I’m in the process of writing a post that gives more background for the letter below. But as a TL;DR: the board of naturopathy has mandated Washington state naturopathic doctors to take a minimum of one-third of all continuing education hours from naturopathic accrediting organizations, whose CE includes courses that:
- Appear to violate federal and state prohibitions on promoting unapproved therapies to prevent, manage and treat COVID-19.
- Oppose vaccination, in general and for COVID-19 and instead advocate homeopathy for the prevention of infectious disease.
- Oppose public-health measures such as masking.
- Promote therapies and diagnostic tools that are not grounded in science and evidence.
While some of the approved CE providers include courses that are reasonably evidence based and address primary care concerns, many of the providers, and a good chunk of the courses, do not.
The board argues that the restriction to approved naturopathic organizations as CE providers applies “only” to 1/3 of the required continuing education hours and thus should not be a concern. However, the feedback from NDs in Washington state has been that the cost and time for these “naturopathic focused” CE will displace money and time better devoted to CE from evidence-based sources such as the Accreditation Council on Continuing Medical Education.
(These are not the only concerns with this particular aspect of the new continuing education rules, but these are some of the most urgent.)
The following is the text of the letter as it was sent to the Board of Naturopathy of the state of Washington
To: The Board of Naturopathy of Washington State
Subject: Regarding item 2.1.3 on the Agenda for August 12, 2022 Board of Naturopathy meeting, WAC 246-836-080
Summary:
- The providers approved for category 1 offer CE that contradict DOH’s own guidelines regarding the prevention and treatment of COVID-19, and do not require substantiation of effectiveness and safety of protocols discussed.
- Some of the CE may be in violation of state and federal guidelines regarding offering unapproved methods to prevent, manage and treat COVID-19.
- Much of the CE focuses on specialized conditions and narrow testing and therapeutic options, rather than the broader category of conditions and therapeutics that WA state NDs routinely encounter as part of primary care.
- Additionally much of the CE is underwritten by commercial interests.
- The board’s mandate, as noted on its own page, is to preserve public health and safety, notphilosophical purity or unspecified principles of naturopathic medicine.
- The increased amount of CE is certainly appropriate, as is the decision to regulate who CE maybe taken from.
- It is still unclear why the board did not allow Oregon CE approved by the Oregon NaturopathicBoard if the board had not evaluated Oregon’s criteria for approving CE, prior to first issuing therules in 2019.
- Board members have not disclosed nor discussed possible conflicts of interest.
Details:
Further concerns re the decision to restrict category 1 to continuing education offered through the WANP, AANP, FNMRA, and the schools:
- The Washington State Board of Naturopathy’s mandate is to “protect the public’s health and safety and to promote the welfare of the state by regulating the competency and quality of naturopathic physicians.”
- So far, the criteria published by the AANP and FNMRA that I have been able to examine, do not appear to include a requirement that the material be supported by scientific evidence as understood by the consensus of the scientific and medical communities. The WANP’s criteria for approving CE are not available.
- At least two CE offered through at least two of the approved CE providers appear to be in violation of both national and state guidelines regarding COVID prevention and treatments that the FDA has not found sufficiently supported by evidence:
- The AANP’s 2022 convention featured a course on “Homeopathic Management of Covid and Long-Covid” The presenter has offered courses in the past claiming that homeopathy can be used to prevent pandemic illnesses.
- And Medicine Talk Pro’s course on “Vaccinosis – A Naturopathic Approach”
- See: https://www.fda.gov/consumers/consumer-updates/beware-fraudulent-coronavirus-tests-vaccines-and-treatments and see https://www.atg.wa.gov/news/news-releases/ag-ferguson-wins-500000-individuals-impacted-us-stemology-s-unproven-claims-its for an recent Washington state case.
- Naturopathic Medicine Institute has a history offered material that is anti-vaccine. During the pandemic they also offered a non-CE course which argued against the use of vaccines, mandates, and promoted non-proven COVID-19 treatments. This can still be seen at https://nmipublicforum.com/corona-sales-info and a sample of their viewpoints is here at https://nmipublicforum.com/ppv/cv-breaking-news.
- While not offered for CE, if this is what they are selling to the public, what are they teaching providers?
- These materials directly contradict WA DOH guidelines for COVID-19 prevention, management and treatment.
As well:
- A survey of courses through AANP showed that all active CE were sponsored by commercial vendors;
- FNMRA is to be commended for their rigor, but it is noteworthy that a requirement for scientific evidence is missing from their criteria.
- While efforts to add more primary-care relevant CE by the three category 1 providers are appreciated, the courses in general tend to focus on specialty diagnoses, testing, and treatment options. Three of FNMRA’s providers focus on homeopathy.
- Certainly the addition of the NAPCP (Naturopathic Academy of Primary Care Physicians) is welcome, as is Dr. Journal Club. I have not had a chance to investigate CCNM’s offerings.
Given the current scope of Washington state NDs with regards to medications, Medicaid, and primary care scope, the board should do the following:
- Publicly document the naturopathic principles it wants vendors to substantiate, and publicly document which “allopathic doctrines” it is concerned are eroding the profession’s uniqueness.
- Publicly document how requiring NDs to take courses that “substantiate” naturopathic principles (as opposed to objectively evaluating naturopathic principles and treatments) will impact public health and safety.
- If the principles referred to are these (https://aanmc.org/6-principles/), the board should publicly document where it believes non-ND sources do not allegedly incorporate these principles. With regards to this, the board should see this article by Jacob Schor in NDNR (https://ndnr.com/geriatrics/practicing-rational-medicine/) on the non-uniqueness of the AANP’s “six principles of naturopathic medicine”
- Publicly document how directing NDs to take CE solely from CE approved by current category-1 accreditors will impact public safety and health, as well as impact the competency of NDs to fulfill their scope as primary care providers in WA state.
- This should look at primary care as defined by medicine at large, including insurers: being responsible for the overall care of that individual, including post-hospital discharge for grave trauma and illness.
- This should include the impact on public health and safety of directing individual ND’s CE dollars and time towards courses in homeopathy and prayer away from other, more evidence-based CE providers such as UW Medicine, Kaiser Permanente and Swedish.
- At 1600+ NDs licensed in Washington state, times 10 CE credits per ND per year, that is 16,000 CE hours that must now be taken through WANP, AANP, and groups accredited by FNMRA.
- The board should publicly document its original rationale in the 2019 rules for excluding CE approved by naturopathic boards of other states and provinces in the US and Canada. As noted, it appears it did not evaluate the criteria of other states and provinces prior to a request to include CE from other states and provinces.Therefore, the argument made by the board regarding an alleged lack of concern for naturopathic principles, on the part of other naturopathic board CE approval criteria, cannot have been the original reason for the exclusion.
- Finally, board members should disclose all potential and actual conflicts of interest in this matter, including roles and positions held in other organizations that may benefit through having CE dollars directed towards them.
I remain interested in this issue because continuing education is how the naturopathic profession improves its skills, knowledge, and competency.
Disclosures: I do not have a financial interest in any entities providing continuing education to the naturopathic medical community, in Washington or any other state.
Sincerely,
Les (Lesley) H. Witherspoon ND (inactive) Seattle, WA
August 10, 2022