For those unaware, on Sept. 22, 2003, then-Governor Gray Davis signed Senate Bill No. 907 into law, granting the right of licensure to doctors of naturopathy (NDs) in California. Currently, there are four naturopathic colleges in the U.S., one in Canada, and approximately 13 states that grant licensure to NDs as independent practitioners.
Until the mid-1950s, several chiropractic colleges, including Los Angeles College of Chiropractic, offered a dual-degree program in naturopathy and chiropractic. With granting of licensure in California and no naturopathic program currently offered here, the Southern California University of Health Sciences (SCUHS) is now faced with an opportunity - or a predicament - depending on one's perspective.
For those desirous of obtaining a doctor of naturopathy degree, offering a naturopathic program may be viewed as an opportunity. For those concerned about "mixing" the practice of chiropractic with other schools of thought and practice, offering a naturopathic program on the same campus as a chiropractic program may be seen as problematic.
Why would anyone seek a doctor of naturopathy degree if he or she already holds a doctor of chiropractic? In states in which chiropractic laws allow a "broad scope" practice, perhaps there would be no need, unless one desired a broader education than what he or she might have received in chiropractic training. In states in which the scope of chiropractic practice is more restrictive and doctors of naturopathy are able to obtain licensure (as in California), and the doctor is desirous of providing a greater range of services to his or her patients, a naturopathic degree could be advantageous.
What can a licensed doctor of naturopathy do that a doctor of chiropractic can't in California? From legislative vernacular, we observe the following:
Sec. 3640. (a) A naturopathic doctor may order and perform physical and laboratory examinations for diagnostic purposes, including, but not limited to, phlebotomy, clinical laboratory tests, speculum examinations, orificial examinations, and physiological function tests. [emphasis mine]
(b) A naturopathic doctor may order diagnostic imaging studies, including X-ray, ultrasound, mammogram, bone densitometry, and others, consistent with naturopathic training as determined by the bureau (board), but shall refer the studies to an appropriately licensed health care professional to conduct the study and interpret the results. [Wonder where a chiropractic radiologists fits into this definition?]
(c) A naturopathic doctor may dispense, administer, order, and prescribe or perform the following:
(3) Devices, including, but not limited to, therapeutic devices, barrier contraception, and durable medical equipment.
(5) Repair and care incidental to superficial lacerations and abrasions, except suturing.
(6) Removal of foreign bodies located in the superficial tissues.
(d) A naturopathic doctor may utilize routes of administration that include oral, nasal, auricular, ocular, rectal, vaginal, transdermal, intradermal, subcutaneous, intravenous, and intramuscular.
Sec. 3640.5 Nothing in this chapter or any other provision of law shall be construed to prohibit a naturopathic doctor from furnishing or ordering drugs when all of the following apply:
(a) The drugs are furnished or ordered by a naturopathic doctor in accordance with standardized procedures or protocols developed by the naturopathic doctor and his or her supervising physician and surgeon. (Naturopathic doctors will have the right to prescribe drugs in a fashion not unlike that of physician's assistant, e.g. under the supervision of a physician and surgeon.)
Sec. 3650. A naturopathic doctor may perform naturopathic childbirth attendance if he or she has completed additional training and has been granted a certificate of specialty practice by the bureau.
What are the educational and licensure requirements to become a doctor of naturopathy?
Sec. 3623. (a) The bureau shall approve a naturopathic medical education program accredited by the Council on Naturopathic Medical Education ...
(1) Admission requirements that include a minimum of three-quarters of the credits required for a bachelor's degree from a regionally accredited or preaccredited college or university...
(2) Program requirements for its degree or diploma of a minimum of 4,100 total hours in basic and clinical sciences, naturopathic philosophy, naturopathic modalities, and naturopathic medicine.
(b) ...The program shall be an institution, or part of an institution of, higher education that is either accredited or is a candidate for accreditation by a regional institutional accrediting agency recognized by the United States Secretary of Education and the Council on Naturopathic Medical Education...
(c) To qualify as an approved naturopathic medical school...shall offer a full-time, doctoral-level, naturopathic medical education program with its graduates being eligible to apply to the bureau for licensure and to the North American Board of Naturopathic Examiners that administers the naturopathic licensing examination.
In summary, an applicant to a doctor of naturopathy or doctor of naturopathic medicine program must have 75 percent of the hours required for a bachelor's degree from a regionally accredited university. He or she must attend no fewer than 4,100 hours of study and clinical training in a program accredited by the Council on Naturopathic Medical Education. Graduates must be eligible to sit the North American Board of Naturopathic Examiners exam to qualify for licensure.
For someone already in practice as a doctor of chiropractic with near-equivalent training in time and content, a four-year, full-time program may be insurmountable. While not stated in the act, advance standing in existing programs is possible. Programs approximating 18 months could potentially be designed to meet existing practice schedules. (In Florida, there is currently an 18-month program for licensed professionals that meets the qualifications noted above.)
So, the opportunity, or predicament, for SCUHS is twofold. First, should it offer an abbreviated program for qualified professionals that would allow them to complete the necessary training to qualify for naturopathic licensure? Second, should SCUHS invest in a full four-year program leading to the doctor of naturopathic medicine?
Your thoughts will help the university as it evaluates problems alongside potential. The question is greater than simply adding another program to our chiropractic, acupuncture and Oriental medicine curriculums. The addition of a program in naturopathic medicine borders on professional boundaries, philosophical intricacies, political intrigue, profits and paradigms.
I look forward to your thoughtful comments.
Reed Phillips, DC, PhD
President, Southern California University of Health Sciences
Whittier, California
