Dr Myhill’s complaint to GMC about PACE authors.

R

Robert 1973

Senior Member (Voting Rights)
Full letter (very long) and template for patients to submit their own complaints can be found here: https://t.co/YPXTiR7Vsc


Dear Sir Terence

‘THE PACE STUDY AUTHORS COMPLAINT’

COMPLAINT RE AUTHORS OF PACE STUDY [Reference 1]

I am referring such authors of the PACE TRIAL [Reference 1 below] as are subject to GMC regulation to the GMC investigation team.

https://www.gmc-uk.org/DC6046_Hardcopy_form_52934724.pdf ) as its format does not lend itself to the complexities and details of this case. I would be grateful if you would pass this on to the relevant department.

....

Edit: There is now a petition you can sign if you wish to support Dr Myhill's complaint: https://www.change.org/p/the-genera...s-complaint-to-the-gmc-about-the-pace-authors
 
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She's accusing the PACE authors of fraud. Previously the thought was that it would be difficult to prove that but it looks like the need to prove intent to deceive may have been relaxed.
A clear test for dishonesty arose in the criminal case of R v Ghosh (1982) 75 CR App. R. 154 where this 2-stage test was marked down as:

  • "Were the person's actions honest according to the standards of reasonable and honest people?" If a jury decides that they were, then the defendant's claim to be honest will be credible. But, if the court decides that the actions were dishonest, the further question is:

  • "Did the person concerned believe that what he did was dishonest at the time?"
However, this 2-stage test was relaxed in the case of Ivey v Genting Casinos (UK) Ltd t/a Crockfords [2017] UKSC 67 where it was decided that a view of the defendant's belief of the relevant facts must be made, but that it is no longer necessary to consider whether the person concerned believed that what he did was dishonest at the time. In other words, the second stage of the test is now no longer required to prove dishonesty.

It is my contention that at all points referenced below it is clear that a reasonable and honest person would conclude that the PACE authors’ actions were dishonest.
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So it will be interesting to see if this argument is accepted. My (complete, uneducated) guess will be this will be rejected initially to see if she will push it on to whatever the next step in the process is.
 
I've not read this yet, but I'm not sure Sarah Myhill is the best person to be doing this, seeing as the GMC has previously made rulings against her for making misleading claims. Also, in that video of her speaking about the problems with PACE, it sounded like she wasn't clear on all the details.

Additionally, I'm not sure this is a good idea coming from anyone. Is anyone aware of an example of a complaint against researchers like this being successful in the past?
 
Esther12 said:
Additionally, I'm not sure this is a good idea coming from anyone. Is anyone aware of an example of a complaint against researchers like this being successful in the past?
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I am not so sure it is a bad idea. From a brief glance I suspect the arguments are not that tight, but all the stuff that has come out in the last year or two is cited. I see no harm in the GMC having to think about it.

I cannot think of a successful complaint quite like this but to be honest I cannot think of a set of circumstances quite like the PACE scam. Companies pointing out serious ethical flaws in widespread policy have been successful in the past, although the context has usually been a bit different. Individuals have been struck off or even imprisoned for unethical clinical practices purporting to be a form of research - particularly in the context of cancer surgery.
 
I'm sure this is one of those "How long is a piece of string?" questions that is completely unanswerable, but how quickly does the GMC reply to accusations against doctors?

In the online magazine, Pulse, I remember a doctor mentioning in some comments that it took several years for a complaint against him from a patient to be finalised and rejected. I would assume a complaint of this complexity from Dr Myhill might take 6 - 8 years to wend its way through the system?
 
politicians will be saying to people that they need to use available routes to complain in order to achieve change. Eg you have to have complained to any govt department before MPs will refer your case to the Parliamentary Ombudsman.


I don't think many people genuinely thought that NICE were going to review the guidelines but that paid off. (Obvs still a long way to go on that but miles better than waiting X years to even get them to start a review)

Even if this isn't successful it could still chip away at the medical establishments support for BPS and anything that causes a few cracks in the wall is positive.
 
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My personal view is that I would need an infinitely long spoon here: ME/CFS critics of things like PACE have already been portrayed as (and I believe I'm pretty much repeating an SMC quote verbatim here) 'little different to anti-vaxxers'. drmyhill.co.uk still (I just checked) contains the following on its autism page [bold mine]:

Three viruses (all single RNA strands) known to cause brain damage on their own are measles, mumps and rubella. Dr Richard Halvorsen's book "The Truth About Vaccines" (see Amazon Link for The Truth about vaccines) explores this in some depth and, indeed, in the introduction of this book Dr Peter Fletcher states that whilst we may not know the mechanism, there is no doubt that our present epidemic of autism is due to vaccination. I encourage all parents to read the Halvorsen book so they can decide for themselves the best vaccination schedule for their children.
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Anti-MMR horseshit? No thanks. I don't want to be associated with that and I don't want ME/CFS patients as a whole to be associated with that.
 
It's possible that any complaint that isn't cautious and accurate will then be used to try to discredit wider concerns about PACE.

Problems with the case presented at the judicial review of the NICE guidelines were used to disparage wider concerns about CBT/GET for a long time after.

I'd feel nervous with anyone making a complaint like this, and I've got less than full faith in Myhill at the moment.

Having said that, things have progressed a lot over the last few years, and it's possible any investigation could shake something useful loose. Do those at the GMC even have any sort of background in assessing research though? Aren't they just going to defer to authority figures telling them it's just a campaign of anti-science harassment?
 
Esther12 said:
It's possible that any complaint that isn't cautious and accurate will then be used to try to discredit wider concerns about PACE.

Problems with the case presented at the judicial review of the NICE guidelines were used to disparage wider concerns about CBT/GET for a long time after.

I'd feel nervous with anyone making a complaint like this, and I've got less than full faith in Myhill at the moment.

Having said that, things have progressed a lot over the last few years, and it's possible any investigation could shake something useful loose. Do those at the GMC even have any sort of background in assessing research though? Aren't they just going to defer to authority figures telling them it's just a campaign of anti-science harassment?
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IMHO, the odds that the GMC would do anything is tiny. The odds are significantly higher that making overblown claims about fraud, orchestrated by a practioner who herself has had run ins with the GMC and who makes somewhat dubious claims about alternative treatments/vaccinations, would feed in to the vexatious anti-science nutters narrative. Let's face it: ME/CFS patients have a PR problem - and this would likely make it worse. I can't see how this action would do anything other than score an own goal.
 
Oh it would be wonderful to see the PACE authors struck off. Don't wake me up from this lovely dream...

I have mixed feelings about this. I think they should be disciplined, but I can't see it happening, and am worried it might backfire, and actually strengthen them as they will be able to say the GMC have investigated and found no case to answer. And this could backfire on the NICE guideline review if they are found not to have fraudulently distorted their data.

I also have mixed feelings about Dr Myhill. She seems sincere and dedicated to helping ME patients, but she seems to have some unscientific ideas too, and doesn't come across well as a speaker.

Would she have to present the case in person, or is it all done through documentary evidence?
 
Andy said:
She's accusing the PACE authors of fraud. Previously the thought was that it would be difficult to prove that but it looks like the need to prove intent to deceive may have been relaxed.

So it will be interesting to see if this argument is accepted. My (complete, uneducated) guess will be this will be rejected initially to see if she will push it on to whatever the next step in the process is.
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I think that's an interesting ploy. I'm sure the team behind this have considered all the possible ways this might play out. I find it riveting.
 
Esther12 said:
I've not read this yet, but I'm not sure Sarah Myhill is the best person to be doing this, seeing as the GMC has previously made rulings against her for making misleading claims. Also, in that video of her speaking about the problems with PACE, it sounded like she wasn't clear on all the details.

Additionally, I'm not sure this is a good idea coming from anyone. Is anyone aware of an example of a complaint against researchers like this being successful in the past?
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Myhill has won ALL her GMC complaints . I think the team behind this venture are more than capable of creating a very tight evidence base in the legal sense. I don't think the Establishment are going to play 'easy' with this, but playing 'hard' might actually turn out to be very embarrassing for them. I sense we're looking at this as a 'long game'.
 
Lilpink said:
Myhill has won ALL her GMC complaints . I think the team behind this venture are more than capable of creating a very tight evidence base in the legal sense. I don't think the Establishment are going to play 'easy' with this, but playing 'hard' might actually turn out to be very embarrassing for them. I sense we're looking at this as a 'long game'.
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I suspect they will want to cover their backs but would prefer not to have to deal with it.
 
I've had a look through the document now. I do think she has done a pretty thorough job, all based on the JHP special issue on PACE as evidence. And I like her idea of inviting patients who have been harmed to submit their own testimony directly to the GMC - I hope a lot are able to do so.

One point I didn't see that I think she perhaps should have included is the fact that White and others didn't declare their conflict of interest as advisers to the DWP and insurance industry to patients on the consent form at the start of the trial, which, as David Tuller pointed out, negates the consent, and makes all the trial data unusable / invalid, and the consent form information fraudulent.

I really hope she succeeds.

A question about submitting evidence. I have not been directly harmed by CBT or GET of the PACE variety, but I, like many of us, believe I have been harmed by the NICE guidelines, both in refusal of referrals to specialists to check for alternative or additional diagnoses, and in consistent encouragement to push myself to exercise more. I don't think this is the sort of evidence required, so don't intend to submit it. Am I right?
 
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