One
aspect of the perpetual controversy over altering scope of practice boundaries
among health provider roles involves which clinicians and practitioners are
permitted to prescribe, dispense, and administer medications. This paper will discuss such friction and
debate by way of the Connecticut Department of Public Health’s 2017 document “A
Report Based on the Committee on the Practice of Naturopathy Convened Pursuant
to Special Act 16-3” (CTDPH, 2017), wherein naturopaths were denied an
expansion of scope by clinician peers. This topic was chosen to demonstrate
that there can be, actually, a great deal of broad agreement within diverse mainstream
clinician education and credential backgrounds regarding necessary basic
knowledge competencies and commitments that preponderantly must be met in order
for a scope of practice to be safely increased.
There can also be a great deal of difference in terms of what those
necessary basic knowledge competencies and commitments should be when one
compares mainstream and fringe preferences.
At the heart of this specific controversy of requested and denied scope
of practice increase, strangely enough and essentially, is how naturopaths
differ / deviate collectively in comparison to what is mainstream as regards science
and nonscience, rationality and irrationality, and even matters of objective
fact versus faith / belief. In exploring
this scope of practice issue, publicly available materials will be employed which
may impress as disturbing examples of mistruthful representations, strangely
comprised / compromised academic labels, and quite unsupportable claims of what
is within science. Also, it will be
pointed out, though the system worked in terms of peer assessment and
collective agreement in this instance, a long-term remedy regarding reasonable
basic knowledge competencies and commitments may not be possible as the
naturopaths have presently found another way to get legislators to vote on a
bill that will increase their scope of practice that avoids such devastating peer-clinician
impediment and also avoids naturopaths changing their deviance / oddity.
A
definition is needed regarding naturopathy, since it is not a well-known sector
of health care, being that it is often marginal / fringe and considered
complementary and alternative medicine. There are two paths [!], at least, in
terms of defining naturopathy.
Naturopaths
are self-defined in several ways: the Connecticut state law, the Connecticut
naturopathy school, the textbook of naturopathy, the CT naturopathy
organization, the national naturopath organization, the contents of the
naturopath North American licensure exam, and through their individual web
sites and peer-reviewed publications. The preponderance of naturopathy
publications and promotional material term naturopathy categorically health
science, science-based, and scientific.
The Connecticut state law for naturopathy has the root “scien” in its
first paragraph five times (CGA, 2019).
The Connecticut naturopathy school places naturopathy with its College
of Health Sciences (UB, 2019, College of Health Sciences). The Textbook of Natural Medicine states that
its contents are “science-based” (Pizzorno, 2012, rear cover). The Connecticut Naturopathic Physician’s
Association states that naturopathy is based on the same sciences as mainstream
health care (CNPA, 2019, Michael Gazsi). The national naturopathy organization,
the American Association of Naturopathic Physicians, states that naturopathy
school is a “scientific medical education” (AANP, 2019, What is a) and
specifically that naturopathy’s homeopathy is a medical science (AANP, 2019,
Zicam). The North American naturopath
licensure exam also claims naturopathy’s homeopathy is a clinical science
(NABNE, 2019). A Connecticut four-naturopath
typical practice web page categorically states that naturopathy is
science-based (WHWC, 2019).
Additionally, the naturopath college’s representative testified before
the CGA in 2015 that naturopathy is solidly scientific evidence based (CGA,
2014). And finally, peer-reviewed journal articles also state that naturopathy
is scientific (Smith, 2002).
Without
knowing what is within naturopathy, one may make the mistake of taking these
science categorical self-definitions on face value. It may come as a surprise that simultaneous
to this categorical “science” claim, naturopathy also is self-defined as
centered essentially around a science-ejected concept known as vitalism [and
kind]. The point will not be belabored,
in order to save room in this paper, so only one source will be employed to
illustrate this commitment. The source
is a global consensus report by the World Naturopathic Federation. Their document is “WNF White Paper:
Naturopathic Philosophies, Principles and Theories.” The word “vital” is in the document at least
132 times. The paper states:
Vitalism
is a central tenet in the philosophy of naturopathic medicine. Vitalism, or
vital force describes the intelligence that animates each and every person and
it refers to forces beyond the physical self that govern life, health and
healing. Vitalism postulates that there is a self-organizing principle within
all life […] the vital force is an invisible power which is discernable only
from its effects. The concept vital force dominated philosophy and scientific
exploration prior to the 17th Century. It postulates that life and its forms […]
develop out of, and under the influence of, an all pervading, unseen force,
beyond the material substance. Vitalism is called by many different names,
including life force, breath, chi, qi, ki, prana, and mana, depending upon the
particular culture or tradition. Vitalism is also associated with concepts of
personal essence, spirit or soul (WNF, 2017).
So, fundamentally, what
naturopathy claims is that within science is vitalism which is akin to the
supernatural.
Naturopaths
are also externally defined. The textbook “Sultz and Young’s Health Care USA”
defines naturopathy doctors as practicing “natural healing methods that include
diet, herbal medicine, and homeopathy” and that “professional medical societies
strongly oppose naturopathy, considering the practice ‘unscientific’ and
‘irrational’” (Young, p. 190). This is
in keeping with the Report’s reasoning for denial of their scope of practice
expansion request. Other external definitions can be found within peer-review
publications, from science promoting entities, at international science
organizations, and from web-based outlets.
These external definitions reveal that naturopathy’s science patina or marketing
labeling is not categorically true. For the sake of space, I will limit myself
to a few examples from top-tier science organizations and educational sources
specific to vitalism and hold that as a symptom of ‘the essentially
naturopathic’. Naturopathy’s homeopathy
serves, too, as quite the symptom of naturopathy’s science false posturing,
since homeopathy is soundly refuted (Blakemore, 2015) yet is still within
naturopathy’s collective science categorical labeling.
For instance, at the National Academies of
Science, Engineering and Medicine, support material for the Next Generation
Science Standards specifically employs vitalism as a science-ejected example
(NASEM, 2012, p. 79). Additionally,
NASEM’s recently published “Reproducibility and Replicability in Science”
employs homeopathy as an example specifically in terms of better constructing pharmaceutical
trails that are not biased by narrow prior preferences, but that are
probabilistically contextualized amongst other findings as opposed to offered
singularly in a cherry-picked manner (NASEM, 2019, p.28-29). And as a final example of science promoting
position statements, the National Association of Biology Teachers’ position
statement on the teaching of evolutionary theory, at the National Center for
Science Education, specifically states that vitalistic theory (and
supernaturalism) is not science (NABT, 1995).
I
think, in sum, the takeaway regarding naturopathy as a system of thought is
that it is quite ‘of the irrational’ and ‘of the quite bizarre’. They seem to think that science, as a method
and mannerism, is whatever they proclaim, as opposed to a consensus on
methodological means arrive at through communal agreement. [I want to make a note here, expressly, that
I highly regard freedom of belief as a fundamental human right, and that my
issue herein is not belief per se since
most scientists are also people of faith, but the false categorization of areas
that are ‘of faith’ / belief as within science. I think posing subjective preferences
as objective facts from an institutional position tramples on that freedom,
that choice regarding what to believe. A central issue is the misrepresentation
of knowledge kinds outside of individual constructions, put out aggressively in
the collective commons of academic, clinical and political commerce and
discourse]. It is quite a stark comparison to place side-by-side what
naturopathy generally considers as doctoral level “science”, such as its
vitalism and homeopathy [and kind], and then to find out what national science
organizations specifically bar as not science, consider science-ejected, or
hold as unscienceable.
There
is a degree granting program in Connecticut that specifically was and is the
vehicle for this requested expansion of scope, the University of Bridgeport
College of Naturopathic Medicine. Publicly available testimony reveals that
naturopaths began earnestly and aggressively appealing to the Connecticut
General Assembly for prescribing rights in 2016. Special Act 16-3, of 2016, is
explained in the Connecticut General Assembly (CGA) document “Substitute House
Bill No. 5534. Special Act No. 16-3. An Act Concerning a Committee on the
Practice of Naturopathy” (CGA, 2016).
The Act mandated that the Commissioner of Public Health establish a
committee comprised of those health professions potentially affected by
naturopaths’ request for prescribing rights.
Oddly enough, even after my brief explanation of naturopathy above, yes,
naturopaths are presently licensed / endorsed by the State of Connecticut to
operate as primary care physicians (CTDPH, 2019) and their college is fully
approved by the Connecticut Department of Education.
The
Committee included the states’ naturopaths, doctors and nurses, and required
that a report be generated for the CGA’s Public Health Committee. Members were
tasked to consider educational and examination requirements, plus whatever else
would be necessary to qualify the naturopaths to prescribe, dispense and
administer a set formulary of prescription drugs (CGA, 2016). The CGA’s Public
Health Committee is a standing committee that “has cognizance” / authority over
all public health matters and programs, and includes all DPH practitioner
licensing boards (CGA, 2019, Public Health Committee). The current Commissioner is Renee D.
Coleman-Mitchell, MPH [CTBOR, 2019], and at the time the Report was published
in 2017, the Commissioner was Raul Pino MD, MPH.
I
will use the report’s findings to illustrate this issue as it specifically pertains
to Connecticut. To the point, the report
states, explicitly:
Naturopathy
is regulated in 17 states and has various levels of prescribing authority in
11states. Connecticut has licensed naturopaths since 1923. The University of
Bridgeport College of Naturopathic Medicine is one of six naturopathic programs
accredited by the Association of Accredited Naturopathic Colleges (AANMC) in
the United States. Graduation from a school accredited by the AANMC is one of
the requirements for licensure in Connecticut […] the physician and APRN
committee members unanimously assert that naturopaths do not have sufficient
education and training at this time to safely prescribe the medications
proposed. The rationale for this opinion was the lack of scientific foundation
of the profession of naturopathy, and a lack of commitment to evidence-based therapy
[{the Report references Jagtenberg, 2006}…] the Department of Consumer Protection (DCP)
also participated since they regulate prescribing practices in Connecticut
(CTDPH, 2017).
Currently in Connecticut,
despite the denial by the Committee’s members for expansion of scope based upon
the likelihood that naturopaths would be dangerous as prescribers due to their
disregard for quality knowledge delineations, it appears that naturopathy will
get prescribing rights. The naturopaths
have done an end-run around the consensus oversight that denied them their
increased scope, and tacked-on language to another bill, House Bill 6544, “An
Act Concerning the Sharing of Genetic Data by Genetic Testing Companies and the
Practice of Naturopathy” (CNPA, 2019, Legislative Update; CGA, 2019, An
Act). That new text has the root “scien”
in it at least eight times.
Nationally,
naturopaths are generally gaining licensure in states and increasing their
scopes of practice. In fact, the
national naturopathy college organization has set as a goal 50-state licensure
and claims naturopathy “ultimately has a positive effect on the entire medical
community” (AANMC, 2019).
A
positive effect of the Report’s scope of practice denial is that the
cooperation and agreement amongst the Report committee’s mainstream healthcare
members was quite encouraging. It
reflects the mainstream communal consensus that certain privileges require
certain rigors. Negatively speaking, I think this was a battle that was won but
in the end the war will be lost and naturopaths will get their way and continue
their ways. Therein, science standards and consumer rights will continue to
erode. There is something maddening and
nauseating about what naturopaths do and who facilitates their perfidy. To a great extent, the stark irrationality /
falsehood of naturopathy is best labeled ‘an insane reversal of values’, in my
view. As a citizen of the State of
Connecticut, I am quite appalled. [I
will also state, as I have done in previous courses, this fact in
terms of my own history: I attended the University of Bridgeport College of
Naturopathic Medicine for four years and left in good standing before
graduating, for ethical / reasonable reasons that I have touched on, in part,
here in this paper.]
This
issue of ‘science that is not science’, as pertains to scope of practice, academic
and clinical commerce and citizen protections, such as is seen with the
Connecticut naturopaths’ prescribing request, is a wrong that must be remedied.
One recommendation I can provide is to better support science education in
general, as a broad literacy solution. My evidence-based recommendation is to
actually be evidence-based when evidence-based / scientific is being claimed!
Much of what is needed to weed out bad thinking / mistaken thinking like
naturopathy is already in place. That may be the tragedy of the matter. For instance, the Georgia Department of
Education has the online document “Health Science Cluster. Introduction to
Healthcare Science. Course Number 25.52100” that states: “SCSh3: Students will
identify and investigate problems scientifically. c. Collect, organize and
record appropriate data. d. Graphically compare and analyze data points and/or
summary statistics. e. Develop reasonable conclusions based on data collected”
(GDE, 2013). Scientific thinking
requires an adherence to what evidence directly indicates, and that is not new,
but that is quite at odds with naturopathy’s claim that something is science
without evidence or data to support it, or when evidence or data refutes it
collectively.
Another
recommendation I can provide is to better support consumer rights, in general,
through such items as the position statements of national science organizations. I find it incredible that a product is
marketed, a health science naturopathy doctorate and a scientific naturopath clinician,
and it is not what it postures itself as, categorically, for either ignorant,
delusional or mendacious reasons. This
is what I find most unreal: though the State of Connecticut’s Department of
Public Health reported to the Connecticut General Assembly that naturopathy is
not the scientific, science-based, science that it claims to be, in May of 2019
another class of naturopathy students were graduated from the University of
Bridgeport’s College of Health Sciences and during the convocation ceremony
they took an oath to naturopathy’s science-ejected vitalism (UB, 2019,
Commencement). I do not think much
thinking has to be done towards simply applying consumer protection standards,
rationality, honesty, and national science standards therein. And while Connecticut has a Healthcare Fraud
Unit within its Office of the Attorney General (SCAG, 2019), and postures
strict oversight of educational institutions, licensed / legislated and accredited
falsehood marches onward.
References
American
Association of Naturopathic Physicians [AANP; not to be confused with the
American Academy of Nurse Practitioners]. (2019). What is a naturopathic
doctor? Retrieved from https://www.naturopathic.org/content.asp?contentid=60
American
Association of Naturopathic Physicians. (2019). Zicam is not homeopathy.
Retrieved from https://www.naturopathic.org/content.asp?contentid=198
Association of
Accredited Naturopathic Medical Colleges [AANMC]. (2019). Naturopathic doctor licensure.
Retrieved from https://aanmc.org/resources/licensure/
Blakemore, E.
(2015). 1,800 studies later, scientists conclude homeopathy doesn’t work.
Retrieved from
https://www.smithsonianmag.com/smart-news/1800-studies-later-scientists-conclude-homeopathy-doesnt-work-180954534/
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of Regents [CTBOR]. (2019). Renee D.
Coleman-Mitchell. Retrieved from
http://www.ct.edu/regents/members/renee_d._coleman_mitchell
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passed the public health committee! Retrieved from https://cnpaonline.org/
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