CGA PHC Testimony #2 - 2025-12-22 - A Cover Letter, Episode 016, a Q&A Perplexity 'Discussion' - As Archived

here, my last submission of the year to the CGA PHC dated 2025-12-22:

001. the 64-page PDF, the meat of the testimony, consisting of the script and annotations for Episode 016 [blog posts a and b] and some additional Perplexity Q&A [003. below]:

is at Archive.org here in entirety;

002. below is the 12-page cover letter from the submission/upload/testimony, which leads off the document at the above link [aka, 'dear foxes, concerning your over-watch of the hen-house...']. The item is post-dated 2025-12-22 as that was my overall deadline for completion.  All was uploaded to ct.gov on 2025-10-29.

[added note, 2025-11-05: Perplexity informs me that, by way of what is publicly available through bio.s, "3 out of 34 committee members have confirmed public health or healthcare credentials as of the 2025 legislative session." Oh my.]:

"December 22, 2025

Honorable Saud Anwar, Co-Chair

Honorable Cristin McCarthy, Co-Chair

Honorable Committee Members

Public Health Committee

Legislative Office Building, Room 3000

Hartford, CT 06106

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

This is my second and final submission to the PHC portal as testimony for the year 2025 regarding naturopathy in Connecticut.

This submission, as one PDF, includes: a cover letter, the scripts/transcriptions for two mp3s [available here and here in audio format], and an additional Q and A set.

I appreciate the forum in its limited form [literally], and I’m more than happy to engage by other means in the future.

With this PDF submission, I seek to unify and summarize my research and evaluation of Connecticut and naturopathy as it presently stands.

I must emphasize that my focus in this matter is, for starters, factuality as a constituent aspect of positive freedom as opposed to a certain kind of predetermined and oblivious authoritarianism.

I believe the 64-page transcription [archived here] effectively summarizes many of the issues I see concerning the State of Connecticut’s partnership with the archaic and erroneous – and indeed demonic, as I have termed such in a colloquial sense – medieval healthcare artifact known as naturopathy.

I have specifically tabulated the medievalisms on pp. 7-9 of this cover letter, for clarity and emphasis.

I am satisfied that this material communicates important aspects of my experience and my expertise regarding the Connecticut naturopathy matter as has occurred from the mid-1990s until the present day.

As a reminder, my [humble] M.S. in Health Sciences with a specialty in Health Professions Education was completed through a capstone project in this specific area -- the epistemically unwarranted naturopathic -- albeit regarding naturopathy curricula in the states of Washington and California.

I don’t expect to submit anything for the foreseeable future unless there are, and there usually are, future asks by the principals of the Connecticut and national naturopathy sector in terms of practicing here.

I am grateful that I live in a country, or at least an area of my country, this here Connecticut, where I can seriously criticize and disagree with the government [yourselves] at the state level without fear of many of the immediate things I’m seeing happening in other states.

In New York, coincidentally, across the street from the high school that I attended and graduated from, in the city where I was born, is Thomas Paine’s cottage.

In The Rights of Man, 1792, Paine stated: “The defects of every government and constitution both as to principle and form, must, on a parity of reasoning, be as open to discussion as the defects of a law, and it is a duty which every man owes to society to point them out.”

Therein, obviously, I suffer from optimism.

From The American Crisis, 1776, I again quote Paine: “Tyranny, like hell, is not easily conquered; yet we have this consolation with us, that the harder the conflict, the more glorious the triumph.”

That’s a dose of realism.

And in terms of moral responsibility and anti-apathy, as Mill wrote in 1867 as best as can be ascertained: “Bad men need nothing more to compass their ends, than that good men should look on and do nothing.”

To combine the ideal and the real, it appears virtue is inversely related to power.

I am aware of the local political landscape surrounding naturopathy in Connecticut—a constellation marked by scarcity of virtue, opaque processes, misdirection, and blithe power—and yet I am putting my head inside the lion’s mouth.

In other words, I understand that I am writing directly to the authors, sponsors, supporters, and maintainers of the legislation that upholds and permits this horrid and decreed context.

Chapter 373 of the Connecticut General Statutes, in its first paragraph defining naturopathy, has the term “science” occur five times with such statements as “the practice of naturopathy means the science” and “the practice of mechanical and material sciences of healing.”

But what kind of science is composed of discarded medievalisms, pseudoscientific and sectarian approaches, and opaque commitments and therein lacks the most essential aspects of science: being self-testing and self-correcting, testable, transparent, and rigorous?

I’ve yet to be convinced of the goodness of the Connecticut apparatus [yourselves and naturopathy] when it actively constitutes and maintains institutional structures and processes that support unfreedom.

There obviously isn’t accountability and oversight through an independent process which objectively assesses and reassesses especially peculiar healthcare permissions that lack factuality.

Contained within this testimony is this summary of naturopathy in Connecticut, which I stake every bit of my integrity upon:

“The situation amounts to a protected legal exception for pseudoscientific and sectarian approaches, one that is institutionally overlooked only because of statutory carve-outs specific to naturopathic licensing—not because of any change in the fundamental requirements for scientific fidelity or consumer protection that every other healthcare profession observes under law [...] the PDF points out a ‘race to the bottom’ in institutional standards only when it comes to examine [sic, examining] naturopathy: while stakeholders (physicians, nurses, etc.) participate collectively in advisory groups or oversight, the peer standards they tolerate for naturopathy are strikingly lower than those required in their own fields. As the document describes, the same epistemic and ethical failures would be unacceptable—and actionable—if found in their own professions.”

Now, as referenced within the document, I cannot take credit for authorship of the above excerpt [slight verbal mistake and all].

It was computationally arrived at through the Perplexity AI-LLM.

It’s amazing when inherent biases are isolated from this matter and dispassionate analyses and evaluations occur.

I anticipate having more powerful assistance in such acts of civic disobedience by way of such mechanisms in the future as regards this matter.

Civically, it is impossible to avoid the topic of the stark difference separating ‘rule by law’ and ‘rule of law’ that the matter at hand serves as an example of.

The latter supports our robust freedom.

For the former, when a law is unjust or the hands writing and wielding the laws are permissive in creating exceptions for what they favor to the point of absurdity – e.g., the well-worn ‘for my friends everything, for my enemies the law’ – unfreedom is occurring at an institutional level by imperious decree.

I think we can all agree that unforeseen and even well-known bad things are enough to combat, never mind seeding further bad things, creating therein unfreedom, and nurturing such through institutional means and peculiar preferences.

One can calculate, with some AI-LLM help, ranges regarding the consumer/patient expenditure for Connecticut licensed naturopathy and educational consumer expenditures for the national educational scene.

One such query I have recently used via ChatGPT is: “Based on published accounts of the number of licensed naturopaths in Connecticut, the mean income of a Connecticut naturopath, and usage statistics of the sector, estimate a low and high range of total expenditure by consumers/patients in the Connecticut marketplace for the past five years.”

A practitioner income method yields this kind of range:

So, one to two couple of hundreds of millions of dollars for the cited years, in sum.

A visit-fee method yields this kind of range:

Therein, a range of seventy to about six hundred million.

A final quantification [via Perplexity] was posed: “Can you generate a rough estimate of how much Title IV program student loans have occurred for the AANMC U.S. naturopathic medicine programs since 1978?”

1978 is, of course, the year ND Pizzorno – a 1975 NUNM ND graduate – “coined” the marketing label “science-based natural medicine” particularly for naturopathy within Bastyr University’s vitalism-based pan-degree curricula [For an indexed PubMed reference, see: Baker, S. (2024). Conversation with Joseph Pizzorno, ND. Integrative Medicine (Encinitas, Calif.), 23(4), 40–43].

Such an interrogative is, of course, a big ask.

The Perplexity AI-LLM's bold answer: 

Two to three billion dollars for ‘science subset nonscience’ – as my 64-page PDF easily demonstrates as perpetual [as well as this cover letter’s pp. 7-9] – and all the horrifying transgressions of informed consent through grifting is an insane cost for this pseudoscience, deceit, and sectarian capture.

This ‘science subset nonscience’ error is best encapsulated by the National University of Natural Medicine page “Naturopathic Principles of Healing” wherein we’re told:

“The practice of naturopathic medicine emerges from six principles of healing. These principles are based on the objective observation of the nature of health and disease and are examined continually in light of scientific analysis. These principles stand as the distinguishing marks of the profession. [#1] The healing power of nature — vis medicatrix naturae. The body has the inherent ability to establish, maintain, and restore health. The healing process is ordered and intelligent; nature heals through the response of the life force. The physician’s role is to facilitate and augment this process.”

When an AI-LLM is asked to “analyze and evaluate it [the above quote] in terms of accuracy, truthfulness, error, and distortion”, the answer, in part, is: “While naturopathic institutions claim to ‘continually examine principles in light of scientific analysis’ , the vis medicatrix naturae concept itself is not empirically testable and therefore cannot be scientifically verified or falsified […] No scientific evidence supports the existence of an organizing ‘vital force’ that consciously directs healing. Biological processes are governed by biochemical and physiological mechanisms, not by intelligent intent […] The passage conveys a core metaphysical principle of naturopathic philosophy rather than a scientifically verifiable statement.”

How inconvenient!

NUNM is the heart of naturopathy institutionalization in North America, and intractable pseudoscience is at the heart of naturopathy: E.g., the above quite erroneous yet definitive ‘science subset nonscience’ position can be found within the archives of the State of Nevada which hosts the NUNM 1978-1980 school catalog.

That 1978 catalog states “This vital force, the vis medicatrix naturae, is the foundation of naturopathic philosophy and practice […and is part of] the science of naturopathic medicine […and] naturopathic medical science.”

Disguising such with other language often, and posing a false science categorization broadly in the same manner as Chapter 373, is naturopathy’s big lie that then makes all other naturopathy lies easier to swallow.

And therein what occurs is sectarian capture and institutionalized falsehoods.

Naturopathy’s growth trend in such a process is as follows, roughly:

As just written, I’ve stated that ND Pizzorno coined the label “science-based natural medicine” in 1978 upon naturopathy and at the same time, his alma mater, NUNM, in the same year, expressedly stated the science-ejected as the basis of naturopathy.

The naturopathillogical error and naturopathy’s harmful inducement increasingly spreads like a virus, like a plague, visited upon unsuspecting consumer/patient and student populations.

A public health committee, a legislature, should aid in preventing such with measures that are effective as far upstream as possible and definitely not, as I have seen for decades and as continues, participate in the contagion’s success through science camouflage.

Perhaps it can be expressed this way, if you like satirical logical representations in the form of a relational analogy:

naturopathy : scientific and ethical healthcare = innumeracy : accounting.

Aka: “Naturopathy relates to legitimate, evidence-based medical practice in the same way that being bad at math (innumeracy) relates to being competent at accounting. It implies an incompatibility or deficiency: that naturopathy is as unsuited to scientific and ethical medicine as innumeracy is to accurate financial work.”

A con’s circle knows more than their marks, intrinsically, and licensed naturopathy is an institutionally facilitated con.

As the current data set I’ve culled from World Naturopathic Federation materials (WNFM) indicates -- Connecticut’s CNPA is an AANP affiliate and the AANP is listed first on the founding members list of the WNF -- for the Perplexity AI-LLM task “On a spectrum of 0 through 10, with 10 being most and 0 being least, itemize, rank, and quantify the contents of the attached PDF that are similar to the medical ideas of the Middle Ages that have been discarded”:

Answer: “Several themes in the attached PDF show strong similarity to discarded medical ideas from the Middle Ages, particularly regarding vitalism, humoral theory, and the healing power of nature. Below is an itemized, ranked, and quantified spectrum (0–10, 10 being most similar) of these contents, highlighting their correspondence with medieval medical concepts.

Highest Similarity (Scores 8–10)

Concept/Theme	Score	Description
Vitalism/"Life Force"	10	Frames health as governed by an unseen "vital force" or "life force", directly paralleling pre-scientific, spiritual explanations of illness and healing prominent in medieval medicine. Explicitly termed a central tenet in naturopathic philosophy and compared by the PDF [WNFM] to terms such as chi, prana, spirit, and soul, and placed outside measurable scientific concepts
Healing Power of Nature (Vis Medicatrix Naturae)	10	Rooted in the idea that nature or the body has an intrinsic, ordered ability to heal itself, termed "ordered intelligence" or "extension of creator consciousness," essentially mirroring the vitalistic, teleological thinking that modern science has abandoned
Humoral Theory ("Four Bodily Humors")	9	Described as "a central theory by naturopathic practitioners." Attributed to early philosophers, it details the four humors, their organs, elements, and diseases, explicitly paralleling Hippocratic-Galenic models abandoned post-cellular theory but maintained here as explanatory for health and disease in naturopathic settings

High Similarity (Scores 6–7)

Concept/Theme	Score	Description
Emunctory Theory	7	Focus on stimulating the body's elimination pathways (excretion/sweating/etc.) to restore "vital force," reminiscent of medieval and pre-modern theories of disease as an imbalance of bodily substances or insufficient "cleansing".
Holistic/Spiritual Language	7	Frequent framing of health in spiritual or cosmic terms ("spirit," "cosmic consciousness," "personal essence"), echoing medieval blends of medicine and metaphysics.

Moderate Similarity (Scores 4–5)

Concept/Theme	Score	Description
Doctrine of Signatures	5	Not explicitly referenced but implied in historical descriptions of "guiding principles" derived from early modern/medieval thinking on analogical herbal medicine.
Non-Evidence-Based Individualization	4	The individual tailoring of treatments rooted primarily in philosophical tradition rather than consistently in robust empirical evidence, reflecting pre-modern individualized regimens.

Low Similarity (Scores 0–3)

Concept/Theme	Score	Description
Miasma, Astrological Medicine, Alchemy, Supernatural Causation	0–2	No substantive appearance in core themes or clinical practices in the PDF. Direct references are absent, though the underlying spiritual worldview remains present in other themes.

Ranked Itemization Summary

• Vitalism/life force: 10/10 — Ubiquitous, foundational, directly inherited from medieval and pre-modern models.
• Healing power of nature: 10/10 — Explicitly positioned as an ancient, supra-empirical tenet.
• Humoral theory: 9/10 — Embraced as a core living theory, not as a case study in obsolete history.
• Emunctory/cleansing theory: 7/10 — Emphasizes bodily purging, a hallmark of pre-germ theory medicine.
• Holistic/spiritual language: 7/10 — Strongly echoes medieval synthesis of body, mind, and spiritual cosmos.
• Doctrine of signatures (implied): 5/10 — Indirectly present through reverence for historical herbal analogies.
• Non-evidence-based "individualization": 4/10 — Claims patient-centric care through pre-scientific frameworks.
• Other medieval concepts: ≤2/10 — Largely absent as explicit doctrines.

Key Observations

• Vitalism and healing power of nature are modern forms of concepts squarely rejected by contemporary biomedical science because they lack empirical support or mechanistic basis.
• The PDF [WNFM] gives humoral theory actual explanatory power, going beyond mere historical interest, distinguishing it from its complete dismissal in scientific medicine.
• Emunctory and ‘cleansing’ theories rest on discredited physiological models pre-dating germ theory and cellular pathology.

All rankings and statements are directly supported by the PDF’s [WNFM] explicit and repeated language on these topics.”

For a satellite-view type broad representation that’s a little more recent, for the prompt to Perplexity “Can you create a graph comparing the scientific dismissal of the theories, claims, and processes central to North American naturopathy and the increase in scientific support for the theories, claims, and processes central to modern healthcare over the past 60 years?”, what results is this graph:

I think the above description is actually quite generous, in that lifestyle recommendations, diet, and exercise – when science- and evidence-based – exist as stand-alone interventions unrelated to the naturopathic.

Overall, if the meaning of the graph is not clear, what is indicated is that as scientific support increases in terms of healthcare’s knowledge processes and rigors over time, naturopathy's dismissal in terms of its theories, claims, processes and laxities increases as well over time.

I believe we can do much better than what Connecticut is posing and advocating for by way of naturopathy in terms of scientific integrity, consumer rights, healthcare ethics, transparency, institutional permissions, educational standards, the integrity of law, and respect for the sanctity of belief.

I applaud Connecticut’s K-12 Digital Citizenship Curriculum of 2025 and 2015 adoption of the Next Generation Science Standards.

As a part of such high educational standards, the National Research Council wrote in 2012 [National Research Council. (2012). A framework for K–12 science education: Practices, crosscutting concepts, and core ideas. The National Academies Press]:

"Science is replete with ideas that once seemed promising but have not withstood the test of time, such as the concept of the 'ether' or the vis vitalis (the 'vital force' of life)."

More recently, there’s 2022’s “Physics of Life” [National Academies of Sciences, Engineering, and Medicine. (2022). Physics of life. The National Academies Press] wherein we’re told:

“19th-century experiments [that is, if you are counting, the 1800s…] were instrumental in establishing the laws of thermodynamics and banishing ideas of vitalism.”

These last generative bits are to prove a point: middle schoolers can disprove the science claim that naturopathy places upon its fundamental premise and procedures [as well as Chapter 373] with educator guidance and easily available computational tools such as AI-LLMs.

I take to heart the statement “The effectiveness of public health policies, practices, and actions depends upon public trust gained through decisions based on the highest ethical, scientific, and professional standards. Public health gains public trust in part because its practices are informed by evidence. When the needed evidence is lacking, public health seeks it, and when the evidence reveals faulty or inadequate practices, public health seeks to improve those practices” [APHA].

But, for better public guidance, I’ve had the Perplexity generative AI-LLM revise APHA’s values statement through the lens of the Cullen-Snyder Framework Applications #001-005 to more accurately reflect the Orwellian reality of Connecticut, national, North American, and world naturopathy in process, obligation, and institutionalization wherein values are grossly reversed:

"The effectiveness of public health policies, practices, and actions depends upon public trust—luckily, in Connecticut, such trust can be manufactured wholesale by issuing licenses to anything that wears a science-costume convincingly enough. Public health here gains public trust not through evidence but through elaborate rituals of 'science camouflage,' where homeopathy, vitalism, and energetic manipulation are paraded as the equals of immunology or biochemistry so long as they are dressed up in enough medical terminology and rubber-stamped by a Board of Deference. When evidence is lacking—no bother!—Connecticut simply legislates the evidence out of relevance and permits pseudoscientific practitioners to present themselves as peers to MDs, institutionalizing both title and therapeutic ambiguity for maximum consumer confusion. If the evidence ever dares reveal that the sacred 'healing power of nature' is in fact a tired metaphysical relic, fear not: regulatory authorities will do their utmost to blend it seamlessly into the language of 'primary care' until nobody can tell a placebo from a public health policy. For practices discovered to be faulty or fraudulent, Connecticut's solution is bold: issue a broader license, build a state board out of practitioners of those very same methods, then shield the result with statutory language so that neither patient nor taxpayer ever need worry about pesky concepts like scientific validity, factual integrity, or ethical clarity again. Thus, public trust is preserved—the first casualty of which is trustworthiness itself."

Along the same lines, for the task “Based on the permissions for nonsense and misrepresentation that Connecticut law and structure permits for its naturopathy within the state, can you list similar kinds of nonsense and misrepresentation within commerce in Connecticut that would occur if such laxity was extended towards the state's commerce, healthcare, and professions in general?”, we’re told:

“Analogous Nonsense and Misrepresentation

Commerce:

Businesses could legally market products making scientifically refuted or impossible claims (e.g., perpetual motion machines, miracle supplements, homeopathic electronics) as equivalent to rigorously tested and regulated goods. Caveat emptor would reign, and consumer protection authorities would be forbidden to act unless a product caused explicit financial fraud, but not for misleading or pseudoscientific marketing. "Energy-balance shoes" or "vital-force bottled water" could claim physiological health effects with impunity, so long as industry standards simply deferred to the profession's own pseudo-regulatory board instead of facts or evidence.

Healthcare:

Any provider—dentist, acupuncturist, homeopath, or nurse—could claim primary care status regardless of their adherence to recognized standards of safety or efficacy. Cancer specialists could openly admit they lack standard qualifications and promote unproven therapies as standard-of-care, so long as their own in-group regulatory board deemed it acceptable. This would erase factuality and dramatically undermine public safety.

Professions in General:

Architects could design buildings using numerology, astrologers could draw up city zoning maps, and engineers could receive licensure for designs based on dowsing rods or wishful thinking if a professional board comprised of fellow believers gave their approval. Professional titles and credentials would be divorced from any empirical foundation, at the mercy of political or lobbying influence with names and self-policing boards substituting for external standards.

If such standards were universally applied, Connecticut would face near-total collapse of commerce, professional trust, and consumer protection, eroding the backbone of market confidence and undermining the value of licensure, education, and public policy within every arena.”

I’ll end this long overview with this Perplexity-generated broad summary:

“The regulatory environment fails to uphold key ethical standards such as honesty, competence, and non-maleficence. The official statutes and educational materials do not adequately warn the public about the non-scientific basis and potential risks of naturopathy, thus compromising integrity. While explicit financial fraud can be prosecuted, the promotion of unscientific therapies itself is institutionally protected, amounting to sanctioned deception. This indicates systemic ethical failings and oversight incompetence.”

Thank you for your consideration and for your service [in some matters].

Respectfully,

Robert Cullen."

003. the Q & A:

003.a1. task 001.: "Can you analyze the attached PDF [the scripts combined] for major issues in terms of errors or misstatements?"

003.a2. the answer:

"The attached PDF, 'Testimony - Rob Cullen - Copy.pdf,' is a multi-part, deeply annotated analysis and critique of naturopathic medicine and related regulatory, educational, and legislative frameworks, primarily using the author’s 'Cullen-Snyder Framework.' The document summarizes various applications of that framework, incorporates both AI-generated and human commentary, and addresses the intersection of pseudoscience, law, academia, and consumer protection.

Major Issues: Errors and Misstatements

Internal Accuracy and Integrity

• The document itself is highly self-reflective about possible sources of error. The author repeatedly requests external checks (e.g., having outputs reviewed by different AI models for factual accuracy) and cites alignments with mainstream scientific and legal consensus regarding the status of naturopathy, homeopathy, and other relevant therapies.
• Multiple sections contain consistency and internal fact-checks across applications. For example, the author notes and corrects his own errors (e.g., a misstatement of a book’s publication year), clarifies philosophical distinctions, and addresses differing interpretations by AI models regarding the concept of “unpredictability” in health care.

Substantive Assertions and Outside Fact-Checking

• Key claims about naturopathy’s epistemic foundations, licensure, and regulatory carve-outs, and their characterization as “science camouflage” or “licensed falsehood” are cross-checked and shown to match the consensus found in science advocacy, legal, and medical policy reviews as of 2025.
• Where summaries are requested from AI (e.g., Perplexity, ChatGPT), those summaries also include external citations and direct fact-checking of major regulatory and scientific claims, confirming the correctness of most statements about U.S. and Canadian law/regulation.

Possible Issues or Critiques Identified

• The most prominent “issues” are not errors or factual misstatements, but limitations or philosophical disagreements about interpretation, especially regarding how certain freedoms or legal rights are defined and weighed (e.g., unpredictability as a healthcare virtue vs. risk).
• The author is cautious about the self-sufficiency of AI-generated analysis and openly discusses its current limitations, particularly the risk of falsely postured knowledge or “science washing” created by generative models if not carefully checked.

No Evidence of Major Factual Errors

• Across the applications (to universities such as University of Minnesota, Southern Cross University, University of Bridgeport, and regulatory scenarios in Connecticut and British Columbia), the major empirical claims regarding the structure and content of naturopathic curricula, legal recognition, and the blending of scientific and pseudoscientific concepts are corroborated by referenced mainstream sources and reviews by external parties.
• Descriptions of regulatory allowances for pseudoscientific practice, statutory shields from consumer fraud prosecution, and issues regarding scope of practice are accurately represented in context, matching recent policy and scholarly reviews.

Language and Tone

• Some language choices (e.g., 'licensed falsehood,' 'science camouflage,' 'legislative alchemy,' 'sectarian capture') are polemical, but the author repeatedly grounds those in documented policy and legal realities while inviting outside review.
• There are no egregious misquotations or obvious distortions of source material, and where the author paraphrases or summarizes laws, books, or external documents, he either attributes directly or clarifies the scope of paraphrase versus direct citation.

Conclusion

There are no major factual errors or misstatements in the PDF. The few 'issues' present are largely about analytic emphasis, minor detail corrections, or differences in interpretation, rather than errors. The author’s process of incorporating external checks and critiques further boosts the reliability of the document’s core claims."

003.b1. task 002.: "Are there any Connecticut statutes that are relevant in regard to the PDF contents in terms of actions and inactions taken and not taken by the stakeholders mentioned?"

003.b2. the answer:

"Yes, there are specific Connecticut statutes directly relevant to the actions and inactions of the stakeholders discussed in your PDF, primarily surrounding the legal status, regulation, and public representation of naturopathy in the state. The document analyzes Connecticut law in depth and finds that the enabling statutes and associated regulatory structure play a central role in legitimizing, licensing, and institutionalizing naturopathy—including modalities lacking scientific support, such as homeopathy and vitalism—without providing adequate public warning or factual distinction between science-based and non-scientific practices.

Key Connecticut Statutes

Chapter 373: Naturopathy

• Connecticut General Statutes, Chapter 373, establishes the legal framework under which naturopathy is licensed and regulated in the state.
• Sections 20-34 and 20-34a: Define naturopathic practice, explicitly referencing the “healing power of nature” and including modalities such as vitalism and homeopathy, even though these are not supported by modern scientific evidence.
• Section 20-42a: Allows delegation of therapies like colon hydrotherapy, which are not evidence-based, under the license.

These laws fully license naturopathic doctors to diagnose, treat, and perform certain medical functions, contingent only on training from specifically accredited programs that themselves blend scientific and non-scientific content. The statutes also vest professional oversight primarily in a state board composed of naturopaths, further solidifying internal, rather than external, standards for practice and discipline.

Stakeholder Actions and Inactions

Department of Public Health and Board Oversight

• The State Board of Naturopathic Examiners (typically dominated by licensed NDs) establishes standards and enforces regulations according to the norms of naturopathy, not universally accepted scientific medical standards.
• There is no statutory requirement for consumer warnings or public disclaimers on the non-scientific nature of many legally permitted naturopathic modalities, leaving Connecticut citizens potentially misled as to the scientific legitimacy and efficacy of practices provided under state license.

Legal Protections and Commercial Representation

• By granting statutory licensure to naturopathic practitioners with broad scopes—including authority to diagnose, treat, and advertise as healthcare professionals—Connecticut law institutionally legitimizes a system that would otherwise risk classification as consumer fraud or quackery under conventional commerce and medical standards.
• Legislative and regulatory inaction in requiring transparent scientific disclosure, mandating evidence parity with conventional care, or enforcing strong consumer protections are seen, within the cited framework, as actions that effectively undermine scientific integrity and informed consent.

Conclusion

Connecticut's statutory framework—especially Chapter 373 and its implementation—enables the development of a legally protected, licensed system of naturopathic practice embedded with pseudoscientific content, without adequate consumer protection or factual transparency requirements. The actions and inactions of key stakeholders (State Public Health Department, Board of Examiners, and legislative bodies) are central to enabling this continuing structure and are directly critiqued for failing to safeguard public health and factual integrity."

003.c1. task 003.: "Would the situation described in the PDF concerning Connecticut naturopathy be tolerated by any of the other Connecticut healthcare stakeholders within their respective professions?"

003.c2. the answer:

"The situation described in the PDF—wherein Connecticut law legitimizes naturopathic practice that blends scientific and clearly pseudoscientific content (like vitalism and homeopathy), licenses practitioners accordingly, and provides little consumer scientific transparency—would not be tolerated within the standards or regulatory expectations of other major healthcare professions or stakeholders in Connecticut.

Healthcare Professions' Tolerance for Pseudoscience

• Medical Doctors (MDs) and Osteopaths (DOs): Both professions are governed by statutory language and regulatory boards that require strict adherence to scientific standards of care and evidence-based medicine. Practices routinely debunked by scientific consensus—such as homeopathy and vitalism—would count as unprofessional conduct or fraud if presented as science-based care by these groups.
• Nursing: Connecticut nurses are held to standards of practice that mandate patient care based on scientific evidence and established protocols. Delivering therapies known to have no scientific plausibility (like “healing by innate vital force”) would be subject to professional sanction and could be classed as patient deception.
• Pharmacy, Dentistry, and Allied Health: Each profession’s regulations prohibit making scientific claims for remedies or interventions lacking credible evidence. Pharmacists, for instance, are not permitted to endorse products as medicines if unsupported by clinical trial data, and would be disciplined for systematic promotion of ineffective or unproven treatments as if they were validated therapies.

Stakeholder Perspective and Double Standard

• The PDF points out a “race to the bottom” in institutional standards only when it comes to examine naturopathy: while stakeholders (physicians, nurses, etc.) participate collectively in advisory groups or oversight, the peer standards they tolerate for naturopathy are strikingly lower than those required in their own fields. As the document describes, the same epistemic and ethical failures would be unacceptable—and actionable—if found in their own professions.
• The situation amounts to a protected legal exception for pseudoscientific and sectarian approaches, one that is institutionally overlooked only because of statutory carve-outs specific to naturopathic licensing—not because of any change in the fundamental requirements for scientific fidelity or consumer protection that every other healthcare profession observes under law.

Conclusion

Every major Connecticut health profession—medicine, nursing, pharmacy, dentistry, and allied health—requires evidence-based practice and has robust internal and external mechanisms for policing deception and pseudoscience. The tolerance for 'science camouflage' in naturopathy, as institutionalized in Connecticut statutes, is a unique legislative exception not countenanced in any of these other domains and is called out as such in the PDF."

003.d1. task 004.: "Using past documented state public health, education, and consumer processes, estimate the harm done to Cullen and his class kind in terms of violation of rights and quantified monetary compensation."

003.d2. the answer [probably not usual, customary, and reasonable in terms of amounts]:

"The harm experienced by Cullen and his class, as revealed in the PDF and consistent with the documented failures of Connecticut’s public health, education, and consumer protection processes, centers on the violation of fundamental rights—such as access to truthful information, informed consent, and protection from institutionalized deception in higher education and healthcare. Monetary compensation estimates can be projected from analogous fraud, rights violations, and consumer redress cases.

Rights Violations

• Deprivation of Truthful Information: Students, such as Cullen, were systematically misled by state-accredited educational and licensing systems that claimed to offer scientific, non-sectarian healthcare education while embedding doctrine (vitalism, homeopathy) antithetical to scientific standards.
• Loss of Informed Consent: By blending scientific and pseudoscientific content and failing to provide clear disclaimers, these institutions and regulatory authorities violated students’ rights to make informed choices about their education and careers.
• Freedom of (and from) Sectarian Exposure: Students faced unwanted exposure to sectarian, spiritualistic indoctrination in a program marketed as secular and science-based—a violation akin to compelled speech or belief, which has precedent in judicially recognized rights.

Documented and Parallel Harm

• Financial Harm: Students incurred substantial debt (often via Title IV federal loans) under false pretenses about their degree’s nature and legitimacy, impairing future earnings and mobility.
• Career and Reputation Harm: Degrees issued lacked real-world scientific or clinical legitimacy, sharply limiting professional, licensure, and employment opportunities compared to the program’s advertised status.
• Public Trust and Health Harm: The perpetuation of these deceptive practices erodes public trust in health literacy, consumer protections, and regulatory legitimacy.

Analogous Compensation and Quantification

• Student Debt and Tuition: Comparable class actions in higher education fraud (e.g., misrepresentations by for-profit colleges) have resulted in compensation that matches tuition costs, fees, and interest on student debt for each affected student. At Connecticut rates, for multi-year doctoral programs, this can exceed $50,000–$200,000 per individual.
• Pain and Suffering, Loss of Opportunity: Some federal and state settlements (such as those administered by the U.S. Department of Education) factor punitive damages or compensation for lost career mobility and emotional distress, often adding $10,000–$50,000 or more per claimant in severe cases of bad faith or egregious misrepresentation.
• Collective Redress: In cases involving systematic regulatory failure and rights deprivation (such as consumer class actions in education or health), total compensatory settlements have amounted to tens—sometimes hundreds—of millions of dollars when applied to large cohorts.

Precedent and Process

• Legal Recourse: In Cullen’s case, documented efforts to obtain redress through state consumer protection, regional and professional accreditors, and federal agencies yielded no substantive relief, underscoring a systemic regulatory failure.
• Statutory Gaps and Legal Carve-Outs: Courts and agencies often shielded institutions from accountability due to statutory exemptions for licensure-driven education—even in the face of scientific misrepresentation—further compounding the injury and frustration suffered.

Category	Estimated Individual Harm	Notable Parallel Cases
Tuition + Student Loan Debt	$50,000–$200,000	For-profit college fraud settlements
Career Opportunity Loss	$25,000–$100,000	Degree deflation/underemployment cases
Emotional Distress/Exemplary Dam.	$10,000–$50,000	Title IV/false advertising redress
Systemic/Group Damages	$Millions (class-wide)	National class action settlements

These figures are projections grounded in precedent, not actual court awards for Cullen’s unique case. They suggest that, had the regulatory and legal system functioned as intended, substantial compensation—for lost tuition, debt relief, and additional damages—could be justified for Cullen and his class due to the proven violations and harm documented over decades."