COMPLAINT TO THE EDITOR OF 
THE LANCET REGARDING THE 
PACE TRIAL 
 
I have today (Monday 25th April) emailed the editor 
of the Lancet, Richard Horton, with my own 
complaint regarding the PACE trial as below
Angela Kennedy
````
Dear Doctor Horton
Further to my email correspondence with one of your 
colleagues, Zoe Mullan, about the PACE trial, I am 
writing to you to complain, formally, about the 
article: 
White PD, Goldsmith KA, Johnson AL, et al. 
Comparison of adaptive pacing therapy, cognitive 
behaviour therapy, graded exercise therapy, and 
specialist medical care for chronic fatigue 
syndrome (PACE): a randomised trial. Lancet 
2011; 377: 823-836.
The PACE trial was subject to a large amount of 
concern and objection by advocates for those 
diagnosed with ME or CFS, from the beginning of the 
study in 2004 and throughout its course. 
I was one of those who outlined specific concerns at 
the beginning of the trial: and various concerns were 
also outlined in response to the publication of the 
protocol mid-trial. For evidence of this please see my 
own and others comments at:
http://www.biomedcentral.com/1471-2377/7/6/comments/comments
I am writing primarily as the mother and long-term 
advocate of a child (now a woman) diagnosed at 13 
with ME/CFS, and who has various objective, 
medically substantiated organic impairments 
(especially neurological and cardiovascular) which 
have led to severe disability. 
If subjected to PACE-type CBT and GET, she would 
be at serious risk of further harm.
There remain a large number of very serious flaws, 
problems and discrepancies in this whole study, 
including the published article in the Lancet. 
I am writing to reiterate the many substantive and 
valid concerns raised by Professor Malcolm Hooper in 
his complaint to you about this article and the trial 
itself, available here:
http://www.meactionuk.org.uk/COMPLAINT-to-Lancet-re-PACE.htm
http://www.meactionuk.org.uk/COMPLAINT-to-Lancet-re-PACE.doc
I am also aware that a large number of valid and 
substantive criticisms of the trial have been made in 
letter form to the Lancet and have been rejected for 
publication.
In addition to the above concerns, I am specifically 
gravely concerned about the dangers to patients 
caused by the unsafe claims that Cognitive 
Behavioural Therapy of the type advocated by White 
et al, and Graded Exercise Therapy, are safe 
treatments for people diagnosed with Myalgic 
Encephalomyelitis/Chronic Fatigue Syndrome, claims 
propounded both within the PACE article itself, and 
the accompanying editorial. 
This has led to similar unsound claims being made 
elsewhere. The potential adverse ramifications for 
patients of these unsound claims are particularly 
serious, and therefore those claims should not have 
been made.
Bleijenberg and Knoop, in their Lancet 
editorial accompanying the publication 
of the PACE article, claim:
"Concerns about the safety of cognitive behaviour 
therapy and graded exercise therapy have been 
raised more than once by patients' advocacy groups.
Few patients receiving cognitive behaviour therapy 
or graded exercise therapy in the PACE trial had 
serious adverse reactions and no more than those 
receiving adaptive pacing therapy or standard 
medical care, which for cognitive behavioural therapy 
has already been shown.
This finding is important and should be 
communicated to patients to dispel unnecessary 
concerns about the possible detrimental effects of 
cognitive behaviour therapy and graded exercise 
therapy, which will hopefully be a useful reminder of 
the potential positive effects of both interventions."
The PACE article itself states:
"Trial findings show cognitive behaviour therapy 
(CBT) and graded exercise therapy (GET) can be 
effective treatments for chronic fatigue syndrome, 
but patients' organisations have reported that these 
treatments can be harmful and favour pacing and 
specialist health care. We aimed to assess 
effectiveness and safety of all four treatments."
The same article concludes:
"Findings from the PACE trial suggest that 
individually delivered CBT and GET, when added to 
SMC, are more effective and as safe as APT added to 
SMC or SMC alone. Patients attending secondary care 
with chronic fatigue syndrome should be offered 
individual CBT or GET, alongside SMC."
Other parties have repeated these unsafe claims, 
informed by the PACE trial. One example of a 
newspaper article is that in the Daily Mail, on 18th 
February 2011, which claims:
"Got ME? Fatigued patients who go out and exercise 
have best hope of recovery, finds study".
A press release from the Science Media Centre about 
the trial included various unsound claims of safety 
from doctors. Alistair Miller, for example, stated:
"It provides convincing evidence that GET and CBT 
are safe and effective and should be widely available 
for our patients with CFS/ME".
Derick Wade, as another example, claimed that the 
trial:
"...confirms the effectiveness of two treatments, and 
their safety. The study suggests that everyone with 
the condition should be offered the treatment, and 
every patient who wishes to be helped should be 
willing to try one or both of the treatments".
In addition to the claim of safety of CBT and GET, 
Wade's comment also indicates that patients may be 
regarded as recalcitrant (for example, in a context of 
welfare support or continued medical support) should 
they, quite rationally, dare refuse to 'try' treatments 
that actually may be dangerous.
The fundamental problem that needs to be 
addressed is that the evidence available shows that, 
contrary to the above claims, the PACE trial did not 
adequately assess, or even address, safety of CBT 
and GET, and this study did not disprove patients 
and doctors' valid and substantive concerns regarding 
the dangers of CBT and GET. 
One major discrepancy of the PACE trial and the 
resulting article was the failure to address the 
biomedical evidence available detailing serious 
organic physiological dysfunction in patients who 
receive a 'CFS' or 'ME' diagnosis. 
Another is the inadequate treatment of adverse 
outcomes within the trial. This is discussed in more 
detail in Professor Hooper's document as detailed 
above.
I wish to raise specific concerns about 
the patient cohort. 
Evidence indicates that research cohorts for 'CFS' or 
'CFS/ME' appear to be obtained (by those promoting 
psychogenic explanations for these conditions) by 
excluding patients with signs and symptoms 
(especially neurological) found in Myalgic 
Encephalomyelitis case descriptions, or indeed other 
organic diseases (the 'alternative diagnoses'). 
The PACE trial used, not just one case criteria to 
exclude patients with symptoms and signs of organic 
disease from the trial, but three: 'Oxford' (Sharpe et 
al, 1991); Reeves et al (2003), and those from the 
NICE guidelines (see White et al, 2011: 2).
Of 3158 patients who had been referred to "six 
specialist chronic fatigue syndrome clinics in the UK 
National Health Service" (White et al, 2011: 2), 1187 
patients (over a third) were actually excluded 
because they did not actually meet Oxford criteria for 
'CFS'. 
Confusingly, no figures are given for those meeting 
Reeves et al (2003) and NICE exclusionary criteria, 
though these are claimed as part of the exclusion 
process. 
This is possibly because the Oxford criteria 
themselves efficiently exclude those with signs and 
symptoms of neurological myalgic encephalomyelitis, 
to the point that the Reeves and NICE exclusionary 
criteria may well have been superfluous.
There are similarities of symptoms and signs of 
neurological dysfunction found in specific case 
descriptions of myalgic encephalomyelitis (for 
example, Ramsay, 1988), or 'ME/CFS' (as defined by 
Carruthers et al, 2003), with other neurological 
conditions, for just one example, those found in 
Multiple Sclerosis (see, for example, Poser 2000). 
Therefore, to have included patients with 
neurological symptoms and/or signs might have 
meant there was a risk of other neurological 
conditions (such as Multiple Sclerosis) being involved 
in the trial. 
Indeed, in his response to me on the biomedcentral 
site, Peter White discusses the need to keep people 
with other neurological conditions out of the trial. 
But, crucially, the key problem here is that, from the 
evidence available (some of which is detailed by 
Professor Hooper), Professor White and his 
colleagues do not appear to believe 'ME' is a 
neurological condition in the first place, despite the 
acceptance of this by the World Health Organisation 
and British agencies, and despite the evidence 
available to support this, and therefore seem unable 
to acknowledge that at least some people given an 
ME or CFS diagnosis have organic neurological and 
other deficits. 
It seems therefore likely that ME/CFS patients 
with signs and symptoms of neurological (and 
indeed other organic) dysfunction were actively 
excluded from the PACE trial.
Ironically, if this premise is accurate, White et al 
cannot have substantiated their claims for the safety 
and efficacy of CBT/GET for patients they claim such 
treatments are safe and efficacious, those given an 
ME or CFS diagnosis who suffer physiological 
impairments including neurological deficits. 
It needs to be noted that the PACE article actually 
claims the results:
"can be generalised to patients who meet alternative 
diagnostic criteria for chronic fatigue syndrome and 
myalgic encephalomyelitis but only if fatigue is their 
main symptom" (citing the London criteria and 
Reeves et al 2003 as the 'alternative diagnostic 
criteria'). 
This is a confusing statement, bearing in mind that: 
the 'London Criteria' used in PACE were not actually 
that as referenced by them (as the documentation 
from the PACE trial protocol shows); the Reeves et al 
criteria were supposed to have been used by them 
within the trial itself (so the question arises, why 
are they 'alternative'?); and their conclusions, and 
that of Bleijenberg and Knoop and others, presents a 
blanket claim of safety and efficacy for all people 
given a diagnosis of ME or CFS, contradicting this 
statement about "only if fatigue is their main 
symptom".
Indeed, it is notable that White et al, from the 
beginning of the trial and throughout, refused to use 
the criteria of Carruthers et al (2003) to include 
people with symptoms (and possibly signs) of 
neurological dysfunction, although they used their 
own (specifically customised and therefore different) 
version of a set of criteria claimed to identify ME (the 
'London' criteria), already controversial due to lack of 
peer reviewed publication, uncertainty in authorship, 
and the existence of different versions. 
Indeed, as is evident from the PACE Trial protocol, 
the specifically customized PACE version of the 
'London' criteria for ME bore close similarities to the 
Oxford criteria for CFS, and were fundamentally 
different to the Carruthers et al criteria (2003).
That so many patients (nearly a third), of whom had 
been referred to a 'specialist chronic fatigue 
syndrome unit' by their GP, were actually excluded 
from the CFS diagnosis favoured by these authors, is 
extremely important, and leads to the question: 
what happens to such patients? When the patient 
exclusion process of another project (the negative 
XMRV study by Erlwein et al, 2009) was clarified by 
co-authors (Wessely et al, 2010), some clinical 
patients who had attended chronic fatigue/CFS clinics 
commented in response that they had not been 
investigated thoroughly in the way the research 
cohorts appeared to be (ironically in order to exclude 
organic disease), either at the clinic or by their GP. 
Another study by Newton et al (2010) found that 
40% of patients referred to a 'chronic fatigue 
syndrome unit' did not have 'CFS', though, crucially, 
Newton was including, as 'CFS' patients, those with 
specific physiological conditions such as positional 
orthostatic tachycardia syndrome (POTS), which are 
associated with neurological dysfunction (Carruthers 
et al, 2003). 
If these patients had been also excluded from a 
diagnosis of CFS (which, according to the Oxford 
criteria and indeed the Reeves et al criteria, they 
should), the amount of patients referred to British 
'chronic fatigue syndrome units' (or, often, 'chronic 
fatigue units'), meeting the Oxford criteria for CFS 
and having no exclusionary conditions that suggest 
organic dysfunction, would appear to be very small 
indeed. 
But even patients excluded under the rubric of the 
Oxford criteria from research, will now be exhorted to 
'try' CBT and/or GET in a clinical context, because of 
the unsafe claims of the PACE trial.
Another major discrepancy in the PACE trial that I 
wish to specifically highlight here is that one of the 
treatments, 'Adaptive Pacing Therapy', bore no 
resemblance to the strategy of 'pacing', specifically 
adopted by ME patients and reported as being 
helpful by them in charity surveys. 
'Pacing' as reported in these surveys is merely an 
autonomous flexible management strategy utilised 
by patients with ME in order to cope with the 
limitations of the illness, like sufferers of other 
chronic impairments. 
The PACE trial's 'Adaptive Pacing Therapy' was not 
autonomous, being therapist led, and imposed a 
regime upon the patient similar to the GET 
treatment. 
This has specific iatrogenic potential in that, 
informed by the claims of PACE, patients may be told 
by health care professionals that an autonomous, 
flexible self-management strategy that is common in 
patients with chronic impairments, that has been 
found to be useful in ME/CFS, must not be practised, 
on the incorrect findings of a trial that did not even 
study the correct type of 'pacing' in the first place.
In light of the extremely complex and serious 
problems of confounding inherent in this trial, it is of 
serious issue that unsafe claims of safety and 
efficacy of CBT/GET as treatments for ME or CFS were 
made by the PACE authors and supporters, to the 
point that iatrogenic harm could be caused to 
patients because of a resulting lack of 
understanding, by medics and ancillary staff, 
misinformed by such unsafe claims, of both the 
neurological and other physiological impairments in 
at least some patients given such diagnoses, and 
the abnormal physiological response to exertion that 
appears to be a key feature in those patients.
I also draw your attention to your colleague Zoe 
Mullan's comment to me in our email 
correspondence: 
"We were not aware of any objections to this study".
I am very concerned about this as objections to the 
PACE trial have been publicly mounted, and indeed 
have been responded to (though in eventuality, not 
satisfactorily) by authors of the trial, some years 
prior to publication.
At the very least, a much more detailed discussion of 
limitations to this study should have been 
undertaken that took into account the concerns that 
were raised. 
In the circumstances and to ensure patient safety, I 
now believe that the article should be retracted, and 
the claims that CBT and GET have been found to be 
safe in ME and/or CFS should be publicly corrected. 
I must ask that you keep to your promise that "we 
will invite the critics to submit versions of their 
criticisms for publication and we will try as best as 
we can to conduct a reasonable scientific debate 
about this paper" made by you on the ABC radio 
programme 'The Health Report'. 
I consider myself as one of those 'critics'. Indeed, I 
believe a full and public good faith investigation of 
my own and others complaints need to be 
undertaken by you and other parties, as appropriate.
In addition, I believe there should be an unreserved 
public apology issued to all the ME community and 
their advocates who have raised legitimate and 
substantive concerns, in various ways, about the 
problems in the PACE trial, for the prejudicial 
misrepresentation of their concerns and motivations, 
made by you on the ABC radio programme 'The 
Health Report', in which you made the following 
comments:
http://www.abc.net.au/rn/healthreport/stories/2011/3192571.htm
"...the criticisms about this study are a mirage, they 
obscure the fact that what the investigators did 
scrupulously was to look at chronic fatigue syndrome 
from an utterly impartial perspective."
"Not this kind of orchestrated response trying to 
undermine the credibility of the study from patient 
groups but also the credibility of the investigators 
and that's what I think is one of the other alarming 
aspects of this. This isn't a purely scientific debate; 
this is going to the heart of the integrity of the 
scientists who conducted this study."
"...indeed in a few examples of allegations have 
been made to professional authorities, the General 
Medical Council here in the UK about the work of 
these scientists on the basis of the flimsiest and 
most unfair allegations. And indeed the study costs 
$4 million pounds to undertake but the allegations 
and the freedom of information requests and the 
legal fees that have been wrapped up over the years 
because of these vexatious claims has added 
another 750,000 pounds of taxpayers' money to the 
conduct of this study."
"Indeed, and I think this is where one sees a real 
fracture in the patient community. One is seeing a 
very substantial number of patients very willing to 
engage in this study, desperate to get good 
evidence on which to base their future treatment but 
one sees a fairly small, but highly organised, very 
vocal and very damaging group of individuals who 
have I would say actually hijacked this agenda and 
distorted the debate so that it actually harms the 
overwhelming majority of patients."
"Well what we're doing right now is waiting for the 
formal response from the authors to this 43 page 
attack on their integrity and the study and the 
request for a retraction. We plan to publish their 
response to that attack, we will invite the critics to 
submit versions of their criticisms for publication and 
we will try as best as we can to conduct a 
reasonable scientific debate about this paper. This 
will be a test I think of this particular section of the 
patient community to engage in a proper scientific 
discussion."
These prejudicial comments should also be retracted. 
They are inappropriate and inaccurate, and sadly 
indicate a possible bad faith on your part from the 
offset, and this is an unusual and extremely worrying 
response from the editor of a key medical journal to 
the reasonable concerns that have been raised, in 
good faith, by a vulnerable patient community and 
others supporting them. 
I cannot emphasise enough that the concerns related 
by myself and others relate specifically to the risks 
to safety of patients, and our concern to prevent 
those: this is the motivation for my own actions 
here.
In addition, please note that I am, here, formally, 
repeating my request, made to Zoe Mullan initially, 
that peer review documentation be made accessible 
to me under the Freedom of Information Act. 
I understand that the usual procedure under this Act 
applies. I am concerned that no response has been 
given to my original request, made in early March.
Please be aware that, in the interests of 
transparency and accountability, I will be publicising 
this email, and I may publish the responses I 
receive.
Yours sincerely,
 
 
Angela Kennedy
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