There has been considerable discussion in the media and on social media surrounding the proposed changes to legislation to remove private health rebates for CAM

I have penned a letter to my sitting member of the house of representatives in protest to these proposed legislative changes.

It makes no sense, either economically or ethically to introduce these changes.

The only real beneficiary is big Pharma. Plain and simple.

I implore the honourable John Gardener to represent me to Government, to oppose this legislation on my behalf with a strong voice and commitment on this issue to support natural medicine and the preservation of health rebates.

Not only do I have a passion for helping people naturally, I also believe in the democratic right of choice of every individual to be able to implement their constitutional right of freedom of choice be it in health care, education, politicical preference or religious belief.

Additionally, Australia, being a part of the Commonwealth of Nations, offers sovereign protection under common law with the royal proclamation of Henry VIII that created the Herbalists Charter to ensure the survival of the profession.

“: Be it ordained, established, and enacted by Authority of this present Parliament, That at all Time from henceforth it shall be lawful to every Person being the King’s subject, having Knowledge and Experience of the Nature of Herbs, Roots, and Waters, or of the Operation of the same, by Speculation or Practice, within any part of the Realm of England, or within any other the King’s Dominions, to practice, use, and minister in and to any outward Sore, Uncome Wound, Apostemations, outward Swelling or Disease, any Herb or Herbs, Ointments, Baths, Pultess, and Emplaisters, according to their Cunning, Experience, and Knowledge in any of the Diseases, Sores, and Maladies beforesaid, and all other like to the same, or Drinks for the Stone, Strangury, or Agues, without suit, vexation, trouble, penalty, or loss of their goods; the foresaid Statute in the foresaid Third Year of the King’s most gracious Reign, or any other Act, Ordinance, or Statutes to the contrary heretofore made in anywise, notwithstanding.”  ( 

Observations published by Michael Tierra, a renowned herbalist, cover some very important aspects of our profession and valid reasons to avoid over-regulation of our profession and to preserve the right of practice (

“Preserving the Tradition of Herbal Medicine

Here are three good reasons why herbal medicine should remain as unregulated as possible:

  1. The roots of herbal medicine are empirical and depend on a stream of trial and error to evolve and renew. To do this, it must remain an inalienable right to be able to access and use herbs obtained in the market, from nature and the garden, and should not be subject to highly restrictive governmental regulations.
  2. The practice of herbal medicine is its own unique methodology that only experienced herbalists understand. Because most herbs are mild and have myriad non-specific biochemical elements, best results are achieved when an assessment methodology is used that takes into account not only the presenting symptoms but the underlying causes. This is the unique strength of traditional herbal medical use and practice.
  3. Further, conventional medicine has a different focus, useful in its own way to attend to the alleviation of symptoms irrespective of wholistic considerations and of course in crisis care. But most medical doctors have, at best, an extremely limited understanding of the practice of herbal medicine.

Because of the above stated reasons, both China and India, which have long standing traditions of herbal medicine, are able to recognize professional herbalists without prohibiting the accessibility to herbs and herbal preparations and the popular practice of herbal medicine by all. (

Not only does the proposal to remove private health rebates for Complementary and Alternative Medicine (CAM) not make sense economically, due to the fact that it will drive hundreds of thousands of people from the realm of CAM to mainstream medicine therefore adding to the already burdened Medicare healthcare system,  it will remove the fundamental individual right of freedom of choice.  We are supposed to live in a democratic society.  This proposed legislation in my view, is a fundamental breach of our constitution and the very reason we vote.

Additionally, CAM therapists commonly practice in clinics in a small business setting that inject considerable funds ($8bn revenue, 2017 marketing statistics ) ( into the economy, whilst offering local employment and contractual opportunities to suitably qualified practitioners, along with the support of many ancillary professions and industries, such as insurance, manufacturing, transport, growers, farmers, wholesale supply chains, marketing and advertising, sales representatives, health food stores and all the support functions of employees that are intrinsically associated with the successful operations of all of these businesses.  It is estimated that the use of CAM nationally in Australia is underestimated and considerably higher than estimated from previous Australian studies and may be a reflection on the popularity of the use of CAM. (1)

It is well documented that Australians utilise CAM to manage their health, (1,2)  either due to prophylaxis or a  range of chronic diseases, (3) in order to ease symptoms, (4)or manage the side effects of their conventional therapy. (4) Research indicates that in a given year, two in every three Australian adults are estimated to use at least one CAM product (e.g. vitamin or mineral supplements and natural or herbal remedies) and one in four are estimated to use a CAM service (e.g. naturopathy, herbal medicine, acupuncture, massage, chiropractic therapy). Others are often disillusioned and dissatisfied with the results received from conventional therapy. (

Reports of adverse drug events (ADE) are common in the Australian health system. Anticoagulant, anti-inflammatory, and cardiovascular drugs feature prominently as preventable, high impact problems, and collectively make up over one-half of all ADEs. (5,6).  Concerns have been raised due to the continuance of drug errors and the inflicted harm caused to patients (7).  Evidence reports about a quarter of the adverse events occurring among outpatients caused permanent disability or death, and investigators judged it likely that more than two thirds were preventable and that patient harm related to allopathic healthcare being a persistent problem, extending the patient stay, increasing risk of in-hospital death and an increased cost to the public system with current recommendations for improvement in pharmacotherapeutic care (8,9,10,11,12,13,14).

Acceptance, integration and use of CAM is widely accepted, (15,16,17) with reported serious adverse events rare (18,19), the majority being associated with adulteration of products, substitution of one herb for another (may be more toxic or less efficacious) allergic reactions, contamination or misidentification of the starting material, incorrect preparation, dose or inappropriate labelling, herb-drug interactions, and reports of delays in diagnosis or medical treatment attributing to adverse events. Adverse reactions to CAM practices can be classified as risks of commission (which includes removal of medical therapy) and risks of omission (which includes failure to refer when appropriate) (20)  Most consumers consider CAM relatively safe, however the growing practice of integration of CAM therapies with drug therapy increases the risk of herb-drug interactions. The Therapeutic Goods Administration (TGA) has a two-tier, risk-based regulatory system for therapeutic goods — CAM products are regulated as low risk products and are assessed for quality and safety; and sponsors of products must hold the evidence for any claim of efficacy made about them.  (21)

Research of CAM, although in some areas in not considered robust, is increasing in both strength and depth.  Research is readily available to calculate pharmacodynamic and pharmacokinetic herb-drug risks. (22,23,24) Standardisation of the methods of data gathering and analysis is increasing around the globe, (25) along with an increase in higher manufacturing standards, in particular in Australia where there are stringent guidelines for good manufacturing practices and procedures accompanied by the TGA regulatory system for therapeutic goods.

In conclusion, given the low risk versus benefit ratio of CAM, the high educational standards of CAM therapists and appropriate CAM associations’ practice guidelines, there is little or no rational argument for the abolition of private health rebates in Australia.

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  2. Reid R, Steel A, Wardle J, Trubody A, Adams J. Complementary medicine use by the Australian population: a critical mixed studies systematic review of utilisation, perceptions and factors associated with use. BMC Complementary and Alternative Medicine 2016;16:176.
  3. Armstrong AR, Thiébaut SP, Brown LJ, Nepal B. Australian adults use complementary and alternative medicine in the treatment of chronic illness: a national study. Australian and New Zealand journal of public health 2011;35(4):384-90.
  4. Beuth J, Ost B, Pakdaman A, Rethfeldt E, Bock PR, Hanisch J, et al. Impact of complementary oral enzyme application on the postoperative treatment results of breast cancer patients–results of an epidemiological multicentre retrolective cohort study. Cancer Chemother Pharmacol 2001;47 Suppl:S45-54.
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  11. de Vries EN, Ramrattan MA, Smorenburg SM, Gouma DJ, Boermeester MA. The incidence and nature of in-hospital adverse events: a systematic review. Quality and Safety in Health Care 2008;17(3):216-23.
  12. Baines RJ, Langelaan M, de Bruijne MC, Asscheman H, Spreeuwenberg P, van de Steeg L, et al. Changes in adverse event rates in hospitals over time: a longitudinal retrospective patient record review study. BMJ Quality & Safety 2013;22(4):290-8.
  13. Marquet K, Claes N, De Troy E, Kox G, Droogmans M, Vleugels A. A multicenter record review of in-hospital adverse drug events requiring a higher level of care. Acta Clinica Belgica 2017;72(3):156-62.
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  19. Sweet ES, Standish LJ, Goff BA, Andersen MR. Adverse events associated with complementary and alternative medicine use in ovarian cancer patients. Integr Cancer Ther 2013;12(6):508-16.
  20. Vohra S, Brulotte J, Le C, Charrois T, Laeeque H. Adverse events associated with paediatric use of complementary and alternative medicine: Results of a Canadian Paediatric Surveillance Program survey. Paediatr Child Health 2009;14(6):385-7.
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