September 28, 2004
Senator Andrew McDonald:
General Assembly Public Health Committee
Legislative Office Building, Room 2500
Hartford, CT 06106-1591
Dear Senator McDonald:
Re: Request for Amendment of State Statutes on Naturopathy
1 Traditional naturopaths represented by the Naturopathic National Council Inc.
2 hereby submit this document for the purpose of obtaining an amendment to the
3 statutes on Naturopathy.
4 Sanctioned by national regulations to exercise delegated power and authority, the
5 Naturopathic National Council Inc. officially sets the standards and scope of practice
13 The General Assembly has violated the eminent rights of traditional naturopaths and
14 made laws that are in conflict with national law to disparage traditional naturopaths
15 and violate their right to work and use their doctoral designation.
16 Traditional naturopathy is an unregulated profession and “The competent authority
17 for the recognition of qualifications presented by persons seeking to work in the
18 United States, in unregulated occupations, is the hiring employer.” and not the
19 state. (www.ed.gov U. S. Dept. of Education. Competent Authority 06/16/04)
20 Traditional naturopathy is an unregulated profession; and federal statutes have
21 prohibited the state to be the competent authority for the recognition of the
22 qualifications of persons in unregulated occupations. Nevertheless, the state has
23 made itself the competent authority to decide whether or not traditional
24 naturopaths can use their doctoral designation without regulating the profession.
25 According to the U. S. Department of Education “Degree, diploma, and credit
26 recognition is not performed or regulated by the federal government. Recognition is
27 not usually done by state or local governments, either, except in the case of
28 professional licensure.” (www.ed.gov U. S. Dept of Education. Foreign diploma and
29 credit recognition 06/17/04)
30 According to the Tenth Amendment to the Constitution, the states cannot establish
31 laws that are prohibited to it by federal statutes. Nevertheless, the states are violating
32 the constitutional rights of traditional naturopaths by establishing laws that are
33 prohibited to it by federal statutes. In the hierarchy of laws, “The United States
34 Constitution is the supreme law of the United States. Federal and State laws which
35 violate the Constitution are said to be unconstitutional and may be struck down by
36 judicial review of the Supreme Court.” American Laws and the American Legal
37 System 7/14/04) (http://www.vidaamericana.com/english/uslaws.html)
38 Current statutes have eliminated our scope of practice because of refusal to
39 acknowledge our body of knowledge as legitimate. The vast knowledge of
40 traditional naturopaths has been considered of substandard quality because it has
41 been acquired through independent studies and not in the conventional setting of a
42 classroom, despite the fact that the highest earned degree is from independent
43 studies. According to the U.S. Department of Education “The research doctorate is
44 the highest earned academic degree in U. S. postsecondary education. It is always
45 awarded for independent research at the professional level in either academic
46 disciplines or professional fields. Research doctorates are not awarded merely for
47 completing coursework, professional preparation, or for passing examinations.”
48 (www.ed.gov U.S. Dept. of Education. Research Doctorate Programs 7/18/04)
49 Traditional naturopathy has been judged in the arena of conventional medical science
50 instead of through the optic of its own merits as the art and science of preventative
51 medicine. I expect that you will peruse the accompanying documents and conclude
52 that in order for laws to impart justice they must be inclusive of everyone. The
53 unconstitutionality of the current statutes demands an immediate amendment as
54 follows:
55 Notwithstanding the requirements of the State’s General Statutes on
56 naturopathy no state license is required for insurers to credential traditional
57 naturopaths, who are legally licensed by the Naturopathic National Council Inc.
58 to practice traditional naturopathy and use their doctoral designation according
59 to the standards and scope of practice as set forth by the Naturopathic
60 National Council.
61 Be advised, our request for an amendment of the current statutes on naturopathy does
62 not constitute a request for permission to implement the licensing regulations of
63 traditional naturopaths by the Naturopathic National Council Inc. The rights of
64 traditional naturopaths are rights secured by law as exhaustively shown in these
65 documents; therefore, the Naturopathic National Council will exercise its legal right to
66 begin licensing traditional naturopaths on November 30, 2004.
Thank you for your sincere cooperation.
Beverly Betancur, N.D.
Chief Executive Officer
Cc: Legislatures, Licensing Boards, Attorney Generals and Governors.
