Guide XII-169

Heilpraktiker tradition

1939Germany
Client cardCompare
[source: …] where a claim comes from[uncertain] not confirmed in a primary source[synthesis] the writer's reconstruction

1. Introduction

Version followed: German federal law as in force in 2026: the Heilpraktikergesetz (HeilprG) of 17 February 1939, last amended 23 December 2016; the Federal Ministry of Health (BMG) guidelines for the Heilpraktiker check of December 2017 as applied in Länder rules (Bavarian administrative rules of 11 February 2025; Landkreis Heilbronn information sheet); and the Psychotherapeutengesetz (PsychThG) as reformed in 2019, in force since 1 September 2020. The Heilpraktiker tradition is a whole-system practice carried out by other practitioners; this guide describes it as its laws and organisations set it out and covers the psychotherapist's work alongside it.

What it is. “Heilpraktiker” is not a single therapy but a German legal status: a person who holds a state permission (Erlaubnis) to practise Heilkunde without being licensed as a physician. HeilprG § 1(1): “Wer die Heilkunde, ohne als Arzt bestallt zu sein, ausüben will, bedarf dazu der Erlaubnis.” Heilkunde is defined in § 1(2) as any professional or commercial activity for the diagnosis, cure or relief of illness, suffering or bodily harm in humans. [source: HeilprG, gesetze-im-internet.de]

Permission, not training. The law prescribes no state training and no state examination. The local health office (Gesundheitsamt) or competent Land authority checks (“Überprüfung”) that the applicant would not endanger public or individual health; the BMG states that medical competence as such is not examined. [source: BMG, Rechtsgutachten zum Heilpraktikerrecht page; Bavarian rules 2025]

Two licence forms. (1) The general licence (Heilpraktiker). (2) A licence restricted to psychotherapy, informally the “sektoraler Heilpraktiker” or “Heilpraktiker für Psychotherapie” (HP-Psychotherapie); Bavaria recommends the title “Heilpraktiker oder Heilpraktikerin, beschränkt auf das Gebiet der Psychotherapie”. [source: Bavarian rules 2025]

How change is said to happen. The tradition has no single theory of change: each method used under the licence carries its own model (see the method guides in this domain). In a BMG-commissioned survey, about 42% of general Heilpraktiker assigned their treatments to complementary medicine, while about 59% of sectoral psychotherapy licence holders assigned their methods to science-based medicine. [source: in vivo GmbH, Kurzbericht empirisches HP-Gutachten, 2024]

Why it matters to psychotherapists in Germany. The sectoral licence is a second legal route to delivering psychotherapy-like treatment, alongside Approbation under the PsychThG. Clients, referrers and some trainees often cannot tell the two apart, and the practitioner's title matters legally. [source: WD 9 - 3000 - 011/22; Eichelberger 2003]

  • Regulatory status (one line): a lawful, state-licensed profession in Germany under the 1939 HeilprG, entered by a health-office check rather than regulated training; in Austria the profession is not permitted (cited by the DNEbM as a model). [source: HeilprG; DNEbM 2017]
  • Evidence status (one line): the licence is a legal status, not an intervention; evidence depends entirely on the method used, and the BMG empirical report could not assess effectiveness or risks across the profession for lack of data. [source: Kurzbericht 2024]

2. Framework

2.1 Route to the general licence

  • Legal basis: HeilprG § 1 plus the First Implementing Regulation (1. HeilprGDV) and Land administrative rules. [source: Heilbronn sheet; Bavarian rules]
  • Typical requirements: a minimum age (the Heilbronn sheet states completion of the 25th year of life), at least a Hauptschulabschluss, a medical certificate of physical and mental fitness, a criminal-record certificate (Führungszeugnis) no older than three months, CV and a declaration on pending proceedings. [source: Heilbronn sheet; Bavarian rules]
  • The check: a written part and an oral part before the Gesundheitsamt, the oral part with lay assessors. The check covers basic medical knowledge, German, relevant health law and awareness of the limits of competence and the dangers of exceeding them. Bavaria plans two rounds a year. It is explicitly not a performance examination. [source: Bavarian rules 2025]
  • Binding content: the BMG “Heilpraktikerüberprüfungsleitlinien”, dated 7 December 2017 (Heilbronn sheet) and published BAnz AT 22.12.2017 B5 (Bavarian rules). [source: both]
  • Limits in the statute: the licence does not allow practice “im Umherziehen” (itinerant practice; § 3, fine up to €2,500 under § 5a); practising Heilkunde with neither medical licence nor Erlaubnis is a criminal offence, up to one year's imprisonment or a fine (§ 5). [source: HeilprG]

2.2 Route to the sectoral licence for psychotherapy (HP-Psychotherapie)

  • When it applies: the applicant states they will practise only psychotherapy; the licence is expressly restricted to that field. [source: Bavarian rules] Legal origin: the licence restricted to psychotherapy rests on case law, not on a separate statute; the Bavarian rules cite the Federal Administrative Court judgment of 21 January 1993 (BVerwG 3 C 34.90, NJW 1993, 2395) for it. [source: Bavarian rules 2025 (BayMBl. 2025 Nr. 102)]
  • Exemption: applicants with a psychology degree including clinical psychology (Heilbronn: at least 9 ECTS, Master building on a psychology Bachelor, or Diplom) may be licensed wholly or partly on their documents; others may be asked for an expert opinion at their own cost. [source: Bavarian rules; Heilbronn sheet]
  • Check content: distinguishing mental disorders from physical illness and psychosis, recognising signs of suicide risk, basic law on compulsory placement and guardianship; general medical basics are not tested (Bavaria). Examiners test whether the candidate knows where Heilpraktiker activity ends and doctor-reserved treatment begins, has adequate diagnostic ability for the restricted field, and can derive psychotherapeutic treatment from the diagnosis (Heilbronn). [source: both]
  • Method knowledge: Heilbronn requires basic knowledge of one psychotherapy method meeting six criteria: a coherent model of therapy and illness; theory and practical training; therapy experience with supervision; self-experience (usually 40 hours); training of at least two years; a broad range of indications. [source: Heilbronn sheet]
  • Format (Heilbronn example): 60 multiple-choice questions in 60 minutes with 75% to pass, then an individual oral-practical check of about 45 minutes; failing the oral part means repeating both parts. In Bavaria the oral panel includes a psychiatrist or psychotherapist and a sectoral Heilpraktiker. Fees in Heilbronn total several hundred euros. [source: Heilbronn sheet; Bavarian rules]
  • Title: the sectoral licence does not allow the unqualified title “Heilpraktiker”. [source: Bavarian rules]

2.3 HP-Psychotherapie versus Approbation (PsychThG)

PointHeilpraktiker restricted to psychotherapyApprobierte Psychotherapeutin / approbierter Psychotherapeut
Legal basisHeilprG 1939 + Land rulesPsychThG (reformed 2019, in force 1 Sept 2020)
Entry routeHealth-office check of knowledge and safety; no prescribed trainingFive-year full-time university study and a passed state examination; transitional rules for old-law trainees run to 2032 (hardship 2035)
What is checkedThat practice would not endanger health; limits of competence; differential diagnosis, suicide riskFull academic and practical qualification
TitleMay not work under the title “Psychotherapeut/in”; must stay clearly distinct; Bavaria recommends “beschränkt auf das Gebiet der Psychotherapie”Protected title “Psychotherapeutin/Psychotherapeut”; physicians may add “ärztliche/r”
Definition of psychotherapyPractises Heilkunde restricted to psychotherapy; methods not limited by statuteDiagnosis, cure or relief of clinically significant disorders using scientifically tested and recognised methods (§ 1(2))
Somatic clarificationMust know the boundary with doctor-reserved treatmentMust arrange somatic clarification during treatment (§ 1(2))
Statutory health insurance (GKV)Cannot bill GKV; patients pay directlyCan bill GKV after Kassenzulassung from the regional KV
Private insuranceDepends on contract; many insurers require a register entryDepends on contract
Professional codeNo legally binding code for all Heilpraktiker; association codes bind members onlyChamber membership and Berufsordnung [uncertain]
SanctionsRevocation by the licensing authority; § 5 HeilprG for unlicensed practiceApprobation law and chamber jurisdiction [uncertain]

[source: PsychThG § 1; WD 9 - 3000 - 011/22 (2022); Bavarian rules 2025; Heilbronn sheet; FDP NRW response to the Gesamtkonferenz Deutscher Heilpraktikerverbände; Ärzteblatt 2017]

Title disputes: misuse of the protected title, or a confusingly similar one, is punishable under § 132a StGB; one legal commentary argued that “Psychotherapeutische Praxis”, “Praxis für Psychotherapie” and even “Heilpraktiker für Psychotherapie” risk confusion. [source: Eichelberger, Ärzteblatt PP 2003] Later, in 2011 the Lower Saxony Higher Administrative Court, granting leave to appeal rather than ruling finally, expressed serious doubts that “Heilpraktiker für Psychotherapie” is unlawful: the title can be read as signalling a licence restricted to psychotherapy, the law sets no title for restricted licence holders, and civil courts had often not found such titles misleading. [source: Nds. OVG, 8 LA 71/10, 2011] The final outcome of that case and later case law are [uncertain]; Bavaria recommends “Heilpraktiker oder Heilpraktikerin, beschränkt auf das Gebiet der Psychotherapie”. [source: Bavarian rules 2025]

Prescribing: whether and how either group may handle prescription-only medicines is outside this guide; neither non-physician group prescribes medicines in ordinary practice [uncertain]. Since 2019 the GSAV makes manufacture of prescription medicines and tissue preparations by non-physician health practitioners subject to licensing (as reported). [source: Ärzte Zeitung 2019]

2.4 What a client experiences

  • With a general Heilpraktiker: a private practice, self-paid fees, a consultation, and whatever methods that practitioner uses (from talking and manual methods to remedies and, in some practices, injections or infusions). Content varies widely; the empirical report found most services are paid privately. [source: Kurzbericht 2024; Ärzte Zeitung 2019]
  • With an HP-Psychotherapie: private, self-paid sessions, often in a talking-therapy format, using whichever method the practitioner trained in; no GKV billing. [source: WD 9 2022]
  • Clients may believe the practitioner is state-trained or equivalent to a doctor or approbierte Psychotherapeutin; the Münsteraner Kreis argued that “staatlich anerkannt” wording invites this. [source: Uni Münster 2017; Ärzteblatt 2017]

2.5 Who practises it and the reform debate

  • Numbers: an estimated well over 40,000 Heilpraktiker in Germany (2017 estimate); about 15,000 in North Rhine-Westphalia (a party's 2022 answer). [source: Ärzteblatt 2017; FDP NRW] Licence counts for HP-Psychotherapie were not reported in the BMG empirical report. [source: Kurzbericht 2024]
  • Associations: the Gesamtkonferenz Deutscher Heilpraktikerverbände und Fachgesellschaften asks parties to keep the “Heilpraktiker für Psychotherapie”. [source: FDP NRW]
  • Münsteraner Memorandum Heilpraktiker (21 August 2017): a 17-member interdisciplinary group initiated by medical ethicist Bettina Schöne-Seifert proposed either abolishing the profession or replacing it with “Fach-Heilpraktiker” as an add-on qualification for existing health professions. The Deutsches Netzwerk Evidenzbasierte Medizin (24 October 2017) supported it but preferred abolition. [source: Uni Münster 2017; DNEbM 2017]
  • Deutscher Ärztetag 2017 resolved to restrict Heilpraktiker activity. [source: Ärzteblatt 2017]
  • BMG: a Rechtsgutachten zum Heilpraktikerrecht (April 2021, 308 pages) on the federal room for reform, to be discussed first with the Länder and then associations; and an empirical report (in vivo GmbH, October 2024) concluding further examination is needed on care provision and patient safety. No reform law had been passed as of these sources. [source: BMG pages]

3. Guiding principles

These are principles for the psychotherapist working alongside clients who use Heilpraktiker services. They are drawn from the statutes above and, where marked, are synthesis.

  • A licence is not a qualification. The Erlaubnis certifies that a check found no danger, not that the holder is trained in a method; ask what the practitioner actually does. [source: BMG; Bavarian rules]
  • Know and name your own legal status exactly. Approbierte Psychotherapeutin, HP-Psychotherapie or trainee: say which, in the title, the consent form and the invoice. [source: PsychThG § 1; WD 9 2022]
  • Ask without judgement. Use is common and legal; disapproval drives disclosure underground. [synthesis]
  • Attribute, do not adjudicate. Describe each method's claims as its practitioners make them, with evidence status in one line; neither endorse nor ridicule. [synthesis]
  • The psychotherapist never performs, sells, prescribes or recommends a Heilpraktiker remedy, procedure or referral for a physical condition. [synthesis]
  • Somatic clarification first. Approbierte Psychotherapeuten must arrange somatic clarification (PsychThG § 1(2)); apply the same standard to any physical complaint a client brings to a Heilpraktiker. [source: PsychThG]
  • Autonomy with information. Adults may choose; your task is to make the choice informed and free of pressure. [synthesis]
  • Coordinate only with consent, and through the client's doctor or pharmacist for anything about medicines. [synthesis]
  • Escalate on danger signs: stopping or delaying medical treatment for serious disease, invasive procedures (injections, infusions) by non-physicians, children, pregnancy, eating disorders, financial exploitation. [source: Ärzte Zeitung 2019; synthesis]
  • Stay in your scope. Neither licence lets you advise on medicines or physical treatment. [synthesis]
  • Record it. Note what is used, by whom, the client's reasons, risks discussed and decisions. [synthesis]
  • No conflicts of interest. Do not refer to, co-market with, or accept fees from Heilpraktiker practices for clients' physical complaints; declare any dual role. [synthesis]

4. Intervention inventory

All items below are the psychotherapist's own work alongside Heilpraktiker care. The psychotherapist does not perform, sell, prescribe or recommend Heilpraktiker methods. Legal facts are sourced in sections 1–2; clinical procedure is [synthesis] unless tagged otherwise.

4.1 Asking routinely and recording

  • Purpose: make Heilpraktiker use visible at intake and at reviews, especially when physical symptoms, medicines, cancer, pregnancy or children are involved. [synthesis]
  • Steps: (1) Add one neutral question to intake about “Heilpraktiker, naturopathic or other practitioners, remedies or procedures”. (2) Ask what the practitioner does, how often, cost, and whether the client's doctor knows. (3) Ask whether the practitioner holds a general or a psychotherapy-restricted licence, if the client knows. (4) Record the practitioner type (not their name unless needed), methods, any substances or procedures in plain words, and the client's view. (5) Repeat at reviews.
  • Example language (illustrative): “Many people see a Heilpraktiker or use natural remedies alongside other care. Is that part of your picture at the moment? I ask everyone, so we have the whole view.”
  • Watch for: hesitation or apology (signals expected disapproval); injections or infusions; a physical illness managed only by the Heilpraktiker. Working if: the client volunteers updates unprompted.

4.2 Licence literacy: helping the client understand what the title means

  • Purpose: correct the common belief that a Heilpraktiker is state-trained or equivalent to a doctor or approbierte Psychotherapeutin. [source: Uni Münster 2017; Ärzteblatt 2017]
  • Steps: (1) Ask what the client understands the licence to mean. (2) Explain, neutrally, that the Erlaubnis follows a health-office check that the holder does not endanger health; there is no prescribed training (cite section 1). (3) For an HP-Psychotherapie, explain the difference from Approbation (section 2.3): different route, no GKV billing, no protected title. (4) Suggest the client ask any practitioner directly about their training, method and supervision.
  • Example language (illustrative): “The Heilpraktiker licence is a permission given after a check by the Gesundheitsamt. It does not say what training someone has had, so it is fine to ask them that directly.”
  • Watch for: hearing this as an attack on a practitioner the client trusts; keep it factual. Working if: the client can say in their own words what the licence does and does not tell them.

4.3 Exploring meaning, hopes, expectations and explanatory model

  • Purpose: understand what draws the client (control, hope, time and attention, distrust of medicine, identity, family tradition, a bad experience in medical care). [synthesis]
  • Steps: (1) Elicit the client's own model of their problem and of how the Heilpraktiker method is meant to help, in the practitioner's terms (“energy”, “detox”, “balance” are recorded as the client's or practitioner's words). (2) Ask what the Heilpraktiker gives them that other care does not. (3) Ask what they hope will change and how they would know. (4) Reflect values underneath (being listened to, agency). (5) Use this to strengthen your own alliance and to inform medical coordination.
  • Example language (illustrative): “What does your Heilpraktiker understand to be going on? … And what is it like for you to be seen there, compared with your GP?”
  • Watch for: an explanatory model that makes medical care seem harmful; hope invested in a single practitioner; secrecy requested by the practitioner. Working if: the client talks about both kinds of care in the same conversation.

4.4 Supporting informed, values-based decisions

  • Purpose: help a client decide about using, continuing or combining Heilpraktiker care with medical care, without coercion. [synthesis]
  • Steps: (1) Clarify the decision and its timescale. (2) Separate questions you can help with (values, fears, pressures, how to get information) from medical questions (route to the doctor or pharmacist). (3) Help the client list what they would need to know: the practitioner's training, what exactly will be done, costs, what happens to their medical treatment, what is the evidence. (4) Explore values and worst-case and best-case scenarios. (5) Agree next steps, including a medical appointment where relevant. No published decision aid specific to this choice is known; these steps are the writer's synthesis [synthesis].
  • Example language (illustrative): “This is your decision. I can help you think it through and work out which questions to put to your doctor and to the Heilpraktiker before you decide.”
  • Watch for: pressure from the practitioner or family; deadlines (“start now or it will be too late”); decisions that replace treatment for serious disease. Working if: the client can state the options, their trade-offs and who they will ask.

4.5 Coordinating with the client's doctor or pharmacist

  • Purpose: make sure the treating physician and, for substances, the pharmacist know what is being used. [synthesis]
  • Steps: (1) Obtain explicit, written consent, specifying what may be shared. (2) Encourage the client to tell the doctor directly first; offer to prepare them. (3) If the client wishes, write a short factual note: what the client reports using, your concerns, no recommendation on remedies or medicines. (4) Never advise starting, stopping or changing a medicine or remedy; refer that question to the prescriber or pharmacist. (5) Document.
  • Example language (illustrative): “Would it be all right if I let Dr X know that you are also seeing a Heilpraktiker? I won't comment on the remedies; that's for your doctor and pharmacist.”
  • Watch for: the client stopping medicines on a Heilpraktiker's advice; contradictory instructions. Working if: the doctor confirms awareness and the client knows whom to ask about substances.

4.6 Recognising and responding to physical-health risk

  • Purpose: act early when Heilpraktiker care could delay or replace effective medical care or involves invasive procedures. Risk flag: the 2016 deaths after infusions in a Heilpraktiker practice (see Harm account). [source: Ärzte Zeitung 2019; DocCheck]
  • Steps: (1) Ask specifically about injections, infusions, “biological cancer therapy”, and stopping prescribed treatment. (2) If serious disease is being treated outside medicine, explore and record the client's understanding; urge a medical review and, with consent, inform the treating physician. (3) If acute symptoms follow a procedure (feeling very unwell, collapse, confusion, breathing difficulty), advise emergency care (112) at once. (4) Document risk discussion and actions. (5) For cancer, offer psycho-oncology and palliative-care links and see 172 (integrative oncology), which is complementary to, never instead of, standard treatment.
  • Example language (illustrative): “I'm not the person to judge the treatment itself, but I am worried that your oncologist doesn't know about the infusions. Could we think together about how to tell them this week?”
  • Watch for: “experimental” substances promised to target cancer, high self-paid fees, being sent home unwell after a procedure. Working if: the medical team is informed and medical follow-up is in place.

4.7 Children, pregnancy and eating disorders

  • Purpose: protect those at highest risk. [synthesis]
  • Steps: (1) For a child: ask what is being given or done, by whom, and whether the paediatrician knows; explore assent and parental consent. (2) If a child is deprived of necessary medical care or given harmful substances or procedures, follow child-protection procedures (local Jugendamt; German child-protection law) [uncertain: specific statutory route]. (3) In pregnancy, ask about any substances or procedures and encourage disclosure to the midwife or obstetrician. (4) Screen for restrictive or orthorexic eating when “detox”, cleansing or elimination diets are part of Heilpraktiker care; refer to medical and eating-disorder care as indicated (see the diet and detox guides in this domain and the eating-disorder guides elsewhere).
  • Example language (illustrative): “When children are treated for something physical, I always ask whether the paediatrician is in the loop. Is that the case here?”
  • Watch for: weight loss, withheld vaccinations or medical care, a parent's fear of medicine. Working if: medical oversight is restored.

4.8 Financial exploitation and group pressure

  • Purpose: recognise when costs or group dynamics are causing harm. [synthesis]
  • Steps: (1) Ask about money spent and committed (packages, prepayments, product sales, paid trainings to become a practitioner). (2) Explore pressure from the practitioner, peers or family. (3) Support the client to set limits and to obtain written information before paying. (4) Point to consumer-advice routes (Verbraucherzentrale) [uncertain].
  • Example language (illustrative): “Can we look at what this has cost so far and what you've committed to? I'd like you to be choosing freely, not because you've already paid.”
  • Watch for: debts, sunk-cost reasoning, isolation from sceptical relatives. Working if: the client makes spending decisions in advance and on their own terms.

4.9 Health anxiety and somatic symptom presentations

  • Purpose: when repeated Heilpraktiker consultations, tests or treatments are driven by health anxiety, somatic symptom distress or idiopathic environmental intolerance, treat the psychological driver with established approaches (cross-reference Domain II). [synthesis]
  • Steps: (1) Ensure somatic clarification by a physician has taken place (PsychThG § 1(2) requires approbierte Psychotherapeuten to arrange it). (2) Formulate the cycle: symptom, worry, checking or seeking treatment, short relief, return of worry. (3) Agree a shared, non-dismissive model. (4) Use the Domain II methods (psychoeducation, attention and reassurance-seeking work, behavioural experiments, graded reduction of checking). (5) Treat Heilpraktiker visits as one form of reassurance-seeking only if the client agrees with that formulation.
  • Example language (illustrative): “Your symptoms are real. What we can work on here is the worry loop around them, and how much of your week it takes.”
  • Watch for: new diagnoses from non-medical tests escalating fear; the client feeling disbelieved. Working if: worry and checking reduce while medical follow-up stays appropriate.

4.10 When a client also sees an HP-Psychotherapie

  • Purpose: avoid parallel, uncoordinated psychotherapy. [synthesis]
  • Steps: (1) Ask whether the client is in any other psychological treatment and with whom (approbierte Psychotherapeutin, HP-Psychotherapie, coach). (2) Explain why parallel treatment can confuse goals and methods. (3) With consent, agree roles or a sequence with the other practitioner. (4) If the other practitioner's work seems to exceed a psychotherapy-restricted licence (e.g. physical treatments, remedies) or to cause harm, discuss with the client and consider reporting (4.12). (5) For GKV clients, explain that HP-Psychotherapie sessions are self-paid. [source: WD 9 2022 for billing]
  • Example language (illustrative): “It's quite common to see more than one person. To make sure we pull in the same direction, could we agree who works on what?”
  • Watch for: splitting, conflicting homework, exposure or trauma work without stabilisation. Working if: clear roles exist and the client reports less confusion.

4.11 Clarifying your own licence, title and scope

  • Purpose: for readers who hold an HP-Psychotherapie, an Approbation, or are in training: practise and advertise lawfully. [source: PsychThG § 1; Bavarian rules; WD 9 2022; Eichelberger 2003]
  • Steps: (1) Check which permission you hold and its exact wording. (2) Approbation: you may use “Psychotherapeutin/Psychotherapeut”; somatic clarification and the definition in § 1(2) apply. (3) HP-Psychotherapie: do not use “Psychotherapeut/in” or confusingly similar titles; use the wording your licensing authority states (Bavaria: “Heilpraktiker/in, beschränkt auf das Gebiet der Psychotherapie”); stay within psychotherapy and the boundary with medical and general Heilpraktiker practice. (4) Trainees: do not practise independently beyond your training status; check with your institute and chamber [uncertain: not verified]. (5) State your licence and fee basis in the treatment contract and on invoices (GKV not billable for Heilpraktiker). (6) Seek legal advice for website titles; title law is contested.
  • Example language (illustrative, for a contract): “I hold a permission under the Heilpraktikergesetz restricted to psychotherapy. I am not an approbierte Psychotherapeutin, and my fees cannot be billed to statutory health insurance.”
  • Watch for: clients assuming GKV reimbursement or chamber oversight. Working if: the client can state your licence status correctly.

4.12 Reporting routes

  • Purpose: act on harm or unlawful practice. [synthesis unless tagged]
  • Steps: (1) Imminent danger: emergency services. (2) Practice of Heilkunde without any licence: criminal offence under HeilprG § 5; police or public prosecutor. [source: HeilprG] (3) Concerns about a licensed Heilpraktiker's fitness or safety: the licensing authority (Gesundheitsamt or Land authority), which grants and can revoke the Erlaubnis. [source: Bavarian rules; Heilbronn sheet lists revocation fees] (4) Title misuse: § 132a StGB (police, prosecutor). [source: Eichelberger 2003] (5) Approbierte colleagues: the Landespsychotherapeutenkammer [uncertain]. (6) Suspected adverse effects of medicines or unlawful manufacture: the Land medicines-supervision authority or BfArM [uncertain]. (7) Misleading health advertising: consumer and competition bodies [uncertain]. (8) Children: Jugendamt (4.7). Discuss reporting with the client first unless that increases risk, observe confidentiality law, and document.
  • Example language (illustrative): “What you describe worries me, because it may have put you or others at risk. Can we talk about who should know, and how much you want to be involved?”
  • Watch for: your own confidentiality duties; the client's fear of losing a trusted practitioner. Working if: the right body has the information and the client feels respected.

5. Handling problems

Most guidance here is [synthesis]; the sources address law and harms, not therapy process.

  • Client hides Heilpraktiker use. Normalise, explain why you ask, and revisit later; never make disclosure a condition of therapy. [synthesis]
  • Client feels judged when you mention the licence route (4.2). Apologise for the impression, return to their experience, and offer the facts only when they want them. [synthesis]
  • Client asks you to recommend a Heilpraktiker or remedy. Decline clearly; explain your scope; offer to help them prepare questions for any practitioner and to involve the doctor. [synthesis]
  • Client asks your opinion on a method. Give its claims as attributed and its evidence status in one line; point to the method's guide; do not argue. [synthesis]
  • Client is stopping or refusing medical treatment for serious disease. Explore values and fears (4.3), keep the alliance, involve the physician with consent, offer psycho-oncology and palliative links, record the discussion. If capacity is in doubt, seek a medical capacity assessment. [synthesis]
  • Rupture after you raise concerns. Name it, take responsibility for your part, reaffirm that the decision is theirs. [synthesis]
  • Family conflict (relatives for or against Heilpraktiker care): offer a joint session focused on shared goals, not on who is right. [synthesis]
  • Client in parallel HP-Psychotherapie making no progress with either: agree a single lead treatment (4.10). [synthesis]
  • You hold an HP-Psychotherapie and the client needs more than your scope (psychosis, acute suicidality, physical illness): refer to psychiatry or medicine at once; the licence check itself centres on recognising these. [source: Bavarian rules; synthesis]
  • Grief and regret after choosing a Heilpraktiker over medical care, or after a harmful procedure: treat as complicated grief or trauma where indicated; avoid blame; address self-blame and anger at the practitioner. [synthesis]
  • Financial loss: problem-solve, involve debt or consumer advice, address shame. [synthesis]
  • Your own bias (for or against Heilpraktiker): use supervision to keep curiosity and safety in balance. [synthesis]

Harm account

What was actually done

  • Setting: a Heilpraktiker's private practice in Brüggen (Bracht) on the Lower Rhine, offering cancer treatment and visited mainly by patients from the Netherlands. [source: Ärzteblatt 2018; Ärzteblatt 2017]
  • Substance: 3-bromopyruvate (3-BP), an experimental agent described as targeting the energy metabolism of cancer cells; anti-tumour effects had been seen only in laboratory studies, no clinical trials had been approved, and it was not an approved medicine. Its use was not generally prohibited. [source: DocCheck; Ärzteblatt 2018; Ärzte Zeitung 2019]
  • Sequence as reported: patients with cancer, some of whom had declined conventional chemotherapy, attended the practice and received intravenous infusions of solutions the practitioner prepared individually on site. In July 2016 four patients received overdoses; three (two women, one man) died. [source: DocCheck; Ärzte Zeitung 2019]
  • Failures the court found or the prosecution alleged: the identity of the substance was not verified; a scale unable to weigh very small quantities was used, so the active substance was dosed several times too high; infusion bottles were inadequately labelled; use was poorly documented; dosing depended on body weight but a patient was not weighed; a patient who felt very unwell after treatment was sent home without an emergency doctor being called. [source: DocCheck; Ärzte Zeitung 2019; Ärzteblatt 2018]
  • Legal course: investigators examined about 70 deaths in total; the Landgericht Krefeld admitted the indictment for negligent homicide and breach of the Arzneimittelgesetz (July 2018); on 15 July 2019 it convicted the practitioner of negligent homicide in three cases, citing serious breaches of the duty of care, and imposed a two-year suspended sentence. The defence argued causation was unproven and that patients knew the therapy was experimental. [source: Ärzteblatt 2018; Ärzte Zeitung 2019]

How it caused harm

  • Direct toxicity: a cytotoxic, unapproved substance prepared without pharmaceutical controls and overdosed through unsuitable equipment and poor checks; even slight overdosing of this agent can be fatal, according to the prosecution. [source: Ärzteblatt 2018]
  • No safety net: no verification, labelling or documentation, and no emergency response when a patient deteriorated. [source: DocCheck; Ärzte Zeitung 2019]
  • Structural: the Heilpraktiker check does not test medical competence, so a licence holder could lawfully offer invasive treatment of serious disease; the Münsteraner Kreis and medical bodies cited such risks in calling for reform. [source: BMG; Uni Münster 2017; Ärzteblatt 2017]
  • Who was most at risk: people with advanced cancer, travelling across a border for hope of an alternative to chemotherapy, paying privately. [source: Ärzteblatt 2018; Ärzte Zeitung 2019; synthesis]
  • Psychological sequelae for families (grief complicated by guilt, anger, legal proceedings) are not documented in these sources [uncertain]; see section 5.
  • Policy response: the 2019 GSAV made manufacture of prescription medicines and tissue preparations by non-physician health practitioners subject to licensing; the president of the Ärztekammer Nordrhein called this “only half the way” and urged reserving cancer treatment for physicians (a proposal, not law). [source: Ärzte Zeitung 2019]

Recognising it today

  • Phrases and offers: “biological” or “holistic” cancer centres; “experimental” or “not yet approved” substances promised to starve or target cancer cells; infusion series in a non-physician practice; cross-border “clinics”; urgency and self-paid packages. [synthesis based on the case reports]
  • Red flags in a practice: infusions or injections given by a non-physician for serious disease; advice to stop or decline oncology care; no written information on substances; no emergency plan; secrecy toward the treating oncologist. [synthesis]
  • Red flags for a psychotherapist colleague: an HP-Psychotherapie who also offers physical treatments under the restricted licence; titles implying Approbation. [source: Bavarian rules; PsychThG; synthesis]
  • How legitimate care differs: integrative oncology adds supportive methods to, never instead of, standard treatment, in coordination with the oncology team (see 172); medicines are approved, prepared under pharmaceutical controls and given with monitoring. [synthesis]

What to do instead and how to help those harmed

  • With a client considering such treatment: use 4.3–4.6: explore hopes and fears, involve the oncologist with consent, offer psycho-oncology and palliative-care support, record the discussion; never argue the client out of hope, but keep medical care in view. [synthesis]
  • With a client or family harmed: assess grief, trauma symptoms, guilt and anger; offer trauma-focused or grief-focused treatment as indicated; address family conflict about the decision; support practical steps (medical records, legal advice, victim support) without leading on litigation. [synthesis]
  • Reporting: acute harm after a procedure: emergency services; suspected unlawful practice or dangerous substances: police or prosecutor, the licensing authority, and the medicines-supervision authority (4.12). [source: HeilprG; synthesis] [uncertain: medicines-authority route]
  • Never name or speculate about individual practitioners in therapy notes beyond what the client reports; record facts. [synthesis]

Sources

Not covered by the sources above [uncertain]: final case law on titles after 2011, chamber and Berufsordnung details for approbierte Psychotherapeuten, and specific reporting routes for medicines, advertising and child protection.