- Open Access
Stakeholder attitudes to the regulation of traditional and complementary medicine professions: a systematic review
Human Resources for Health volume 19, Article number: 42 (2021)
There has been a considerable increase in the number of traditional and complementary medicine (T&CM) practitioners over the past 20 years and in some jurisdictions are estimated to outnumber general practitioners. Despite this globally significant role, it is apparent that worldwide not all T&CM professions operate under adequate accountability and regulatory oversight for maintaining public protection. To date there has been no published systematic examination of stakeholder opinions regarding regulated and unregulated T&CM occupations. In response, this review aims to investigate, describe, and analyse attitudes held by a range of stakeholder groups towards the regulation of T&CM professions.
A database search of AMED, CINAHL, Embase, Ovid MEDLINE, ProQuest, PsycINFO, PubMed, Scopus, and Google Scholar was conducted for original research published between 2000 and 2020 on stakeholder opinions regarding the regulation of T&CM professions.
Sixty studies across 15 countries reported on the views of six health care stakeholder groups: consumers, T&CM practitioners, conventional medicine practitioners, professional associations, education providers, and policy-makers. Across all stakeholder groups there was between 15% and 95% (median 61%) support for, and 1% to 57% (median 14%) opposition to the regulation of various T&CM professions. The main reasons for supporting regulation included providing greater public protection, raising training and practice standards, establishing title protection, and gaining acceptance from conventional medicine providers. Concerns regarding regulation included potential restrictions to practice, misappropriation of practice, and medical oversight of T&CM practitioners. Few studies canvassed the views of professional associations (n = 6), education providers (n = 2), and policy-makers (n = 2).
There appears to be broad support for the regulation of T&CM professions, although there was wide variation in attitudes as to how this should be applied. Further research, with a particular focus on policy-makers, education providers, and professional associations, is critical to inform appropriate health policy and practice recommendations relating to T&CM professional regulation across jurisdictions. Systematic review registration: the a priori protocol for this systematic review was registered in PROSPERO and is available at: www.crd.york.ac.uk/PROSPERO/display_record.asp?ID=CRD42020198767.
Health care systems are coming under increasing pressure from challenges posed by the growing burden of non-communicable diseases [1, 2], the health care needs of ageing populations , the accelerating incidence of epidemics and pandemics , burgeoning health care costs , and the prospect of health care workforce shortages . Changing needs, shifting priorities and the increasingly consumer-led nature of health care systems have resulted in significant changes in the contemporary health care workforce. This includes the evolution or growth of new professions and changes in scope of existing professions. According to the World Health Organization (WHO) there are now over 150 occupations in the health workforce sector , although one commentator considers this number closer to 350 .
One area of the health workforce in which there has been considerable growth and evolution is traditional and complementary medicine (T&CM). T&CM refers to a broad set of health care practices and beliefs indigenous to a culture and place (traditional medicine), and practices that are neither indigenous nor part of the predominant health system of a country (complementary) [9, 10]. T&CM designations are therefore jurisdictionally defined . Although some T&CM practices have ancient roots, the worldwide growth in consumer use and recognition of T&CM commenced in the latter part of the twentieth century, in part due to the Declaration of Alma-Ata  and later the release of WHO traditional medicine strategies [9, 12]. The rise in T&CM use has proved to be a global phenomenon, evident in both developing and developed nations [13,14,15,16,17,18,19,20]. Commensurate with this rise in use there has been a substantial increase in the number of T&CM practitioners over the past 20 years [21,22,23]. Indeed in some jurisdictions the T&CM cadre is estimated to outnumber general practitioners (GPs) , making this cohort a significant part of the health care workforce globally.
Regulation of health practitioners is generally defined as the actions taken by public authorities to control activities and standards relating to health practice [24,25,26]. While models of health workforce regulation vary across jurisdictions [27, 28], one schema classifies six categories of occupational licensing: no regulation, self-regulation, state sanctioned self-regulation, statutory self-regulation, co-regulation and statutory regulation . In many jurisdictions the regulation of health professions appears to be moving away from non-government regulatory models towards nationally based regulatory approaches , and greater regulatory partnerships between the public, professions, and regulators . Further, the WHO has identified regulation as a key milestone of their global health workforce strategy , and regulation of the T&CM workforce specifically as one of three strategic objectives of the WHO T&CM strategy . Despite these strategic priorities, there is considerable variation worldwide in the way in which T&CM occupations are regulated, as well as the form of regulation applied. Regulatory developments for T&CM practices are argued to be lagging behind their growth in use , and not all T&CM occupations operate within adequate accountability-based, public interest regulatory frameworks [9, 10]. For instance, some T&CM professions are statutorily regulated in certain countries, others reside outside statutory frameworks but occupy a state-recognised place in health provision, and some T&CM practices are neither statutorily regulated nor acknowledged by the state, but continue to operate within their jurisdictions, sometimes informally .
There is a public health imperative for governments to establish mechanisms for recognising and monitoring T&CM practices and practitioners, and promote their appropriate integration or restriction within health care systems . Establishing suitable regulatory frameworks may ensure appropriate and consistent minimum standards of education and practice [10, 32], and facilitate workforce mobility across country borders , potentially alleviating forecast health care workforce shortages , and contributing to the WHO’s mission of promoting health for all . WHO, through its traditional medicine strategy, has noted the lack of action in progressing T&CM regulation and encourages member states to engage more actively with this policy to facilitate the appropriate regulation of T&CM within their jurisdictions . By taking a global perspective the development of insights regarding potential enablers and barriers of regulation across a range of jurisdictions is facilitated, which can inform future application of regulatory policy in a number of different settings.
Despite widespread consumer utilisation of T&CM, the broadening reach of these practices, and the increasing tendency to regulate T&CM professions, what remains unknown and requires greater understanding are the attitudes and perceptions towards regulation of T&CM across the health care stakeholder landscape. In the broadest sense, stakeholder attitudes are important considerations in many contexts and settings . Within the health care context, understanding stakeholder attitudes is important to ensure that regulation is sustainable, responsive, and appropriate, and serves the public interest in a manner that is reflective of societal norms, expectations, and practices. Attitudes are shaped by self-interest, social identification, and personal values through which opinions are formed . Attitudes and opinions have a bearing on policy by influencing regulatory and policy agendas [35,36,37]. Disregarding the attitudes of key stakeholders risks privileging the views of certain groups at the expense of others [36, 37] and may result in regulatory developments that are not responsive to changing health workforce requirements. To date there has been no systematic examination of stakeholder opinions regarding regulated and unregulated T&CM occupations, a deficiency this systematic review aims to address. Consistent with regulatory trends, this review takes an expansive view across a range of stakeholder groups and jurisdictions to investigate, describe, and analyse attitudes towards the regulation of T&CM professions.
In order to inform the development of evidence-based policy, the objective of this review was to investigate, describe, and analyse all available stakeholder attitudes regarding T&CM regulation canvassed over the past 20 years, classifying and reporting the data according to emergent stakeholder groupings.
The review protocol was developed in accordance with ‘Assessing the Methodological Quality of Systematic Reviews’ (AMSTAR) guidelines  and the ‘Preferred Reporting Items for Systematic Review and Meta-Analysis Protocols’ (PRISMA-P) 2015 checklist . It was registered in PROSPERO (#CRD42020198767)  prior to completing the literature search.
Searches were conducted in eight databases (AMED, CINAHL, Embase, Ovid MEDLINE, ProQuest, PsycINFO, PubMed, Scopus) between 22/05/2020 and 26/05/2020, supplemented by a Google Scholar search 26/06/2020 to 28/06/2020. The search strategy consisted of free text and medical subject heading search terms. T&CM terms were developed using the Cochrane Complementary Medicine Glossary of CAM terms  as well as a selection of commonly used terms within T&CM professions and practices . Regulation-related terms were developed by the first author (JC) from background reading of research regarding health care regulation [31, 43,44,45]. Search terms were modified to suit the Google Scholar interface. The research team has published multiple systematic literature reviews related to health policy and T&CM, and a librarian was consulted in the development of the database search protocols. Table 1 provides the search terms used for Ovid MEDLINE. The full search protocol is available at: https://www.crd.york.ac.uk/PROSPEROFILES/198767_STRATEGY_20200714.pdf.
Studies were included if they were original research, in English, published between 2000 and June 2020. A stakeholder attitude map  was used to conceptually consider categories of stakeholders within a health care context. Specific stakeholder groups were not defined a priori. All available stakeholder research canvassing views regarding T&CM practitioner regulation was accepted for inclusion. From background reading and consideration of stakeholder categories  the following groups were expected to feature in the search results: consumers, T&CM practitioners, conventional medicine practitioners, professional associations, education providers, and policy-makers. Defining T&CM professions applicable to all jurisdictions was problematic [46, 47], hence this review accepted the classification applied by each included study. Review articles, narrative research, commentaries, editorials, and non-English language studies were excluded.
Retrieved records were imported into EndNote X9 (Clarivate Analytics 2018) by JC. Records were deduplicated, titles and abstracts were screened, and resulting full texts were scrutinised by JC. Those meeting the selection criteria were accepted for inclusion. Reference lists of included manuscripts, and all referenced systematic reviews, were manually searched by JC for additional relevant titles. A proportion of records (10%) was reviewed at each screening stage by all members of the research team (AS, JC, JW). Any discrepancies regarding inclusion eligibility were resolved through discussion.
Data extraction and appraisal
A data extraction table was developed in Microsoft Excel® (Microsoft 365) to capture the attributes of interest. The table was established by the research team based on the research aim and informed by previous systematic reviews. It was piloted through the collection of attributes of interest, was developed iteratively, and modified by the research team as data extraction proceeded. Data were recorded by JC from detailed reading of included studies during which the relevant data were transferred to the data table and subsequently verified by the research team.
Identified studies were appraised for risk of bias. Cross-sectional observational studies adopting qualitative research designs were assessed using the Joanna Briggs Institute Critical Appraisal Checklist for Qualitative Research . Cross-sectional observational studies employing quantitative research methods were appraised using Hoy et al.’s checklist for population-based prevalence studies . The assessments were conducted by JC, and a sample of studies was reviewed by the research team. As this was the first systematic review of this topic, the authors considered it appropriate to include the entirety of available research conducted over the past 20 years irrespective of assessment outcomes.
Data synthesis and analysis
A meta-analysis was not possible due to significant heterogeneity between studies. Where quantitative data were available this is summarised and narratively analysed. Qualitative data were analysed, categorised inductively, and reported narratively based on themes that emerged from the data in the identified studies. Stakeholder categorisation was undertaken inductively.
Throughout this review, the term regulation refers to the statutory/legislative governance of health care occupations or the registration of practitioners, unless otherwise stated.
The database, Google Scholar and manual searches yielded 3132 non-duplicated records. Following screening, a total of 54 published and unpublished papers met the inclusion criteria and were selected for review. The reasons for study exclusion are detailed in Fig. 1.
Risk of bias
Two studies were excluded from critical appraisal because they were qualitative analyses of open-ended questions that were part of larger, and separate, quantitative studies [50, 51]. One report included three separate stakeholder studies  which were assessed individually. Therefore, a total of 54 studies were appraised.
Cross-sectional observational studies using qualitative research design methods (n = 21)
Six studies met the appraisal requirements for the first five domains [53,54,55,56,57,58]. A further six adequately addressed domain 6 [55,56,57,58,59,60]. Most studies (n = 16) addressed domain 7 [53,54,55,56,57,58,59,60,61,62,63,64,65,66,67,68,69,70], and all studies met the requirements of the final three domains, except for one which did not address research ethics . The overall risk of bias was considered moderate in 17 studies [52,53,54,55, 59, 61,62,63,64,65,66,67,68,69,70,71,72] and low in the remaining four [56,57,58, 60].
See Table 2 for full details of critical appraisal of qualitative studies.
Cross-sectional observational studies using quantitative research design methods (n = 33)
Descriptive studies were at the greatest risk of bias in the first four domains where only nine adequately addressed all items [52, 73,74,75,76,77,78,79,80]. All studies met the requirements of domains 5 and 6. Studies performed reasonably well for domains 7 and 8. Domain 9 was considered irrelevant because all studies employed survey methods. Seventeen studies failed to address the final domain [74, 77, 79, 81,82,83,84,85,86,87,88,89,90,91,92,93,94]. Overall, three studies were rated as high risk [85, 91, 92], 16 were considered moderate risk [81, 82, 84, 86,87,88,89,90, 93,94,95,96,97,98,99,100], and 14 studies were judged as low risk [52, 73,74,75,76,77,78,79,80, 83, 101,102,103,104].
See Table 3 for full details of critical appraisal of quantitative studies.
The 54 included studies consisted of one book chapter , two government/industry sponsored reports [52, 75], three doctoral/master’s theses [58, 78, 94], and 48 journal articles [50, 51, 54,55,56,57, 59,60,61,62,63,64,65,66,67,68,69,70,71,72,73,74,75,76,77, 79, 81,82,83,84,85,86,87,88,89,90,91,92,93, 95,96,97,98,99,100,101,102,103,104]. Four papers examined two stakeholder groups and were included separately in this review [70, 88, 91, 100]. One report , which was published in summarised form , consisted of five separate stakeholder studies, two of which were published in their entirety in scholarly journals [73, 101]. The published version of a third study  did not include the full data set relating to regulation. This study and the two remaining studies have been included in this review using the data from the unpublished report . Contact with the corresponding authors of the book chapter, government/industry reports, and theses confirmed their research has not been published in any journal. Overall, the papers selected for inclusion were 60 separate studies from 54 original publications.
Twenty-four studies employed qualitative design methods, and 36 used quantitative methods. The studies spanned 15 countries: Australia (n = 19), Canada (n = 13), New Zealand (n = 10), UK (n = 5), Korea (n = 2), USA (n = 2), and Egypt, Ghana, India, Netherlands, Portugal, Saudi Arabia, Sierra Leone, South Africa, and Taiwan (n = 1 each). Six stakeholder groups were investigated: consumers (n = 8), T&CM practitioners (n = 19), conventional medicine practitioners (n = 23), professional associations (n = 6), education providers (n = 2), and policy-makers (n = 2). The T&CM occupations under study encompassed 36 discrete professions, the most common being naturopathy (n = 26), homeopathy (n = 22), acupuncture (n = 21), herbal medicine (n = 21), chiropractic (n = 18), and traditional Chinese medicine (n = 13). Nine studies did not specify the occupation, using terms such as alternative therapies, complementary and alternative medicine, traditional healing, as well as traditional and complementary medicine.
Table 4 provides details of study characteristics and findings.
Attitudes to regulation
Fifteen of 24 quantitative studies reported greater than 60% support for the regulation of T&CM practices. Across all stakeholder groups there was between 15% and 95% (median 61%) support for, and 1% to 57% (median 14%) opposition to the regulation of various T&CM professions.
T&CM practitioner support for regulation was between 33% and 85% (median 54%) [74, 82, 92, 96, 97, 100], while 8% to 58% (median 43%) opposed regulation [74, 82, 92, 96]. Notably, the main opposition to regulation came from outlier results in one study of Taiwanese folk medicine practitioners of ba guan, gua sha, reflexology, and tuina whose disapproval of regulation ranged from 42% to 58% . Removing these outlier data points from the results shows median T&CM practitioner opposition to regulation was 25% [74, 82, 96, 100].
Two-thirds of professional association studies [54, 63, 68, 70] reported endorsement for regulation, the only quantitative study finding that 36% of Australian associations supported regulation, 36% preferred self-regulation, and 27% called for a stronger, unspecified model of regulation . Canadian T&CM associations [63, 68, 70] and education providers  reported regulation was necessary for the professionalisation of T&CM practices. In contrast, only 53% of Australian education providers supported regulation, with significant differences between private (36% support) and university (100% support) sector providers . Representatives of Canadian conventional medicine associations indicated reluctance for encouraging T&CM groups to pursue regulation and reported that while regulation may be important for T&CM it had to be earned through established evidence and standards . Canadian policy-makers were generally supportive of T&CM professional regulation and integration into mainstream health provision [65, 66].
Consumers favoured regulation for certain T&CM professions, indicating it should be the same as for medical practitioners in half of all consumer studies [79, 83, 91, 93]. In decreasing order of highest reported percentage consumers in Australia, New Zealand, and UK supported the regulation of Ayurveda, naturopathy (90%) , herbal medicine (90%) [76, 79], homeopathy, osteopathy, reflexology (90%) , Chinese medicine (76%-90%) [79, 93, 94], acupuncture (71%-90%) [76, 91, 94], aromatherapy, chiropractic, hypnotherapy (71%-90%) [76, 91], and Rongoā Māori (71%) .
Conventional medicine practitioners also preferred certain T&CM professions to be regulated. Studies from Australia, Netherlands, and UK reported provider support for regulation of Western herbal medicine (77%-92%) [86, 99, 101], naturopathy (73%-92%) [75, 86, 99, 101], chiropractic (15%-88%) [85, 101], acupuncture (56%-87%) [89, 101], and Chinese herbal medicine (80%) . Most notable is the low support for regulating T&CM practices reported by Korean medical professionals (33%) , and for regulating chiropractors reported by physiotherapists (15%) and manual therapists (24%) in the Netherlands . Also noteworthy in the latter study is that 19% of physiotherapists and 67% of manual therapists agreed that chiropractic was in competition with their profession .
Public, practitioner and practice impacts of regulation
Thirty-three studies reported stakeholder reasons for attitudes towards regulation of T&CM practices. These attitudinal drivers were analysed inductively and summarised into three key themes of stakeholder impact; the public, T&CM practitioners, and T&CM practices. Full details of these findings can be found in Table 4.
Regulation and the public
Twenty studies reported stakeholder attitudes regarding the impact of regulation on the public. Studies from Australia, Canada, New Zealand, and UK reported consumer, practitioner, and policy-maker views that regulation of T&CM practices was needed to safeguard the public [65, 66, 75, 94, 99, 101] and protect patients from unqualified, incompetent or unethical T&CM practitioners [50, 52, 60, 65, 66, 69, 71, 74, 93].
Representatives of Canadian nursing associations emphasised public safety to justify their support of T&CM regulation, however allied health association representatives stated regulation should be deferred until T&CM practices established evidence of safety and efficacy . Consumers and GPs stressed the potential for harm from T&CM treatments including interactions with pharmaceuticals [51, 62, 83, 91, 98, 101], as well as harm due to patient exploitation [51, 98], financial cost [98, 101], and inadequate or delayed diagnosis [51, 101]. In one study GPs reported that the risk of harm was primarily due to lack of regulation , while in another GPs indicated that well-trained T&CM practitioners caused little or no patient harm . Conventional medicine practitioners in Sierra Leone stated that herbal medicine posed such serious risks they would not collaborate with T&CM practitioners regardless of regulatory status . Some Australian naturopaths could not agree on whether regulation would improve complaints handling , while consumers identified the need for an official body to hear complaints because of doubts that self-regulated professional associations would adequately sanction errant members .
Regulation and T&CM practitioners
The training and qualifications of T&CM practitioners came under scrutiny from all stakeholder groups in 16 studies conducted in Australia, Canada, New Zealand, Sierra Leone, and UK. Consumers , conventional medicine practitioners [59, 62, 64, 103], and policy-makers [65, 66] expressed concerns regarding the training, qualifications or biomedical knowledge of T&CM providers. T&CM practitioners indicated that regulation would improve training standards, qualification standards [60, 69, 71, 73, 77], and practitioner competence [71, 77]. However, not all Australian and Canadian T&CM practitioners were positive about the likelihood of raised training standards due to perceptions of unfair or unachievable qualifications, grandparenting, or language proficiency requirements [50, 71].
Regulation was seen to confer intra-professional and inter-professional advantages to T&CM practitioners. These include enhancing status and prestige [50, 71, 73, 74, 77, 78], promoting professional acceptance and recognition [60, 69, 71, 73, 77, 78], granting legitimacy [63, 65, 66, 71], improving inter-professional relationships [71, 77], encouraging greater collaboration , and facilitating integration into health care systems [74, 77]. GPs perceived that training quality assurance would promote patient referral to T&CM providers  or conversely did not favour patient referral due to perceived inadequate training standards .
T&CM education providers and representatives of professional associations noted that improving educational standards was an integral part of achieving regulation and professionalisation [52, 63, 68, 70]. Canadian policy-makers stated that poor quality T&CM training and credentialling practices created barriers to achieving regulatory status [65, 66]. They indicated that T&CM could have a legitimate place in health care provided they demonstrated an evidence base and established appropriate standards .
Regulation and T&CM practice
The impact of regulation on practice standards, occupational title protection, and scopes of practice drew most comments from T&CM practitioners and professional associations in studies from Australia, Canada, New Zealand, and UK.
T&CM practitioners anticipated that practice, professional, or ethical standards would improve following regulation [71, 73, 74, 77], while GPs indicated that variations in T&CM standards, practices and treatments, due primarily to lack of regulation, increased risks to patients . Representatives from T&CM professional associations and analysis of association documentation indicated that regulation and professionalisation provided the means for monitoring and mandating practice standards , and preventing unprofessional conduct . In contrast, New Zealand massage therapists regarded benefits such as practitioner monitoring, education standardisation, and professionalisation were readily provided under both self-regulatory and statutory frameworks . Similarly, some Australian naturopaths and herbalists argued that regulation was unnecessary because of membership of professional associations [71, 74] that maintained and monitored practice standards .
A key benefit of regulation according to some T&CM practitioners  and professional association representatives [54, 63] was the provision of legal protection of T&CM occupational titles. Though some T&CM practitioners were divided on the issue , and others were uncertain whether regulation could resolve the problem of overlapping practice scopes , regulation was regarded by some T&CM practitioners  and association representatives  as facilitating the establishment of scopes of practice or practice boundaries. For conventional medicine association representatives the prospect of a T&CM scope of practice prompted concerns over jurisdictional boundary infringements, including limiting scope for T&CM integration . This view was shared by Canadian policy-makers who stated that such boundary infringements on medical practitioner territory could stymy attempts at ‘legitimation’ and integration [65, 66]. T&CM regulation was seen by policy-makers as a contractual bargain in return for T&CM accepting practice restrictions aimed at protecting the public . However, the possibility of practice restrictions arising from regulation concerned some Australian consumers , Australian T&CM professional associations , and Australian, Canadian, and New Zealand T&CM practitioners [50, 53, 71, 73, 77].
Other issues perceived by T&CM providers were related to undue biomedical influence over practice or extra-professional regulatory oversight [50, 71, 74, 77]. Some practitioners indicated this could negatively affect practice , others considered such influence would be overcome through regulation by allowing greater autonomy , a position also taken by some professional association representatives .
A related issue concerns practice misappropriation by untrained/undertrained practitioners from other branches of health care. While T&CM practitioners perceived that regulation could prevent practice misappropriation [53, 69, 71], conventional medicine associations proposed co-optation as a way to maintain control of integration of T&CM practices by conventional medical practitioners rather than non-medical T&CM providers . T&CM practitioners [50, 71] and professional association representatives [52, 54] were concerned that external influences may lead to the diminution of traditional practice philosophies, as were consumers who lamented the potential loss of an intuitive practitioner approach due to regulation .
This review provides the first known systematic examination of the contemporary empirical literature regarding stakeholder attitudes to the regulation of T&CM professions.
Of the 60 identified studies, six sought opinions from professional associations in Australia, Canada, and UK, two studies from Australia and Canada investigated education providers, and only two, both from Canada, canvassed the perceptions of policy-makers. The largely positive views of these stakeholders are tempered by the limited available research. The lack of research from many countries where T&CM is practised also limits the international generalisability of the findings. In particular, the views of policy-makers outside of Canada are yet to be determined and, consistent with other jurisdictional differences, may well be dissimilar to that seen in the present review. Scholars and commentators have long recognised the crucial role of policy-makers and policymaking in formally recognising T&CM professions. Policy-makers reported their priority of upholding the public interest while outlining a roadmap for regulation and integration. These were considered inducements in exchange for practice restrictions, which some T&CM practitioners and professional associations considered unacceptable. Further research focussed explicitly on these stakeholder groups, particularly those of policy-makers, is clearly needed to inform decisions regarding implementation of the WHO Traditional Medicine Strategy recommendations .
Another key finding from the review is that, consistent with regulatory policy provisions, the main focus of stakeholders outside of T&CM professions was on public protection and raising inadequate training and practice standards. While these views were dominant among T&CM practitioners as well, attention was also directed towards the professional benefits and disbenefits of regulation, suggesting that better communication regarding the purpose of regulation is needed. Previous research examining the impact of Chinese medicine regulation in the Australian state of Victoria supports the position that regulation enhances public safeguards with significant improvements in the management of consumer complaints and enforcement of professional standards after its inclusion in the statutory regulation scheme . In addition, comparative examination of T&CM and non-T&CM professions in Australia’s National Registration and Accreditation Scheme has been shown to work at least as well as conventional medical practitioner regulation [107, 108].
Our review found that some T&CM practitioners perceived that professional associations adequately monitored and upheld professional standards obviating the need for regulation, a view contrary to stated consumer concerns. Examination of regulated and unregulated Australian T&CM professions indicates that self-regulatory mechanisms are not as effective for improving public protection when using T&CM services . Furthermore, research on health care workforce regulatory frameworks and reforms emphasise the growing global focus on the public interest, a move away from self-regulatory governance models, and increased independence of complaints handling and oversight of disciplinary proceedings [27, 110].
As increasing T&CM use is a largely consumer-driven phenomenon (given T&CM is rarely integrated into public health systems), it is interesting that most consumers in this review stressed the need to regulate T&CM practices, a finding consistent with research conducted in 1996 (prior to the date inclusion of this review) . This temporal consistency of consumer opinion suggests a long-standing public preference for the independent governance of health practitioners, including T&CM practitioners, who in this review were considered to require the same regulation as that governing conventional health practices. This is notable for two reasons. Firstly because consumer opinion regarding regulation persists despite the diversity of jurisdictions and T&CM professions examined, and secondly because these results run counter to research identifying temporal considerations of stakeholder analysis as potentially limited .
Although a common critique of T&CM regulation by some stakeholders is that regulation may grant these professions undue legitimacy, this view was not widely expressed in the identified studies. This finding, in addition to the worldwide reported rates of consumer use of [13,14,15,16], and trust in [113, 114] T&CM practices suggests that the issue of professional legitimacy may be immaterial to a significant proportion of consumers and health professionals who may already view these practices as legitimate regardless of regulatory status . Additionally, the relevance of established accountabilities and minimum standards of a profession for reasons of public safety and debates about professional legitimacy should be viewed as separate and divorced issues.
While the findings suggest support for T&CM regulation across stakeholder groups, this may not necessarily indicate majority support. Support for or opposition to regulation of T&CM providers is highly contextual and based on factors such as integration, marginalisation, perceived professionalisation, competition, as well as the specific type of therapy or practice. For example, support for regulation from conventional health practitioners was clearly not universal. Physiotherapists and manual therapists in the Netherlands were less supportive of regulation of chiropractors. Conventional medicine professionals in Korea were also less supportive of legislative governance of acupuncture, chiropractic, and traditional Chinese medicine. These differences may be partly explained by perceived inter-professional competition, as indicated by policy-makers and conventional medicine associations, and implied by physiotherapists and manual therapists in this review. The above examples suggest a clear competitive tension in terms of similar scopes of practice. Such competitive tensions have also been suggested to exist between conventional medicine and naturopathy in Australian, Canadian, and German studies [116,117,118]. One commentator has proposed that the care offered by T&CM practitioners could be used to alleviate conventional care workforce shortages , a role which is broadly supported (where appropriate) by the WHO . Competition between medical and non-medical clinicians has also been a long-standing issue with respect to policy development and integration beyond T&CM . However, the degree to which T&CM-specific issues influence standard issues associated with inter-professional competitive tensions, and consequently issues such as views towards regulation and scope of practice of another health profession requires further research before it can be confirmed.
In this review lack of regulation was cited by numerous stakeholders as exposing patients to direct and indirect risks. Yet some GPs indicated that well-trained T&CM practitioners posed no risk of harm, and consumers indicated that T&CM treatments should only be prescribed by qualified providers. The issue of harm, therefore, may be a function of the competence of the practitioner and the quality of T&CM training [121, 122]. Supporting this argument is the uncertainty regarding T&CM practitioner competence and training standards which was frequently reported by stakeholders in this review, including T&CM practitioners. These, together with other non-health risks of T&CM practices, have been extensively reviewed by researchers with many of these risks purported to be exacerbated by lack of regulation . These findings suggest that risks to consumers posed by T&CM practices may be mitigated by appropriate regulatory mechanisms that promote greater public protections via appropriate standards and accountability, while ensuring that consumer choice is protected, and practices can be appropriately integrated where there is evidence of patient benefit. In support of this, naturopathic education standards have been found to vary internationally, with nations that have workforce regulatory frameworks in place reporting higher and more consistent education standards than those without regulation .
As distinct from previously mentioned conflicting opinions between T&CM professions and consumers, there was also disagreement within the professions. The contrasting attitudes towards regulation between various T&CM practitioners, and between practitioners and organisational representatives may potentially be driven by professional self-interest. Several studies highlighted the benefits to and concerns of T&CM practitioners regarding regulation, revealing potential motivations of self-interest for attitudinal positions taken. ‘Self-interest’ may also be evident at the institutional level, particularly when organisations have been granted privileged roles within professions (such as through accredited or self-regulatory structures) that may be removed should those professions become statutorily regulated. This is suggested by previous examination, which has drawn attention to the resistance of much T&CM regulation in Australia being led by professional associations with commercial interests in educational institutions that may be adversely affected by the higher educational standards imposed by regulation [52, 124]. This view accords with researchers of T&CM and non-T&CM professions who contend that self-interest of education providers  and professional associations  are often incompatible with the public interest. As such, while T&CM stakeholder perspectives should be considered important context for development of policy, they should not be elevated above other stakeholder perspectives (particularly consumer expectations), and ultimately regulatory decisions should be guided by public interest arguments, and jurisdictional, health system and professional needs, irrespective of T&CM stakeholder views on regulation.
Despite a comprehensive search strategy, over two-thirds of included studies were conducted in three jurisdictions; Australia, Canada, and New Zealand. Yet these jurisdictions represent only a small part of global T&CM practice. High rates of consumer use of T&CM practices are reported in sub-Saharan Africa , South America , the Arab states , Asia , India , and other world regions  where traditional medicine is integral to many cultural health practices and beliefs. These regions are implementing widespread T&CM practitioner regulation  with little or no formal research examining stakeholder support, as evident from the review findings. Greater research focus is required into stakeholder opinions of regulation in these regions to ensure evidence-informed policy implementation efforts, and consistent application of regulatory measures across jurisdictions and practices.
Although most research on stakeholder attitudes and perceptions of T&CM regulation has been conducted in Australia, Canada, and New Zealand, this appears to have had limited impact as these jurisdictions have been amongst the most hesitant to implement consistent workforce regulation policies across T&CM professions [10, 31]. A striking example comes from Australia where herbal medicine and naturopathy has consistent stakeholder support for regulation, as well as having regulation recommended by every Commonwealth and State government review of the issue since 2000. Yet these professions remain self-regulated almost 50 years after the first government review recommending they be statutorily regulated . Australia, like many countries, has placed much of its T&CM regulatory emphasis on product regulation, which the WHO considers is only part of the regulatory requirements it recommends to national governments . This political inertia, described by some WHO member states as lack of ‘political will’ , also defies T&CM evidence of efficacy and demonstrable public health arguments for regulation of T&CM . In addition to an increased global need for evidence to better inform regulatory decisions when implementing T&CM regulation, governments should also be accountable for ensuring that evidence, where it exists, is used to inform appropriate T&CM policy development. The most appropriate form of regulation for each health system, population, profession, and jurisdiction requires consideration based on evidence, and needs to be explored more explicitly. Our review indicates that regulation of TC&M is not being conducted in an evidence-informed manner. The juxtaposition of jurisdictions generating stakeholder research which has not translated into regulatory policy with jurisdictions implementing regulation without corresponding stakeholder evidence may have significant policy implications and requires careful consideration from the research community engaging with this topic.
This comprehensive review of the state of the current literature on the regulation of T&CM professions comes with several limitations which should be considered when interpreting the findings. Firstly, one-third of studies was identified through hand and grey literature searching. This was likely due to varying definitions, terms and practices used across jurisdictions making a systematic search more difficult. The lack of consensus on T&CM definitions resulted in considerable heterogeneity that was compounded by differences in jurisdictional definitions of conventional medicine versus T&CM practices, and inconsistencies regarding regulation across stakeholder groups. The use of collective T&CM terminology in some studies meant profession-specific data was not available. However, it is worth noting that T&CM is, by definition, a subjective term defined by the health system in which care is offered and as such this variability is understandable. Critical appraisal of qualitative studies was also problematic because there was no identified fit-for-purpose tool for the predominantly descriptive nature of these studies. The included papers cover an extensive time period and variation in attitudinal perspectives due to increasing use of T&CM practices may be expected over that time. However, temporal trends were generally not considered due to high heterogeneity across stakeholder groups as well as being considered of limited value in stakeholder analysis . The results do not report on attitudes to the regulation of professions outside of T&CM such as conventional providers or hospital staff. Nor do the results report the impact of regulation on institutional stakeholders such as health insurers, accreditors, and product manufacturers, or on the health care system generally. Due to these factors, we can only make claims about attitudinal responses to specific professions for a select group of included studies during a specific time period, with a call for greater research into health care workforce regulation in order to explicate these factors. Notwithstanding these limitations, this work provides the most extensive review of this topic to date and may be useful for researchers and policy-makers seeking to examine or implement appropriate T&CM regulation in line with WHO recommendations.
This systematic review identifies widespread consumer and practitioner support for the regulation of T&CM professions. Significantly, consumers and practitioners from all branches of health care are calling for greater independent governance of, and accountably for unregulated T&CM health care professions. The support for regulation derives from a need to safeguard the public by promoting practitioner competence through the establishment of professional and practice standards. Consumers, T&CM practitioners, and conventional medicine practitioners comprised the vast majority of identified studies and their opinions regarding regulation are well represented in the literature. However, there is little research on the views of professional associations, education providers and policy-makers, and no published research on institutional stakeholders such as health insurers and accreditors. The available empirical evidence suggests stakeholders largely support regulation, with policy-makers expecting certain professional commutations which may not be acceptable to T&CM practitioners. In order to corroborate the conclusions of this review, further research is required from a broader range of jurisdictions using rigorous research methods. Determining attitudes across the breadth of health care stakeholders is a critical first step in offering insights into the barriers and enablers of regulation, developing relevant policy and practice recommendations, and informing appropriate policy change regarding T&CM professional regulation.
Availability of data and materials
All data generated or analysed during this study are included in this published article and key sources are cited.
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Jenny Carè was supported by an Australian Government Research Training Program Scholarship while working on this manuscript. The funding body played no role in the study design; data collection, analysis, or interpretation; drafting or editing of the manuscript; or decision to submit the article for publication.
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JC is a naturopath and current member of the Australian Register of Naturopaths and Herbalists, the Australian Natural Therapists Association, and the Naturopaths and Herbalists Association of Australia. JC is a board director of the Naturopaths and Herbalists Association of Australia, an appointment for which no remuneration is paid. AS is a director of the Australian Register of Naturopaths and Herbalists, an appointment for which no remuneration is paid. JW has no competing interests to declare.
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Carè, J., Steel, A. & Wardle, J. Stakeholder attitudes to the regulation of traditional and complementary medicine professions: a systematic review. Hum Resour Health 19, 42 (2021). https://doi.org/10.1186/s12960-021-00579-y
- Complementary medicine
- Complementary and alternative medicine
- Systematic review
- Traditional and complementary medicine