It’s not too late!!! TODAY is the final day to give feedback on the regulations that will govern how your naturopathic doctor cares for you in the years to come. Please consider providing your feedback to the Transitional Council today if you have not already done so. The draft regulations can be found here.
Email your comments, questions and concerns to firstname.lastname@example.org or fax to (416) 874-4095.
Thank you for your support in optimizing the way naturopathic doctors can serve you toward optimal health care, today and in the generations to come.
-Elizabeth Cherevaty ND
OPEN LETTER TO THE TRANSITIONAL COUNCIL OF THE COLLEGE OF NATUROPATHS OF ONTARIO
Dear Transitional Council,
I have reviewed the proposed Naturopathy Act regulations and commend you on the hard work you have put in to develop them. I have the following points of feedback on the proposed regulations:
1. I would like to see the regulations better reflect the scope of training that naturopathic doctors have, including:
(a) protecting their ability to prescribe any natural/non-prescription substance that is within their training (without the use of lists of nonprescription substances, which will undoubtedly restrict naturopathic practice in the near and distant future) – please request that the Ministry dismiss the request for restrictive lists on the non-prescription substances that we recommend to our patients. It will be terribly restrictive to naturopathic practice from the day after the regulations become law. I suggest using categories of substances (if at all) – as an example, the Natural Health Products Regulations define non-prescription self-care substances by classes, e.g. whole or part of a plant, fungus or non-human animal material or extract thereof; an isolate or synthetic duplicate of a substance found in the latter category; a homeopathic medicine, etc. etc.
(b) respecting the general regulatory clause that allows practitioners to work only within the scope of their training and ability according to their own professional judgement, without having to have specific certifications for parenteral or other therapies. NDs have the appropriate professional judgement and adherence to the oath of “first, do no harm” to know whether and when to use a certain treatment or practice a certain modality with their patients.
(c) providing for the use of basic primary care drugs like antibiotics and birth control for NDs who take the appropriate pharmaceutical upgrade training, as those with identical training as Ontario NDs have upgraded in B.C. The ability to receive a prescription for a required pharmaceutical from the patient’s ND will not only allow for more complete patient care but could alleviate hundreds to thousands of MD. Nurse Practitioner and emergency room visits annually for these basic drugs. We would only have to follow B.C.’s template to implement this type of approach. At the same time, providing for the ability to prescribe basic primary care drugs need not mandate those Ontario NDs who do not wish to undertake this aspect to do so.
2. I would also recommend removing the requirement for NDs to indicate “Naturopathic Doctor”, “ND” or equivalent after every instance of their name when preceded by “Dr” as this will become cumbersome and redundant in any written or audio materials which include one’s name more than once. The “threat of breaking the law” or “professional misconduct” charges when the qualifier is not placed after one’s name is truly unfair. The argument that an ND could misrepresent themselves as another type of doctor is truly patronizing to our profession as well as to the public, who do not appear to be confused by the use of the title “doctor” for PhDs, veterinarians, dentists, etc. Other professions do not have to use such a qualifier and a legal requirement to do so is demeaning to naturopathic doctors, is unreasonable and quite unnecessary.
3. I suggest the removal of the requirement to qualify “inactive” ND’s as such – members of other professions do not have to do this and it is demeaning to our elders or those on maternity leave, etc.-the quality assurance approach proposed in the regulations does not appear to be affordable, sustainable or necessary and could instead be approached through the existing types of mechanisms – when a complaint is made to the College against an ND, an investigation is then performed. There is no need to increase the administrative and financial burden on NDs as a whole through adversarial practice assessment. Third-party or College practice assessment only needs to occur if problems or concerns are identified by a complaint from the public or fellow professional.
4. I suggest the removal of provision 29 that prohibits the use of internet marketing/testimonials, as this is outdated in today’s world and to a large extent outside of an ND’s control e.g. if a patient remarks on a social media platform about the good work of his or her ND, the ND risking professional misconduct charges is absolutely inappropriate. Further, NDs should be allowed to use tasteful testimonials if desired – without paying patients or otherwise compromising integrity or doctor-patient relationships, of course-I suggest that we remove restrictions on delegation to other NDs, ND students and other professionals. For practice efficiency and quality of patient care, NDs who practice parenteral therapy or administer B12 injections must have the ability to delegate this task to a registered nurse or other professional with this controlled act within their scope.
5. I would like to see the terminology “naturopathic doctor” be the preferred way to refer to our professional designation in the regulations, rather than “naturopath”, which is less professional and credible in the views of the public and other health professionals. Title protection should be for “Naturopathic Doctor” or its alternate terminology and our college would be more aptly named, “College of Naturopathic Doctors of Ontario”.As Premier McGuinty has recommitted his support for NDs to work to their full scope of practice in the province of Ontario, I suggest requesting an appropriate extension beyond January 1, 2012 from the Ministry of Health in order to allow the Transitional Council to adequately review the feedback on these draft regulations, make the necessary revisions to ensure the Naturopathy Act becomes a robust and comprehensive piece of legislation that protects the naturopathic doctor’s scope of practice, protects the safety of the public and allows Ontarians to receive the best possible naturopathic health care today and for generations to come.
Thank you again for your hard work and service in drafting these regulations, and I so look forward to the robust, comprehensive and modern legislation that will take the practice of naturopathic medicine in Ontario into the future.
Elizabeth Cherevaty ND