September 28, 2004
Senator Andrew J. McDonald, Chairman
Connecticut General Assembly
Public Health Committee
Legislative Office Building, Room 3100
Hartford, CT 06106-1591
Re: Address of unlawful disciplinary actions taken against traditional naturopaths for
using the title N.D. and for practicing unlicensed in the professional discipline of
Naturopathy.
1 Please be aware that our scope of practice, which is traditional naturopathy, is different
2 from the scope of practice of conventional naturopathy. Currently several states regulate
3 the practice of conventional naturopathy while most states do not regulate either discipline.
4 Traditional naturopathy is an unregulated profession, subsequently, traditional naturopaths
5 are exempt from state licensure by federal regulations.
6 According to U. S. regulations, licensure regulates a profession. “The competent authority
7 for persons seeking to work in the United States in regulated occupations is the licensing
8 authority at the appropriate state or territorial level that monitors that occupation.”
9 (www.ed.gov U. S. Dept of Education. Competent Authority 06/16/04)
10 Traditional naturopathy is unregulated because no state license is offered to practice this
11 profession. “The competent authority for the recognition of qualifications presented by
12 persons seeking to work in the United States in unregulated occupations, is the hiring
13 employer.” and not the state. (www.ed.gov U. S. Dept. of Education. Competent
14 Authority 06/16/04)
15 According to the U. S. Department of Education “Degree, diploma, and credit recognition is
16 not performed or regulated by the federal government. Recognition is not usually done by
17 state or local governments, either, except in the case of professional licensure.”
18 (www.ed.gov U.S. Dept. of Education. Foreign diploma and credit recognition 06/17/04)
19 Traditional naturopathy is excluded from state licensure therefore; the professional discipline
20 of traditional naturopathy remains an unregulated profession. In light of this, I have
21 established the Naturopathic National Council Inc. to license and regulate the professional
22 discipline of traditional naturopathy.
Sincerely,
Beverly Betancur, N.D.
Chief Executive Officer
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