Posted on: Mon 14-12-2020

National Complementary and Alternative Medical Association (NACAMA) of Nigeria with my humble self, Prof. Peter Emeka ',Catchy (Gold Medalist) FCAI FIPAM as its National President, has presented a memorandum against the above proposed bill to the Chairman, Senate Committee on Health through our Legal Adviser, Amaka Ezeno, Esq. 

The purpose of this Public Notice is to seek the Senate Committee on Health to STOP the approval and consequent enacting into an Act of the above draft bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria. 

The said draft bill is a calculated move to actualize through the back door the unbridled selfish desire of some persons to lump Traditional Medicine with Complementary and Alternative Medicine under the same Medical Council as was evident in their earlier "bill for an Act to provide for the establishment of the Traditional, Complementary and Alternative Medical Council of Nigeria (TCAMCN) and for matters connected therewith" which the then Hon. Minister for Health, Prof. Isaac F. Adewole, sent to the Federal Executive Council in 2017 to seek the Council's approval of same. In reaction to the said bill, we put up a vehement and profound objection against same to the Secretary to the Government of the Federation, who is also the Secretary of the Federal Executive Council on the 21 day of March, 2017.

Subsequently, we got a reply dated the 9 day of September, 2017 from the Special Adviser to the Hon. Speaker on Legal and Legislative Matters in respect to the said objection, informing us that our said objection has been referred to the House Committee on health for consideration as the Memorandum from the National Complementary and Alternative Medical Association of Nigeria (NACAMA). However, after the said correspondences there was no record of gazetting of the said bill by the Rules and Business Committee of the House, nor the Senate Committee on Rules and Procedure, and there was also no record of the first reading. Second reading, committee reading or any other thing done in respect of the said bill in the 8 Assembly as well as in the 9 Assembly.

There is no doubt that public hearings on bills are organized by the Committees to which the bills are referred and that bills are referred to Committees after they must have been gazette (either by the Rules and Business Committee of the House, or the Senate Committee on Rules and Procedure depending on where the bill originated), passed first reading and second reading. Thus, the call for memoranda and invitation to public hearing on 14th December, 2020 in respect to "bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria" by the Senate Committee on Health implies that the said bill must have been gazetted and passed first and second reading. It is however surprising and worrisome that there is no record of such bill in the website of the 9th Assembly. Out of the 414 bills under consideration in the 9h Assembly as at today, there is no matching record for the "bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria" and no record whatsoever as to whether first and second reading has been conducted, and if yes, the dates it was conducted. Upon entering the said bill into the search box for tracking bills in the National Assembly website, we were confronted with the words "No matching records found". But on the contrary, upon entering the other bill for Sickle Cell Anaemia (Control and Prevention) 2020 (SB. 166) on which the Senate Committee on Health is also having public hearing on the same 14 December, 2020, its records were clearly shown on the website of the 9 Assembly, which said records show that first and second readings of the said bill were conducted on 14 November 2019 and 12 May 2020 respectively on the floor of the Senate. In the light of that, the absence of any record on the bill under consideration and the apparent exclusion of our Association from the list of those specifically invited for the said public hearing as is evident in the notice on page 11 of The Punch Newspaper of Wednesday, December 2, 2020, agitates the mind of our members towards the existence of a high-powered plan to pass this new bill into law, without the knowledge of our Association and some other persons for fear of serious objections.

This new "bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria" has come to achieve the spirit and mission of the said 2017 bill which seemed to have gone into oblivion after Our Association's objections. Our Association's said objections to the 2017 bill are herein stated in stronger terms against the current bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria" because the passing of same into law will amount to collapsing two diametrically different fields of study and practice into one. Traditional Medicine Practice is of parallel relationship with Complementary and Alternative Medical Practice. Both of them are of different content and practice, and should therefore not be collapsed into one. Traditional Medicine involves healthcare delivery methods and practice that are directly traceable or related to culture and ancestral heritage of the people. It is classified into three categories of "Herbalism", "Spiritualism and Occultism" and "Traditional Orthopedics and Surgeries". Alternative Medicine, on the other hand, refers to the practice of different approaches to management of ailments not typically used in Allopathic Practice-Conventional Orthodox Medicine. It has pharmaceutical processes, empirical values and pharmacopeia which are recognized worldwide. It includes the practice of Homeopathy, Naturopathy, Acupuncture and Osteopathy. Complementary Medicine on its own comprises treatments used in addition to Alternative Medicine and Conventional Allopathic Orthodox Medicine, which includes practices like Chiropractic Therapy, Magnotherapy, Kadionic Remedies and Radiesthesia. Complementary and Alternative Medical Practice are of seamless compatibility mode and their general efficacy has led to their more frequent combination with conventional medicine.

Complementary and Alternative Medicine was given statutory flavor in Nigeria upon being incorporated into the MEDICAL AND DENTAL COUNCIL OF NIGERIA by Decree 78 of 1992 called Medical and Dental Practitioners (Amended) Decree No.78 of 1992, Cap M8 Laws of the Federation 2004, which said Decree is still in force and has not been repealed. Since the enactment of the said Decree, Complementary and Alternative Medical Practice have been under the control and supervision of the Medical and Dental Council of Nigeria. 

National Complementary and Alternative Medical Association (NACAMA) of Nigeria was thereafter formed and registered with the Corporate Affairs Commission on the 20th day of May, 2009. Before the said registration with the Corporate Affairs Commission, the Federal Ministry of Health wrote a letter of Recommendation to the Registrar General of Corporate Affairs Commission on 29h August 2008, stating that NACAMA is the recognized body approved by the Federal Ministry of Health to represent the interest of Practitioners of Complementary and Alternative Medicine in Nigeria.

Since its incorporation, National Complementary and Alternative Medical Association (NACAMA) of Nigeria has been overseeing the interest of its members and has its Code of Conduct and Ethics. 

It is our Association's position that the said "bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria" is an attempt to force an unholy marriage between Complementary and Alternative Medicine and Traditional Medicine which said marriage is quite amorphous and incompatible for the already stated reasons amongst others. The educational requirement of the said two fields of medical practice is diametrically different. A Traditional Medicine Practitioner requires little or no education. 

Its practice is based on experience handed down from generation to generation mainly viva voce. And such experience is of a person who is recognized by the community where he lives as competent to provide healthcare through the use of vegetables, animal, mineral substances and plants. However, a Homeopathical Medical Practitioner, which comes under Complementary and Alternative Medicine, is always grounded with sound professional training and medical curricular education for the course in a Medical College and must subscribe in Homeopathic Practitioners' Oaths prior to practice.

It is this requirement for professional training in the practice of Complementary and Alternative Medicine that initially led to the establishment of the Federal College of Complementary and Alternative Medicine (FEDCAM) situate at No.505 Wushishi Crescent, behind CBN Quarters Utako District, Abuja and which said College is factored into the National Budget as passed by the National Assembly. The said College had been in existence until it was closed down by National University Council (NUC) on the 16 day of October 2010, pursuant to which a Ministerial Committee was set up to look into the cause of the closure and the modalities on how to negotiate with NUC for the re-opening of the said College, but the said Ministerial Committee deviated from their terms of reference into making proposal for joining Complementary and Alternative Medicine with Traditional Medicine. In reaction, our Association (NACAMA) wrote to the Hon. Minister of Health stating the true position of facts which made the Federal Ministry of Health take over the administration of FEDCAM, set up a Management Committee for FEDCAM and commenced the process of negotiating with NUC on the closure of FEDCAM Teaching Campus Utako. It was, however, later resolved that FEDCAM be transferred to University of Abuja Teaching Hospital at Gwagwalada given the fact of the nexus and compatibility between Orthodox Medicine and Complementary and Alternative Medicine, being both governed by the Medical and Dental Council of Nigeria and arrangement was concluded in that respect but not yet implemented.

It is pertinent to note at this juncture that since the said close down of FEDCAM by NUC on 24th October, 2010, the National Assembly have been passing the Budgetary Provisions of FEDCAM, and financial transactions are being carried out till date in the name of FEDCAM-a closed down Medical College of the Federal Ministry of Health. Sometime in 2018, our Association issued one month pre-action notice to the Hon. Minister of Justice and Attorney-General of the Federation, Hon. Minister of Health, Hon. Minister of Finance, Head of Civil Service of the Federation and Accountant-General of the Federation, which said pre-action notice is in respect of CONTINUED CLOSURE OF FEDERAL COLLEGE OF COMPLEMENTARY AND ALTERNATIVE MEDICINE (FEDCAM). MISAPPROPRIATION OF THE BUDGET FUND OF FEDCAM AND CONSTITUTING UNREGULATED TRADITIONAL MEDICINE AND REGULATED COMPLEMENTARY AND ALTERNATIVE MEDICINE INTO ONE DEPARTMENT IN THE FEDERAL MINISTRY OF HEALTH. After the said pre-action notice, the misappropriation continued. Even in the 2020 Budget Appropriation Bill of the Federal Ministry of Health, Abuja, budgetary provisions were still made for the said FEDCAM and two projects were reflected to be on going in the name of FEDCAM and which Said project names are: (i) PROCESS LEADING TO THE CONVERSION OF COLLEGE OF COMPLEMENTARY & ALTERNATIVE MEDICINE TO AN INSTITUTE having Code No ERGP2511414, and (ii) STUDY TOURS FOR THE ESTABLISHMENT OF COMPLEMENTARY & ALTERNATIVE MEDICINE HOSPITAL IN NIGERIA with Code No. ERGP25114147.

Now, instead of calling for an account and audit of all the budgetary provisions approved every year for FEDCAM since 2010 that the said FEDCAM was closed down till date, so as to unmask those who have been misappropriating the said FEDCAM funds, our attention is rather being channeled to a new bill for establishment of another Federal College for both Traditional Medicine and Complementary and Alternative Medicine. This new bill, as it is, wants to marry Complementary and Alternative Medicine under the same College with Traditional Medicine, without considering their compatibility in form, content and practice. This intended purpose of this new bill even becomes more worrisome when juxtaposed against the backdrop of the fact that Federal College of Complementary and Alternative Medicine (FEDCAM) had earlier been established for Complementary and Alternative Medicine, and which said College was quite independent of and distinct from Traditional Medicine both in content, practice, administration and management. It is therefore expected that objective steps be taken towards the re-opening of the earlier established FEDCAM that was closed down by NUC, so that it can begin its proper functioning again. This "bill for an Act for the establishment of Federal College of Traditional, Complementary and Alternative Medicine of Nigeria" should thus be amended to read a "bill for an Act for the establishment of Federal College of Traditional Medicine of Nigeria' for such will ensure field specialization and enhance clear-cut delineation as to form and content between Traditional Medicine practice on one side and Complementary and Alternative Medicine practice on the other side. 

Finally, this proposed joining of Traditional Medicine with Complementary and Alternative Medicine in one Federal College will occasion conflict of policy given the fact that they have different educational requirement, line of practice and code of conduct. It is therefore our humble prayer that the Chairman, Senate Committee on Health should use his good office and position to ensure that Complementary and Alternative Medicine is not lumped with Traditional Medicine in one Federal College as being now proposed.

Yours sincerely, 

Prof. Peter Emeka Katchy (Gold Medalist) FCAI FIPAM 

National President 

Dr. Michael Ayodele Akindipe

Secretary Board of Registered Trustees 

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