Memorandum submitted by the Association
of McTimoney-Corley Spinal Therapists (Vet 12)
1. I am writing with reference to your email
dated 10 July 2007 concerning the above, and would like to thank
you for consulting our organisation and inviting us to provide
evidence on the proposed changes to the 1966 Act.
2. The Association of McTimoney-Corley Spinal
Therapists (AMCST) was established in July 2002, and supports
150+ members who practise the McTimoney-Corley Spinal Therapy
technique on animals and humans. Our organisation supports graduates
from the Oxford College of Equine Physical Therapy (OCEPT), who
have sent a separate response to this inquiry, and the former
Oxford College of Chiropractic (OCC). The British Association
for Applied Chiropractic (BAAC), formed in 1988, was the original
representative body of graduates from the OCC. Our member animal
diploma graduates have for many years provided a competent and
responsible manipulative therapy service working alongside veterinary
surgeons. We would like to point out, however, that we are a completely
separate organisation and have no links to the McTimoney Chiropractic
Association.
3. We agree that many changes have taken
place in the veterinary profession since 1966 and generally welcome
the proposal to modernise the Act, but at the same time want to
make sure the livelihood of our members is not compromised as
a result of any amendments made.
4. We have responded to the proposed changes
to the Act identified in your email in order as follows:
Whether the provisions of the 1966 Act are out
of step with developments in the veterinary surgeon and related
professions?
5. Since 1966, many new types of complementary
therapy and other veterinary services have become available to
owners and their animals, but the current law stipulates that,
subject to a number of exceptions eg, Farriers, only registered
members of the Royal College of Veterinary Surgeons (RCVS) can
provide veterinary treatment. The Veterinary Surgery Exemptions
Order of 1962 refers to these exceptions, including certain
complementary therapies, which can only be applied to an animal
under direct veterinary referral.
6. Whilst the welfare of the animal is of
course of paramount importance, many providers of alternative
veterinary services are members of their own professional organisations;
undergo appropriate training to ensure they are competent in their
particular field of expertise; follow a code of conduct and have
knowledge of contra-indications and referral procedures should
veterinary help need to be sought. They are also covered by indemnity
insurance, should something go wrong. In these circumstances,
where the veterinary service provider works in a professional
capacity alongside veterinary surgeons, it would seem sensible
to make certain changes to the 1966 Act to allow alternative providers
of veterinary care that are recognised by the veterinary profession,
to treat an animal where appropriate, as long as they are competent
to do so, without direct veterinary referral.
Whether there ought to be regulation of providers
of veterinary care other than veterinary surgeons?
7. We are in agreement that there ought
to be regulation of other providers of veterinary care as this
protects the welfare of the animals concerned, as well as the
public from lay practitioners who have very little if any training
and could potentially cause more harm than good. However, we would
like to see this achieved in a fair and equitable manner, where
the regulatory council is represented fairly by all parties involved
eg, if the council had a larger representation of veterinary surgeons,
they could be biased in making decisions in their favour in order
to eradicate or control competition from others in the veterinary
care market place.
Whether the delivery of veterinary services ought
to be regulated through a mandatory practice standards scheme,
with a professional code of ethics, rather than the RCVS regulating
practitioners on an individual basis?
8. As there are many different organisations
providing alternative forms of veterinary care, we believe it
would be very difficult to provide a mandatory practice standards
scheme that would cover all forms of manipulative therapy. We
believe it would inevitably lead to the many forms of manipulative
therapy techniques losing their individuality and also restricting
the future development of valuable manipulative techniques. This
could also lead to less choice of manipulative therapies being
available to the general public and loss of personal choice. Whilst
vets can advise a form of alternative therapy for their animal,
owners still have control over the service they are willing to
pay for and will choose what they believe to be the best form
a treatment for their animal. This choice is often wrongly or
rightly based on personal experience as well as how their animal
reacts to the form of treatment provided.
9. As our organisation fully understands
the McTimoney-Corley manipulative therapy technique, we believe
we are best placed to provide our own professional code of ethics,
although we are willing to consider any suggestions from the RCVS
that relate specifically to animal welfare and to the veterinary
referral process etc.
Whether the RCVS and VNC should be given the power
to require continuing professional development and validation?
10. We already request that our members
attend continuing professional development (CPD) courses but,
as an organisation, we have to be mindful as to what type of development
training is appropriate. Our members are fully insured to perform
the McTimoney-Corley Manipulative Therapy technique, which is
a gentle form of manipulation. It would therefore, not be appropriate
for our members to attend courses teaching techniques that would
deem their insurance cover invalid. Whilst many CPD courses specified
by the RCVS/VNC may be valid and useful, other courses specified
by our organisation may be more appropriate and better aid the
future development of our manipulative therapists. For this reason,
our organisation believes it important that the RCVS/VNC is not
given complete power over CPD requirements.
11. The Oxford College of Equine Physical
Therapy (OCEPT) has provided training to our animal therapists
for many years, and we believe the veterinary profession has generally
been confident of our members' abilities to provide alternative
therapy in a safe and competent manner. Training is provided by
professional tutors who are very experienced and established practitioners
in their own right. We believe handing complete powers of validation
over to the veterinary profession would not be appropriate as
it could result in them having control over what training is appropriate
in their view, when they are not properly qualified to decide
what this should be from a manipulative therapy standpoint. However,
as our members work alongside the veterinary profession we would
welcome their input and any suggestions for improvement which
we will more than happily pass on to OCEPT.
Whether the governing body of the RCVS and VNC
ought to include appointed lay persons as well as veterinary professionals?
12. We believe this would be a very good
idea, as it would potentially introduce unbiased and broader views
across the veterinary profession. In relation to matters regarding
manipulative therapy or other alternative veterinary care services,
appropriate representatives on the governing body would ensure
that the views of all organisations providing veterinary care
could be made known. As veterinary surgeons are not manipulative
therapy experts they would not in our opinion be best placed to
offer a fair and educated opinion on any related matters that
reach the discussion table of the governing body.
Whether the RCVS and VNC ought to have a separate
conduct committee with the powers to investigate complaints, give
warnings and to make interim orders pending proceedings?
13. Our organisation has its own disciplinary
procedure should any of its member's professional activities be
brought into question. Should we receive any customer complaints
these are investigated and the practitioner dealt with in the
appropriate manner. Whilst there may need to be an open communication
channel between the RCVS/VNC and our organisation to report complaints
etc, as we have a full understanding of the manipulative therapy
provided, we consider we are best able to discipline our members
if deemed appropriate.
Whether the RCVS ought to have power to delegate
specified procedures to people holding qualifications recognised
by the RCVS Council?
14. Currently, in order to perform manipulative
therapy our members need permission from the appropriate veterinary
surgeon. As veterinary surgeons are busy individuals and not always
easy to contact, delegation of certain aspects of veterinary care
would definitely make sense. This could be achieved if organisations
such as ours, whose members undergo training in order to reach
an acceptable standard of competency, became listed as a recognised
veterinary care organisation for veterinary delegation of manipulative
therapy.
COST CONSIDERATIONS
15. Whilst we would like to offer our full
support for the regulation of other veterinary service providers,
there are also other considerations relating to extra costs, which
may affect our members. Setting up a regulatory body, will obviously
cost money and who will fund this? Assuming the veterinary profession
will wish to impose certain standard conditions in order for any
organisation, such as ours, to become listed as a recognised veterinary
care provider, this may well increase our administration costs,
which in-turn will be passed onto our members. Whilst we realise
that this is inevitable in the interests of continued professionalism,
we would hope that careful thought is given to keep any imposed
conditions/costs to a minimum, especially as some of our members
prefer to work on a part-time basis.
16. Assuming our organisation would have
representation on any regulatory council, who will incur the cost
of attending meetings? Who will hold lists of individual practitioners
that are deemed competent—if not our organisation then would
the RCVS incur extra costs in setting up more database records?
17. In conclusion, we would like to thank
EFRA once again for inviting us to comment on the proposed changes
to the Veterinary Surgeons Act of 1966, and would like to offer
our full support. We hope that the points we have made are useful
and will help to ensure that any necessary changes can be achieved
in a fair and equitable manner. We also hope that any changes
to the Act will improve the provision of alternative veterinary
services available, whilst ensuring continued freedom of choice
in the market place, and preserving the rights of any current
alternative veterinary care professional to continue working alongside
veterinary surgeons.
18. If you wish to discuss any of the points
above or require further information please do not hesitate to
contact us.
September 2007
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