Testimony to the State of CT 2025 Regarding CT Naturopathy by Way of the Cullen-Snyder Framework

here, I post what I uploaded after linking to the Connecticut General Assembly's Public Health Committee:

001. the CT PHC of the GA states its current membership as:

"Co-Chair Anwar, Saud, Co-Chair McCarthy Vahey, Cristin, Vice Chair Belton, Kai J., Vice Chair Marx, Martha, Vice Chair McCrory, Douglas, Ranking Member Somers, Heather S., Ranking Member Klarides-Ditria, Nicole, Member Berger-Girvalo, Aimee, Member Biggins, Patrick, Member Carpino, Christie M., Member Dauphinais, Anne, Member Demicco, Mike, Member Elliott, Josh, Member Genga, Henry J., Member Gilchrest, Jillian, Member Gordon, Jeff, Member Hochadel, Jan , Member Kavros DeGraw, Eleni, Member Keitt, Sarah, Member Kennedy, Kathy, Member Kushner, Julie, Member Marra, Tracy, Member Martinez, Rebecca, Member Morrin Bello, Amy, Member Parker, John-Michael, Member Polletta, Joe, Member Rahman, MD, Member Reddington-Hughes, Karen, Member Romano, Amy, Member Ryan, Kevin, Member Slap, Derek, Member Steinberg, Jonathan, Member Zupkus, Lezlye”;

that is a BIG public health committee. 

002. testimony:

"August 28, 2025

Honorable Saud Anwar, Co-Chair

Honorable Cristin McCarthy, Co-Chair

Public Health Committee

Legislative Office Building, Room 3000

Hartford, CT 06106

Dear Co-Chairs and members of the Public Health Committee,

My name is Rob Cullen of Bridgeport, CT and I have deep and persistent concerns about the State of Connecticut and naturopathy.

Consider this testimony pertinent to future legislative considerations regarding naturopathy.

My knowledge on the subject has been accumulating over the course of roughly 33 years.

In those decades, I prepared for and attended naturopathy school here in Connecticut, taught medical assisting for about twenty years, and acquired an extensive number of credits studying Health Sciences at the Masters and Doctorate level.

To be clear, I am not a graduate of the ND program I attended here in Bridgeport, and my completed graduate degree to date is an M.S. in Health Sciences with a specialty in health professions education from New York State’s Excelsior University.

I carry current healthcare credentials as both an allied health instructor and a medical assistant.

The Code of Conduct of my organization implores:

“AMT professionals shall strive to increase their technical knowledge, shall continue to learn, and shall continue to apply and share scientific advances in their fields of professional specialization.”

The State lists me, accurately, as a member of the AMT Registry.

Thus, I feel it my duty, broadly, due to the standards of behavior of healthcare and education to share my knowledge specifically about naturopathy with the Public Health Committee.

The knowledge I will share is in the form of a tool I created that is portable, accurate, and meaningful.

I’ve titled the tool “The Cullen-Snyder Framework for Evaluative Analysis of Naturopathy with Regard to Freedom (v.1.0).” and it is Part A. of what follows.

From its synopsis:

“This framework provides a structured method to simultaneously evaluate medical claims’ validity and their implications for societal freedom, operationalizing Snyder’s philosophical constructs through Cullen’s empirical critique.”

Thus, the framework broadly and deeply synthesizes critical epistemology (Cullen) which is the study of knowledge and political philosophy (Snyder) which is the all-too-important need to create a better world for us all through ‘freedom for’.

As a framework and in terms of its results, I find it portable, accurate, and meaningful because it is designed to be used through the current AI-LLM models, specifically ChatGPT and Perplexity, and generate a report that is accessible and focused.

Such an application follows as Part B, which I provide as an example.

Expertise in science, healthcare ethics, and logical, rational, nonbiased analysis and evaluation is, perhaps in these times, a rare commodity.

The results, from that Part B:

“Public policy revision is needed to:

• Require explicit disclaimers of non-scientific status.
• Enforce evidence-based practice standards.
• Protect public liberty through transparency, factuality, and institutional integrity."

Thank you for your consideration and for your service,

Robert Cullen

[...]

Part A. The Framework [live here]:

“The Cullen-Snyder Framework for Evaluative Analysis of Naturopathy with Regard to Freedom (v.1.0).

Note: The Snyder aspect of this framework is drawn from the publication “On Freedom” (2024) and is not meant to portray involvement in any way by Tim Snyder whatsoever.

Overview

The Cullen-Snyder Framework for Evaluative Analysis of Naturopathy with Regard to Freedom synthesizes critical epistemology (Cullen) and political philosophy (Snyder) to assess naturopathy’s societal impacts through dual lenses of scientific integrity and human liberty. This interdisciplinary approach evaluates how naturopathic practices intersect with fundamental freedoms while maintaining analytical rigor.

Foundational Principles

• Epistemic-Social Interdependence. Combines Cullen’s concept of "epistemic conflation" (blending scientific and pseudoscientific claims) with Snyder’s "factuality freedom" (access to truth as prerequisite for liberty). Establishes that misrepresented knowledge systems inherently threaten freedom.
• Freedom as Active Construction. Integrates Snyder’s positive freedom ("freedom to" through institutional support) with Cullen’s warning about institutional erosion from pseudoscience. Positions authentic freedom as requiring both accurate information and structural safeguards.

Key Analytical Components

A. Naturopathy’s Epistemic Profile (Cullen-Based)

• Science Camouflage Index. Measures proportion of science-exterior claims presented as science-based.
• Institutional Legitimacy Score. Assesses academic/professional recognition relative to evidentiary support.

B. Freedom Impact Matrix (Snyder-Based). Evaluates effects on Snyder’s five freedoms:

Implementation Protocol

A. Dual Constituent Models Assessment

• Epistemic Audit: Map naturopathic claims using Cullen’s knowledge-blending taxonomy
• Freedom Impact Analysis: Apply Snyder’s five freedoms through weighted metric

B. Institutional Evaluation. Analyze how healthcare systems/policies:

• Enable Snyder’s "positive freedom" through science literacy
• Counteract Cullen’s "erosion vectors" of pseudoscientific infiltration

Synopsis

This framework provides a structured method to simultaneously evaluate medical claims’ validity and their implications for societal freedom, operationalizing Snyder’s philosophical constructs through Cullen’s empirical critique.

References

Cullen, R. (2021). Epistemically unwarranted medical claims and methods at Bastyr University’s Center for Natural Health: Science, ethics, effects, and remedies [Unpublished master’s capstone project]. Excelsior University.

Snyder, T. (2024). On freedom. Random House.”

[End of CSF framework.]

Part B. The Cullen-Snyder Framework (v.1.0) Application #004 – "Connecticut Representative Naturopathy 2025-07" [live here]

(The fourth application of the C-S Framework.)

001. The Source Documents:

This single PDF set was titled "Connecticut Representative Naturopathy 2025-07."  The contents include: Pages 2-10 – Connecticut State Law- “Chapter 373 – Naturopathy”; Page 11 - Department of Public Health Naturopathy Page “State Board of Naturopathic Examiners"; Pages 12-22 – Connecticut Healthcare “Rules of Practice”; Pages 23-28 – Connecticut Naturopathic Physicians Association “About”; Pages 29-31 – ND Hunter et al. ‘Homepage’; Pages 32-34  – ND Hunter et al.  “Naturopathic Medicine”; Pages 35-40 – ND Tranguch “Naturopathy”; Page 41 – ND Tranguch “Homeopathy”; Page 42-43 – ND Tranguch “Meet Me”; Page 44-51 – ND Tranguch “Dare to Know Homeopathy”.

[The respective Archive.org pages are: Pages 2-10; Page 11; Pages 12-22; Pages 23-28; Pages 29-31; Pages 32-34; Pages 35-40; Page 41; Page 42-43; Page 44-51.]

002. A Word on the Framework and Its Application:

The Framework is a fusion of my critical epistemology / scientific skepticism and Tim Snyder’s 'freedom to' / political philosophy.  The Framework version used is 1.0.  The application is achieved through a task by way of ChatGPT, wherein the 2025-07 default NLP model set was asked:

"Can you apply the attached framework docx to the contents of the attached pdf on Connecticut naturopathy and generate a detailed report? Please itemize the naturopathy science posturing and the science-unsupported contents including those for vitalism and homeopathy. Answer, too, these three questions: Does Connecticut law adequately inform the public about naturopathy's transgressions and hazards? When naturopaths base their activity on a science-ejected vital force / healing power of nature and poorly supported procedures, yet claim science as a basis, what is this usually considered as in terms of commerce and medicine? Does the Connecticut naturopathy scene meet the description of a state-sanctioned, predatory, licensed falsehood?"

In large part, my interest in using this method is to see if what is generated jibes with my knowledge of the sources.  Overall, I find the results robust and poignant.

003. The Evaluation Report:

"Here is the detailed report applying the Cullen-Snyder Framework for Evaluative Analysis of Naturopathy with Regard to Freedom to the contents of the Connecticut naturopathy PDF. This includes an epistemic audit and freedom impact analysis, along with direct answers to your three evaluative questions.

Cullen-Snyder Evaluation Report on Connecticut Naturopathy

I. Epistemic Audit (Cullen-Based Analysis)

1. Science Camouflage Index (SCI)

The SCI assesses how non-scientific or pseudoscientific content is portrayed as science-based.

Domain	Scientific Basis?	Framed as Scientific?	Notes
Vitalism ("natural healing force")	❌ No	✅ Yes	Central to definition in Sec. 20-34(a); a science-ejected idea.
Homeopathy	❌ No	✅ Yes	Promoted by licensed NDs on pp. 41–51; lacks plausibility and empirical support.
Phytotherapy	⚠️ Partial	✅ Yes	Plant-based treatments vary widely in evidence basis.
Colon Hydrotherapy	❌ No	✅ Yes	Approved for delegation under Sec. 20-42a despite lacking scientific validation.
Electrotherapy/Phototherapy	⚠️ Partial	✅ Yes	Evidence varies by modality; often not supported in context used by NDs.
Mechanotherapy/Articular Manipulation	⚠️ Mixed	✅ Yes	Often overlaps with chiropractic-style interventions.
Diagnostic Authority	⚠️ Partial	✅ Yes	Limited training yet permitted to order diagnostics; risks epistemic overreach.

Summary SCI Score: High

• Connecticut naturopathy law and practice show a high level of science camouflage by cloaking discredited and inadequately supported modalities in scientific language.

2. Institutional Legitimacy Score (ILS)

Assesses the extent of institutional endorsement relative to evidence.

• State Licensure and Endorsement: Full legal licensure through Chapter 373, with authority to diagnose, treat, and use medical diagnostics.
• Educational Requirements: Training from institutions approved by the Council on Naturopathic Medical Education (CNME)—an entity not recognized by mainstream medical science.
• Professional Integration: NDs are overseen by a state board largely composed of NDs (pp. 11, 23–28), reducing external accountability.

Summary ILS Score: Inflated

• Despite weak evidentiary foundations for many practices, naturopaths in Connecticut enjoy significant state-sanctioned legitimacy.

II. Freedom Impact Matrix (Snyder-Based Analysis)

Freedom	Evaluation
Sovereignty	Patient autonomy is undermined by misinformation and deceptive framing of pseudoscience as legitimate care.
Unpredictability	Wide treatment variability exists with inconsistent standards, especially across homeopathic and alternative modalities [see my comments].
Mobility	Licensing fosters market growth and access—but also entrenches pseudoscience as a legal care option.
Factuality	Critical failure. The epistemic basis of naturopathy contradicts factual integrity by promoting refuted ideas like vitalism.
Solidarity	Public trust in medicine is eroded. Scientific community's commitment to collective health is bypassed through state recognition of pseudoscientific modalities.

III. Science-Unsupported Content (Itemized)

A. Explicitly Unscientific:

• Vitalism – Defined in law via "support of the body's natural healing processes" (Sec. 20-34), reflecting outdated, falsified notions.
• Homeopathy – Entirely discredited; yet central in public materials from NDs (pp. 41, 44–51).
• Colon Hydrotherapy – Lacks scientific foundation; included via Sec. 20-42a.
• Electro/Phototherapy – Promoted outside evidence-supported boundaries.
• Nutritional Detoxes, “Natural Substances” – Often unregulated and misrepresented as therapeutic.

B. Science-Posturing Modalities (Poorly Supported or Misapplied):

• Diagnostic Authority – Scientifically grounded tools used by under-qualified personnel.
• Phytotherapy, Mechanotherapy, Articular Manipulation – Selective or fringe evidence used to justify sweeping treatment claims.

IV. Evaluative Questions

1. Does Connecticut law adequately inform the public about naturopathy’s transgressions and hazards?

• No. There is no substantive consumer warning or disclaimer in Connecticut statutes or regulatory materials acknowledging the pseudoscientific foundations of many naturopathic practices. Instead, the legal structure gives the impression of equivalence with science-based care, which misleads the public.

2. When naturopaths base their activity on a science-ejected vital force / healing power of nature and poorly supported procedures, yet claim science as a basis, what is this usually considered as in terms of commerce and medicine?

• It is typically classified as consumer fraud or professional misrepresentation. In medical and regulatory contexts, this blending of pseudoscience with scientific posturing fits definitions of "health fraud" or "quackery", particularly where it induces patients to rely on ineffective treatments.

3. Does the Connecticut naturopathy scene meet the description of a state-sanctioned, predatory, licensed falsehood?

Yes. Connecticut law:

• Legitimizes epistemically invalid ideas (vitalism, homeopathy).
• Fails to require evidence parity with mainstream medicine.
• Shields this structure under licensure, leading to:

A licensed, state-endorsed pseudomedical system that misrepresents its scientific legitimacy to the public.

Conclusion

Under the Cullen-Snyder Framework:

• Connecticut’s naturopathy licensing system enables epistemic conflation.
• It facilitates an erosion of factuality freedom and scientific integrity.
• The law, rather than correcting these hazards, embeds them institutionally.

Recommendation

Public policy revision is needed to:

• Require explicit disclaimers of non-scientific status.
• Enforce evidence-based practice standards.
• Protect public liberty through transparency, factuality, and institutional integrity."

[End of Application #004 ‘part B’.]

[End of testimony.]"

for what it's worth. 

 [Oh, and the receipt for the process:

 

This was done 2025-08-28.  There has been no other acknowledgement and no communication in my direction.]