Aug. 9, 2024

Naturopath Proposal Preliminarily Rejected by DOH

The Department of Health has released a draft report rejecting the sunrise review proposal from naturopaths that sought to increase their scope of practice to include full prescriptive authority and broader allowance for in-office procedures, among other elements. Additionally, WSMA members seeking further engagement on this issue should note that the department is seeking public comment on its findings in a new survey, with a deadline of Aug. 30.

What the DOH report says

The report's findings align with the physician community's advocacy, which urged the department to reject the proposal on the grounds that it would have jeopardized patient safety. According to the report's executive summary:

• The proposal does not demonstrate sufficient minimum education and training to safely prescribe Schedule II-V controlled substances.
• The other states that grant authority to prescribe controlled substances limit naturopaths to Schedules III-V or specific formularies and include safeguards such as collaboration or supervision by MDs, additional or continuing education, an additional pharmacology examination, and oversight by the state medical board.
• The proposed definition of "minor office procedures" is vague and subject to a wide range of interpretations. The department cannot evaluate adequate training without knowing what specific procedures would be included in this definition.
• The Board of Naturopathy does not include practitioners with sufficient expertise to evaluate what additional education and training is needed to safely expand naturopaths' scope of practice.
• Providing primary care includes coordination of care and referrals when needed. Referrals for controlled substances are often necessary because of their significant risks to public health due to overdose, abuse, and misuse. This is especially true in long-term opioid therapy or behavioral health treatment, to ensure only the most qualified health care professionals are prescribing these substances.

Action alert! Your feedback needed in new public comment survey

We thank you all for your engagement on this important issue, but there's more work to be done. The department is soliciting additional comments in response to the draft report, asking that interested parties complete a survey to provide feedback. The survey is available here and responses are due by Aug. 30. If you have issues completing the survey you can email sunrise@doh.wa.gov. And if you have questions about the sunrise review process, contact WSMA Associate Director of Policy Billie Dickinson at billie@wsma.org.