



I complained about the PACE authors to the GMC

After much time passing, the GMC issued a decision notice stating that it was not going to investigate the PACE authors

I made a Freedom of Information Act data request, requiring that the GMC release their reasons for not investigating the PACE authors

The GMC replied with a short opinion-based document, with no evidence base

I made a second Freedom of Information Act data request, requiring that the GMC either release the evidence base for their decision or admit that no evidence base actually existed

The GMC replied and stated that they considered that they had complied with this second Freedom of Information Act data request within the document supplied as above

I wrote to the Information Commissioner’s Office asking that they review the GMC’s insistence that it had complied with my second data request

On 1 October, [see below] the ICO upheld my point of law and put a Decision Notice on the GMC requiring that they either release the evidence base for their decision not to investigate the GMC or that they state that there is no such evidence base.

The GMC appealed against the above ICO Decision Notice to force such disclosure

In a turnaround of logic, the ICO accepted this GMC appeal

I appealed against the ICO decision to accept the GMC’s appeal against the original Decision Notice

The ICO has accepted my appeal against their decision as noted directly above

I will appear in person at a Hearing [Myhill versus ICO]. I will update you on when and where this will take place.

You can download the full Signed Decision Notice here - ICO Full Signed Decision Notice re Myhill vs GMC

GREAT NEWS regarding my complaint to the GMC about the PACE authors

The Information Commissioner’s Office [ICO] has slapped a Decision Notice on the GMC. The GMC must release the evidence base for its determination not to investigate the PACE authors or admit that there was no evidence base for that decision. If there is no evidence base, then I will take the decision not to investigate the PACE authors to the High Court for a Judicial Review.

The GMC has consistently refused to release any evidence base for its decision not to investigate the PACE authors and so one might assume that there is no evidence base!

BRIEF SUMMARY

The ICO has determined that the GMC was in breach of the FOIA when it failed to give proper reasons to me as to why it determined not to investigate the PACE authors. The GMC now has 35 calendar days to provide the evidence base for its refusal to investigate the PACE authors or to state that it has no evidence base. If it does not, it will be held in contempt of court. If it transpires that there is no evidence base for the GMC’s decision not to investigate the PACE authors, then I will take that decision to the High Court for Judicial Review.

FULLER SUMMARY

Dr Myhill complained to the GMC about the PACE authors

The GMC determined not to investigate her complaint

Dr Myhill conducted an FOIA search on the GMC to try and determine the reasons for that rejection of her complaint

When the GMC papers of the above FOIA search were released, Dr Myhill considered that the GMC had determined their decision not to investigate the PACE authors based purely on opinion and that there was no evidence base for their decision, or at least no evidence base as released to Dr Myhill under the FOIA search

Dr Myhill then asked the GMC, again by way of a FOIA request, that Either they release the evidence base for their decision not to investigate the PACE authors Or state they had no evidence base for such decision and that indeed their decision not to investigate the PACE authors had been based on opinion only

Dr Myhill considered that the GMC reply to her FOIA request as directly above was inadequate and so complained to the ICO

The ICO has upheld Dr Myhill’s complaint

The GMC now has 2 options Appeal this decision Answer that either they had no evidence base for their decision not to investigate the PACE authors or release the evidence base for that decision.

If the GMC fails to do either of the options in point 8, they will be held in contempt of court. They have 35 calendar days in which to do so.

If the GMC cannot supply an evidence base within 35 calendar days for their decision not to investigate the PACE authors, then Dr Myhill will take that decision not to investigate to a Judicial Review.

MY PRESS RELEASE

The PACE study published in the Lancet 2011 has been shown in peer reviewed scientific journals to be flawed. Since this was bankrolled by public money, this further amounts to financial fraud.

The PACE study has further defrauded people with CFS/ME from obtaining proper benefits: both financial and medical. Indeed, many have been made much worse by the poor medical advice that flowed from this study.

Timeline

Jan 2018 Dr Myhill reported the PACE authors to the GMC for scientific and financial fraud.

July 2018 The GMC refused to investigate the PACE authors.

Sept 2018 Dr Myhill asked that the GMC supply her with the evidence base for its refusal to investigate. The GMC has consistently refused to supply this despite repeated demands.

March 2019 Dr Myhill reported this to the Information Commissioner arguing that failure to do so is a breach of the FoI Act.

Sept 2019 The ICO agreed with Dr Myhill and has demanded the GMC supply Dr Myhill with the relevant information within 35 calendar days of its decision notice of 30 Sept 2019.

If the GMC is unable to supply Dr Myhill with the evidence base for its decision not to investigate the PACE authors, then Dr Myhill will take this decision to the High Court for Judicial Review.

Further information from Dr Myhill (office@doctormyhill.co.uk)

As you may remember, the GMC has made an initial determination on 26 July 2018 not to investigate the PACE authors, following my complaint of 14 January 2018. The full text of the complaint is attached to this post.

Dissatisfied with this, I set the wheels in motion to have a Judicial Review of that GMC decision not to investigate. The legal arguments were [and still are!] drawn up and ready to go.

Straight after I wrote to the GMC informing them of my intention to take their decision to a Judicial Review, the GMC wrote back to me on 3 December 2018, stating that it was going to conduct an internal ‘Rule 12’ review of the decision.

It may be that this is a delaying tactic, or it may be an attempt by the GMC to show that it has done ‘all it can’ before its decision not to investigate is sent for Judicial Review.

Of course, there is the ‘possibility’ that the internal Rule 12 review will reverse the initial GMC decision and the GMC will determine that the PACE authors should be investigated.

The ball is currently in the GMC’s court and I await their Rule 12 review decision. I have confirmed that the ‘Judicial Review clock’ does not start ‘ticking’ until the Rule 12 review decision has been made and so I still have plenty of time to submit my legal arguments for a Judicial Review.

Thank you all for your continued support.

The GMC has sent a letter to me, 'rejecting' my complaint about the PACE authors.

This is not the end of the story.

The GMC rejection letter consisted only of assertions and opinions - there was not a single piece of evidence to back up these assertions and opinions. My letter of complaint was fully evidenced in exquisite detail - please see below to remind yourself!

So, since that rejection letter, what has been happening?

1--I have requested a full subject data access request under the Data Protection Act and the Freedom of Information Act for all papers concerning this case, held by the GMC, and in particular, the evidence base that they have used [if any!] in coming to their decision. The GMC have promised a response by 4 Dec 2018

2--I have been in contact with a QC concerning taking the GMC to Judicial Review over this case.

3--I have issued a 24 page rebuttal letter to the GMC rejection letter, pointing out errors in the GMC letter, and demanding evidence to back up their assertions and opinions.

4--I have also responded to the letter in the Times from the Head of the Medical Research Council [MRC] which was supportive of PACE. I have done an FoI search of the MRC requesting the evidence base for the assertions in that letter.

You will understand that I cannot release any more detail of these actions as that will prejudice the case, but be assured that things are being done, and you will be informed of progress, just as soon as I can. Also, there is no need for you to act at the moment, but as soon as I need your further help, I will be asking!

Once again, thank you for all your support.

NEW YOUTUBE VIDEO 2 July 2018



In conjunction with Life the Basic Manual (LTBM), Dr Myhill has produced another YouTube video on the MAIMES campaign. In this YouTube, Dr Myhill discusses the chances of getting a fair hearing of her complaint against the PACE authors. You can see this YouTube video here:



PLEASE SIGN MY PETITION

There is now a petition where you can show your support for this Complaint simply by clicking. Please do support me in this way - the more letters and the more clicks on the petition we get, the better! Thank you.

DATE - 15 September 2019 - 10,294 clicks of support - NOW CLOSED

Running total of number of letters of support so far submitted

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters, a participant in the PACE trial

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters

Comment made by one of our supporters

DATE - 25 March 2018 - 210 letters submitted - THE DEADLINE FOR SUBMISSION [25 March 2018] HAS NOW PASSED as copied to Dr Myhill's GMC Complaint Team (cr648@hotmail.co.uk)

How you can help

If you are able to write a bespoke letter specific to your circumstances please read the information below in sections 4-14

If you are not able to do this, please download the 'Simplified Letter' below. Then all you need to do is to put the date and your name and address at the top and then go down to the paragraph in red font and simply delete what is not relevant to you and keep in what is relevant to you. Then please send the email/letter to the addresses as noted on the Simplified Letter.

Simplified Letter

Note - where to send your letters of support

The GMC has made it more difficult to access email addresses in order to find where to complain! One is directed to a standard form of complaint. This standard form is rather restrictive and so I decided to complain direct to the Chair of the GMC - Sir Terence Stephenson. I would ask please that you send your letters of support to him too. His address details are as below

1--email it to Sir Terence Stephenson (TStephenson@gmc-uk.org) - Sir Terence Stephenson is the Chair of the GMC

2--if you can, please send your letter by post too, here is the address –

Sir Terence Stephenson,

General Medical Council,

Fitness to Practise Directorate,

3 Hardman Street,

Manchester,

M3 3AW.

3—if you feel comfortable with doing so, please can you copy your letter of support to Dr Myhill at Dr Myhill's GMC Complaint Team (cr648@hotmail.co.uk)

Introduction

On 14th January 2018, I complained to the Chair of the GMC, Sir Terence Stephenson, about the authors of the PACE study. PACE study.

In this letter of complaint I stated that:

I shall be informing CFS/ME sufferers through social media and other means to get in touch with the GMC directly, by way of example of the harm done by the PACE authors, and to confirm the seriousness of the injuries they have suffered. I shall ask patients to report directly to the GMC in the following categories:

*Those who have suffered damage as a result of CBT.

*Those who have suffered damage as a result of GET.

*Those who have been denied disability benefits because the physical nature of their disease has not been properly recognised and/or they have been told they have a psychological condition.

*Those who have been denied industrial compensation for their disease because the physical nature of their disease has not been properly recognised and/or they have been told they have a psychological condition.

*Those who have been denied referral or funding for referral to a physician specialising in the biomedical approach to treating CFS/ME.''



This list is not intended to be exhaustive and any harm in any manner caused by PACE should be reported to the GMC - see the section directly below. These 'letters of support' from sufferers are key to this Complaint.

Below you will find the full text of my Complaint letter, available to download. Also you will find a template letter of support available to download. The template letter will need to be personalised as noted in the text of the letter. Please do use your own style of letter if you prefer.

If you have any queries please email Dr Myhill's GMC Complaint Team (cr648@hotmail.co.uk)

It would be very helpful if you could send a copy of your letters of support to Dr Myhill's GMC Complaint Team (cr648@hotmail.co.uk) so that we can keep a complete file of all such letters of complaint.

Blog Post by Sally Burch

Please do also see this excellent Blog post by Sally Burch which includes extracts from her personal letter of support. This may help you to compose your own letter. Thank you Sally!

Sally Burch's Blog Post on her PACE Complaint letter of support

Examples of how you may have been harmed by PACE

Jacqueline Miller of the 'Support for Followers of Dr Myhill's Protocol Facebook group' (Support for followers of Dr Myhill's protocol Facebook Group) has submitted a letter with the following points included.

I have suffered mental distress as a result of PACE. For example, benefit applications, and assessments were more stressful because my illness was considered psychological

Visits to doctors, and consultants, and NHS emergency departments are more stressful because my illness is considered psychological.

I am denied treatment because my illness is considered psychological

I am accused of wasting time, and lying, and treated with contempt and suspicion because my illness is considered psychological

My word and experience is dismissed because my illness is considered psychological, and I am labelled as ‘mentally ill’.

I am labelled as a delusional patient because of negative connotations implied by doctors and NHS staff.

It appears all my other health issues, and concerns are now considered psychological, and therefore dismissed as imaginary

I experienced extreme trauma, HARM & LOSS because my illness was considered psychological

I was targeted, and harmed after complaining, because my illness was considered psychological

I am denied compensation for my disease because the physical nature of it has not been properly recognised and/or told I have a psychological condition

It is my belief PACE WAS AT THE ROOT OF THESE PROBLEMS

I WAS HARMED BY GET AND PACE RECOMMENDED GET AND SO PACE AUTHORS ARE AT FAULT BECAUSE I WAS RECOMMENDED GET BECAUSE OF PACE and denied funding for referral to a physician specialising in the biomedical approach to treating CFS/ME. Note: Funding which was already agreed, and put into place was later withdrawn, and denied.

This is a great example of the kind of DISTRESS that has been caused by PACE. These points do not necessarily 'fit' easily within the broad 5 categories listed above.

So, please do think about ANY harm that has been caused to you by PACE - in my experience most ME sufferers have been harmed in some way.

Harm and distress caused by PACE to children

If you feel able [and we know that this is an extremely difficult area where there can be coercion to say the least] then please do send letters to the GMC concerning children, supporting Dr Myhill's Complaint regarding the PACE authors. This could be on any of the broad areas of harm and distress as listed above but also may include harm done to children being forced to go to school and being subject to child protection plans.

See also False Allegations of Child Abuse in Cases of Childhood Myalgic Encephalomyelitis (ME)

PACE has created a general background environment of harm and neglect

A key point is -- consider the general background environment that PACE has created surrounding ME. This has meant that many forms of 'indirect' harm and distress are more likely.

Examples may include:

your illness being ignored

having your symptoms being dismissed

being thought of as 'problem patient'

having to endure disbelief from the medical profession

being dealt with in an off-hand or even aggressive manner

Text of my Complaint Letter

Please find the full text of my Complaint here as below:

Letter of Complaint to GMC about the PACE authors

Text of Template Letter of support

Please do make any adjustments you wish to improve upon this or submit your own letter entirely. This template is for guidance only and will need personalising where stated in the text of the letter - noted in red.

Please find the full text of the Template letter of support here as below:

Template Letter of support - Word document to enable easy amendments and editing.

Text of Social Media post regarding this complaint

Here is the full text of the Social Media post announcing this Complaint:

*** DR MYHILL HAS COMPLAINED TO THE GMC ABOUT THE PACE AUTHORS ***

*** SHE WANTS YOUR HELP ***

PLEASE SHARE THIS POST AS WIDELY AS POSSIBLE. THIS COMPLAINT IS IN THE PUBLIC DOMAIN.

The GMC is the UK doctor’s regulatory authority – the General Medical Council. Patient support is sought from all patients who feel they have been harmed by PACE. You do not have to be a UK citizen.

PACE is the study ‘Comparison of adaptive pacing therapy, cognitive behaviour therapy, graded exercise therapy, and specialist medical care for chronic fatigue syndrome (PACE): a randomised trial. (2011)’, published in The Lancet.

SEVEN other medical doctors are supporting this complaint but wish to remain anonymous - they are concerned about the impact of such “whistle-blowing” on their future careers within and without the NHS.

The letter of complaint is attached. The complaint is one of Fraud, namely:



--fraud by false representation

--fraud by failing to disclose information

--fraud by abuse of position



There are also numerous breaches of:



--GMC Guidance on Good Medical Practice

--GMC Guidance on Good Practice in Research

--GMC Guidance on Consent to Research



Dr Myhill is asking for your help.

Please read the letter of complaint and also the ‘PACE patient support letter’.

HELPING DR MYHILL

We want people who have been harmed by PACE to write in support of this complaint. You could have been harmed in any of these ways and possibly others too:



•suffered damage (including physical, mental or emotional distress) as a result of CBT.

•suffered damage (including physical mental or emotional distress) as a result of GET.

•been denied disability benefits because the physical nature of your disease has not been properly recognised and/or you have been told you have a psychological condition.

•have been denied industrial compensation for your disease because the physical nature of your disease has not been properly recognised and/or you have been told you have a psychological condition.

•have been denied referral or funding for referral to a physician specialising in the biomedical approach to treating CFS/ME.



You do NOT have to have been diagnosed or have fallen ill with CFS/ME after PACE was published [March 2011] to support this complaint.

So, for example if you were diagnosed/fell ill in 1980, but have recently been refused benefits as a result of PACE [for example, for not engaging in CBT or because your illness was considered psychological) or maybe you have suffered mental distress as a result of PACE (for example, benefit applications were more stressful because your illness was considered psychological) then you CAN support this complaint. It will help our case to have as many support letters as possible.

If you feel you have even the smallest ‘case’ for inclusion then please do submit a letter of support – it is incumbent on the GMC to prove that you have not been so affected, not for you to prove that you have!

Please do email if you are in doubt or need help phrasing why you have been harmed by PACE. Please be patient – we will respond as quickly as possible. Dr Myhill's GMC Complaint Team (cr648@hotmail.co.uk)'

Just put your reasons for supporting this complaint in the relevant section in the attached template letter ‘PACE patient support letter’ and fill in any other portions that need filling in [all marked in red] and then:

1--email it to Sir Terence Stephenson (TStephenson@gmc-uk.org) - Sir Terence Stephenson is the Chair of the GMC

2--if you can, please send your letter by post too, here is the address –

Sir Terence Stephenson

General Medical Council

Fitness to Practise Directorate

3 Hardman Street

Manchester,

M3 3AW.



3—if you feel comfortable with doing so, please can you copy your letter of support to Dr Myhill at Dr Myhill's GMC Complaint Team (cr648@hotmail.co.uk)

Tie in with MAIMES - Medical Abuse In ME Sufferers

I am also running a campaign to get a Public Inquiry into the abuse of ME sufferers - please see Medical Abuse in ME Sufferers for details of how you can get involved in this too! There are many external links on this page showing the evidence for the debunking of PACE.

Related Article

Downloadable documents

Signed By

BAGs Sarah

A friend has named me Balls and Guts Sarah.





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