12 May 2023

Below is my summary of the key discussions and decisions made at today's regular business meeting of the Board of Naturopathy, which regulates the practice of naturopathic medicine. (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 in any way.)

Non-Surgical Cosmetic Procedures Rule-MakingThe Board is currently awaiting a CR-102, which they are hoping to receive in June, to allow them to move this rule-making forward. Dr. Amira Ahdut moved to schedule a special meeting for the public hearing on proposed rules once the CR-102 is obtained and prior to the regular business meeting of the Board in August. Dr. Joanne Hillary seconded the motion and the motion was passed unanimously by the Board. Notice will be given of this special meeting once the CR-102 is received. The Board is open to receive any comment on this topic up through that special meeting (date to be determined).

Continuing Education Rule-Making
Dr. Krystal Richardson presented a brief summary of the April 19 meeting of the Health Equity/Continuing Education subcommittee, which is composed of Drs. Richardson and Elias Kass and public member Brooke Fotheringham. Dr. Richardson advised that the Board would need to hold a special meeting prior to a July 5 legislative deadline if rules are not adopted at today's meeting. She shared that the subcommittee members were in agreement that their original proposal to remove the American Association of Naturopathic Physicians (AANP) and the Washington Association of Naturopathic Physicians (WANP) as providers of continuing education for Washington-licensed naturopathic physicians would greatly reduce the options for naturopathic continuing education so they were no longer considering that as an option.

There was much confusion during this meeting as there appeared to be several different versions of the language being proposed by the subcommittee for the full Board's consideration. What had been sent out in advance in the meeting packet did not match what was being presented on screen during the meeting, so there were questions about what the final recommendations were from the subcommittee. Among the recommendations brought forward by the subcommittee for today's meeting were removing the accredited naturopathic medical schools as providers of continuing education and removing the requirement for recognized residencies to be approved by the Council on Naturopathic Medical Education (CNME).

A lengthy discussion ensued with familiar points being repeated: perceived conflicts of interest and favoritism were raised; assertions of there being no standards for naturopathic continuing education were made; the mission and purpose of the regulatory Board was discussed; pros and cons of requiring some amount of naturopathic-specific continuing education were argued. Members of the public expressed concern about the removal of the accredited naturopathic medical schools as providers of continuing education and about the removal of the requirement that residencies be approved by CNME. Several commenters requested that the naturopathic-specific Category 1 be expanded to include other naturopathic state and specialty organizations in order to create more opportunities for naturopathic-focused CE.

Ultimately, Board Chair Chad Aschtgen made effort to identify where in the proposed language the Board could find consensus. After discussing as a Board, the Board voted unanimously to approve all proposed changes to the CE rules EXCEPT for the changes related to the Category designation. In other words, the Board voted to accept the language pertaining to Health Equity, to pharmacology requirements, and to counting teaching hours as proposed by the subcommittee. Dr. Kass moved to combine Categories 1 and 2 and this motion was seconded by Ms. Fotheringham. Drs. Kass and Richardson and Ms. Fotheringham voted to combine Categories 1 and 2; Drs. Ahdut, Aschtgen, and Hillary voted against it. Because the vote was tied 3-3, the motion to combine Categories 1 and 2 did not pass. Dr. Aschtgen requested that a brief survey be developed by Department staff and sent out to all licensees in order to obtain additional feedback from the profession and the Board agreed to hold an additional special meeting prior to the July 5 legislative deadline to try to resolve the issues of Category designation in the current continuing education rules.

Colon Hydrotherapist Affiliation FormAt the last regular business meeting, a WANP member had raised a concern about the newly available Colon Hydrotherapist Registration of Affiliation Relationship Form published through the Department of Health. The form included language that established that the affiliated naturopathic physician was equally liable for the actions of the colon hydrotherapist - a liability that the WANP worked hard to ensure was not a part of the law. On legal review, Board attorney Luke Eaton indicated there is nothing in the statute that supports a shared liability as written into this form. Dr. Ahdut moved to edit the wording on the form to eliminate shared liability. This motion was seconded by Dr. Hillary and the motion passed unanimously. We here at the WANP are grateful to our astute member raising this concern and to the Board and Department staff for correcting this issue. (Edited to add: the current form linked above reflects the adjusted language.)

Scope of Practice Response PolicyThe Board engaged in a lengthy discussion, led by Mr. Eaton, about the role of the Board in responding to questions about legal scope of practice. Mr. Eaton indicated that more than half of all Board meetings over the last several years have involved a question about scope of practice. He advised that current statute does not provide for the Board of Naturopathy to serve as a legal resource center and that responding to these inquiries takes up significant time both of the Board and of support staff. Mr. Eaton shared that most boards and commissions respond to these types of inquiries by recommending consultation with personal legal counsel. This approach would not only save time and energy of the Board and support staff, but also would ensure the Board is not engaging in rule-making activity without going through the proper processes. Mr. Eaton will work with Drs. Ahdut and Richardson to develop language for a policy to be considered by the full Board at a future meeting.

Election of Chair and Vice ChairDr. Aschtgen's term is set to end prior to the next regular business meeting in August, so the Board held its annual election to identify the Chair and Vice Chair of the Board. Drs. Richardson and Hillary were nominated and unanimously voted into the roles of Chair and Vice Chair of the Board, respectively, effective immediately.

Current StatisticsAs of this meeting, there are 1,624 licensed naturopathic physicians and 14 registered colon hydrotherapists in Washington State.

Please direct any questions about this summary to me at executive@wanp.org.

~Angela Ross, ND | Executive Director, WANP