November 8, 2023

Deadline Approaching for Comments on Naturopath Scope Expansion Effort

The naturopathic profession in Washington state is continuing its effort to expand naturopaths' scope of practice through legislation and rulemaking without stipulating specific additional education requirements or training. At each juncture, the WSMA has opposed these efforts on the grounds that a naturopath's education and training do not include the comprehensive medical and pharmacological background needed to safely prescribe controlled substances and perform additional procedures as proposed. We strongly encourage physicians in all specialties to provide feedback on the proposal ahead of the Nov. 20 deadline.

In the latest chapter of this years-long effort, the Washington State Department of Health will be conducting a sunrise review of the naturopathic scope of practice as requested by the Washington Association of Naturopathic Physicians. The DOH will review Senate Bill 5411 from the 2023 legislative session. As a reminder, SB 5411 makes several updates to the naturopathic practice act including:

• Expanding prescriptive authority to include controlled substances schedules II-V. This change would include opioids. Naturopaths currently have a very narrow prescriptive authority that is limited to legend drugs, codeine, testosterone, hormones, and other substances consistent with the practice of naturopathic medicine.
• Allowing a naturopath to sign and attest to any certification cards, forms, or required documents that a physician can sign.
• Changing the definition of "minor office procedure" to include primary care services and treatment of minor injuries. This "minor office procedure" has been interpreted by the naturopathic association to include things like in-office abortions.

The WSMA strongly believes that this proposal is a threat to the entire physician community. Most recently, the naturopathic community has expressed interest in the scopes of practice for obstetrics and gynecology, urology, ophthalmology, dermatology, plastic surgery, and anesthesiology. The applicant report expresses interest in treating behavioral/mental health conditions, performing in-office abortions, and treating opioid use disorder, among other things.

All specialties urged to provide feedback on proposal

As part of its sunrise review and to help DOH make informed recommendations to the Legislature on this proposal, the department is accepting public comments at sunrise@doh.wa.gov through 5 p.m. on Nov. 20, 2023. Given the naturopaths' wide-ranging interest in scope expansion, WSMA staff have routed a call to action to our specialty society partners urging opposition to this proposal. WSMA's policy team is in the process of reviewing the application, and we will share our draft comment as a model for WSMA members from all specialties to work from.

The proposal under review consists of the following documents DOH received from the Legislature and applicant group:

• Letter from Senate Health and Long Term Care Committee
• Senate Bill 5411
• Applicant report submitted by WANP

Learn more about the DOH sunrise review process.