January 24, 2005
Ms. Judith Peters
Office of the Attorney General
6 State House Station
Augusta, Maine 04333-0006
RE: Adjoining document for letter addressed to Ms. Judith Peters
Scope of practice of traditional naturopaths vs. scope of practice of conventional naturopaths.
The practice of (N.M.D.’s) or conventional naturopathic medicine includes the following methods of healing:
“(1) Counseling and (2) the practice of mechanical and material sciences of healing as follows:
The mechanical science such as mechanotherapy, articular manipulation, and orthopedic gymnastics,
physiotherapy, hydrotherapy, electrotherapy and phototherapy; and the material sciences such as
nutrition, dietetics, phytotherapy, treatment by natural substances and external applications.”
Chapter 373 Sec. 20-34 State of CT. Dept. of Public Health. This scope of practice is also in accordance
with the definition of the U. S. Department of Labor.
The scope of practice of naturopathic physiciens does not include any mechanical or body based
practices nor electrotherapy, phototherapy and mind-spirit practices. The practice of the Doctor
of Naturopathy (N.D.) or traditional naturopaths includes the following: (1) Counseling and (2)
the practice of analytical nutritional biochemical sciences such as: iridopathology, functional
hematology, functional immunology and functional endocrinology, traditional gynecology, reams
urinalysis, thermography, hair mineral analysis, oxidative stress test and the health assessment
practices of myophysics, and computerized analyzers. (3) Material sciences of healing as follows:
Naturopathy, nutrition, dietetics, phytotherapy, orthomolecular nutrition, homeopathy, nutritional
psychotherapy, nutritional lymph therapy, chelation therapy, colon hydrotherapy, detoxification
therapy and cold laser inflammation reduction therapy. External applications with natural
substances as follows: Hydrotherapy, aromatherapy, neuro-reflexology, sunlight therapy, fresh
air therapy, exercise therapy and rest therapy.
Mechanical sciences or body-based practices not included in the practice of traditional naturopaths:
Rolfing structural integration, chiropractic manipulation, massage therapy, medical massage, bowen
therapy, tui na, alexander technique, stone therapy, acupressure, therapeutic massage, lymph-bodytherapy,
feldenkrais, sujok acupuncture, esthetics, cranio-sacral therapy, ayurvedic body therapy, trager body work,
osteopathic manipulation, bodywork, mechanotherapy, articular manipulation, orthopedic gymnastics,
physiotherapy.
Metaphysical or holistic energy practices (mind-spirit) not included in the practice of traditional naturopaths:
Hypnosis, visual imagery, transcendental meditation, yoga, biofeedback, tai chi, qi gong energy healing, taiji,
neurolinguistic programming, energetic healing, reiki, DNA theta healing, orion technique, guided imagery,
healing touch, chaldean astrology, crystal therapy, magnetic therapy, breathwork, thought field, therapeutic
touch, magnotherapy, johrei, polarity therapy, intuitive medicine, spiritual healing with light and color,
kundalini healing energy, cellular energy healing, astral healing, chakras energy healing, vortex healing,
sound energy healing etc.
Phototherapy and Electrotherapy practices not included in the practice of traditional naturopaths:
T.E.N.S. therapy (transcutaneous electrical nerve stimulator), neural therapy, color and light therapy for
affective disorders, pulsing electromagnetic field (PEMF).
Sincerely,
Beverly Betancur, N.D.
Chief Executive Officer
