Ad description
A website promoting Life Works behavioural health clinic, www.lifeworkscommunity.com, focused on the treatment of addictions and behavioural health disorders. On a page headed "Primary/Residential" was the text "Our private residential treatment programmes are some of the finest in the country and can help to treat a whole host of issues, including the following behavioural and addiction issues: Alcoholism, Drug addiction, Eating disorders, Depression and anxiety, Sex addiction, Love addiction, Co-dependency, Gambling".
A page headed "Heroin Addiction Treatment" included the text "We believe that together these elements provide a strong foundation for healthy, sustained, long-term recovery". Another page was headed "Twelve-Steps Work" and included the subheading "Why Choose Life Works?" with the text "See why choosing Life Works is the first step in getting the right treatment for you".
Another page, headed "Anorexia Treatment Centre", with the line "Life Works - the leading specialist in the treatment of anorexia" included the text "Life Works provides all of our patients with a holistic treatment programme. We focus on treating the physical, psychological and spiritual problems caused by anorexia, while tailoring our treatments around the needs of the individual. Our treatment programme helps anorexics look at the underlying causes of their eating disorder and come to terms with their illness. We also look at any co-occurring conditions like alcoholism or drug addiction. This helps each of our anorexic patients understand the reasons behind their illness and start to create healthy strategies for coping once they leave".
Further on, under the subheading "Advice on what you can do about your problems with anorexia" was "Find a treatment programme that includes assessment and treatment for any other pre-existing or co-occurring mental health issues, behavioural health issues or mood disorders - for example, anxiety or depression that may also be affecting you. At Life Works we know these issues often exist alongside a person's anorexia and if left untreated, they can impair the effectiveness of treatment, so it's essential that they are identified and addressed as part of your treatment programme".
Issue
The complainant challenged whether the advertiser could substantiate the efficacy claims made for the conditions mentioned.
Response
Life Works Community Ltd (Life Works) said that their treatment programmes had been designed by some of the world's leading experts in the field of addictions and behavioural health issues who also continued to provide support to Life Works in a consultancy capacity. They said that these experts were nationally and internationally renowned in their fields and had been providing groundbreaking treatment in their respective areas for a number of years. They said the USA had for a number of years been the leading exponents of addiction and behavioural health recovery and as such, Life Works had drawn on those resources in creating the programmes they delivered.
They said that in the world of addictions and behavioural health treatment, the practice of undertaking psychotherapy had been normal for decades in the USA and that it had evolved over time in response to the need for treatment to be accessible, affordable and practical. They said that this was something that was still in its infancy in the UK. They stated that as a result, the leading exponents in the field of addictions and behavioural health were from the USA, which is why they had used them as consultants on their programmes. They said they used a relapse prevention model which was used by world leaders in the field of addictions.
They said that in order to ensure their treatment programmes were some of the finest in the country, as well as bringing a UK perspective, they employed a number of Masters-qualified psychotherapists to deliver and provide added value. They also said that as far as they could ascertain, they were the only treatment centre in the UK that used only Masters-qualified practitioners to deliver its core programmes. They stated that private residents of Life Works were initially assessed by a GP, a consultant psychiatrist and an allocated primary psychotherapist and that from this assessment the individual treatment plan was devised. They said clinical discussions on each resident took place on a daily basis. They provided details of the consultants used by Life Works along with summaries of Life Works’ psychotherapists and their relevant qualifications.
They said they followed the National Institute of Clinical Excellence (NICE) guidelines by ensuring clients who presented unique symptoms got the most effective recommended treatment. They said although they provided an integrated psychotherapy programme for a client's treatment episode, those clients identified with disorders such as depression and anxiety or anorexia, bulimia or overeating would embark on a treatment episode pathway that was aligned to their condition as well as the integrated psychotherapy. They said that in practice, this meant that a client with an eating disorder may well be in a number of psychotherapy group sessions with people whose issues were not manifesting themselves through an eating disorder but through a misuse of alcohol or cocaine but nevertheless shared a similar root cause. They provided a client handbook, a pre-screening form (used where the patient had been referred by a GP or psychiatrist), a sample patient assessment and exit survey, and full details of the various treatments available.
Assessment
Not upheld
The ASA noted the website claimed the programme could "help to treat" a variety of conditions including addiction and eating disorders. We considered the claims including "this helps each of our anorexic patients to understand the reasons behind their illness and start to create healthy strategies for coping once they leave" and "We believe that together these elements provide a strong foundation for healthy, sustained, long-term recovery" would be understood to mean that the programme would assist individuals' development towards recovery from the conditions they were afflicted with but would not be seen as a claim that recovery was a certainty or that the their condition could be "cured".
We considered that, providing the treatments were carried out under the supervision of suitably qualified health professionals, the claims on the website were unlikely to discourage essential treatment for conditions for which medical supervision should be sought. We understood there were various psychotherapists who worked at Life Works including a BACP accredited psychotherapist and counsellor specialising in humanistic and integrative therapies, a registered psychologist specialising in adult mental health and a lead consultant psychiatrist who was a Fellow of the College of Psychiatry. We concluded that because the treatments at Life Works were carried out under the supervision of suitably qualified health professionals following a clinical assessment, the claims to help treat the listed conditions would not discourage essential treatment where medical supervision should otherwise be sought and that the claims were not misleading.
We investigated the ad under CAP Code (Edition 12) rules
3.1
3.1
Marketing communications must not materially mislead or be likely to do so.
(Misleading advertising),
3.7
3.7
Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.
(Substantiation) and
12.1
12.1
Objective claims must be backed by evidence, if relevant consisting of trials conducted on people. Substantiation will be assessed on the basis of the available scientific knowledge.
Medicinal or medical claims and indications may be made for a medicinal product that is licensed by the MHRA, VMD or under the auspices of the EMA, or for a CE-marked medical device. A medicinal claim is a claim that a product or its constituent(s) can be used with a view to making a medical diagnosis or can treat or prevent disease, including an injury, ailment or adverse condition, whether of body or mind, in human beings.
Secondary medicinal claims made for cosmetic products as defined in the appropriate European legislation must be backed by evidence. These are limited to any preventative action of the product and may not include claims to treat disease.
and
12.2
12.2
Marketers must not discourage essential treatment for conditions for which medical supervision should be sought. For example, they must not offer specific advice on, diagnosis of or treatment for such conditions unless that advice, diagnosis or treatment is conducted under the supervision of a suitably qualified health professional. Accurate and responsible general information about such conditions may, however, be offered (see rule
12.1
12.1
Objective claims must be backed by evidence, if relevant consisting of trials conducted on people. Substantiation will be assessed on the basis of the available scientific knowledge.
Medicinal or medical claims and indications may be made for a medicinal product that is licensed by the MHRA, VMD or under the auspices of the EMA, or for a CE-marked medical device. A medicinal claim is a claim that a product or its constituent(s) can be used with a view to making a medical diagnosis or can treat or prevent disease, including an injury, ailment or adverse condition, whether of body or mind, in human beings.
Secondary medicinal claims made for cosmetic products as defined in the appropriate European legislation must be backed by evidence. These are limited to any preventative action of the product and may not include claims to treat disease.
).
Health professionals will be deemed suitably qualified only if they can provide suitable credentials, for example, evidence of: relevant professional expertise or qualifications; systems for regular review of members' skills and competencies and suitable professional indemnity insurance covering all services provided; accreditation by a professional or regulatory body that has systems for dealing with complaints and taking disciplinary action and has registration based on minimum standards for training and qualifications.
(Medicines, medical devices, health-related products and beauty products) but did not find it in breach.
Action
No further action required

