19 April 2023

Below is my summary of the key discussions from today's public meeting of the Health Equity/Continuing Education Subcommittee of the Board of Naturopathy. This subcommittee is composed of Drs. Elias Kass and Krystal Richardson and public member Brooke Fotheringham. (Please note that this summary does not reflect official meeting minutes of the Board, which is a completely separate entity from the WANP. The reflections and notes below are my own and should not be assumed to represent the Board of Naturopathy or this subcommittee in any way.)

The primary purpose of this meeting was to gather public comment on several proposals being considered by the subcommittee on Health Equity/Continuing Education rule-making. This meeting did not constitute a full Board meeting, as quorum was not established, and no decisions were to be made nor votes taken at this meeting. The goal was to solicit feedback from the profession to help the subcommittee draft language and determine a proposal to present to the full Board for consideration.

Shortly before the meeting, we were surprised to see item 3.1 on the meeting agenda, which proposed removing both the American Association of Naturopathic Physicians (AANP) and the Washington Association of Naturopathic Physicians (WANP) as sources of continuing education for Washington-licensed naturopathic physicians. Prior to this meeting, we were aware of several petitions aimed at creating a more inclusive Category 1, but we were not previously aware of large-scale efforts to remove two of the largest providers of continuing education specifically geared toward naturopathic physicians. Agenda item 3.2 proposed moving all conventional sources of continuing education currently listed under Category 2 into Category 1. Agenda item 3.3 sought public comment on whether any number of "naturopathic-focused" continuing education credits should be required of Washington-licensed naturopathic physicians.

Agenda item 2 focused on drafting language around a new legislature-established requirement for Health Equity continuing education for all health care practitioners in Washington. The subcommittee drafted language aligned with the legislative requirement and this agenda item was addressed very briefly.

On moving on to the proposal to remove both the AANP and the WANP as providers of continuing education, Dr. Kass and Ms. Fotheringham raised a concern of a perceived conflict of interest in the regulatory board requiring some credits to come from the nonprofit naturopathic professional organizations, which frequently charge money for these offerings. Attorney for the Board, Luke Eaton, explained that this raises no concerns in terms of the state ethics laws, but deferred to the Board of Naturopathy to determine if the Board wanted to create policy around this. Many members of our profession attended this public meeting to share their support for maintaining both the AANP and the WANP as providers of continuing education for Washington-licensed naturopathic physicians. Several pointed out that our professional organizations are registered nonprofit organizations led by volunteer doctors with the mission of protecting and advancing the entire profession. On the question of quality of naturopathic-specific CE, AANP Executive Director Laura Farr provided information on the rigorous review and approval process for naturopathic continuing education offered by the AANP, and I have offered the same information on the review and approval process in place for the WANP. Ms. Farr also pointed out that the Accreditation Council on Continuing Medical Education (ACCME) is increasingly denying CE accreditation to any practitioners it deems "alternative" such that agenda items 3.1 and 3.2 taken in sum would serve to drastically reduce the sources of quality, vetted continuing education offered by naturopathic physicians. Many pointed out that the challenge with the current rules is already limited access to continuing education options and that the removal of AANP and WANP as providers of CE would exacerbate this challenge - not fix it. Ms. Fotheringham suggested that the Washington Board of Naturopathy should become like the Oregon Board of Naturopathic Medicine (OBNM) and take over the responsibility of approving any CE credits offered by naturopathic organizations. Several pointed out that the infrastructure simply does not exist for that in Washington at this time in terms of staff support and availability of Board members and that it would take quite some time to build a strong approval process and people to run it - time and effort that has already been invested by the currently approved sources of CE.

On the question of moving all conventional sources of CE currently listed under Category 2 into Category 1, the subcommittee members appeared unified and the public attendees were mixed. This agenda item became merged with item 3.3 - the fundamental question of whether licensed naturopathic physicians should be required to take any credits specific to foundational naturopathic medicine and modalities. Several attendees suggested that the relatively small number of credits required from Category 1 is very reasonable and actually less than what had been required prior to this rule change. Some shared that naturopathic conferences are a primary way that they stay in touch with the profession and aware of any advances in naturopathic therapeutics. Others stated that the requirement for naturopathic-specific CE is not necessary because licensed naturopathic physicians will choose to take naturopathic-specific CE regardless of the requirement. Some argued that removing the requirement for naturopathic-specific CE will make our profession more safe and others argued that removing this requirement would make our profession less safe. Others circled back to the reality that the safety data on our profession makes clear that our doctors are not causing harm to patients or to the public safety.

Ultimately, this meeting was simply about engaging with the profession and receiving feedback on the proposals being considered by the subcommittee. Next steps are that the subcommittee will discuss feedback received today and will develop proposed language to submit to the full Board of Naturopathy at the regular business meeting in May.

Please feel free to reach out to me directly at executive@wanp.org with any questions about this summary.

~Angela Ross, ND | Executive Director, WANP