Senate Bill (SB) 532, which would license naturopathic “doctors” (NDs) as “primary care” providers, was recently heard before a Wisconsin Senate Committee. As usual, the naturopaths put on a dog-and-pony show, with carefully curated patient anecdotes, misrepresentation of their education and training, support from credulous physicians (and chiropractors), and cherry-picked studies supposedly showing that they are capable of practicing as primary care doctors. The committee has not voted but the bill has plenty of time to find its way into the statute books given that the Wisconsin Legislature is year-round and the current session does not officially conclude until January of 2023. A companion bill, AB 529, has been introduced in the Wisconsin Assembly.
This is yet another example of the continuing scourge known as Legislative Alchemy, the incorporation of pseudoscience into law (especially health care practitioner licensing) by state legislatures and Congress. So far, naturopaths have succeeded in gaining licensure or some other form of legal recognition in 23 states and D.C., with varying scopes of practice. Once licensed, naturopaths return to the state legislatures year after year seeking to expand their scope of practice, the Holy Grail being (despite all the rhetoric about “natural” remedies) full prescription privileges, a goal they’ve met in only one state: Oregon.
- Although they call themselves “doctors” and “physicians” and claim expertise as primary care providers, their education and training takes place in naturopathic “medical schools” that operate outside the mainstream American higher education system. These schools reject science and evidence-based medicine. Unlike conventional medicine, only a handful of residencies are available to graduates, and most go directly into practice after school. Or, as Dr. Mark Crislip put it: “Next time you see a naturopath, remember it is the same as seeing an unsupervised medical student”.
- Licensed naturopaths are only nominally regulated by the states in which they practice, with naturopaths themselves controlling licensing standards (like exams), continuing education, and the standard of care, the latter of which apparently does not exist. In many states, they control the boards that are supposed to regulate them.
- Naturopaths do not practice evidence-based medicine, which they reject in favor of folk remedies and pseudoscience. Many are anti-vaccination. Their practices include dubious diagnostic methods, like hair analysis for “toxicities” (used as a pretext for “detoxification“), and unproven treatments, like herbs, supplements, homeopathy, and colonic irrigation, many of which carry risks, including death, but provide no proven benefit. While they claim otherwise, there is no compelling evidence that “naturopathic medicine” improves health, prevents disease, or saves money. In fact, “what little data there is suggests that utilizing a naturopath for primary care is associated with worse care . . .”
SB 532 licenses naturopaths who’ve graduated from accredited naturopathic “medical” schools, passed a licensing exam created, and graded, by North American Board of Naturopathic Examiners, and passed a “pharmacology examination” approved by a Naturopathic Medicine Examining Board, which would regulate the practice of naturopathy in Wisconsin. (There is also a “limited scope naturopathic doctor license” for long-time practitioners who did not graduate from accredited schools.)
Per the bill, licensed naturopaths would be allowed to practice “primary health care for the prevention, diagnosis, and treatment of human health conditions, injury, and disease” without limitation as to the patient’s age or health status. In other words, licensed naturopaths could diagnose and treat, for example, both severely ill children and complex geriatric patients suffering from multiple conditions like cardiovascular disease, diabetes, and cancer.
Their scope of practice would include:
- “[S]upport and stimulation of a patient’s inherent self-healing processes”, meaning vitalism, the amorphous pre-scientific notion that an “invisible, intangible, unique form of energy is responsible for all the activities of living organisms”.
- Ordering and performing physical and lab exams for diagnostic purposes “consistent with naturopathic education and training” including, but not limited to, diagnostic sonography and electrocardiography, as well as ordering diagnostic imaging studies.
- Dispensing (in other words, selling) and administering nutraceuticals, vitamins, botanical medicines (e.g., herbs) and dietary supplements (none of which must be proven safe or effective), homeopathic remedies (pure quackery), and hydrotherapy (e.g., “colon cleansing“).
- The prescription of any drug except those listed in Schedule I and Schedule II, and certain Schedule III narcotics. In other words, naturopaths would be prevented from prescribing only those drugs with a high degree of potential for abuse, but could prescribe many other pharmaceuticals like anabolic steroids, testosterone and other hormones, anti-depressants, and stimulants. They could also prescribe compounded drugs, or compound the drugs themselves, using any substance not prohibited by the FDA. (Naturopaths’ liberal use of dubious ingredients in compounded drugs, like the now-banned quack cancer treatment cesium chloride, has only recently been curbed by more stringent FDA oversight.)
- Use of almost all routes of administration for substances like vitamins, minerals, homeopathic remedies, as well as prescription drugs, including intravenous, vaginal, auricular, and ocular.
- Minor office procedures, including minor surgery.
- “Any other diagnostic, therapeutic, or other procedure” approved by the Board.
As suggested by that last quote, the Naturopathic Medical Examining Board would be incredibly powerful, able to expand naturopathic practice to include anything not expressly prohibited by the licensing law (like surgery or therapeutic use of ionizing radiation). In case that was not explicit enough, the bill also provides, in another section:
The board may promulgate rules to do any of the following . . . (a) Further define the scope of practice of naturopathic medicine. The board may expressly authorize diagnostic, therapeutic, or other practices that may be used by naturopathic doctors.
In addition to expanding the scope of practice, the Board would write the rules governing standards of practice, ethics, continuing education requirements, and standards for licensure and discipline, and would have jurisdiction over disciplinary actions against naturopaths. The Board would consist of four naturopathic doctors, one MD or DO physician practicing primary care who has worked with a naturopath (a requirement aimed at getting a “naturopath-friendly” physician on the Board), and two public members, all appointed by the Governor. This composition virtually guarantees that there will be no real oversight of the Board’s rule-making and other activities and, given the fact that there is apparently no naturopathic standard of care, naturopaths would be left free to practice their many forms of quackery with little fear of discipline.
Of particular concern, this Board would approve the pharmacology exam required for practice. This would almost certainly mean adoption the North American Board of Naturopathic Examiners NPLEX Elective Pharmacology Examination, about which little is known except that it “is comprised of 75 stand-alone items” and is not “case-based”, must be completed in 90 minutes, requires a score of 60-70% (a specific figure was not given) and, as best I can tell, can be taken an unlimited number of times. This exam was created “in house” presumably to stave off any attempt by outside entities to determine whether naturopathic education and training is actually sufficient for prescribing privileges. All available indications are that this is most certainly not the case.
The Senate Committee on Insurance, Licensing and Forestry held its hearing on SB 532 on September 29, 2021. (There is no official recording or transcript but you can read the documents submitted online.) The Wisconsin Medical Society, the Medical College of Wisconsin, the Wisconsin Academy of Family Physicians and several other medical specialty groups, and the Chiropractic Society of Wisconsin, have all indicated opposition to the bill, although not all groups oppose all of the bill’s provisions.
The American Academy of Family Physicians opposes naturopathic licensing altogether and written testimony from the Wisconsin Academy did a good job of objecting to the conflation between medical doctors and naturopathic “doctors” and designating naturopaths as “primary care” providers. The Academy also provided data undermining the naturopaths’ claims of equivalency between medical and naturopathic education and training, especially regarding pharmacology and the lack of a residency requirement.
In addition to naturopaths and their organizations, who are hardly objective, naturopathic patients submitted anecdotes of their favorable experiences with naturopaths. Three immediate problems with this sort of testimony come to mind: (1) anecdotes are not evidence; (2) no medical records are submitted to verify patient’s claims of successful treatment; and (3) there was no attempt (that I could find) to solicit testimonials from those who had bad experiences with naturopathic care (or their families, for those killed by naturopathic treatment). In other words, the fact that some patients are satisfied with naturopathic treatment is no reason to license naturopaths as primary care providers with prescription privileges and give them free rein to expand their scope of practice as they see fit.
Other than information submitted by medical groups challenging naturopaths’ claims about their education and practices, there was no objective analysis of naturopathy. To me, it is absolutely stunning that legislative bodies basically depend on naturopaths to evaluate their own fitness for practice, and decide the scope thereof, and almost never employ any outside, disinterested evaluators to assess their claims. It is the equivalent of creating a whole new class of licensed health care practitioners based on Google reviews.
The most accurate evidence of the way Wisconsin naturopaths would actually practice, as opposed to their lofty claims of competence and effectiveness, can perhaps best be gleaned from the way they are already practicing, apparently unimpeded by the lack of licensing. Here’s a sampling from naturopaths who testified in favor of SB 532 and their practices.
Allison Baker, ND:
- Claims that wet socks, worn overnight, will “bring warm blood to the feet, creating a pumping mechanism in the blood vessels that stimulates circulation and promotes release of congestion in the head and upper respiratory passages. In turn, this invigorates the immune system to fend off acute illness” and will relieve congestion. This is nonsense.
- Uses homeopathy (which is, by definition, ineffective for anything) to treat acute infections.
Lakeside Natural Medicine:
- Uses unvalidated salivary hormone tests to diagnose “adrenal fatigue”, a fake disease.
- Claims that physicians treating your hypothyroidism with thyroid replacement medication are treating “lab tests, not YOU” and are failing to address the underlying “cause”, which may include gluten, which can “destroy” your thyroid.
- Recommends a “toxic exposure and heavy metal assessment” and “detoxification support” to address fertility issues. Convincing patients they are infested with “toxins” and “heavy metals”, discovered through bogus testing, and “detoxifying” them are favorite naturopathic schemes.
Family Clinic of Natural Medicine:
- Offers “IV Nutritional Therapy” to “help the body detoxify . . . enhance our immune system, decrease inflammation, support the liver, help combat chronic infections like Lyme disease and cold viruses”. These claims lack evidence.
Jill Crista, ND:
- Recommends that tick bites be treated with homeopathy.
- Sells genetic testing and dietary supplements based on naturopath Ben Lynch’s MTHFR quackery.
- Sells Czech “peat therapy”, claiming that “a half hour in this mud bath saves your internal organs months of hard work trying to detox mold toxins.”
All of this is consistent with what we’ve learned about naturopathic practice from former naturopathic doctor Britt Hermes and surveys of naturopathic websites. As the authors of one of these surveys concluded:
A review of the therapies advertised on the websites of clinics offering naturopathic treatments does not support the proposition that naturopathic medicine is a science and evidence-based practice.
That being the case, they should not be licensed as health care practitioners in Wisconsin, and certainly not as providers of primary care with prescription authority, allowed to diagnose and treat any patient of any age with any disease or condition.