Here we go again. A naturopathic licensure bill stealthily passes the Michigan Senate

In a way, I have to hand it to naturopaths. Grudgingly, I have to give them respect. No, I don’t mean I respect them for their medicine. That is, always has been, and always will be quackery. Rather, I have to admire their persistence. They have a goal, which is to have laws licensing naturopaths in all 50 states by 2025, up from the current 20 states plus Washington, DC and Puerto Rico and the Virgin Islands today. Yes, it’s an ambitious goal, to achieve licensure in 30 more states in only seven years. What worries me is that they might very well come close to achieving this goal. Why? Relentlessness.

If there’s one thing that naturopaths possess, at least organized naturopathy like the American Association of Naturopathic Physicians (AANP), it’s utter relentlessness and single-mindedness. That’s what why it’s hard not to grant a grudging respect to them. No matter how many times they fail to achieve naturopathic licensure in any given state, they always come back and try again. Always. In that way, they are like The Terminator. They can’t be reasoned with. They don’t feel pity, remorse, or fear. And it absolutely will not stop, ever, until you are dead. Oh, wait. Until science-based medicine is dead in all 50 states.

Let me use my own state as an example. The first time I took note of the efforts of naturopaths to be licensed in Michigan, led by the AANP and the Michigan Association of Naturopathic Physicians (MANP) was in 2013. Then, a bill to license naturopaths was introduced. Fortunately, it failed. Then, in 2016, naturopaths tried again, bolstered with funding from the supplement industry. That effort failed, too, fortunately.

Then, yesterday, I learned that there is another effort underway. It’s been very stealthy in that I’ve heard very little about it. I had heard that there was yet another bill to license naturopaths being considered, but it seemed just like any other of the many bills that had come and gone before. There was nothing special about it. Fortunately, I’m on the MANP mailing list, and I learned this from it:

The Michigan Association of Naturopathic Physicians is thrilled to announce that our bill, Senate Bill 826, was heard on the Senate floor on Thursday, May 17th and passed with a majority vote of 24 to 10 and 1 absention!

Next step is on to the House of Representatives! Our association is still waiting to hear on a bill number and to which committee the bill will be heard in. We will be sure to pass on that information as soon as we know and will once again ask for your help in contacting your local House Representatives in support of our bill!

This is a HUGE step in our efforts to gain licensure for Naturopathic Physicians in Michigan and we are incredibly grateful for all of the continued support!

Please pass on the wonderful news. We are also continuing to ask for donations to continue our important relationship with our lobbyist. Details on how you can help are below.

Wait, what? How did this happen without my having been more aware of it? After all, Naturocrit noted that this bill was a stealth naturopathic licensure bill, and he noted it over a month ago. This bill had been reported a month and a half ago. This bill was introduced by Senator Rick Jones. He’s a Republican from Eaton County, which is a county in central Michigan that encompasses some of Lansing’s western suburbs. Oddly enough, what I could find out about Sen. Jones was not a lot, and it didn’t include any mentions of alternative medicine other than his sponsoring of this bill. Oddly enough, he doesn’t seem to be a fan of medical marijuana, touting his experience as Sheriff of Eaton County.

Basically, Sen. Jones’ bill would amend the public health code, specifically sections 16265 and 17708 (MCL 333.16265 and 333.17708), section 17708 as amended by 2016 PA 499, and by adding section 16348a and part 186, to add a section allowing the licensure of naturopaths:

THE DEPARTMENT SHALL ANNUALLY ESTABLISH A SCHEDULE OF FEES FOR AN INDIVIDUAL LICENSED OR SEEKING A LICENSE AS A NATUROPATHIC PHYSICIAN UNDER PART 186 TO OFFSET THE DEPARTMENT’S ADMINISTRATIVE EXPENSES UNDER THAT PART.

So what is S.B. 826? Basically, it gives naturopaths everything they want, but stealthily. Here’s what the bill says:

SEC. 18615. A NATUROPATHIC PHYSICIAN MAY DO ANY OF THE FOLLOWING, CONSISTENT WITH HIS OR HER NATUROPATHIC EDUCATION AND TRAINING:

(A) ORDER AND PERFORM PHYSICAL AND LABORATORY EXAMINATIONS FOR DIAGNOSTIC PURPOSES, INCLUDING, BUT NOT LIMITED TO, PHLEBOTOMY, CLINICAL LABORATORY TESTS, ORIFICIAL EXAMINATIONS, OR PHYSIOLOGICAL FUNCTION TESTS.

(B) ORDER DIAGNOSTIC IMAGING STUDIES.

(C) SUBJECT TO SECTION 18617, DISPENSE, ADMINISTER, ORDER, OR PRESCRIBE OR PERFORM ANY OF THE FOLLOWING:

(i) FOOD, EXTRACTS OF FOOD, NUTRACEUTICALS, VITAMINS, AMINO ACIDS, MINERALS, ENZYMES, BOTANICALS AND THEIR EXTRACTS, BOTANICAL MEDICINES, HOMEOPATHIC MEDICINES, ALL DIETARY SUPPLEMENTS, OR NONPRESCRIPTION DRUGS AS DEFINED BY THE FEDERAL FOOD, DRUG, AND COSMETIC ACT, 21 USC 301 TO 399H.

(ii) PRESCRIPTION OR NONPRESCRIPTION DRUGS AS DESIGNATED BY THE BOARD.

(iii) HOT OR COLD HYDROTHERAPY, NATUROPATHIC PHYSICAL MEDICINE, ELECTROMAGNETIC ENERGY, OR THERAPEUTIC EXERCISE.

(iv) DEVICES, INCLUDING, BUT NOT LIMITED TO, THERAPEUTIC DEVICES, BARRIER CONTRACEPTION, OR DURABLE MEDICAL EQUIPMENT.

(v) HEALTH EDUCATION OR HEALTH COUNSELING.

(vi) REPAIR AND CARE INCIDENTAL TO SUPERFICIAL LACERATIONS OR ABRASIONS.

(vii) NATUROPATHIC MUSCULOSKELETAL MOBILIZATION.

(D) UTILIZE ROUTES OF ADMINISTRATION THAT INCLUDE, BUT ARE NOT LIMITED TO, ORAL, NASAL, AURICULAR, OCULAR, RECTAL, VAGINAL, TRANSDERMAL, INTRADERMAL, SUBCUTANEOUS, INTRAVENOUS, OR INTRAMUSCULAR CONSISTENT WITH HIS OR HER NATUROPATHIC EDUCATION AND TRAINING.

(E) OTHER NATUROPATHIC THERAPIES AS APPROVED BY THE BOARD.

So let’s unpack this. First, I can’t believe that the Michigan legislature would even consider granting naturopaths practice authority. Note in the text above how the bill would specifically grant naturopaths the power to prescribe “homeopathic medicines” (i.e., The One Quackery To Rule Them All). This is because, as I have said so many times before, you can’t have naturopathy without homeopathy. Homeopathy is an integral part of naturopathy.

This law, if actually passed, would allow naturopathic quacks (but I repeat myself) to do physical exams and order whatever laboratory tests that a naturopath would consider appropriate. It would even allow naturopaths to repair lacerations, presumably with stitches. It would also allow naturopaths to order whatever “food extracts” that they view as appropriate. Of course, if naturopaths view a treatment as appropriate, you can bet that it’s highly likely that that treatment is quackery based on pseudoscience. In fairness, there are some limitations:

SEC. 18617. A NATUROPATHIC PHYSICIAN SHALL NOT DO ANY OF THE FOLLOWING:

(A) PRESCRIBE, DISPENSE, OR ADMINISTER ANY CONTROLLED SUBSTANCE OR DEVICE IDENTIFIED IN THE FEDERAL CONTROLLED SUBSTANCES ACT, 21 USC 801 TO 971.

(B) PRESCRIBE, DISPENSE, OR ADMINISTER A PRESCRIPTION DRUG OR DEVICE UNLESS THE PRESCRIPTION DRUG OR DEVICE IS INCLUDED IN THE NATUROPATHIC FORMULARY ESTABLISHED UNDER SECTION 18623.

(C) PERFORM NATUROPATHIC MUSCULOSKELETAL MOBILIZATION INVOLVING HIGH-VELOCITY, LOW-AMPLITUDE MOBILIZATION AT OR BEYOND THE END RANGE OF NORMAL JOINT MOTION, UNLESS HE OR SHE MEETS THE REQUIREMENTS TO PERFORM HIGH-VELOCITY, LOW-AMPLITUDE MOBILIZATION AS ESTABLISHED BY THE BOARD BY RULE.

(D) PERFORM SURGICAL PROCEDURES EXCEPT, SUBJECT TO SECTION 18623(F), MINOR OFFICE PROCEDURES.

(E) ENGAGE IN THE PRACTICE OF OR CLAIM TO ENGAGE IN THE PRACTICE OF ANY OTHER HEALTH PROFESSION, INCLUDING, BUT NOT LIMITED TO, PERFORMING CHIROPRACTIC ADJUSTMENTS, UNLESS HE OR SHE IS LICENSED TO ENGAGE IN THAT HEALTH PROFESSION UNDER THIS ARTICLE.

(F) USE GENERAL OR SPINAL ANESTHETICS.

(G) ADMINISTER IONIZING RADIOACTIVE SUBSTANCES FOR THERAPEUTIC PURPOSES.

(H) PERFORM SURGICAL PROCEDURES USING A LASER DEVICE.

(I) PERFORM SURGICAL PROCEDURES INVOLVING THE EYE, EAR, TENDONS, NERVES, VEINS, OR ARTERIES.

Imagine my relief that, at least, this bill won’t let naturopaths use a laser or radioactive substances or prescribe controlled substances. I was curious about the part about “naturopathic musculoskeletal manipulation.” That struck me as a bit of turf protection for chiropractors, although naturopaths do have a history of using manipulation similar to that used by chiropractors. Indeed, the AANP published a position paper on manipulative therapy in which “naturopathic manipulation” is described as a “traditional, integral and essential part of naturopathic medical practice, is a distinct and unique manipulative technique.”

But how is naturopathy defined? What are the requirements to be licensed? The bill defines “naturopathic medicine” as a “system of practice that is based on the natural healing capacity of individuals for the diagnosis, treatment, and prevention of diseases.” In other words, it’s the usual meaningless description. After all, conventional medicine relies on the “natural healing capacity of individuals” as well. For instance, each and every time I as a surgeon make an incision or remove a cancer, I rely on the natural healing capacity of the body to heal that incision.

But what about naturopathic “education”? How is it defined? What sort of school is considered acceptable? The bill states:

SEC. 18603. (1) “APPROVED NATUROPATHIC MEDICAL PROGRAM” MEANS ANY OF THE FOLLOWING:

(A) A NATUROPATHIC MEDICAL EDUCATION PROGRAM THAT IS LOCATED IN THE UNITED STATES, THAT PROVIDES THE DEGREE OF DOCTOR OF NATUROPATHY OR DOCTOR OF NATUROPATHIC MEDICINE, AND THAT MEETS ALL OF THE FOLLOWING REQUIREMENTS:

(i) OFFERS GRADUATE-LEVEL FULL-TIME DIDACTIC AND SUPERVISED CLINICAL TRAINING.

(ii) IS ACCREDITED OR HAS ACHIEVED CANDIDACY STATUS FOR ACCREDITATION BY A FEDERALLY RECOGNIZED ACCREDITING BODY FOR NATUROPATHIC MEDICAL PROGRAMS APPROVED BY THE BOARD.

(iii) IS AN INSTITUTION OR PART OF AN INSTITUTION OF HIGHER EDUCATION THAT IS ACCREDITED OR IS A CANDIDATE FOR ACCREDITATION BY A REGIONAL OR NATIONAL INSTITUTIONAL ACCREDITING AGENCY RECOGNIZED BY THE UNITED STATES SECRETARY OF EDUCATION.

(B) A NATUROPATHIC MEDICAL EDUCATION PROGRAM OFFERED BY A DEGREE-GRANTING COLLEGE OR UNIVERSITY THAT MEETS ALL OF THE FOLLOWING REQUIREMENTS:

(i) OFFERED A FULL-TIME STRUCTURED CURRICULUM IN BASIC SCIENCES AND SUPERVISED PATIENT CARE COMPRISING A DOCTORAL NATUROPATHIC MEDICAL EDUCATION.

(ii) WAS AT LEAST 132 WEEKS IN DURATION AND REQUIRED COMPLETION OF THE PROGRAM WITHIN A PERIOD OF AT LEAST 35 MONTHS AS A PREREQUISITE TO GRADUATION.

(iii) WAS OFFERED BY A COLLEGE OR UNIVERSITY THAT WAS REPUTABLE AND IN GOOD STANDING IN THE JUDGMENT OF THE BOARD.

(iv) IF THE PROGRAM IS STILL OFFERED, IT IS ACCREDITED BY A FEDERALLY RECOGNIZED ACCREDITING BODY FOR NATUROPATHIC MEDICAL PROGRAMS APPROVED BY THE BOARD.

(C) A NATUROPATHIC MEDICAL EDUCATION PROGRAM OFFERED BY A DIPLOMA-GRANTING, DEGREE-EQUIVALENT COLLEGE OR UNIVERSITY LOCATED IN CANADA THAT MEETS ALL OF THE FOLLOWING REQUIREMENTS:

(i) WAS OFFERED BY A COLLEGE OR UNIVERSITY THAT HAD PROVINCIAL APPROVAL FOR PARTICIPATION IN GOVERNMENT-FUNDED STUDENT AID PROGRAMS.

(ii) OFFERED A FULL-TIME STRUCTURED CURRICULUM IN BASIC SCIENCES AND SUPERVISED PATIENT CARE COMPRISING A DOCTORAL NATUROPATHIC MEDICAL EDUCATION.

(iii) WAS AT LEAST 132 WEEKS IN DURATION AND REQUIRED COMPLETION OF THE PROGRAM WITHIN A PERIOD OF AT LEAST 35 MONTHS AS A PREREQUISITE TO GRADUATION.

(iv) WAS OFFERED BY A COLLEGE OR UNIVERSITY THAT WAS REPUTABLE AND IN GOOD STANDING IN THE JUDGMENT OF THE BOARD.

(v) IF THE PROGRAM IS STILL OFFERED, IT IS ACCREDITED BY A FEDERALLY RECOGNIZED ACCREDITING BODY FOR NATUROPATHIC MEDICAL PROGRAMS APPROVED BY THE BOARD.

(vi) IF THE PROGRAM IS STILL OFFERED, THE COLLEGE OR UNIVERSITY HAS PROVINCIAL APPROVAL FOR PARTICIPATION IN GOVERNMENT- FUNDED STUDENT AID PROGRAMS.

(D) A NATUROPATHIC MEDICAL EDUCATION PROGRAM OFFERED BY A DIPLOMA-GRANTING, DEGREE-EQUIVALENT COLLEGE OR UNIVERSITY LOCATED IN CANADA THAT PROVIDES THE DEGREE OF DOCTOR OF NATUROPATHY OR DOCTOR OF NATUROPATHIC MEDICINE AND THAT MEETS ALL OF THE FOLLOWING REQUIREMENTS:

(i) OFFERS GRADUATE-LEVEL FULL-TIME DIDACTIC AND SUPERVISED CLINICAL TRAINING.

(ii) IS ACCREDITED OR HAS ACHIEVED CANDIDACY STATUS FOR ACCREDITATION BY A FEDERALLY RECOGNIZED ACCREDITING BODY FOR NATUROPATHIC MEDICAL PROGRAMS APPROVED BY THE BOARD.

(iii) IS OFFERED BY A COLLEGE OR UNIVERSITY THAT HAS PROVINCIAL APPROVAL FOR PARTICIPATION IN GOVERNMENT-FUNDED STUDENT AID PROGRAMS.

I realize that this text was rather repetitive, but basically this provision provides a fairly wide range of naturopathy schools whose degrees will be acceptable in Michigan, specifically schools in the US, Canada, or elsewhere that meet the above requirements. Of course, the bill also includes a provision requiring that naturopaths pass a “competency-based national naturopathic physicians licensing examination administered by an agency that is nationally recognized to administer a naturopathic physicians licensing examination that represents federal standards of education and training that is approved by the board.”

Of course, that brings us to this new board that the bill would create to regulate the practice of naturopathy in Michigan. The bill requires that the board have eleven members, including six naturopaths, one physician, one pharmacist, one chiropractor, and two public members. I’m guessing that the inclusion of one physician was a sop to those who question the scientific basis of naturopathy, but I ask myself: What sort of physician would agree to serve on this new board—or would even be asked to serve. Surely no one would be likely to invite me to be on this board. No, most likely any physician acceptable to the board would be at least woo-friendly, if not an “integrative medicine” doctor himself embracing much of the pseudoscience and quackery in naturopathy.

Fortunately, at least one medical group opposes S.B. 826. The Michigan Academy of Family Physicians released a statement opposing naturopathic licensure, noting:

  • There is a lack of scientific evidence that naturopathy is effective.
  • Naturopathic teaching claims that natural herbal remedies are generally superior to pharmaceuticals in the treatment of most diseases, yet the federal Food and Drug Administration (FDA) forbids manufacturers of herbal preparations and dietary supplements from making therapeutic claims.
  • The bill allows naturopaths to perform “minor office procedures.” Naturopaths should not be engaging in such procedures, however minor they may be. Naturopaths have no training in the care of hospitalized patients and are not familiar with the clinical manifestations of diseases serious enough to require hospital care.
  • Compared to medical school and residency training, a naturopathic education consists of relatively few hours of study on pharmacological treatment of disease and provides virtually no clinical reinforcement of pharmaceutical intervention on patients during clinical rotations or optional post-graduate training.
  • Naturopathic practitioners might fail to diagnose in a timely fashion or delay referring patients for appropriate medical treatment, endangering the health and safety of patients with serious diseases who are relying solely on care from naturopathic practitioners.
  • Naturopathic treatments may divert patients away from proven evidence-based medical therapies.
  • An injection of any kind, even something as seemingly benign as vitamin B-12, comes with risks. Crohn’s disease, pancreatic insufficiency, autoimmune atrophic gastritis, and certain prescription medications—as well as other treatable diseases that cause persistent pernicious anemia—can only be treated by non-naturopaths.
  • Even some naturopathic associations are divided over the administration of injectable medications. The American Association of Naturopathic Physicians and the American Naturopathic Medical Association, two naturopathic organizations, are divided over this and other issues of naturopathic medicine.
  • Naturopathic services are not covered by Medicare or most insurance policies.

Yes, all of this is true, and the new naturopathic board, if formed, would be free to include on the new naturopathic formulary basically any “injectable” that naturopaths routinely use, such as high dose vitamin C. The MAFP is basically urging its members to call their Representatives, noting that ” that SB 826 is a threat to patient safety and should be voted down when it comes up for a vote in committee and on the House floor.” I couldn’t agree more. Unfortunately, I can’t see the MAFP’s talking points because I’m not a family physician, and to see them requires a log in. This is a mistake on the MAFP’s part. It should let any physician (or, indeed, anyone who wants to call his or her Representative to oppose SB 826) to see those talking points. Heck, I’d even go so far as to offer my services to MAFP regarding its opposition to naturopathy, as I would be willing to bet that I know more about naturopathy and its dangers than pretty much anyone in the MAFP (and if I don’t, I want to meet the person in the MAFP whose knowledge surpasses mine).

Unfortunately, S.B. 826 represents more progress in Michigan than naturopaths have ever made before. They’ve never gotten a naturopathic licensing bill voted on by the full Senate or House before, much less passed in a chamber. I fear that my state is perilously close to joining the other 20 states that license naturopaths and thus legitimize quackery as a state-sanctioned, state-regulated medical “specialty.” Make no mistake, naturopathy is a cornucopia of quackery, and the last thing I want to see in medicine in my state is the licensing of quacks. We already license chiropractors, and that’s bad enough.