WA Board of Naturopathy- April Meeting on Continuing Education

empty classroom with a large screen at the end, and rows of adult desks facing towards the front.
Photo by Ivan Aleksic on Unsplash

I did not attend the Washington state board of naturopathy meeting in February 2023, so I did not post on it. However, I did attend the board of naturopathy’s subcommittee meeting on continuing education, held on April 19, 2023. Because it has been a busy week, I am going to give an overview and summary rather than a deep dive into the details.

This was the health equity/continuing education subcommittee, comprised of Krystal Richardson ND (board vice-chair, Elias Kass ND, and public member Brooke Fotheringham. The purpose was to look at some potential courses of action the board could take on naturopathic continuing education, discuss them, and get input from the public.

The WANP (Washington Association of Naturopathic Physicians) had a number of their representatives there. The AANP (American Association of Naturopathic Physicians) sent their executive director. I know that there were a number of naturopathic doctors in on the meeting though they did not speak.

Continuing education – the board’s proposals

The agenda for the meeting is at https://doh.wa.gov/sites/default/files/2022-02/AG-NP.pdf?uid=6442b19430fc8 and the notice of the meeting can be found on the page for the board of naturopathy at https://doh.wa.gov/licenses-permits-and-certificates/professions-new-renew-or-update/naturopathic-physician/board-naturopathy.

The subcommittee’s first item was discussing the state-mandate regarding including continuing education on the subject of health equity. The second item was “Other Continuing Education Rulemaking”, with two proposals that the board wanted to look at, and get public input about.

  1. Revise the current continuing education rule for naturopathic doctors by removing the AANP (American Association of Naturopathic Physicians) and WANP (Washington Association of Naturopathic Physicians) as CE sources. The naturopathic medical schools such as Bastyr, and NANCEAC (the North American Naturopathic Continuing Education Accreditation Council) would remain as a Category 1 approved provider for continuing education.
    1. Something that was apparently left off the agenda under the first proposal, was that the board would also implement a plan to approve CE from WANP and AANP if they removed them from Category 1. 
    2. Under this plan, the AANP and WANP would submit their individual CE offerings to the board of naturopathy, which would review the course material, conflict of interest statements, and other factors, and vet it against a list of criteria. 
    3. Thus courses from AANP and WANP would still be available. They would simply need approval from the board and would no longer have blanket pre-approval. This is how the Oregon board of naturopathy operates, and has done so for many years.
    4. Oregon does not list either the AANP or its own state naturopathic association (OANP) as pre-approved sources of CE. Instead, the AANP and OANP submit their CE offerings to the Oregon naturopathic board, which checks that they meet certain criteria before approving them. So far both the AANP and the OANP appear to be doing just fine, and Oregon has plenty of CE for its NDs. In fact, there is quite a bit of CE offered in Oregon that is not available in Washington state.
  2. Adding Category 2 continuing education sources such as the ACCME (the American Council for Continuing Medical Education, the national conventional medical continuing education accreditation body) to Category 1. This would essentially combine the two categories of continuing education. 

Who accredits whom?

Both Richardson and the current naturopathic program director noted that CE from the WANP and AANP needed to be vetted. The subcommittee also noted that they were concerned about conflicts of interest in the selection of the WANP and the AANP, though the assistant attorney general stated there did not appear to be violations of the Washington ethics code involved. During the meeting Richardson, the subcommittee chair, asked if NANCEAC accredited either the WANP or AANP. The answer is no, NANCEAC does not accredit either.

A number of representatives from the WANP (Washington Association of Naturopathic Physicians) and the AANP (the American Association of Naturopathic Physicians) presented their arguments against the subcommittees proposals. Neither the AANP nor the WANP agreed with any of the subcommittees proposals. 

The AANP and WANP arguments against the board’s proposals

Up front, let me state that I know many of the people who spoke at this meeting. Speakers in the room have gone to school with me, shared patients with me, advised me, mentored me. I don’t doubt their good intentions, and they have a right to make their case.

There were a number of arguments made by the WANP, AANP, and their members. While some of them focused on the improvements they had made to naturopathic continuing education, the AANP and WANPs main arguments came down to:

  • The two proposals would deprive the WANP of revenue and would mean naturopathic doctors wouldn’t have naturopathic CE available. 
  • The AANP and WANP also argued that naturopathic doctors wouldn’t attend the AANP’s and WANP’s CE if there was competition from conventional medical continuing education sources. 
  • Plus, the AANP and WANP argued that learning about conventional medicine would dilute naturopathic identity. 
  • Also, the AANP argued that NANCEAC focuses on homeopathy and doesn’t have enough providers. 
  • And there was a hint that they (the AANP) were concerned the board wouldn’t be able to approve enough courses fast enough. 

Below are brief summaries of the main AANP and WANP arguments presented during the meeting. I’ve noted where an argument was presented solely by one organization. The counterarguments include some that were presented during the meeting. Other counterarguments were not presented at the time, especially the arguments around naturopathic identity. This is because the main purpose of the meeting was for the board to gather information.

WANP argument one: The WANP’s president, Kelsey Klausmeyer, stated that continuing education was a source of revenue for the WANP, and that this revenue allowed the WANP to advocate for the naturopathic profession. His concern was that removing the WANP as a pre-approved CE provider would reduce the WANP’s revenue and affect its ability to advance the profession. The AANP stated that CE was not a significant source of revenue for them.

Counterargument one: The continuing education rules are there to ensure public safety, not financial benefit to the WANP. The state mandates continuing competency/continuing education for healthcare providers to ensure safe practice and protect the public. The regulations are not there to provide a revenue stream for the state and national naturopathic associations, and they are certainly not there to provide revenue for those associations to lobby in Olympia and DC.

WANP argument two: The WANP’s president argued that because WANP officers are volunteers, it isn’t a conflict of interest to have the state make a rule that requires NDs to take continuing CE from the WANP (or AANP). Note the assistant attorney general at the meeting (Luke Eaton) stated he believed that there was not a conflict of interest here on the part of any of the board members, as none held offices in the WANP or AANP during their tenure on the board, and none were receiving any direct financial benefit from the rule. 

Counterargument two: The WANP and AANP certainly have organizational conflicts of interest in this matter, even if their individual officers or members do not. And while I will defer to the assistant attorney general’s statement that there was no conflict for the board members who made the rule, I will note that it’s important to avoid the appearance of a conflict of interest. In general, if someone in a position of power holds a membership in an organization that they are also actively regulating, then they are often regarded as having a potential conflict of interest and must move cautiously. 

AANP/WANP argument three:  The AANP maintained that without the AANP and WANP, NDs would be deprived of naturopathic-specific eduction, as neither NANCEAC nor the naturopathic schools are significant sources of ongoing continuing education (see next statement). The AANP also repeatedly stated that NANCEAC only accredits three continuing education (CE) providers, three of which are focused on homeopathy. 

Counterargument three: AANP and WANP would still be able to offer CE under the proposals. They would have their CE approved through the board of naturopathy. And while this would be additional work for the board, Oregon has managed it for many years, while having a similar level of naturopathic providers. And Oregon still has a thriving naturopathic continuing education scene. 

AANP/WANP argument four: The AANP and WANP objected that if the ACCME-accredited CE was placed in category 1 together with the AANP and WANP, that no one would take CE from the AANP and WANP, and that Washington state naturopathic doctors would stop learning about naturopathic medicine. Both stated that prior to the current set of rules, NDs had been going to conventional and other sources for their CE and not obtaining CE from either the AANP or the WANP.

Counterargument four: The AANP and WANP may be right that NDs stopped attending the associations’ CE once other alternatives were available. However, the state regulations on continuing competency education are not there to ensure that the AANP and WANP continue to have attendees for the CE they offer. Both the AANP and WANP should reflect on why Washington naturopathic doctors would rather go to other organizations for their continuing education. And if NDs are attending conventional CE instead of naturopathic CE, the naturopathic organizations should reflect why that might be.

AANP/WANP argument five: This is a matter of identity; naturopathic medicine will be “diluted” if conventional medical continuing education groups are placed on a par with naturopathic continuing education.

Counterargument five: the state does not regulate professional identity. As Kass noted at the meeting, the regulations state that “the job of the Board is to make rules concerning continuing competency, as it relates to the safety and welfare of the public, and not to make rules about identity, philosophy, or even the health of the profession.”

While not stated during the meeting, one response to this is that if the AANP and WANP are worried about “diluting” naturopathic identity with conventional medical therapies and procedures, why do they push to include so many of them in naturopathic scopes of practice? And when the WANP asked the board last year if vasectomies were in scope of practice for Washington naturopathic doctors, I do not recall them discussing whether performing vasectomies would “dilute” naturopathic identity. (The WANP brought this question on behalf of a member.)

However, even though it’s not a subject for state regulation, the questions about professional identity do raise some issues that the naturopathic profession needs to look at.

AANP/WANP argument six: Naturopathic doctors should be expected to learn naturopathic medicine in their continuing education, and they need naturopathic-specific CE. Without the AANP and WANP as pre-approved providers, Washington NDs won’t get that CE. 

Counterargument six:  Board members noted that CE from the WANP and AANP would continue to be available under these proposals. It would just need to be approved by the board first. The question of whether or not naturopathic doctors should be forced to take naturopathic CE, regardless of what therapies they use in practice, was not discussed at the meeting. One response is that certainly naturopathic doctors should continue to obtain education in the types of therapies they use and the conditions they see. But as many NDs have stated to the board in the last few years, they prefer to go to organizations that focus in their specific areas for that continuing education. Otherwise they end up paying for CE hours that do not apply to their practice. By their nature, the WANP and AANP are not specialty-focus organizations.

Washington state naturopathic doctors also have a broad scope of practice, including the ability to prescribe many conventional pharmaceuticals and to practice as primary care providers. This is as much a part of the practice of a naturopathic doctor as lifestyle changes or botanical medicine, and they need continuing education in these areas.

AANP argument seven: The state of Oregon is an outlier in not listing the AANP as a pre-approved source of CE.

Counterargument seven: It is true that other states (I have not checked all states that license NDs) include the AANP as a source for continuing education. However, states such as California and Arizona allow their naturopathic licensees to take their CE from a much longer list of CE providers, including conventional medical sources such as the ACCME. Neither California or Arizona require their licensees to take a fixed amount of hours solely from a short list focused primarily on their state association and the WANP. Both still seem to have active state associations and so far their licensees have not decamped for conventional medicine en masse. 

As I noted in the meeting, the broader context here is that at least for Washington state, the naturopathic profession is an outlier among healthcare professions in including state and national naturopathic associations as CE providers, let alone in mandating courses from them. The current Washington state naturopathic continuing education rule is highly unusual in not only including the state and national naturopathic associations as sources for continuing education, but in mandating that that a fixed number of CE hours must come through a list restricted to just the state organization, the national organization, the accredited naturopathic schools, and NANCEAC. Because the last two groups offer far fewer CEs, in effect the regulation makes it difficult to obtain that naturopathic CE through sources other than the AANP or WANP.

In a later article I will look at other arguments made against the board’s proposals, and look more at some of the questions raised by the arguments above.

Edited May 10, 2023 to clarify counterarguments for argument seven.

By Les Witherspoon

Formerly practicing naturopathic doctor. Views are my own and do not speak for any employers or clients, nor for the profession at large.