September 28, 2004
Senator Joseph F. Vitale, Chair
New Jersey State Legislature
Health and Human Services
State House Annex
Trenton, NJ 08625-0068
Who We Are:
1 The Naturopathic National Council Inc. is a non-profit organization incorporated under the
2 laws of the State of Connecticut, as stated in the Articles of Incorporation, the purpose
3 for which the corporation is established is for the professional licensing and regulation
4 of traditional naturopaths. The Naturopathic National Council Inc. will be governed by
5 an executive board consisting of Doctors of Naturopathy, Naturopathic Consultants, and
6 individuals of the private sector.
7 "The Dormant Commerce Clause (Article I Section 8, Clause 3) grants Congress the power to
8 regulate interstate commerce." Even when Congress chooses not to exercise such power,states
9 cannot regulate interstate commerce. Therefore states cannot adjudicate the right of the
10 Naturopathic National Council Inc. to regulate traditional naturopathy within their jurisdictions.
Our Mission:
11 To regulate the standards of traditional naturopaths through independent licensure to ensure
12 professional recognition to practice preventative medicine.
13 To continuously improve the quality of care provided to the public by providing occupational
14 licenses to traditional naturopaths, which include but are not limited to: Doctors of
15 Naturopathy, Naturopathic Nutritional Consultants and Herbalists. The Naturopathic National
16 Council will begin issuing licenses to traditional naturopaths November 30, 2004. The purpose
17 of licensure is to set the standard for traditional naturopathic health professionals to protect the
18 health and safety of the public.
What We Do:
- The Naturopathic National Council Inc. conducts administrative functions involving evaluation of
credentials for licensure of traditional naturopaths
- Provides a professional license to practice traditional naturopathy legally
- Provides a professional license for insurers to credential traditional naturopaths
- Protects the rights of naturopaths to practice traditional naturopathy
- Provides licensure to traditional naturopaths which number will be preceded by the letters
“ND-000000” to distinguish it from state issued licenses
Purpose:
19 Our purpose is to prevent conflicts between traditional naturopathy and conventional
20 naturopathy by obtaining an amendment of the current statutes. The words traditional and
21 conventional are not interchangeable. As a rule, a word is not interchangeable with another
22 word if it cannot be replaced with said word in a sentence, for example, in the following
23 sentence: The way they prepare their food is traditional of their culture. The words are not
24 interchangeable therefore they have different meanings. Our purpose is also to protect the
25 rights of traditional naturopaths by regulating the profession through licensure. State
26 governments mistakenly believe that by regulating conventional naturopaths they are also
27 regulating traditional naturopaths, not by licensure as required by U. S. regulations but by
28 exclusionary regulation. Presently, the state is not regulating the profession. Licensure will
29 protect the public by restricting unqualified people from practicing the profession.
30 National licensure gives our system structure and validates our profession; it therefore:
- Impedes state governments from implementing regulation by omission
- Relieves government of its burden and gives freedom of choice to the people
- Gives states more freedom to license conventional naturopaths
- Prevents the exercise of unreasonable treatment by the state
- Prevents traditional naturopaths from being displaced by government
- Helps to enforce and protect the freedoms of traditional naturopaths
- Defines the profession and distinguishes it from conventional naturopathy
- Gives the legal right to practice and use the traditional naturopathic doctoral designation
- Gives the public added assurance of the naturopaths’ qualifications
- Protects the health and safety of citizens
Role of National Associations According to U. S. Dept. of Education:
31 “National associations are usually, but not exclusively, non-profit membership
32 organizations that represent their constituents’ interests before government; supply
33 assistance and services to their members; and may set policy and regulate standards
34 within their areas of interest and jurisdiction. While associations are non-governmental
35 organizations (NGOs), they nevertheless exercise considerable influence in national
36 policymaking, are regularly consulted by government in their areas of expertise and
37 concern, and in some cases (as with accreditation) may exercise delegated power and
38 authority.” (www.ed.gov U. S. Dep. of Education. Competent Authority 06/17/04)
39 The Naturopathic National Council is a non-governmental legally chartered national
40 association; therefore, it may set policy and regulate standards within its area of interest and
41 jurisdiction. It may exercise delegated power and authority to issue licenses to traditional
42 naturopaths. Non-government national associations can delegate the authority of
43 accreditation, certification and licensure of unregulated professions because that authority is
44 not assumed by the state.
45 “State governments are responsible for regulating those occupations that are practiced within
46 their jurisdictions and deemed to require licensure and oversight in order to protect public
47 health, safety, and economic well being.” (www.ed.gov U. S. Dep. of Education. Regulation
48 of Professions. According to the Tenth Amendment to the Constitution of the United States,
49 “Powers not delegated to the federal government, nor prohibited by it to the states are
50 reserved to the states or the people.” In light of the tenth Amendment to the Constitution,
51 when the state fails to assume the power to regulate a profession the power is transferred to
52 the people.
53 Licensure is not the exclusive right of the state because if the state does not assume the power
54 to regulate a profession by licensure it relinquishes its right to be the competent authority to
55 regulate the standards within the unregulated profession. The authority to regulate the
56 standards of the profession is then within the jurisdiction of national associations.
57 “The paramount goal is compassionate results, and private and charitable groups, including
58 religious ones, should have the fullest opportunity permitted by law to compete on a level
59 playing field, so long as they achieve valid public purposes…The delivery of social services
60 must be results-oriented and should value the bedrock principles of pluralism,
61 nondiscrimination, evenhandedness, and neutrality”
-President George W. Bush
Accreditation in the United States
62 There is presently a misconception that the recognition of qualifications and the rights of
63 traditional naturopaths to practice and use the designation Doctor of Naturopathy (N.D.) is
64 governed by the state. According to the U. S. Department of Education the state lacks
65 jurisdiction for recognition of qualifications when a profession is unregulated. The state
66 also lacks jurisdiction over graduates of independently accredited colleges of naturopathy.
67 According to Congress, institutions of higher education are permitted to be independently
68 governed. Therefore, we have the legal right to choose independent education and
69 subsequently, the legal right to use the title obtained from that independent education to
70 practice legally according to our training and background in our respective states.
71 “The United States has no Federal Ministry of Education or other centralized authority
72 exercising single national control over postsecondary educational institutions in this country.
73 The states assume varying degrees of control over education, but, in general, institutions of
74 higher education are permitted to operate with considerable independence and autonomy.”
75 (self governed) (www.ed.gov U.S. Department of Education 1/25/04 Sec. 1099B of the
76 Higher Education Act of Congress Vol. 20 U. S. C.)
77 The state does not have centralized authority (sole control) over education. The state has
78 authority over public education in general but lacks authority over private postsecondary
79 educational institutions. Institutions of higher education are permitted by the Higher
80 Education Act of Congress to be autonomous (self-governed). This is also made evident
81 in the State System of Higher Education because there is a Board of Governors of Higher
82 Education to serve as the central policy-making authority for public higher education and
83 not for private education.
84 “Accreditation in the United States involves non-governmental entities as well as
85 governmental agencies.” (www.ed.gov U.S. Department of Education 1/25/04 Accreditation
86 in the United States. Congress here acknowledges the legal authority of non- governmental
87 accrediting agencies to confer degrees throughout the United States. Therefore, as graduates
88 of a non-government affiliated institution, we have the right in the United States to use the title
89 Doctor of Naturopathy (N.D.) and “Naturopath” which we have earned from our
90 postsecondary private educational studies.
91 The Council on Naturopathic Medical Education (CNME) is recognized by the Secretary of
92 Education; therefore, as a government-affiliated agency, it accredits the conventional
93 naturopathic institutions whose graduates are licensed in several states. The American
94 Naturopathic Medical Accreditation Board (ANMAB) is a non-government, legally chartered
95 accrediting agency. It accredits traditional naturopathic institutions whose graduates are not
96 licensed by the state. “Private institutions are chartered educational systems…which are
97 independent of state affiliation” (www.ed.gov U. S. Department of Education. Private
98 Institutions. Organization of U.S. Education, Institutional Level, Public and Private. 6/17/04
99 However, not being recognized by the Secretary does not diminish the status of private
100 accrediting agencies since “The Secretary only evaluates accrediting agencies that apply for
101 recognition…” Furthermore, being recognized by the Secretary of Education does not ensure
102 a superior quality of education since quality is not the only criteria for recognition by the
103 Secretary but also the criterion requiring a link to Federal programs. (www.ed.gov U. S.
104 Department of Education. Accreditation in the United States 1/25/04) A disadvantage of
105 attending a non-government accredited institution is that credits earned at non-government
106 accredited institutions are generally not transferable to government-accredited institutions.
107 Nevertheless, a degree earned at a non-government accredited institution is equally valid as a
108 degree earned at a government-accredited institution because “The U.S. education system
109 recognizes both public (state) and private education and makes no distinctions between them
110 as to restrictions or limitations.” (www.ed.gov U. S. Department of Education Institutional
111 Level. Public and Private Institutions 6/17/04.
Competent Authority for Recognition of Degrees:
112 “National law does not control things like the establishment of institutions, the recognition of
113 degrees and qualifications, recognition of professions, prescribed curricula or academic
114 requirements, institutional governance, or the status of students and faculty.” (www.ed.gov
115 U. S. Dept. of Education. Competent Authority 06/17/04). Although the role of the federal
116 government is limited in education it does establish the standard that the states must follow.
117 “Degree, diploma, and credit recognition is not performed or regulated by the federal
118 government. Recognition is not usually done by state or local governments, either, except in
119 the case of professional licensure.” (www.ed.gov U.S. Dept of Education. Foreign diploma
120 and credit recognition 06/17/04)
121 The federal government does not exercise control over the recognition of degrees. If the state
122 does not recognize the degree either, then it is within the jurisdiction of national associations
123 to recognize the degree. This concept parallels the concept of the Tenth Amendment to the
124 Constitution of the United States, which states “Powers not delegated to the federal
125 government, nor prohibited by it to the states are reserved to the states or the people.”
126 The state is the competent authority for recognition of qualifications for employment in
127 occupations that are monitored by state licensure according to the U.S. Department of
128 Education but the state does not have jurisdiction for recognition of qualifications of
129 individuals in unregulated professions. Nevertheless, the state, not being assigned as the
130 competent authority for the recognition of degrees of individuals in unregulated professions,
131 has usurped the authority and thus prohibits traditional naturopaths from using their doctoral
132 designation, a right protected by Congress.
133 Graduates of government-accredited institutions are under the jurisdiction of the state
134 licensing laws. However, the state lacks jurisdiction over non-government accredited
135 institutions and subsequently they also lack jurisdiction over their graduates. The state
136 cannot therefore, impose their licensing laws on graduates of non-government accredited
137 schools. Licensure is a privilege of the state that can be exercised only over graduates of
138 government- accredited institutions. Licensure should not be a means of the state to
139 monopolize the autonomous postsecondary educational system in the United States by
140 excluding from practicing all those who do not fall under their auspices.
Certification or Registration vs. Licensing
141 Certification or registration may be used interchangeably but “Certification is not the same
142 as licensing and accreditation, although these, too, may involve being evaluated in order to
143 receive credentials. Each type of credential is different and the terms are not
144 interchangeable.” (http://ancb.net/certification.html 06/18/04) American Naturopathic
145 Certification Board (ANCB).
146 Webster’s Dictionary defines certification as “having a certificate that is proof that
147 requirements, standards, etc. have been met.” The function of certification or registration is
148 to show that the requirements and standards of education have been met but does not give a
149 legal permission to practice or use a scholastic designation. The American Naturopathic
150 Certification Board also acknowledged this by the following statement “It should further be
151 recognized that successful completion of the exam in no way qualifies Board Certified
152 Naturopaths to use the doctoral designation.” (http://ancb.net/certification.html American
153 Naturopathic Certification Board (ANCB). 06/18/04
154 “Licensure is a formal or legal permission to do something specified” (Webster’s
155 Dictionary) National licensure gives traditional naturopaths the authority to practice and use
156 the doctoral designation legally. As defined by Webster’s Dictionary, “Accreditation is
157 given to an institution to certify as meeting certain standards.”
Competent Authority for Regulation of Professions in the United States:
158 “The competent authority for persons seeking to work in the United States in regulated
159 occupations is the licensing authority at the appropriate state or territorial level that
160 monitors that occupation.” (www.ed.gov U. S. Dep. of Education. Competent Authority
161 06/16/04). Traditional naturopathy is not a regulated profession therefore traditional
162 naturopathy does not require a license or recognition of qualifications by the state.
163 Unequivocally, we recognize that “The competent authority for the recognition of
164 qualifications presented by persons seeking to work in the United States, in unregulated
165 occupations, is the hiring employer.” and not the state. (www.ed.gov U. S. Dept. of
166 Education. Competent Authority 06/16/04)
167 Sanctioned by national regulations, the Naturopathic National Council Inc. will implement
168 the licensing regulations for traditional naturopaths. In mutual interest, the statutes should
169 be amended. It will prevent conflicts and litigations should someone acting in their official
170 capacity interfere with the rights of a traditional naturopath licensed under the Naturopathic
171 National Council Inc. while working within their scope of practice.
172 Traditional naturopathy is a branch of medicine that differs from conventional naturopathy.
173 Traditional naturopathy is an unregulated profession, which does not require a license from
174 the state for its practice. Although no state license is required to practice traditional
175 naturopathy states have overstepped the boundaries of their authority by imposing fines,
176 arresting and imprisoning traditional naturopaths for practicing without a license. For this
177 reason the Naturopathic National Council Inc. has been established to protect the rights of
178 traditional naturopaths to practice traditional naturopathy.
179 Traditional naturopathy is the only unregulated profession that is unlawfully regulated by
180 militant methods instead of by licensure. If traditional naturopathy required oversight,
181 it should have been the responsibility of the state to regulate the profession not militantly but
182 by licensure. Prohibiting the practice of traditional naturopathy or using militant methods to
183 regulate the profession are not valid ways of regulating a profession under the rules
184 established by the federal agency that establishes those standards. “State governments are
185 responsible for regulating those occupations that are practiced within their jurisdictions and
186 deemed to require licensure and oversight in order to protect public health, safety, and
187 economic well being.” (www.ed.gov U. S. Dep. of Education. Regulation of Professions.
188 The Naturopathic National Council can exercise influence as a licensing authority within the
189 field of traditional naturopathy because it is sanctioned by national law as well as by
190 traditional naturopaths. Traditional naturopaths are the competent authority for the
191 recognition of qualifications within their profession.
Competent Authority to Designate Titles.
192 Coalition for Natural Health president, Jeffrey Goin, testified before the White House
193 Commission in Seattle, October 31, 2000 as follows: “Throughout this town hall hearing,
194 both speakers and members of the commission have been using the terms “naturopathic
195 medicine” and “naturopathy” interchangeably. It’s imperative for the members of the
196 Commission to understand that traditional naturopathy involves natural and non-invasive
197 modalities that serve to stimulate the body’s own, intrinsic self healing capacity without the
198 use of drugs. “Naturopathic medicine” is a hybrid toward health that combines traditional
199 naturopathic modalities with allopathic procedures such as the prescription of drugs and
200 surgery. There is a material and very important difference between “Naturopathy” and
201 Naturopathic Medicine” (www.mail.naturalhealth.org Coalition for Natural Health 7/23/04)
202 The title Doctor of Naturopathy (N.D.) denotes a practice that is based solely on the principles
203 of natural medicine, and should not be confused with the title Doctor of Naturopathic
204 Medicine (N.M.D.) which is based on a combination of natural and synthetic medicine.
205 Presently conventional Doctors of Naturopathic Medicine use four titles for their scope of
206 practice, which are: Doctor of Naturopathic Medicine, Doctor of Naturopathy and the
207 abbreviated titles (N.M.D.) and (N.D.). The title Doctor of Naturopathy and its abbreviation
208 (N.D.), has been usurped by Doctors of Naturopathic Medicine (N.M.D.’s). This infringement
209 precludes Doctors of Naturopathy from using their title as well as the abbreviation of their
210 title (N.D.). Furthermore, the title Doctor of Naturopathy and its abbreviated title (N.D.)
211 when used by Doctors of Naturopathic Medicine is deceptive because it is a misrepresentation
212 of the true nature of the scope of their practice.
213 Doctors of Naturopathic Medicine (N.M.D.s) should not be able to use the title Doctor
214 of Naturopathy (N.D.) because the title conferred to them on their degree is Doctor of
215 Naturopathic Medicine. Neither should Doctors of Naturopathic Medicine (N.M.D.s) be
216 able to further abbreviate their title to (N.D.) because it is the incorrect abbreviation for their
217 title according to the grammatical rules of the English language. According to the
218 International Abbreviations Dictionary by Ralph De Sola, recognized standard reference for
219 abbreviations, the title "Doctor of Naturopathy is abbreviated (N. D.)" This designation has the
220 exclusive right to this abbreviation. Any other terms using these letters such as: "Naval
221 District, North Dakota, Notre Dame and Navy Department are abbreviated (ND)" without
222 punctuations. (Ralph DeSola Abbreviations Dictionary Eight Edition 1992 CRC Press Inc.)
223 Scholastic degrees or diplomas and their designated titles are conferred by schools, colleges
224 and universities to their graduates. Titles are given by learning institutions to their graduates
225 based on the description of the curriculum pursued. It is not within the jurisdiction of state
226 licensing boards to arbitrarily choose titles for their licensees or to change the title of a degree
227 or diploma from its original designated title. Nevertheless, states have changed the title
228 Doctor of Naturopathic Medicine (N.M.D.) to the title Doctor of Naturopathy (N.D.) in order
229 to exclude traditional naturopaths from using their title Doctor of Naturopathy (N.D.) to
230 diminish their credibility. The abbreviation of a title cannot be chosen arbitrarily but must
231 adhere to linguistic rules. If the rules were not followed and the letters (R.P) were chosen
232 arbitrarily as the abbreviation of the title Doctor of Naturopathy it would cause confusion.
233 The established standard for abbreviating titles containing several words is that the first letter
234 of each word in the title must be included in the abbreviation. According to Oxford Advanced
235 Learner’s Dictionary 2000, 6th edition "a phrase is abbreviated by using only the first letter of
236 each word in the phrase." According to the American Heritage Dictionary of the English
237 Language 2000, 4th edition the word abbreviate means "to reduce (a word or phrase) to a
238 shorter form intended to represent the full form, such as Mass. for Massachusetts or USMC
239 for United States Marine Corps." For this reason the title Doctor of Naturopathic Medicine
240 (N.M.D.) cannot be abbreviated (N.D.) without the letter (M) included in the abbreviation.
241 Furthermore, Doctors of Naturopathic Medicine (N.M.D.s) should not be represented by the
242 title Doctor of Naturopathy (N.D.) because they embrace allopathic medical principles which
243 do not represent the moral values that encompass naturopathy such as: Administering surgery,
244 x- ray radiation, dispensing legend drugs, prescription drugs or controlled substances, and
245 practices that invade the human body. According to Stedman’s Medical Dictionary, "these
246 allopathic principles are not embraced by Doctors of Naturopathy" (N.D.s)
Two Branches of Medicine
247 “The basic principles underlying naturopathic medicine are: The body has the power to heal
248 itself. Self healing is considered more effective than introducing chemical substances into
249 the body.” (Gotto, Antonio M. Jr. The Cornell Illustrated Encyclopedia of Health
250 Naturopathy. Washington, D.C. Lifeline Press 2002) Traditional naturopaths (N.D.s) do not
251 embrace the philosophy of eradicating disease by operation or suppression of symptoms;
252 instead, traditional naturopaths believe that the body has the inherent power to heal itself by
253 restoring the balance that the individual may have lost through nutritional deficiencies and
254 stress factors.
255 The following is in reference to (N.M.D.s) or conventional naturopathic medical training.
256 “The naturopathic medical college program is a 4-year post-graduate curriculum consisting of
257 two years of instruction in basic sciences…The first two years of training are reportedly
258 similar to that received by medical doctors.” (Colorado Department of Regulatory Agencies.
259 Naturopathic Physicians. Education and training p.7 June 1993) Despite the fact that
260 there are similarities in the basic curriculum Doctor of Medicine (M.D.) and Doctor of
261 Naturopathic Medicine (N.M.D.) both are completely different branches of medicine.
262 Likewise, the core curriculum of the traditional Doctor of Naturopathy (N.D.) and the
263 conventional Doctor of Naturopathic Medicine (N.M.D.) have similarities but the emphasis of
264 the two branches of medicine are vastly different. This principle is also seen with the “Doctor
265 of Chiropractic (D.C. or D.C.M.), a curriculum divided in “straight” or “progressive”
266 chiropractic depending upon the philosophy of the institution.” (www.ed.gov U.S. Dept. of
267 Education. First-Professional Studies 7/25/04)
Scope of Practice
268 The practice of (N.M.D.s) or conventional Naturopathic Medicine includes the following
269 methods of healing: “(1) Counseling and (2) the practice of mechanical and material
270 sciences of healing as follows: The mechanical science such as mechanotherapy, articular
271 manipulation, and orthopedic gymnastics, physiotherapy, hydrotherapy, electrotherapy and
272 phototherapy; and the material sciences such as nutrition, dietetics, phytotherapy, treatment
273 by natural substances and external applications.” Chapter 373 Sec. 20-34 State of CT. Dept.
274 of Public Health. This scope of practice is also in accordance with the definition of the U. S.
275 Department of Labor
276 The practice of (N.D.s) or the traditional Doctor of Naturopathy is a system in which neither
277 surgical nor controlled substances are used and includes the broad domain of the following
278 non-invasive naturopathic methods of healing but not limited to: (I) iridopathology, (II)
279 functional endocrinotherapy, (III) hydrotherapy, (IV) traditional phytotherapy, (V) homeopathy,
280 (VI) naturopathy, (VII) diet and clinical nutrition, (VIII) functional hematology, (IX) traditional
281 psychotherapy, (X) orthomolecular nutrition, (XI) functional immunotherapy, (XII) traditional
282 neurotherapy, (XIII) myophysics, (XIV) lymph-hydrotherapy, (xv) chelation, (xvI) traditional
283 gynecology.
284 State governments mistakenly believe that because traditional naturopaths are in the
285 practice of natural or functional medicine they are practicing medicine as set forth in the State
286 General Statutes that prohibits diagnosing, operating, prescribing, treating and curing
287 without a license. To the contrary, traditional naturopaths are not interested in such practices;
288 instead they are interested in restoring harmony and equilibrium to the body.
289 The scope of practice of traditional naturopathy is limited to: Analyzing, subscribing,
290 preventing, and giving protocols. The following describe the conventional naturopathic
291 medical scope of practice as defined by the state in contrast to the scope of practice of
292 traditional naturopathy. The terms have completely distinct meanings and cannot be used
293 interchangeably. Diagnose (examine symptoms and inflections) contrasted by; analyze
294 (examine metabolic functions). Prescribe (order for compliance) contrasted by; subscribe
295 (signature of approval). Treat (exposing to chemical substances) contrasted by; protocols
296 (agreement of natural regimen). Cure (do away with disease) contrasted by; prevent (restore
297 metabolic balance). (Guralnik, David B. Webster’s Dictionary New Jersey: William Collins
298 Publishers, Inc 1976)
299 A relevant issue that is subject to discussion within this forum includes the use of certain
300 words that traditional naturopaths are precluded from using because of refusal to
301 acknowledge traditional naturopathy as a legitimate medical science. Traditionally, the word
302 medicine has been used by allopathic doctors in their title Doctor of Medicine (M.D.) which
303 establishes allopathic medicine as having the exclusive right to the word “Medicine” when
304 used as a title; but it does not give them the monopoly on the general usage of the word
305 outside the context of a title. It cannot be refuted that no one can have the exclusive right to
306 any single word of the English language except in the context of a title. Therefore, precluding
307 others from the common usage of certain words in their vocabulary that are related to
308 medicine is unconstitutional.
309 Refusal to acknowledge traditional naturopathy as a legitimate medical science has also
310 restricted the use of the word patient within the profession. Therefore, traditional
311 naturopaths have adapted the word client. The word client has an impersonal
312 connotation that destroys the virtue that must be imparted to the person seeking to be
313 refreshed in body, mind and soul. However, according to Webster’s Dictionary a patient is
314 “a person receiving medical care” and because “an herb is a medicine” according to
315 Webster’s Dictionary and traditional naturopaths subscribe herbs, then the person receiving
316 preventative medical care is indeed a patient.
317 Everyday traditional naturopaths face the challenge of working with individuals who
318 have been prescribed drugs by allopathic medical doctors. Therefore, traditional naturopaths
319 must have a firm knowledge of the potential side effects that can result from the interaction
320 between prescription drugs and herbs. This knowledge is essential in order to safely work
321 with individuals who are taking prescription drugs however, traditional naturopaths do not
322 sanction the administration of drugs. Among traditional naturopaths herb therapy is
323 considered superior to drugs because of its efficacy in counteracting the myriad negative
324 effects of drugs.
325 The language conveying the scope of practice of traditional naturopathy is not based on
326 semantics to evade the law; they are alternative approaches to reach a common ground. The
327 paramount objective of any method of healing is to relieve humanity’s suffering, but what
328 differentiate each modality are the intermediate steps taken to achieve the final objective.
329 The intermediate steps define the scope of practice. For example: If a law prohibits taking
330 route X to get to point Y and you take route Z instead, you have not broken any law because
331 there was no law prohibiting taking the alternate route to get to point Y. Likewise, traditional
332 naturopathy is not following the route prohibited by law it is following the alternate
333 route to reach a common ground. This analogy conforms to the principle of the Ninth
334 Amendment to the Constitution, which in essence says if there is no law against it, it is legal.
Respectfully,
Beverly Betancur, N. D.
Chief Executive Officer
Cc: All States
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