23 June 2023
The Board of Naturopathy, which regulates the practice of naturopathic medicine, convened a special meeting this afternoon to take action to advance the CR-102 rule making on Health Equity and Continuing Education. Below is my summary of the key discussions and decisions made at today's special meeting. (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.)
The only agenda items for this meeting were to gather comment from the public, to review results from a survey that was written by the subcommittee on Health Equity and Continuing Education (Drs. Elias Kass and Krystal Richardson and public member Brooke Fotheringham), and to discuss and vote on proposed changes to the continuing education rules for Washington-licensed naturopathic physicians. The meeting was held at a time that Dr. Chad Aschtgen - the most tenured Board member and the member who has spent many years specifically on this issue - was not able to be present.
During the open public comment period, the following points were made by attendees (to the best of my ability to understand and document):
- The survey that was sent out prior to this meeting was incredibly biased and that bias should be considered when reviewing the results.
- Removing any requirement for ND-specific continuing education is deeply problematic and requiring a mere 10 hours per year is not a significant requirement.
- The current CE rules are too limiting and prevent our doctors from seeking out conventional sources of continuing education.
- There are not enough naturopathic-specific courses on pediatrics.
- NDs should not be forced to take an additional 20 credits specific to naturopathic education.
- Any organizations that charge for continuing education should not be allowed to comment on rule-making for continuing education.
- ND-specific credits cost a lot more money than conventional credits.
- Naturopathic medicine is not any specific modality but rather a foundational philosophy that is taught in medical school - not through continuing education.
- Organizations like AANP and WANP should be approved to provide naturopathic continuing education, but so should organizations like ACCME, AMA, Pharmacy, and Nursing associations.
- These new rules actually expanded the ability to take these conventional courses, not limit it. Look into the statute and the history of this rule-making to verify this fact. What constitutes naturopathic CME is not any particular modality, but rather a foundational philosophy that guides how we think about patients, how we approach care, etc. Naturopathic philosophy and approach runs through all naturopathic-offered CE.
- The decision to hold this meeting without Dr. Aschtgen present is noteworthy.
- Naturopathic medicine is demonstrably very safe and naturopathic physicians should support the conferences organized by the associations that support and advance our profession.
- Category 1 should be expanded to include all naturopathic state and specialty organizations.
Dr. Richardson then presented results of the survey the subcommittee had written and sent out prior to this meeting. Dr. Joanne Hillary expressed concern about aspects of the survey - to include the presence of questions that did not give respondents an option to indicate that the current CE rules were not problematic; that there was no way to verify that the survey was filled out by Washington-licensed naturopathic physicians; that respondents were prompted at the end of the survey to submit another response such that individuals could fill out the survey numerous times; and that written comment made clear that there was a lot of confusion about the current rules. She went on to acknowledge that this rule-making process has been incredibly complicated and took many years to get the rules to where they are right now and that additional communication about the rules would be helpful. Dr. Richardson expressed that the survey results were very consistent, that she did not see confusion in the responses, and that this is a representative sample of the profession.
In terms of the legislature-required addition of Health Equity continuing education, the Board agreed that the proposed language had already been accepted by the full Board at its May Board meeting.
In terms of the changes to the categories of continuing education, the subcommittee made two proposals:
- The first option involved increasing the requirement in Category 1 from 20 credits every 2 years to 40 credits every 2 years; adding "continuing medical educational programs in the clinical application of naturopathic medicine that are approved by any naturopathic licensing authority in the States or Canada"; and moving ACCME, ANCC, and ACPE from Category 2 to Category 1. This would make Category 2 consist only of CE credit for teaching and for publishing. Category 3 would remain unchanged.
- The second option involved reducing the requirement in Category 1 from 20 credits every 2 years to 8 credits every 2 years and adding "continuing medical educational programs in the clinical application of naturopathic medicine that are approved by any naturopathic licensing authority in the States or Canada" to this category. Categories 2 and 3 would remain unchanged.
Dr. Kass advised that the subcommittee has a strong recommendation for the first option. Dr. Hillary indicated she is opposed to removing any requirement for ND-specific continuing education. Dr. Amira Ahdut shared that requiring some amount of ND-specific continuing education is important not only in ensuring our profession stays up to date on naturopathic philosophy but also to maintain our professional identity. It is important to consider that patients seek out naturopathic physicians because we tend to approach our patients differently than many conventional practitioners do. Drs. Richardson and Kass both assert they do not support the inclusion of a requirement of any naturopathic-specific continuing education.
After much discussion, Dr. Hillary moved to separate out the Health Equity language in order to meet the legislative deadline and to continue discussions on the categories of CE at a later time. Dr. Ahdut seconded this motion. Ms. Fotheringham suggested that this piece cannot be separated out and Dr. Kass recalled that the Board had already approved the language around Health Equity CE at the May Board meeting. Policy Analyst Heather Cantrell, who supports the Board in rule-making, advised that the Board would need to vote in order to advance to the CR-102.
At this point, Program Manager Lana Crawford read a prepared statement that had been submitted by Dr. Aschtgen prior to the meeting, expressing his interest in being involved in this conversation, providing some perspective of his many years of effort on this rule-making process, and requesting that he be allowed a vote on this matter. Attorney Luke Eaton advised that the Board could decide to allow Dr. Aschtgen a vote on this matter, given his interest and years of work on this issue. Dr. Ahdut affirmed that Dr. Aschtgen clearly wanted to be present at this meeting, that he has been an active contributor to this rule-making since the very beginning many years ago, and that this topic should be tabled until he has an opportunity to be involved in the discussion and vote. The Board was then reminded that there was already an open motion on the table to separate out the Health Equity portion and to revisit the categories when all Board members would be able to participate. When called for a vote, Drs. Ahdut and Hillary voted to move forward on the Health Equity language and to continue efforts on the category discussion at a later date; Drs. Kass and Richardson and Ms. Fotheringham voted against and the motion failed. Dr. Richardson then indicated that the Board will vote today because the subcommittee has spent several hours on this topic already. Drs. Ahdut and Hillary pointed out that the other Board members have literally spent years on this topic. Dr. Ahdut further noted that Dr. Aschtgen had the opportunity to shut the entire conversation down at the May Board meeting and he did not do that out of professional respect and a commitment to hear from licensees and the public and to ensure that everyone felt like they were able to be heard. Dr. Ahdut then moved again to table the conversation and Dr. Hillary seconded. Drs. Ahdut and Hillary voted to suspend this conversation and Drs. Kass and Richardson and Ms. Fotheringham voted against; the motion did not pass.
Ms. Fotheringham then moved to adopt the language proposed in the first option submitted by the subcommittee and Dr. Kass seconded. Dr. Ahdut once again requested that the Board wait until all Board members are able to participate and stated that this issue deserves the attention and participation of the full Board. Dr. Richardson called for a vote and Drs. Kass and Richardson and public member Ms. Fotheringham voted to adopt the language proposed in option 1; Drs. Ahdut and Hillary voted against. The motion carried and the meeting was adjourned.
There remains confusion about next steps on this. The rule-making process is not yet complete, so these proposed changes will not be in effect until after the rule-making is finalized. We will do our best to communicate updates on this as we receive them, but please note that the rules that went into effect on January 1, 2021, are still in effect until the Department of Health communicates differently.
Please direct any questions about this summary to me at firstname.lastname@example.org.
~Angela Ross, ND | Executive Director, WANP