initially knows nothing about him and to which he does not belong. Please don't blame me – I didn't make this up.

Both the Federation of Holistic Therapists and the Complementary Therapists Association have such agreements with CNHC in respect of the therapies currently on the CNHC register. Interestingly, the (old) Cranial Forum announced in August that the Federation of Holistic Therapists was joining the Forum.

The clear implication of all this is that we did not need at the AGM to agree, with much controversy, to be represented on the new Cranial Forum. Any CSTA member who wants to register with the CNHC can just go to an organisation which verifies the credentials of therapists who are not their members and fulfils the other criteria. Now that this is clear one may sigh deeply and say, 'Hey ho!'

Perhaps what the CSTA needs is space away from these controversies to get on with the work it has to do, to help all of us be better and more successful practitioners.

About the Author
Roger James is the Secretary of Craniosacral Therapy Association  Tel: 01342 810112  

Further Information

Please contact the Craniosacral Therapy Association  Tel/Fax: 07000 784735  


Revised and reprinted version of How Regulation is Developing by Roger James, reprinted from The Fulcrum Issue 49: 2-4. Winter/Spring 2010.


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