January 24, 2005
Ms. Judith Peters
Office of the Attorney General
6 State House Station
Augusta, Maine 04333-0006
RE: Clarification of issues raised by the State of Maine, Washington and Alaska.
Dear Ms Peters:
Please observe the diploma of your licensees and note that the title on their degree is Doctor of Naturopathic
Medicine (N.M.D.) and not Doctor of Naturopathy (N.D.). The state, by inappropriately using the abbreviation
(N.D.) for the title Doctor of Naturopathic Medicine (N.M.D.), is usurping the authority of the dictionary as the
most authoritative source for defining the correct abbreviations within the English language. According to the
dictionary, when abbreviating phrases all the words in the phase must be abbreviated. A phrase is not properly
abbreviated if only some of the words in the phrase are abbreviated, as explained in more detail in the document
dated September 28, 2004.
The only phrase dealing with the word “naturopath” to which the state has an exclusive right is the title Doctor of
Naturopathic Medicine (N.M.D.), which is the title of their licensees. The Doctor of Naturopathic Medicine
(N.M.D.) must use their designated title and not any other title given them by a state government because the
legislature and licensing board does not have the authority to give titles, in doing so the state is usurping the authority
of schools, colleges and universities who are the only ones authorized to confer degree titles.
The state has the authority to decide if a person can use a title or work in a given profession, only when they license
the profession. The profession of traditional naturopathy that uses the title Doctor of Naturopathy (N.D.) is not
regulated by state licensure; therefore, your state law cannot prohibit traditional naturopaths from working in this
field and using their title, if they do they are in violation of federal regulations.
Concerning the issue raised of your state not distinguishing between traditional naturopathy and conventional
naturopathy, it is not the responsibility of the state to distinguish between traditional naturopathy and conventional
naturopathy in their statutes. The two practices are distinguished based on the philosophy of each modality, which
determines their core curriculum. The scope of practice of the Doctor of Naturopathy (N.D.) is based on a
nature-science philosophy and the scope of practice of the Doctor of Naturopathic Medicine (N.M.D.) is based on
the philosophy of mind, body, spirit and nature; therefore, they are two separate branches of medicine as described
in the accompanying document.
Sincerely,
Beverly Betancur, N.D.
Chief Executive Officer
