Federal Health Minister Jens Spahn declared yesterday, 17.09.2019, that he would adhere further to the reimbursability of homeopathy by the statutory health insurance funds. He cited the comparatively marginal costs compared to the total expenditure of the SHI funds, i.e. the sufficiently strained “peanuts” argument, as the reason for this.

There are undoubtedly only bad reasons for Mr. Spahn’s decision, but this is undoubtedly the worst of all. We will see how politicians and other groups react. We, for our part, feel obliged to respond to his decision in the form of an open letter to Mr Spahn:

Information Network Homeopathy
We clarify – you have the choice!

18.09.2019

Mr
Federal Minister for Health
Jens Spahn
by e-mail

Dear Federal Minister Spahn,

From your statement of 17.09.19 we have learned that you have decided not to exclude homeopathy from the benefits of statutory health insurance. In our opinion, you are basing your decision on an aspect which is ultimately irrelevant and which has never been or is the subject of scientific criticism of homeopathy.

Of course, we regard every single euro for homeopathy as an unjustified use of contributions from the solidarity community and not as “peanuts”. However, the reasons underlying the demand for an end to reimbursement and ultimately the questioning of the property as medicine of homeopathic products are quite different and far more important. With your decision and its justification, you give room not least to an increasing hostility to science and facts, the effects of which you then try to recapture elsewhere with a compulsory vaccination.

• • It is not understandable for us that homeopathy continues to be supported politically, contrary to the clear scientific situation, which is not affected in any way by the constant interventions of the homeopathic lobby. Homeopathy has no specific medicinal effect and therefore no medical relevance. It is full of internal and external contradictions and thus incompatible with the valid and proven scientific view of the world.
  • As a method that is at best capable of producing a placebo effect and that ascribes its successes to her method itself altough natural disease processes and the body’s self-healing abilities do the work, it must no longer enjoy a public reputation in the interest of patients. This public reputation was wrongly granted to it for decades, resulting in a completely distorted image in the public. By declaring that you will not touch the reimbursability, you are perpetuating this instead of necessarily finally counteracting it. Unfortunately, the effects will not be limited to homeopathy, but will more or less benefit the entire field of “alternative medicine” means and methods.
  • Conveying the impression that homeopathy is effective medicine is not only dishonest towards patients, it is also dangerous. We have no doubt that every day people suffer unnecessary pain, disease progression is prolonged, effective therapies are delayed or in the worst case even prevented – not in every case with a “spectacular” outcome, undoubtedly, but not to be accepted, since avoidable. As a rule, these cases remain in the dark, and their effects are not reflected in homeopathic statistics, but in the case and death statistics of the “orthodox medicine”, which is so poorly estimated. The responsibility of politics for the public good should be remembered here. We are talking about patient protection, Minister!
  • The fact that this also applies to so-called medical homeopathy, which is represented by the German Central Association of Homeopathic Physicians, can be seen from the lectures which it allows under its direction at its annual medical congresses. Treatment of cancer, AIDS, HPV infections, ADHD and more are the spectacular rule, not the exception.
  • We also don’t want to hide the fact that you counteract the many years of educational work of the scientifically founded homeopathy criticism with your statement per homeopathy reimbursement. Homeopathy propaganda, which we oppose daily with our educational work, regains credibility.
  • Allow us to make a few remarks on the pecuniary aspect without trying to relativize its subordinate importance.
    Perhaps it has not become quite clear to you how contradictory the cost aspect is dealt with. On the one hand, it is said to be a matter of peanuts, but on the other hand, a change in the reimbursement system is exaggerated into an affair of enormous – also economic – significance.
    Moreover, there are fundamental doubts as to whether the amount you mentioned fully covers the costs of homeopathy.
    The amount you mentioned does not include the regular benefits for homeopathic treatment of children and adolescents and, above all, not the expenses for medical remuneration for homeopathic services, both of which, to our knowledge, are not statistically recorded.
    According to Witt/Ostermann’s investigations, patients with an affinity for homeopathy consistently incur higher health insurance costs. The collective of more than 22,000 patients of a large health insurance company alone caused direct additional costs of almost 35 million euros in the first 18 months. This can surely be transferred to other health insurance companies. We leave it up to your imagination how this will look like when the majority of patients with an affinity for homeopathy will reach a higher age with higher risks for chronic illnesses.
    Beyond these concrete points, however, it should also be taken into account that follow-up costs – in the medical as well as in the economic field – are to be expected as a result of therapy delays due to disease patterns developing factually untreated.
    Even if one is inclined to view the argumentation with the allegedly low costs in isolation, it is nevertheless based on at least an incomplete consideration and cannot therefore be valid on its own.

We would like to draw your attention to neighbouring European countries such as England, France and Spain, which are clearly scientifically oriented and unimpressed by the protest and demagogy of the homeopathy lobby. In these countries the responsible authorities proceed according to the clear scientific findings and in the sense of patient protection. From there, some initiatives for an amendment of the EU Medicines Directive are launched in order to end the false attribution of medicinal properties to homeopathy at this level. How should Germany position itself in this discussion?

As an organisation that has played a leading role in the discourse of science-based criticism on homeopathy in Germany since 2016, we feel obliged to make these comments. We regret your decision and cannot follow it. We will continue our criticism and continue to pursue the goal of giving homeopathy the role that is appropriate for it: that of one of the many methods that are well-known, partly popular and will certainly remain available, but which are specifically ineffective and therefore cannot be the subject of legal privileges and health care in a public solidarity system.

Yours sincerely
Information Network Homeopathy – INH

The above Open Letter is an opinion of the Homeopathy Information Network, but it is open for co-signature by all those who share the positions expressed therein.

Who would like to co-sign with name / title and place of residence, can explain this gladly by Mail to info@netzwerk-homoeopathie.info We will only use the data provided for this purpose and will not pass on any further data, such as e-mail addresses, to third parties.

This is the list of the named co-signatories, which is constantly supplemented:

Picture  credits:  S. Hermann & F. Richter on Pixabay

In the meantime, the Spanish government has initiated a wide outreach against pseudomedicine. For example, it no longer wants to accept the medicinal status of homeopathy, wants to ban homeopathy from pharmacies and has already “discontinued” the first batch of homoeopathics which could not present a valid proof of efficacy upon request. England is currently performing a complete “blacklisting”, i.e. a process that means the end of any registration for homeopathic medication with a drug authority.

The EU Medicines Directive does not regulate in detail how exactly the member states deal with homeopathy in health care. However, it does fix two key points: It includes homeopathy in its definition of a medical drug and obliges the states to regulate a simplified registration procedure for homeopathy instead of the usual drug approval. If one seriously wants to dispute the status of homeopathic medicinal products (and thus their privileges), one cannot completely ignore EU law.

Spain knows that. At various levels (including that of the government), there are efforts to achieve a revision of the EU directive on medicinal products in the field of homeopathy. These efforts need support. The INH has therefore addressed the following letter to German MEPs, which is initially intended to provide basic information on the facts of the case and support Spain’s position in the expected discussion. This seems all the more necessary as the European homeopathic manufacturers and associations have for a long time maintained a lobby organisation directly in Brussels, which apparently has quite good material and personnel resources and whose task is to exert direct influence “on the spot”. We do not have such resources, but we do have the facts. And who knows – perhaps one or the other national government will even join Spain and become active in the EU?

______________

Mr. Mrs. …
MEP

by e-mail                                            7 August 2019

Homeopathy in the EU Medicines Directive

Dear Madam / Sir,

The European Medicines Directive (Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to medicinal products for human use,  Official Journal of the European Community L 311, 28.11.2001) classifies homeopathic preparations as medicinal products and requires national governments to establish a simplified registration procedure outside the otherwise prescribed rules for marketing authorisation for pharmaceutical remedies.

However, the consensus of the worldwide scientific community has long since classified homeopathy as a specifically ineffective sham therapy, the spread and “popularity” of which have completely different bases than those of medical relevance (evidence). In many countries, this insight is now gaining acceptance. It will be in the well-understood interest of the public’s health to take consequences of this. The misguiding of the public that homeopathy is a form of therapy expressly recognised by the legislator and therefore endowed with the credit of efficacy and harmlessness may not be continued.

In this respect, the Kingdom of Spain is already campaigning for an amendment to European pharmaceutical law, which not only grants homeopathic preparations the status of medicinal products by definition, but also grants them the additional privilege of registration (see also http://www.europarl.europa.eu/doceo/document/E-8-2018-004948-ASW_EN.html). This special legal framework has no objective justification, as the EASAC – as official advisor to the EU institutions – clearly stated in its statement of 20.09.2017 (https://easac.eu/publications/details/homeopathic-products-and-practices/).

In the interest of a science-based, honest and patient-oriented health policy, also on behalf of the German Consumer Association e.V. and its regional associations, we ask you to support a revision of the Medicines Directive in the sense described, in order to clear the way for appropriate national regulations under Community law.

You can inform yourself about the scientific status of homeopathy on the (multilingual) website of our association: www.network-homeopathy.info .

Yours sincerely

For the  Information Network Homeopathy

Dr. Natalie Grams – Dr. Ing. Norbert Aust – Dr. Christian Lübbers

Mrs. Karin Maag, member of the Health Committee of the German Bundestag, has recently spoken out on several occasions against the reimbursement of homeopathy by the statutory health insurance funds. She did use a number of arguments which, in the opinion of the INH, require clarification. For this reason, Mrs Maag has received the following Open Letter from the Homeopathy Information Network:

______________

Mrs.
Karin Maag MdB
Place of the Republic 1
11011 Berlin

Mail to: karin.maag@bundestag.de                                                                 29.07.2019
Informational to: Federal Minister of Health, Mr Jens Spahn

Homeopathy and statutory health insurance

Dear Mrs Maag,

We have learned from the press reporting that in the discussion about the reimbursement of homeopathy by statutory health insurers you have clearly positioned yourself against plans to abolish it. At the same time, however, we can also see from this reporting that you are apparently not sufficiently informed about the aims and arguments of the scientifically based critique of homeopathy and that you also argue in part outside the context of the problem.

We would therefore like to make a few comments on this.

We, the Information Network Homeopathy, raise awareness since 2016 that homeopathy is a sham therapy that has neither ever been able to provide valid proof of efficacy nor to eliminate the incompatibility of its basic assumptions with scientifically proven principles. There is a broad consensus on this in the scientific world. We refer exemplarily to the clear judgement of the EASAC, the advisory board of the Association of European Academies of Science, which was published in 2017.

Against this background, we also see the discussion on the reimbursability of homeopathy by statutory health insurance funds. And against this background we also contradict the thesis that there must be a coexistence of homeopathy and science. Either one recognises the relevance of the scientific evaluation of homeopathy – then the consequences are obvious. Or one doesn’t – then one speaks out in favour of equating facts and opinions.

The core problem lies in the fact that the current reimbursability strengthens the public reputation of homeopathy, which is scientifically and, in our opinion, also unacceptable from the point of view of health policy. It lends additional credibility to the already widespread misconception among the population that homeopathy is a well-established form of therapy, which at any rate must be regarded as equivalent to scientific medicine.

Part of this misconception is that homeopathy is wholly or partly identical with naturopathy. But nothing could be more wrong than an equation of homeopathy and naturopathy. Nothing is “natural” in the esoteric assumption that there is a “principle of similarity” in nature that is related to human interests. There is nothing “natural” about the postulate that through dilution and ritual shaking, a “spiritual medicinal power”, today called “vibrations” or “energy”, will not only pass into the solvent, but will also become essentially “stronger”. There is no doubt that the public has not yet been sufficiently informed about all this.

A solidarity community such as the statutory health insurance needs an intersubjectively defined framework whose criterion is the general advantage. This framework is guaranteed by evidence-based medicine, which requires proof of efficacy of means and methods based on recognised scientific methodology. Homeopathy cannot satisfy this requirement; it is marketed under “medicinal product” only because the Medicines Act exempts it from this requirement.

We are fully aware that, as you are quoted, “many people feel better off taking homeopathic medicines”. The explanations for this have been known for a long time, but they have nothing to do with the specific medical effectiveness of homeopathy. These are contextual effects of various kinds that occur with any kind of treatment, often even with pure attention.

We even see in this one of the central dangers of the application of homeopathy. Anyone who has had “good experiences” with homeopathy with minor health disorders, or perhaps only with mood disorders, runs the risk of relying on it even in the case of more serious illnesses. The patient “conditions” himself to the medically ineffective homeopathy. The associated potential danger is obvious; the more homeopathy is erroneously perceived as a “gentle and side-effect-free” alternative to normal medicine, the less the risks will be perceived.

On the question of reimbursability in the statuary health solidarity system, the cost aspect plays a completely subordinate role, if at all. It is not a question of whether the expenses for homeopathy are “peanuts” or not, not of whether the system can “afford it”. It’s about drawing clear border lines in the matter.

Medicine is what has been proven to work beyond contextual effects. This defines the boundary between necessary, appropriate and economic care – the object of health insurance according to the social law – and what belongs to the realm of subjective, personal well-being. Which everyone may use for themselves on their own responsibility and at their own expense. We therefore consider it a reversal of the facts to refer insured persons who rightly reject homeopathy as a medical method to health insurers who do not offer their reimbursement.

It is therefore in the interests of the solidarity community that the health insurance reimbursement, which suggests a medical significance of homeopathy, should not be continued. It would be even more desirable if homeopathy were to be deprived of its special status in pharmaceutical law, which exempts it from scientifically based proof of efficacy. It is by no means a question of banning homeopathy. For everyone who wants to use it – informed! – it remains available.

We are therefore convinced that the well-understood patient interest requires a correction of the decision per reimbursement. Of course, regardless of the clear facts, this is also a political matter of balancing rights and interests. We have no doubt, however, that the arguments put forward against reimbursement of homeopathy are so far-reaching and in the public interest that they cannot be outweighed by other particular interests.

For discussions and further information, we are at your disposal at any time in any form you like.

Yours sincerely

For the Homeopathy Information Network

Dr. Natalie Grams.
Dr. Ing. Norbert Aust
Dr. Christian Lübbers