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COMPLAINT
For ease of reference, I attach the following documentation:
Exhibit 1: My letter to the Investigations and Resolutions Office College of
Chiropractors of Ontario, dated 4 February 2001
Exhibit 2: Reply to the Investigations/Resolutions Officer from Dr. Nantais, dated 17
May 2001
Exhibit 3: Complete copy of information found at www.nantaischiro.com
Exhibit 4: Copy of Dr. Nantais' yellow page advertisement from Windsor and
Surrounding Area Phone Book, September 2000 to 2001
Exhibit 5: Standards of Practice with respect to Advertising
Exhibit 6: CCO Website - Policies
Exhibit 7: Bronfort, G. "Asthma and Chiropractic." European Journal of
Chiropractic, Vol. 44 (1996): 1 - 7.
Exhibit 8: Hviid, C. A Comparison of the Effect of Chiropractic Treatment on
Respiratory Function in Patients with Respiratory Distress Symptoms and Patients
without." Bulletin of the European Chiropractic Union, Vol. 26 (1978): 17 - 34.
Exhibit 9: New England Journal of Medicine, Vol. 339, No. 15, Oct. 8th, 1998. "A
Comparison of Active and Simulated Chiropractic Manipulation as Adjunctive
Treatment for Childhood Asthma".
Exhibit 10: Letter from Dr. Winston Rajkimar, M.D., F.R.C.P., Consultant
Respirologist at Windsor Regional Hospital, Windsor, Ontario.
Exhibit 11: Letter from Professor Alan Donner Ph. D. of the Department of
Epidemiology and Biostatistics, University of Western Ontario.
Exhibit 12: College of Physicians and Surgeons of Ontario, Policy Statement on
Complimentary Medicine.
Advertising
- My original complaint did not address advertising directly. Dr. Nantais, however, directed
me to review the policies of the College of Chiropractors of Ontario with respect to Internet
advertising and during my review I discovered many violations which I feel I am obligated to
bring to the attention of the College.
- The current policies of the College of Chiropractors of Ontario (CCO) are located on the
web site of the CCO (Exhibit 5). It is suggested that these policies have been proposed as
regulations, but to date have not yet been approved.
- As stated on the CCO website (Exhibit 6): Generally policies aim to assist members in their
understanding of their professional responsibilities, clarify and interpret regulations and
state CCO's position on a variety of topics.
- For ease of reference, I submit the following quotations from the policy with respect to
advertising (my own numbering has been inserted):
- Members are to ensure, as much as possible, that they (sic, the public) have the
information to make rational choices for their care
- Any advertising with respect to a member's practice must not contain
- anything that is false or misleading
- anything that, because of its nature, cannot be verified
- a testimonial except within the practitioner's office
- a guarantee as to the success of the services provided
- any offer of free consultative, diagnostic or treatment services
- With respect to Dr. Nantais' yellow page advertisement Exhibit 4), I note:
- the "Free Initial Consultation". This is a clear violation of 2(v), as this is an offer of
free consultative services if a patient is not "totally satisfied", according to the yellow
page advertisement.
- "Your satisfaction is unconditionally guaranteed". "You will be completely satisfied
with my service, or your initial visit is complimentary and I guarantee it!" "My
personal guarantee to you." These three statements in the advertisement are a clear
violations of 2(iv), as they all imply a guarantee as to the success of the services
provided.
- Patients are invited to call a toll free number to "listen firsthand to actual recorded
voices of our satisfied patients who want to share their true story of living pain free
with YOU!" To determine whether or not this is a violation of 2(iii) I submit that the
CCO is obligated to investigate those making the "testimonials" to ensure compliance
with this aspect of the current advertising policy.
- To determine whether or not any of the claims made in Dr. Nantais' yellow pages
advertisement violates 2(i), that is being anything that is false or misleading, I urge
the CCO to instigate a review of Dr. Nantais' OHIP billings to ensure that when a
patient has been dissatisfied with the consultation service provided, and this
consultation service has been funded by OHIP that OHIP has been refunded its fee for
service.
- Dr. Nantais replied to my initial letter on 17 May 2001 (Exhibit 2) by advising that "there are
no regulations presently or policy on the use of websites within our profession. Further, I
consider the website to be an in-office informational program for my patients and myself."
- I submit that this statement from Dr. Nantais is misleading. His website is referred to both
on the bottom of his letterhead (Exhibit 2) and also in his yellow pages advertisement
(Exhibit 4).
- I submit that the mention of the website in his yellow pages advertisement is not an
informational program for his patients and himself. I submit that his patients already know
the location of his office and the telephone number to contact it and will not be using the
yellow pages once initial contact with Dr. Nantais has been made.
- The yellow pages advertisement states "New patients welcome. No referral required". I
submit that the mention of the website is clearly an invitation to visit it extended to persons
who are not yet patients, and thus is not an in-office informational program for his patients
and himself.
- Concerning the website and violation of CCO policies, I submit the following statements
from the Dr. Nantais' website (Exhibit 3):
- Under "10 Reasons to Choose Our Clinic for Your Health Needs", no. 9 states
"Complimentary Consultation" which violates policy 2(vii) above for the same
reasons as have been discussed with respect to the advertisement in the Yellow
Pages.
- Under "10 Reasons to Choose Our Clinic for Your Health Needs", no. 7 states
"Hundreds of satisfied patrons because we care" which violates policy 2(ii) above
which states "Any advertising with respect to a member's practice must not contain
anything that, because of its nature, cannot be verified". A claim such as this could
never be substantiated as names would not be provided by Dr. Nantais as this would
violate patient-chiropractor confidentiality.
- I submit the testimonials printed on Dr. Nantais' website, another violation of policy
2(iii) which states "Any advertising with respect to a member's practice must not
contain a testimonial except within the practitioner's office". As with the
testimonials retrieved by calling the toll free number in the yellow pages
advertisement, to determine whether or not this is a violation of 2(iii) I submit that
the CCO is obligated to investigate those making the "testimonials" to ensure
compliance with this aspect of the current advertising policy.
Asthma and Epilepsy
- Dr. Nantais lists 46 "conditions" on his website that he claims "chiropractic commonly
helps". Among these conditions are asthma and epilepsy. Despite the assertion in his
responding letter to you claiming that "...there is wonderfully scientifically sound evidence
that chiropractic or more specifically, the restoration of normal nervous system function has
the ability to help these conditions", he offers neither the evidence itself nor any references
to such.
- I submit that there is no credible scientific evidence at all that relates to epilepsy, and that in
the case of asthma that such evidence (Exhibit 9) clearly indicates that chiropractic is
ineffective as treatment.
- I submit that the "studies" that the chiropractic profession elsewhere refers to (Exhibits 7
and 8 being examples) rely entirely on anecdotal and survey evidence. Moreover, the
studies are so technically flawed that to use them to defend the use of chiropractic as
treatment for asthma constitutes a gross breach of The Code of Ethics of the Chiropractic
College of Ontario, section 1, clauses 1 and 6, and section 4, clauses 1 and 2. To support this
view, I direct you to Exhibits 10 and 11. These are the opinions of a Consultant
Respirologist and an Academic Epidemiologist which point out the inadequacies of Exhibits
7 and 8. Although I have submitted only these three examples of chiropractic research, I
conducted an exhaustive search of the reports that chiropractors, like Dr. Nantais, constantly
refer to as being "wonderfully sound and scientific". With only one exception (Exhibit 9), I
found all to be totally inadequate to be used to support such an assertion. In contrast to this,
Exhibit 9 is a blinded, randomized and controlled study performed by a group of researchers
that included a chiropractor and used scientific evidence-based principles and epidemiologic
techniques to test the theory that chiropractic has a beneficial medical effect on asthma in
children. Please note these researchers conclude that this is not the case.
- I submit that for a chiropractor to promote chiropractic as a treatment for asthma (see his
website, Exhibit 3), as Dr. Nantais does, while failing to indicate to his clients and potential
clients that such treatment is not only unproven but that the best evidence available shows it
to be useless, is a breach of the C.C.O. Code of Ethics, section 1, clauses 1 and 6, and section
4, clauses 1 and 2.
- To illustrate how physicians in Ontario are guided in such matters I have included Exhibit
12, College of Physicians and Surgeons of Ontario, Policy Statement on Complimentary
Medicine. Dr. Nantais, if he were to be governed by College of Physicians and Surgeons of
Ontario, would be in breach of College Policy #1-00 (Exhibit 12) under sections 2, 3, and 4
that concern "treatment" and section 1 that relates to "advancing knowledge". I submit that
one of the principle points of the Regulated Health Professions Act of 1991 was to
incorporate common professional, ethical and scientific standards throughout the medical
professions in Ontario. Surely, to exempt chiropractors from these standards and allow them
to base their practices on scientifically unsubstantiated anecdotal evidence and implausible,
unverifiable theories, backed only by surveys of "patient satisfaction", is to relegate the
profession to the status of astrology and Voodoo. Unfortunately, leaders of the chiropractic
profession in the United States (where Dr. Nantais trained) have already done exactly this.
The following is a direct quote of Dr. Sid Williams, D.C., founder and president of Life
College of Chiropractic, the largest chiropractic school in the United States: "Chiropractors
say subluxations exist and the correction of it lets out the healing force, rejuvenating and
healing the body. Now, all of your story has to be centered on that. Tell that story, learn to
talk with authority on that subject. You don't have to love it. You don't have to believe it."
- Having noted the following:
The Chiropractic Act, 1991, S.O. 1998, c.21 (the "Act").
Scope of practice
- The practice of chiropractic is the assessment of conditions related to the
spine, nervous system and joints and the diagnosis, prevention and treatment,
primarily by adjustment, of,
- dysfunctions or disorders arising from the structures or functions of
the spine and the effects of those dysfunctions or disorders on the
nervous system; and
- dysfunctions or disorders arising from the structures or functions of
the joints.
Authorized acts
- In the course of engaging in the practice of chiropractic, a member is
authorized, subject to the terms, conditions and limitations imposed on his or
her certificate of registration, to perform the following:
- Communicating a diagnosis identifying, as the cause of a person's
symptoms,
i a disorder arising from the structures or functions of the spine
and their effects on the nervous system, or
ii a disorder arising from the structures or functions of the joints
of the extremities.
I submit that there is absolutely no credible scientific evidence anywhere that shows that on a
microbiological, biochemical physiological or anatomical level the pathogenesis or natural
history of asthma or epilepsy is dependant on the structure or function of the spine or joints. I
would qualify this by pointing out that the result of epilepsy may result in involuntary motor
actions and that neurological and joint function is needed for breathing.
- However, the vast majority of those that suffer from epilepsy and asthma do not have any
demonstrable disorder of the spine or joints. I note that, not once in the history of science
have "subluxations" or "misalignments" been objectively demonstrated in individuals whom
the medical profession would regard as healthy.
- Thus, I finally submit that Dr. Nantais, by treating asthma and epilepsy, and numerous other
medical conditions he claims to benefit, is acting outside the scope of practice of the
Chiropractic Act, 1991.
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