Thursday, December 11, 2025

Tabulating Licensed Naturopathy Harms States-wise via Perplexity 2025-12

here, musing with Perplexity on Bastyr U., its promises and peculiarities, truthfulness, and monies [see the three bolded red areas for the gist]:

001. I was inspired to muse by way of Perplexity on 'naturopathy harms' due to:

001.a. this new Bastyr University video [uploaded 2025-09-22 and titled "Welcome to Fall Quarter at Bastyr University!"] wherein ND Pizzorno speaks of naturopathy as "science-based natural medicine":

"[at about 33 seconds in he states] We created Bast University with a very clear vision of science-based natural medicine";

now, as I pointed out in recently submitted material to ct.gov, ND Pizzorno is an NUNM graduate, and NUNM is quite clear about the essential vitalism which is the goal of all naturopathic activity and in fact written in coded fashion into the naturopaths' oath.  Similarly to 'science-based subset vitalism / the science-exterior', NUNM to this day states that vitalism as life force survives objective observation and scientific scrutiny.  Ah, the apple and the tree it fell from!

001.b. and indeed:

BU still claims "science-based natural medicine" upon such things within naturopathy as supernaturalism, homeopathy, vitalism, [and their homeopathic vitalism!].

actually, when asked to find the five most science-divergent aspects of bastyr.edu as a web site in terms of naturopathy, Perplexity states:

"these five areas—homeopathy, constitutional hydrotherapy/vital force stimulation, detox cleanses, craniosacral/visceral manipulation, and spirituality framed as a formal therapeutic modality—are among the clearest examples where Bastyr’s naturopathic program diverges from a rigorously science‑based, mechanism‑ and evidence‑driven standard while still being presented as part of an ostensibly 'science‑based' curriculum."

001.c. now, in the same month as that recent upload of 001.a.:

BU uploaded an admissions video titled "Doctor of Naturopathic Medicine Virtual Information Session" wherein we're shown in a slide that, according to ND Conner their "dean of naturopathic medicine", the central premise of naturopathy -- the vis medicatrix naturae or healing power of nature -- is "analogous to Paracelsus's concept of the archeus."

when you do a little research on that little gem, the archeus -- with the question to Perplexity "What science-ejected concept is Paracelsus's concept of the archeus most similar to?" -- we're told:

"nineteenth‑ and early twentieth‑century vitalists posited a non-physicochemical 'vital force' or élan vital that produced life phenomena and distinguished living from nonliving matter, a view now rejected in mainstream biology. Archeus anticipates this by positing an occult inner principle governing organic processes, so among science-ejected notions, generic vital force / élan vital -style vitalism is the closest conceptual successor";

So, obviously, there is quite a contradiction: the science based which is inherently focused on the science-ejected.  The same old naturopathillogical madness.

001.d. and BU was part of the AANP Alliance whose message, back in the late 1990's, induced me into studying naturopathy in a very major way. Their language:

"naturopathic physicians are the modern day science based primary care doctor [...] it is not a belief system."

002. so, in thinking about decades and decades of harm in terms of claims, methods, and knowledge categorizations:

002.a. I came up with this question / task for Perplexity:

"if naturopathy has falsely placed a 'science-based' label upon itself while inherently the essentially naturopathic [vitalism, supernaturalism, homeopathy, craniosacral therapy, supplements etc.] either lacks scientific support or is science ejected, what are the projected harms caused by state licensure of such? Can you create a table of states the license naturopathy and list any particular harms within each based upon respective state law?"

002.b. the answer:

"state licensure of naturopathy tends to amplify, not contain, the harms associated with vitalism, homeopathy, and similar pseudoscientific practices by granting them a legal status, creating public confusion about their scientific validity, and sometimes permitting physician‑like scopes (diagnosis, prescriptions, minor surgery) without physician‑level training. The specific harms vary by state law but cluster around misdiagnosis and delayed care, unsafe or unproven treatments, misleading use of titles such as 'doctor,' inadequate informed consent, and regulatory shielding of practices that would otherwise be easier to challenge as deceptive."

002.c. I also asked the follow-up question: "Are there any concerns with misleading students interested in healthcare careers?"

002.d. The answer:

"yes. There are well‑documented concerns that naturopathic programs and marketing can mislead students who are sincerely interested in science‑based healthcare careers. The core issues are misrepresentation of scientific rigor, career prospects, and the ethical status of practicing pseudoscientific medicine under a 'doctor' title [...] critical analyses and insider accounts show that, alongside some basic sciences, students are systematically taught homeopathy, iridology, craniosacral therapy, and other rejected or untestable modalities as if they were legitimate medicine, which fails to equip them with the critical tools and evidence standards expected in modern healthcare [...] former naturopathic students have described realizing, often after accruing large student‑loan debt, that their degree does not confer the recognition, career stability, or scientific credibility they had been led to expect [...] ethically, steering well‑meaning prospective clinicians into a profession built on vitalism and discredited therapies risks diverting talent away from evidence‑based pathways and embedding them in careers where their daily work may conflict with core professional duties to provide scientifically grounded, non‑deceptive care."

002.e. a large table was generated titled "Selected Harms Linked to State Naturopathic Licensure":

Jurisdiction (examples)

Licensure/registration status (illustrative)

Noted or projected harms/concerns tied to licensure or scope

Alaska

Identified among states with mandatory naturopathic licensure.[10][11]

Licensure allows naturopaths to present as regulated health professionals despite reliance on unproven modalities (homeopathy, “natural” cures), increasing risk of patients substituting ND care for physician care in serious disease; malpractice frameworks hinge on naturopathic standards rather than scientific medicine, potentially weakening redress.[1][3][4]

Arizona

Licenses naturopathic physicians and allows prescriptive authority, including some controlled substances; statute defines practice as “nonsurgical methods” yet board rules permit “minor surgery.”[10][2]

Regulators in another state explicitly cite Arizona as an example of scope creep and ambiguous “minor surgery” language, warning this can be interpreted to allow procedures beyond training and increase risk of patient harm.[2] Legitimization of naturopathic oncology and chronic‑disease care risks delayed or foregone evidence‑based treatment.[4][7]

California

Licenses only those using titles “Naturopathic Doctor” / “ND,” with limited prescribing and controlled substances under physician supervision.[10][11]

Title‑based licensure can blur distinctions for patients between NDs and MD/DOs, especially when NDs claim “primary care” roles; prescriptive authority plus pseudoscientific frameworks (homeopathy, detox) raises concern about inappropriate medication use and inadequate cancer or chronic‑disease management.[10][3][6]

Colorado

Allows naturopaths to practice under a registration or “complementary & alternative” framework; collaborative agreement with a physician must be attempted but not necessarily obtained.[10][11]

Weak collaboration requirements risk NDs functioning de facto as independent primary‑care providers despite lower training, with concerns about misdiagnosis and failure to recognize red‑flag symptoms; the legal ability to practice within an alternative‑care framework can limit accountability to mainstream standards.[10][1][3]

Connecticut

One of 16 states requiring licensure; prescriptive authority more limited than in some western states.[10]

Full physician‑level title (“naturopathic physician”) and independent practice create state‑endorsed equivalence in the eyes of the public despite systematic use of non‑scientific modalities, raising risks of delayed conventional care, misleading advertising as “science‑based,” and consumer‑protection concerns similar to those flagged in national critiques of naturopathic boards.[10][4][6]

District of Columbia

Licenses naturopathic physicians with authority to diagnose, treat, and order tests; allowed to prescribe certain legend drugs.[12][8]

As in other prescribing jurisdictions, NDs can manage complex conditions and medications without physician‑level training, heightening risks of drug interactions, undertreatment of serious disease, and malpractice centered on ND standards.[3][8][13]

Hawaii

Listed among states requiring licensure.[10][11]

State recognition and broad “natural medicine” practice permissions risk normalizing use of homeopathy and vitalist explanations for serious illness, with concerns about vaccine hesitancy and delayed oncologic or cardiovascular care noted in broader critiques of naturopathic practice.[4][7][13]

Kansas

Included in lists of states with mandatory ND licensure.[10][11]

Licensure authorizes a parallel provider class that can market services as science‑based primary care while grounded in non‑falsifiable doctrines, potentially undermining public understanding of science and complicating malpractice and oversight when harm occurs.[10][1][4]

Maine

Requires licensure; often cited as a state with relatively broad ND scope.[10][11]

Broader scopes (diagnosis, some prescribing) embed naturopathic practice into primary care, with concerns about mismanagement of chronic disease, vaccine counseling inconsistent with scientific preponderance, and substitution of unproven “detox” or supplement regimens for standard care.[2][4][7]

Maryland

Licensure conditioned on collaborative agreement with a physician; limited prescriptive authority.[10]

Although collaboration is intended as a safeguard, critics warn that even restricted prescriptive authority grants unwarranted legitimacy; patients may assume physician‑equivalent training, while collaborative arrangements in practice may be thin, leaving NDs to make complex decisions beyond their competence.[10][6][7]

Massachusetts

Has a Board of Registration in Naturopathy that evaluates qualifications and licenses NDs.[11][14]

Official registration and a state board signal state endorsement and “integrity and competence” of licensees, while core naturopathic modalities remain poorly supported; this can erode informed consent if patients are not clearly told that key treatments (homeopathy, craniosacral therapy) are not evidence‑based.[14][6][7]

Minnesota

Does not license NDs as independent physicians but allows practice under a “Complementary & Alternative Health Care” framework.[11]

Even without full physician‑style licensure, statutory recognition can permit broad advertising of unproven therapies; informed‑consent and disclosure requirements may be unevenly implemented, leading to patients misunderstanding the evidence status of treatments and delaying standard care.[11][1][3]

Montana

Listed among mandatory‑licensure states.[10][11]

Similar concerns as other rural western states: state‑sanctioned ND primary care in areas with limited physician access may steer patients with serious conditions toward inadequately trained providers relying on supplements and homeopathy, increasing risk of avoidable morbidity.[10][3][7]

New Hampshire

Licenses NDs and grants prescriptive authority, including some controlled substances.[10]

Ability to prescribe controlled substances combined with naturopathic dietary‑supplement regimens raises risk of polypharmacy and interaction harms; public may conflate ND and MD training, and malpractice actions must navigate naturopathic standards and boards that have historically endorsed non‑scientific modalities.[10][1][4]

New Mexico

Licenses NDs with prescriptive authority and broader scopes than in some eastern states.[10]

Critics warn that broad scopes enable NDs to practice near‑physician primary care while drawing on vitalism and homeopathy, thereby institutionalizing pseudoscience and risking mismanagement of complex illnesses (e.g., cancer, autoimmune disease).[10][4][7]

North Dakota

Included among states requiring licensure.[10][11]

In low‑density regions, licensure may encourage NDs to fill perceived primary‑care gaps, but with training and epistemology that diverge from scientific medicine, potentially increasing misdiagnosis, use of ineffective therapies, and difficulty for patients seeking recourse.[10][3][6]

Oregon

Long‑standing licensure with broad scope, including prescriptive authority and minor office procedures.[10][3]

Oregon malpractice commentary notes that NDs can be held liable, but also highlights risks where they manage serious conditions, perform minor procedures, or deviate from mainstream standards, with harms including delayed diagnosis, inappropriate supplement use, and procedural complications.[3][4][7]

Pennsylvania

Recent adopter of ND licensure/registration.[9][12]

New licensure potentially expands ND presence in primary care and integrative clinics; as elsewhere, the main projected harms are public confusion about training, reliance on unproven therapies, and difficulty for regulators unfamiliar with naturopathic doctrines to police misleading claims.[12][5][6]

Rhode Island

Requires ND licensure with mandatory collaborative agreement with a physician and limited prescriptive authority.[10]

Collaborative‑agreement requirement reflects explicit concern about ND training; however, licensure still grants professional status and can facilitate patient misperception of equivalence with physicians, while collaborative structures may in practice be loose.[10][2][6]

Utah

Licenses NDs with relatively broad scopes and some controlled‑substance prescribing.[10][15]

Legal scholarship on naturopathy/chiropractic in Utah notes malpractice cases where alternative providers’ mismanagement caused harm; combining prescribing power with non‑scientific frameworks heightens the risk of such outcomes.[10][4][15]

Vermont

Licenses NDs; allows prescribing including some controlled substances under specified conditions.[10][2]

Vermont is cited by Washington commentators as an example of a broad ND scope being used rhetorically to justify expansion elsewhere, raising concerns that such scopes normalize NDs as primary‑care physicians and obscure the pseudoscientific basis of many treatments.[2][5][7]

Washington

Licenses NDs as primary‑care providers with prescriptive authority including some controlled substances and minor procedures.[10][2][13]

A 2024 Washington sunrise review comment packet from physician and public‑health groups explicitly warns that current ND scope “poses a serious threat to public health,” citing inferior training, inappropriate procedural claims, and the risk that expanded authority would further compromise safety.[2] Critics also note that ND licensure boards endorse unproven practices, meaning licensure can “shield quackery from the scrutiny of the law.[4]

Wisconsin

Included among jurisdictions with ND regulation/licensure.[9]

As in other states with narrower ND scopes, harm is projected primarily through misrepresentation of scientific status, inappropriate management of serious illness with unproven therapies, and potential conflicts with established public‑health standards (e.g., vaccination, cancer screening).[4][5][7]

Puerto Rico & U.S. Virgin Islands

Territorial regulation/recognition of NDs.[9]

Territorial licensure adds to overall public perception that naturopathy is a standard health profession, which can influence patient choices in settings where access to physicians is already constrained, increasing risk of reliance on ineffective care.[9][5][7]


002.f. money thoughts:

002.f1. for this question to Perplexity: 

"what is the Title IV loan aggregate that has passed through Bastyr University since its founding, adjusted to today's dollars?  Are there any implications in terms of Title IV agreement requirements between a school, a student, and a bank?"

002.f2. this answer was provided:

"Publicly accessible data do not give a precise, inflation‑adjusted total of all Title IV loan dollars that have flowed through Bastyr University since its founding, but available indicators suggest the aggregate is likely in the hundreds of millions of dollars rather than tens of millions. Title IV participation creates specific legal duties for Bastyr (and any school) toward both the federal government and students, especially around truthful representation of programs, outcomes, and finances; violations can trigger institutional liability, sanctions, and borrower‑defense claims [...] given decades of operations, tuition at professional‑school levels, reliance on federal loans as the primary aid vehicle for graduate students, and typical ND‑program aggregates over $200,000 per borrower, the cumulative Title IV volume since founding is plausibly several hundred million dollars in 2025 dollars, but that remains a reasoned estimate rather than a documented figure [...] even without the exact aggregate, the regulatory implications are clear because every participating institution must sign a Program Participation Agreement (PPA) under Title IV. The PPA conditions a school’s initial and continued access to federal loan and grant programs on compliance with numerous requirements, including fiduciary duties in handling federal funds, proper return of funds when students withdraw, and meeting eligibility/administrative capability standards. Federal 'program integrity' and misrepresentation rules require that an institution provide accurate information to prospective and enrolled students about the nature of its programs, charges, and the employability of graduates; substantial misrepresentation in these areas is treated as a serious violation of the school’s fiduciary duty and can justify fines, limitation, suspension, or termination of Title IV eligibility. The Department of Education also emphasizes that schools are responsible for statements made by their agents or third‑party servicers (including marketing and recruiting contractors), and recent guidance highlights potential personal liability for owners or executives who sign PPAs if the institution cannot cover Title IV liabilities. ​For Bastyr specifically, these rules mean that any categorical claims that its programs are 'science‑based,' or that degrees lead to particular employment or licensure outcomes, must not materially mislead students whose borrowing is underwritten by Title IV; if they do, both institutional sanctions and borrower‑defense discharges of those federally backed loans become live issues under current policy."

002.f3. and for the follow-up question:

"is Bastyr's science categorical label upon naturopathy, and posture of the naturopathic as a modern physician, a truthful representation based on all that defines naturopathy in content, commitment, and activity?"

The simple answer was: "No."

002.g. many of the references  

[I haven't carried over many of the in-text numerical indicators above and those that are there may not be numbered right because I've revisited the thread and added follow-ups a few times]:

"1.    https://www.sholljanlaw.com/blog/2015/10/can-i-hold-my-naturopathic-doctor-accountable-for-malpractice/        
2.    https://doh.wa.gov/sites/default/files/2024-03/Sunrise-NP-ScopePracticeWrittenComments-Part1.pdf           
3.    https://cklegal.com/naturopathic-medical-malpractice-in-oregon/            
4.    https://pmc.ncbi.nlm.nih.gov/articles/PMC1140750/                
5.    https://sciencebasedmedicine.org/legislative-alchemy-2019-naturopaths-gain-licensure-in-two-states-try-for-authority-to-grant-vaccination-medical-exemptions/       
6.    https://www.ama-assn.org/practice-management/scope-practice/whats-difference-between-physicians-and-naturopaths        
7.    https://edzardernst.com/2024/03/naturopaths-are-not-physicians/             
8.    https://www.washingtondcinjurylawyers.com/can-you-sue-a-naturopathic-doctor-for-medical-malpractice/   
9.    https://aanmc.org/licensure/     
10.    https://www.cga.ct.gov/2023/rpt/pdf/2023-R-0240.pdf                               
11.    https://ancb.net/legislative-action-and-advocacy/naturopathy-laws-state-by-state/            
12.    https://ncanp.org/legislation/    
13.    https://pmc.ncbi.nlm.nih.gov/articles/PMC8874159/   
14.    https://www.mass.gov/orgs/board-of-registration-in-naturopathy  
15.    https://dc.law.utah.edu/cgi/viewcontent.cgi?article=3144&context=ulr  
16.    https://naturopathic.org/page/RegulatedStates 
17.    https://wyoleg.gov/LSOResearch/2025/NATUROPATHIC DOCTOR TITLE REQUIREMENTS BY STATE (Combined).pdf 
18.    https://www.ddrlawyers.com/blog/malpractice-in-alternative-medicine-legal-challenges-in-florida/ 
19.    https://www.bio.txst.edu/prehealthadvising/professionalprograms/naturopathic.html 
20.    https://educate.bastyr.edu/becoming-a-licensed-naturopathic-doctor-chapter-2 
21.    https://www.cbc.ca/news/opinion/naturopath-credentials-1.4890971 
22.    https://pmc.ncbi.nlm.nih.gov/articles/PMC1140750/   
23.    https://sciencebasedmedicine.org/nd-confession-part-ii-the-accreditation-of-naturopathic-medical-education/    
24.    https://www.science.org/content/blog-post/regrets-naturopath   
25.    https://www.nuhs.edu/what-you-dont-but-need-to-know-about-naturopathic-medicine/  
26.    https://journalofethics.ama-assn.org/article/cam-education-medical-schools-critical-opportunity-missed/2011-06 
27.    https://healthydebate.ca/2013/12/about-healthy-debate/opinions-about-healthy-debate/naturopaths-and-the-creep-of-pseudoscience/ 
28.    https://jamesistrying.com/2013/04/23/why-im-panicking-about-naturopathic-medical-school/ 
29.    https://www.naturopathicdiaries.com/naturopathic-students-illinois-felonies/ 
30.    https://ebm-nd.org/a-time-for-reflection/ 
31.    https://www.ctpost.com/opinion/article/Calls-coverage-of-naturopathy-degree-13752952.php 
32.    https://www.naturopathicdiaries.com/fact-checking-naturopathic-points-dcfli/ 
33.    https://www.aamc.org/media/87211/download 
34.    https://www.reddit.com/r/canada/comments/9ucycg/why_can_naturopaths_mislead_the_public_about/ 
35.    https://careersinmedicine.aamc.org/about-cim 
36.    https://careersinmedicine.aamc.org/about-cim/careers-medicine-cim-advisors 
37.    https://hms.harvard.edu/education-admissions/md-program/advising-academic-support/career-planning 
38.    http://brittmariehermesfactcheck.com/should-i-go-to-naturopathic-school-fact-check/ 
39.    https://www.apa.org/news/press/releases/2021/03/education-alternative-medicine-misinformation 
40.    https://careersinmedicine.aamc.org/about-cim/careers-medicine-awareness-utilization-and-value 
41.    https://bastyr.edu/admissions/financial-aid/fund-your-graduate-degree   
42.    http://www.ed.gov/laws-and-policy/higher-education-laws-and-policy/program-integrity-information-questions-and-5   
43.    https://bastyr.smartcatalogiq.com/en/2024-2025/academic-catalog/general-admissions/financial-aid    
44.    https://www.hklaw.com/en/insights/publications/2025/01/us-department-of-education-focuses-on-misrepresentation    
45.    https://www.law.cornell.edu/cfr/text/34/668.14   
46.    https://collegescorecard.ed.gov/school?235547  
47.    https://studentaid.gov/data-center/student/title-iv 
48.    https://studentaid.gov/data-center/student 
49.    https://studentaid.gov/data-center/school 
50.    https://bastyr.edu/sites/default/files/images/pdfs/financial-aid/Financial Aid FAQ.pdf 
51.    https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2025-01-16/notice-interpretation-regarding-misrepresentations-third-party-service-providers-engaged-institution-higher-education  
52.    https://www.faegredrinker.com/en/insights/publications/2023/3/us-dept-edu-announces-personal-liability-rqmts-postsecondary-insts-participating-title-iv-pgrms 
53.    https://bastyr.edu/admissions/financial-aid 
54.    https://www.bppe.ca.gov/webapplications/annualReports/2020/details/73713030 
55.    https://bastyr.edu/tier-one-arrangement-disclosure 
56.    https://bastyr.edu/about/news/important-federal-student-loan-changes-what-bastyr-students-need-know 
57.    https://bastyr.edu/sites/default/files/images/pdfs/financial-aid/FINAL- UND DEP.pdf 
58.    https://bppe.ca.gov/webapplications/annualReports/2024/details/73713030 
59.    https://www.opb.org/article/2024/08/30/oregon-alternative-medicine-loan-forgiveness/ 
60.    https://www.wsipp.wa.gov/ReportFile/1274/Wsipp_Washington-States-Student-Financial-Aid-Programs_Full-Report.pdf 
61.    https://en.wikipedia.org/wiki/Bastyr_University   
62.    https://bastyr.smartcatalogiq.com/en/2023-2024/academic-catalog/school-of-naturopathic-medicine/graduate-programs/doctor-of-naturopathic-medicine  
63.    https://en.wikipedia.org/wiki/Naturopathy   
64.    https://bastyr.edu/academics/naturopathic-medicine/doctoral/naturopathic-doctorate  
65.    https://experience.bastyr.edu/admissions-blog/innovations-in-naturopathic-medicine-emerging-trends-to-watch  
66.    https://www.statnews.com/2016/10/20/naturopath-critic-britt-hermes/  
67.    https://bastyr.edu/sites/default/files/images/pdfs/course-catalog/2013-14-catalog/school-naturopathic-medicine-13-14.pdf 
68.    https://bastyr.smartcatalogiq.com/en/2023-2024/academic-catalog/courses/ho-homeopathic-medicine/6000/ho6305 
69.    https://pmc.ncbi.nlm.nih.gov/articles/PMC6389764/ 
70.    https://clinicalgate.com/a-hierarchy-of-healing-the-therapeutic-order/ 
71.    https://richmondnaturalmed.com/functional-medicine-versus-naturopathic-medicine/ 
72.    https://pmc.ncbi.nlm.nih.gov/articles/PMC1140750/  
73.    https://sciencebasedmedicine.org/tag/bastyr-university/  
74.    https://www.forbes.com/sites/kavinsenapathy/2016/05/31/why-is-big-naturopathy-afraid-of-this-lone-whistleblower/ 
75.    https://qz.com/1088056/a-naturopaths-fight-against-her-alma-mater-shows-how-to-break-out-of-echo-chambers 
76.    https://www.reddit.com/r/medicine/comments/6qbiez/quackerybased_bastyr_university_makes_legal/ 
77.    https://bastyr.edu/about/accreditation-compliance 
78.    https://bastyr.edu/sites/default/files/images/uncategorized/reports/ND_Brochure_Eml16.pdf 
79.    https://straighterline.com/blog/bastyr-university-naturopathic 
80.    https://cnme.org/accredited-programs/"

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