Some in the chiropractic profession have sought the right to add prescription rights to chiropractic's scope of practice. Short of that, there are chiropractors who seek to prescribe and administer vitamin (and other supplement) injections for their patients. For most chiropractors, puncturing the skin (an "invasive" procedure) is simply not part of what chiropractors do; to do so is crossing the line from chiropractic into the medical realm. However, not all chiropractors see it that way. In Oklahoma for the past 20 years, chiropractors have had the authority to be certified to give vitamin and mineral shots to patients. (See the "The Oklahoma Story" by Michael Taylor,DC,DABCI).
If you can do it in Oklahoma, why not in other states? The Florida Chiropractic Physicians Association, founded and headed by Roderic Lacy,MD,DC, is of that opinion.
The International Chiropractors Association, in cooperation with the Florida Chiropractic Society, Life University, Life Chiropractic College-West and Sherman College of Straight Chiropractic, are strongly opposed to incorporating injectibles to chiropractic's scope of practice in Florida, or any other state. They feel that injectibles are anathema to chiropractic's historic drugless status, and they also have public health concerns about the practice.
At a hearing of the Florida Board of Chiropractic Medicine in Orlando on Friday, December 7, 2001, Florida officials heard arguments on the question of injectables. The ICA was represented at the hearing by the association's newly elected assembly representatives for Florida, DCs Armand Rossi, and Joseph Accurso. The ICA presented its position in a letter from ICA President Dr. D.D. Humber to the chairman of the Florida Chiropractic Board, Dr. Gene Jenkins Jr.
Dr. Humber outlined ICA's position against the proposed scope expansion:
"ICA's opposition to the injectibles proposal is based on the clear understanding that the prescription and application of such substances constitutes the practice of allopathic medicine under Florida law.
"This association is extremely conscious of the need to maintain clear boundaries between the health professions for the protection of the public. The proposal to authorize doctors of chiropractic to prescribe and administer injectible substances raises such boundary issues on many levels. First among ICA's concerns is the issue of safety and patient welfare. Doctors of chiropractic do not have such training as a part of their professional instruction and qualification processes. The injections process is one that requires extensive training not only on the safe administration of the procedure, but also on the proper maintenance, security and accountability for the materials and paraphernalia used in the process. No one should minimize the potential for injury, secondary infection and related complications that attend the administration of the injections process. Those risks are obviously proportional, according to the skills and experience of those administering the procedure. Doctors of chiropractic have none of the requisite skills as a matter of national definitions and educational processes.
"Considering the risks in the direct injection of any substance, responsible people must ask whether any major health care gap is being filled by the addition of this authority. The ICA firmly believes that the range of oral, ingestible nutritional supports and supplements is so extensive and diverse that any general nutritional support is available via this medium. If the doctor of chiropractic is seeking to treat a specific disease through such procedures, the line between professions and professional competence has been clearly crossed, and such persons are illegally attempting to practice allopathic medicine.
"The public is entitled to clear definitions between health professions and to the full protection of the regulatory process to assure that any health professional holding themselves out as qualified to perform any service, is licensed and qualified at the highest standard. The International Chiropractors Association promotes and supports a drugless chiropractic profession, separate and distinct from the practice of medicine. The injectible proposals before the Florida Board of Chiropractic Medicine blur the distinctions between professions to the detriment of public health and safety and should be rejected."
The ICA's view of the outcome of the hearing, as released to the chiropractic media, was that a senior official from the Florida Board of Pharmacology, based on the reading of the law by the office of the Florida Attorney General, told the Florida Chiropractic Board that only the Florida Legislature could mandate this change to the scope of practice of Florida DCs.
Dr. Humber said he was "very pleased to see that the law was enforced in Florida and that this initiative received the reception that it did."
"ICA will be standing by to cooperate with the Florida Chiropractic Society and other groups, educational institutions and dedicated doctors of chiropractic to lobby against any legislative change that those behind this medical move will likely propose, now that the administrative route has been closed," Dr. Humber promised.
Viewpoint of the FCPA
Dr. Lacy of the Florida Chiropractic Physicians Association (FCPA), however, had a different interpretation of the meeting of the Florida Board of Chiropractic Medicine:
"The discussion revolved around the definition of injectible vitamins, and not whether DCs have the right to inject," Dr. Lacy told DC.
"It was understood that Florida DCs have the right to inject. The attorney that represents the interests of Florida's Attorney General had the opinion that we are not licensed to inject any legend drug, and that injectible vitamins are classified as legend drugs; that food concentrates and items for which a prescription is not required (in injectable form) are also classified as legend drugs. These items are classified by their method of administration, not where they are derived. Glucose is glucose, whether it is taken orally or by IM, and it's not a drug. With this thought in mind, anyone knows that the classification due to route of administration is a poor way to classify any chemical compound, and that a simple law change would remedy the incorrectness our law reflects. Apparently no profession has ever concerned itself with the distinction between foods and food concentrates in an injectible form.
"Our law basically states that we have the right to administer, but that we cannot prescribe any legend drugs. We will educate our lawmakers that vitamins are not drugs, regardless of the route of administration. The board did not make an official ruling.
"Our experts were excellent and all received standing ovations during and after their individual speeches. The experts included: Dr. Joe Johnston, FCA president; Dr. James Winterstein, president of National University of Health Sciences; Dr. David Wick, president elect NUHS; Dan Richardson,PhD, pharmacologist; Dr. Michael Taylor, past president, Oklahoma Chiropractic Association; and attorney Ed Grauke, leading the presentation.
"We had professional unity, as the FCA had their president there and he testified to the fact that the FCA supports complete nutrition regardless of the portal of entry.
"As expected, Life College West, Sherman and the WCA had representatives there. The state's agenda showed they had submitted three letters to the board for them to read prior to the meeting, but did not show them on the agenda to speak. Apparently they were very unorganized, for they got upset when they realized they were not scheduled on the agenda and were not going to be allowed to speak. They had to disrupt the meeting to ask the chairman, Dr. Jenkins, to be heard. At first he denied them the time, but soon gave into their verbal pressures. Finally they were allowed to be heard after the meeting had concluded. They were allowed 15 minutes to speak. Their presentation was nothing more than the usual 'religious' testimony we have all heard for the last 100 years, with no basis of any scientific evidence.
"The FCPA packed the room with over 140 FCPA supporters. Almost every chair was filled with an FCPA supporter. Almost everyone in the room wore an ID tag that said, 'It's Time.' The religious delegation had about six there. We had no problem educating the board on the methods of administration. There was no argument that the Florida DC doesn't have the right to inject. The discussion was what we could inject.
"We have several options available to us now. We, the FCPA, are ecstatic about the outcome and consider it a huge victory for nutritional injections and professional unity.
"The FCPA is proud of the DCs of Florida for their ability to stand up against the religious few and let them know the Florida DC will not put up with the restrictions of the past. Freedom is in the air, all around the world and it is no different here. The FCPA is committed to expanding the rights of the Florida DCs and has just begun the fight.
"The FCPA will now begin a campaign to change the law so it properly reflects that DCs can inject vitamins, foods, food substances and items for which a prescription is not required. Foods are not drugs and it should be very easy to get our legislation to understand this basic concept."
Dr. Lacy asserts that the FCPA has a membership "approaching 800 members," and that it is a member of the Congress of Chiropractic State Associations. The FCPA is also promoting expansion of DC rights in Georgia, Alabama, and South Carolina.
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