January 10, 2025

Department of Health Rejects Naturopath Scope of Practice Expansion Proposal

The Washington State Department of Health has issued its final report to the Legislature responding to a Washington Naturopathic Physicians Association proposal to expand naturopaths' scope of practice to include the prescribing of controlled substances, among other procedures. Based on our cursory review, the final report is consistent with the department's preliminary report in rejecting the sunrise review proposal from the naturopaths.

DOH recommendation to the Legislature, in short

In the DOH report's executive summary, the department recommends the naturopath proposal not be enacted by the Legislature because it does not meet the criteria in RCW 18.120.010:

• The proposal does not demonstrate sufficient minimum education and training to safely prescribe Schedule II-V controlled substances. Naturopathic programs have evolved to include more pharmacology focus. However, many of the courses that include pharmacology include topics that do not have foundations in the basic sciences that the other medical programs include, and pharmacology training on controlled substances is not standardized and consistent across programs. In addition, naturopathic clinical training can occur almost entirely in naturopathic clinics without exposure to a variety of providers, settings, and situations where they could experience treatment of patients on a broad array of controlled substances.

• The other states that grant authority to prescribe controlled substances limit NDs to Schedules III-V or specific formularies and/or include safeguards such as collaboration with MDs, additional or continuing education, an additional pharmacology examination, or include MD or DO members on the naturopathic board or formulary advisory committee.

• 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.

Review the full report here: Sunrise Review Naturopathic Physician Scope of Practice Report to the Legislature, December 2024. 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. The WSMA would like to thank you all for your engagement on this important issue. If you have questions about the sunrise review process or the final report, contact WSMA Director of Policy Jeb Shepard at jeb@wsma.org.