Scope of Practice in Traditional Complementary and Alternative Medicine, Dubai

The Health Authority in Abu Dhabi has released its TCAM policy.

Thanks to friend and colleague Sassan Behjat for passing along this information. According to the Policy:
The Health Authority Abu Dhabi (HAAD) is responsible for regulating the Traditional, Complementary and Alternative Medicine (TCAM) practice in the Emirate of Abu Dhabi. The purpose of the scope of practice is to clearly define the competency framework for professional practice of TCAM and to encourage the practitioners to work within a broader frame work that does not ignore the role of orthodox medicine.
The Policy defines "orthodox medicine" as: "A system in which medical doctors and other healthcare professionals (such as nurses, pharmacists and therapists) treat symptoms and diseases using drugs, radiation, or surgery. Also called conventional medicine, Western medicine, mainstream medicine, biomedicine, and allopathic medicine." It defines TCAM, or traditional, complementary and alternative medicine as:

Traditional Medicine--"It is the sum total of knowledge, skills and practices based on the theories, beliefs and experiences in indigenous to different culture, whether explicable or not, used in the maintenance of health as well as in prevention, diagnosis, improvement or treatment of physical and mental illness."

Complementary / Alternative Medicine: "Often refers to a broad set of health care practices that are not a part of country's own tradition and are not integrated into the dominant health-care system."

Some familiar concepts are present, such as licensure and scope of practice, as well as concern over medical malpractice and negligence. Some relevant sections provide:
4. The TCAM practitioners should ensure that their practice and procedures are well defined and transparent, they are operated in a way that is fair and hygienic and that all efforts to ensure standards of good medical practice are involved.

5. TCAM practitioners should be aware of extend and limits of their specialty. They should essentially know which conditions they will be unable to treat successfully, and be able to identify and refer patients to medically qualified physicians and specialists when necessary. A patient showing signs and symptoms of an underlying pathological condition should be advised to seek a medical diagnosis.

6. The practitioner should assist the patients in weighing the possible benefits and risks of other types of treatment, helping them to consider conventional diagnostic procedures; routine screening tests etc, acknowledging the usefulness of such procedures at appropriate times, even for those who may wish to avoid conventional treatment.
Misleading claims are also addressed, in the following language: "When a remedy is prescribed, it is not enough to say that the remedy is traditional and considered not harmful. It is the duty of the practitioner to ensure that the remedy is, in fact, not harmful or potentially harmful....Claims, whether explicit or implied, orally or in writing implying cure of any named disease must be avoided."

Appropriately, non-medical providers are prohibited from countermanding a medical prescription.

The language of the policy reveals some nuances which incorporate more of the flavor of the provider-patient relationship--for example: "TCAM practitioners can offer hope to patients, both by attempting to influence the underlying disease and, often more importantly, by addressing emotional states, energy levels, coping styles, and other aspects that contribute to quality of life. This is particularly important for patients with chronic diseases and no prospect of cure from conventional medicine."


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The Law Offices of Michael H. Cohen offers corporate legal services, litigation consultation, and expertise in health law with a unique focus on holistic, alternative, complementary, and integrative medical therapies. The law firm represents medical doctors, allied health professionals (from psychologists to nurses and dentists) and other clinicians (from chiropractors to naturopathic physicians, massage therapists, and acupuncturists), entrepreneurs, hospitals, and educational organizations, health care institutions, and individuals and corporations.

Michael H. Cohen is Principal in Law Offices of Michael H. Cohen and also President of The Institute for Integrative and Energy Medicine, a nonprofit organization exploring legal, regulatory, ethical, and health policy issues in the judicious integration of complementary and alternative medical therapies (such as acupuncture and traditional oriental medicine, chiropractic, naturopathic medicine, homeopathy, massage therapy, energy healing, and herbal medicine) and conventional clinical care. Michael H. Cohen is author of books on health care law, regulation, ethics and policy dealing with complementary, alternative and integrative medicine, including Healing at the Borderland of Medicine and Religion, Complementary and Alternative Medicine: Legal Boundaries and Regulatory Perspectives (1998), Beyond Complementary Medicine: Legal and Ethical Perspectives on Health Care and Human Evolution (2000), and Future Medicine: Ethical Dilemmas, Regulatory Challenges, and Therapeutic Pathways to Health Care and Healing in Human Transformation (2003).
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Health care and corporate lawyer Michael H. Cohen has been admitted to the Bar of California, Massachusetts, New York, and Washington D.C. In addition to qualifying as a U.S. attorney, he has been admitted and to the Bar of England and Wales as a Solicitor (non-practicing). For more information regarding the law practice of attorney Michael H. Cohen, see the FAQs for the Law Offices of Michael H. Cohen. Thank you for visiting the Complementary and Alternative Medicine Law Blog.
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