of the American Naturopathic
DANGER DANGER DANGER
The following is a report prepared by the Washington Association of Naturopathic Physicians (WANP) for the Washington State Legislature. The naturopaths are asking for drugs, surgery and IV therapy which would cover Chelation. These naturopaths are not just asking for any drug; they want narcotics under the Controlled Substances III & IV categories. It is obvious that these naturopaths want to be MD’s without earning the education and doing an internship in hospitals. We urge you to read this carefully, understand it, then write, call or email a Washington State legislator whose name, address and phone number will appear on this page. We do not oppose properly trained doctors doing these practices. However, a naturopath pretending to have the knowledge to practice in this manner is definitely a “danger to the public”.
This legislation promoted by the Washington Association of Naturopathic Physicians verifies what American Naturopathic Medical Association has said all along. That the goal of the northwest naturopaths is to gain access to practice allopathic medicine through the back door.
Washington Association of Naturopathic Physicians
Final Applicant Report
Naturopathic Physicians have been practicing in the state of Washington since the early 1900s. They have been licensed in this state since 1919. From 1919 until 1987 they practiced as "drugless healers". In 1987 the legislature passed legislation which eliminated the title of drugless healers and created the Naturopathic Act (RCW 18.36A). This was done to reflect the then current state of the practice of naturopathic medicine which needed greater definition' and statute that was contemporary to the practice of naturopathic medicine.
During the ensuing ten years questions about the language in the Naturopathic Practice Act have arisen within the Department of Health, the profession, and the general public regarding the clarity of the definitions in the Practice Act as they relate to current medical practice. The bulk of the proposal before the panel simply clarifies some of the questions that have been brought forth to the Department of Health and to members of the Naturopathic profession.
The proposal before the panel does slightly broaden the scope of practice of Naturopathic Physicians particularly in the area of the use of a limited array of controlled substances and other legend drugs. Primarily this is an extension of their current pharmaceutical prescriptive authority so that Naturopathic Physicians can more effectively treat patients. The primary reason for this language change is to ensure that patients seeking naturopathic care will not unnecessarily be burdened with seeking a second office visit by a another licensed practitioner in order to get, for example, codeine cough syrup or an antibiotic which is not currently in the list of legend drugs that a naturopathic physician can prescribe.
Since the Naturopathic Act has been in place and has successfully protected the public from unqualified practitioners, many of the sunrise questions are not applicable. In the draft before the review panel, there are no proposed changes in the regulatory entity that currently licenses naturopathic physicians. Since there is no supervision of naturopathic physicians by other practitioners, that issue is moot. There is nothing in this proposal that would restrict any practitioner seeking to enter the practice of naturopathic medicine. There should be no or limited increase cost to the state in regard to implementing this proposal since it is a fee born program and we're not changing in this draft the regulatory licensing scheme currently administered by the Department of Health.
A question has been asked as to whether the expanded prescriptive authority would impact the cost to the state or to patients. It is our assessment that costs for the patient should, in fact, decrease since they would not be required to seek a second healthcare provider to get a prescription for codeine cough syrup or some other substance not currently prescribable by a naturopathic physician. In -regard to pharmacy investigations of naturopathic physicians, we believe that would be quite limited since it would be a very limited list of controlled substances which are being sought by naturopathic physicians. The Washington Association of Naturopathic Physicians (WANP) would expect that the number of investigations carried forth by the Department would be quite limited. It would probably reflect only partially, the percentage of investigations which are brought forth in reviewing other healthcare practitioners who currently have a broader controlled substance prescriptive authority. Essentially we don't believe this is much of an issue for naturopathic physicians and their patients.
The specific question by the panel about adding to the definition of naturopathic medicine, (page 2, lines 32-36), the language "and controlled substances III and IV", the WANP believes is an appropriate addition to clarify the legend drugs and controlled substances III and IV and improves the consistency with naturopathic medical practice. We view this as an appropriate technical correction to the legislation.
The training for naturopathic physicians is clearly identified in the course curriculums in the addendum, however, generally a naturopathic physician must graduate from a four-year program which is approved by the Secretary. This program is similar in basic science requirements as that of other physician level primary care providers. This is a post-graduate program and takes a of four and generally five years to complete. During the years of naturopathic education, the physician experiences clinical rotations for primary care in naturopathic clinics.
The proposal before the review committee should promote effective health outcomes by ensuring a full range of care to patients by their naturopathic primary provider without interruption to seek other primary care from another provider, i.e. the prescription for cough syrup or another antibiotic that would be more effective for the patient in overcoming the presented illness.
The proposal, when compared to other jurisdictions, is actually quite conservative. (ANMA INSERTION) Show us these jurisdiction(s). This is all part of the big lie that AANP, WANP, Bastyr, and National stand accused. There are no other jurisdiction(s). This is just a way naturopaths promote something as being legitimate, when it doesn't even exist. Some of these privileges may exist in Oregon but that is hardly "jurisdiction(s)". Oregon, for example, has a broader list of substances than the profession is seeking in this state. Their licensing standards are similar to those in Washington and there are national standards for this profession. (See addendum.) Naturopathic physicians currently are required to maintain CE and are disciplined as prescribed by the Uniform Discipline Act. In addition to this, the WANP has peer review for licensed practitioners. In addition to this, there is an adopted code of ethics for the profession and a quality assurance standard.
During the initial meeting the use of the phrase, "injections and insertion of needles for therapeutic purpose," was interpreted by some to mean acupuncture. This was not the intent of such language. The intent of the language is to deal with routes of administration of naturopathic medicines. Currently, naturopathic physicians, just like osteopathic physicians and allopathic physicians, do some procedures which are also utilized by acupuncturists. Naturopathic physicians do not seek to be acupuncturists. The profession, in fact, actively discourages and does not support naturopathic physicians from describing their practice as acupuncture. Acupuncture is a specific procedural training which all other physician groups, naturopathic physicians included, recognize in their treatment plans. In other jurisdictions, naturopathic physicians use the procedures that are also in the scope of practice of acupuncturists. However, most of the naturopathic community refers patients to licensed acupuncturists. This is quite similar to how osteopathic physicians or allopathic physicians refer for these specific procedures. The definition in minor office procedures, page 3. line 7-8, was not focused (as the review panel seems to imply) on acupuncture. Acupuncture procedures have been part of naturopathic practice for numerous years. Some drugless healers, in fact, practiced acupuncture procedures prior to the 1987 statutes which modernized the Naturopathic Practice Act. Since 1987 naturopathic physicians have continued to use the procedures that licensed acupuncturists provide (as well as allopathic physicians, osteopathic physicians and physicians assistants provide). WANP does not consider this to be any change in the scope of practice of naturopathic physicians.
In 1987 when the legislature modified and cleaned up the drugless Therapy Act, this issue was discussed with leadership of the acupuncturists in this state. Language was placed in the exemption section for naturopathic physicians 18.36a.050 to alleviate the acupuncturists' concerns that the Naturopathic Practice Act as it had been revised would have eliminated then certified acupuncturists from doing acupuncture. Section 4 of RCW 18.36a.050 specifically exclude the practice of Oriental medicine or Oriental herbology or the rendering of dietary advice or nutritional advice. This language was put in place after discussions with the Acupuncture Association of that time. The scope of practice section 1836a.040 includes broad language including the treatment of disorders of the body "by stimulation or support". This was the language that caused the acupuncture leadership some concerns when coupled with the other sections of the statute which include immunizations and injections which naturopathic physicians are currently authorized to do.
The change in the definition of minor office procedures is intended to clarify language in the Naturopathic Practice Act and to expand the scope of practice to clearly enable naturopathic physician to do the most appropriate route of administration of naturopathic medicines to their patients. (The iv route of administration of substances such as vitamin C or other supplements appropriate to naturopathic medicine is the reason for this language change.) This is a procedural scope of practice increase but is not in the opinion of the WANP a change in common medical practice for which they are trained and currently licensed in other states' jurisdictions.
The profession is amenable to language changes which would further clarify that naturopathic physicians do not consider themselves acupuncturists. Currently there is no known threat to the public where naturopathic physicians have used some of the procedures currently within the acupuncture scope of practice. There is evidence, however, that the public has benefited from the ability of naturopathic physicians to do naturopathic care using procedures done by acupuncturists, osteopathic physicians and allopathic physicians.
A question was asked about "minor office procedures" during the initial meeting. Naturopathic physicians have been doing these procedures as defined since the inception of their practice act. The technical changes just identify these procedures as "limited surgical procedures and further clarifies removal of lesions (warts, moles, etc. as minor office procedures.
The review panel also asked the question about the changes in common diagnostic procedures, page 3, line 11. The change (vene puncture to withdraw blood to) venipuncture consistent with naturopathic medical practice. This language change is primarily to allow naturopathic physicians to provide appropriate care for patients and the authorization would enable, for example, saline infusion for patients who are dehydrated, etc. It would also allow naturopathic physicians to utilize venipuncture to administer vitamin supplement and naturopathic medicines to the patient to the iv route. Currently the statute is restrictive and patients are often unable to get the most cost-effective or efficient means of receiving naturopathic medicines.
The review panel also questioned language added to the definition (exclusion beyond that which is authorized as minor office procedures, page 3, line 18 of the draft). And the question was raised by the committee that the language removes from current legislation "removal of malignant lesions." This language was put in place to make it easier to define minor office procedures and minor surgery so that naturopathic physicians do not provide medical service beyond what is appropriate to their primary care training.
The original bill, HB 2286, also excluded (removal of malignant lesions) and the panel has asked the question why this exclusion no longer exists. The intent behind this change is to protect and promote public health. This change does not increase the scope of practice of naturopathic physicians. The public will benefit because malignancy is often not determined (and generally not proven) until tissue which has been excised is examined by a pathologist. Tissues which are excised should be examined by a pathologist in order to rule out possible malignancy. The current language authorizes excision but only if the lesion's are not malignant This cannot be definitively proven without pathology.
The pharmacology training of naturopathic physicians is similar to that of osteopathic physicians and allopathic physicians. The ability to prescribe other antibiotics, some legend drugs and a limited array of controlled substances are supported by their education. It is also supported by the continuing education requirements. The pharmacological training of naturopathic physicians is similar to that of osteopathic and allopathic physicians (see addendum attached). Pharmacology training is in addition to the curriculum of naturopathic physicians, however, their basic training has been in place for many, many years. All physicians who were licensed under the drugless Healers Act 18.36 RCW were given a year to complete course work offered by the Association and classes offered by the Department of Health before naturopathic physicians to become licensed under 18.36a RCW.
Current pharmacological training meets or exceeds the needed skill levels to prescribe legend drugs and controlled substances and current CE requirements can be utilized to enhance the skills of naturopathic physicians in the appropriate use of these substances. Since WANP is actually seeking a very limited increase in the legend drugs and controlled substances consistent with naturopathic medical practice. The WANP believes that current training and CE requirements will protect the public from inappropriate prescriptive actions by naturopathic physicians. The rule process on these limited array of legend drugs and controlled substances will also be utilized to scrutinize any substance not within appropriate training levels.
During the initial public meeting a question arose concerning radiography and the changes in the earlier draft. As stated at that time, it was a technical error which the applicant group made in its language and has since withdrawn that language and rewritten it to remove the interpretation of ultrasonic images.
The initial applicant report also raised the question about Section 8 of the proposed legislation. This section allows naturopathic physicians to employ unlicensed persons to assist in the preparation, monitoring and procedures involved in colonic therapy. This is a result of a legal question that is in the Department of 'Health regarding who can do colonic therapy. There have been some adverse outcome in an unregulated practice by a group who call themselves Colonic Therapists. There have been some adverse outcomes by medical doctors who have provided similar services. Since naturopathic physicians have been trained and have provided colonic therapy to their clients for many years without adverse outcomes by utilizing persons they train and are responsible for, the section was written to grant this authorization. To our knowledge there has never been a naturopathic physician or an unlicensed person whom they employee to assist in this procedure, who has had an adverse outcome. This question was raised by the Department of Health and the language is to reflect the needs to authorize the use of unlicensed persons.
The WANP has no current data regarding numbers of naturopathic physicians who provide colonic therapy in Washington State. However, WANP estimates that at least 30 naturopathic physicians provide this service. The intent of this change is to protect the public health. This change does not increase the scope of practice of naturopathic physicians. Colonic therapy has been safely performed by naturopathic physicians in Washington State since the inception of the Drugless Healers Act. The public will benefit because colonic therapy will be available in a safe environment Preparation and monitoring by unlicensed persons includes inspection and sanitation of all equipment, supervision of proper insertion of rectal speculae, positioning of the patient, and monitoring of the temperature and flow of the colonic solution. Preparation and monitoring by unlicensed persons does not include rectal examination or determination of the appropriateness of colonic therapy. When unlicensed persons are performing colonic therapy at the direction of a naturopathic physician, a naturopathic physician will be on the premises and responsible for the care of the patient. Unlicensed persons will be trained by naturopathic physicians and will be knowledgeable of sanitation requirements, avoidance of transmission of disease, proper insertion of rectal speculae, proper positioning of the patient, proper composition and temperature of colonic solution and recognition of symptoms indicative of poor tolerance of colonic therapy. Naturopathic physicians are trained in proper administration of colonic therapy during naturopathic medical training.
Section 9 is another new section for Naturopathic Practice Act dealing with their ability to sell naturopathic medicines from their own offices excluding controlled substances and legend drugs commonly available by prescription. Naturopathic physicians do compound many naturopathic medicines for their patients on an individual basis and the medicines would not be available at other sources for their patients. Section 10 also is related to the ability of a naturopathic physician to sell naturopathic medicines or products from his or her office in accordance with limitations of Section 9. This is just a reflection of the need to make naturopathic medicines available to the general public.
As earlier indicated, the bulk of 'the draft is technical clean-ups and modernization of existing language to meet the scope of practice needs of naturopathic physicians and their needs to provide comprehensive services to their patients.
In the opinion of the Washington Association of Naturopathic Physicians, this draft simply clarifies some legal issues that have arisen during the last ten years, expands the scope of practice in pharmacy areas on a limited basis and allows the public to get a better range of services from naturopathic physicians, thus reducing patient costs and allowing naturopathic physicians and their patients to be more fully integrated into the clinical settings and healthcare provision systems that currently exist
The WANP fully believes that the proposal before the review committee has the protections that are necessary for the public and benefits the public both financially and in a practical sense of not having to seek other healthcare 'practitioners when their primary physician, the naturopathic physician, can provide the service in one setting. The WANP believes that the new language in the prescriptive drug definition will allow the Secretary of Health to adopt an appropriate list of legend and controlled substances, consistent with naturopathic medical practice, to meet the needs of the patients who are seeking naturopathic care. The WANP is comfortable with this proposal and sincerely hopes that the sunrise review process will support this draft and our recommendations.
Thank you for your consideration.