December 27, 2004

Ms. JoAnne Davis-Trexler, Supervisor

Florida Department of Health Board of Medicine

4052 Bald Cypress Way

Tallahassee, FL  32399-3253

Dear Ms. Davis-Trexler:

This communication is to notify you that the Naturopathic National Council, Inc. is the national licensing agency for traditional naturopaths. On November 30, 2004, the Naturopathic National Council, Inc. implemented licensure regulations for traditional naturopaths on a national level. The Naturopathic National Council, Inc. is legally the national regulatory agency of traditional naturopathy. This governing body has jurisdiction over the branch of medicine of traditional naturopathy; therefore, all complaints against its licensees must be referred to this agency.  Enclosed are the articles of incorporation and the documents that were submitted to the legislature of your state that affirms our legal status.

The Naturopathic National Council, Inc. has jurisdiction over the branch of medicine of traditional naturopathy, which is designated by the title Doctor of Naturopathy, (N.D.) and we intend to use this title in our practice. We have already established in the accompanying documents that current statutes pertain only to the scope of practice of the branch of medicine designated by the title Doctor of Naturopathic Medicine (N.M.D.); therefore, the use of the title Doctor of Naturopathy, (N.D.) by traditional naturopaths does not infringe upon the title of the naturopaths licensed by the state.

The scope of practice of the Doctor of Naturopathic Medicine (N.M.D.) is in contradistinction to the scope of practice of the Doctor of Naturopathy (N.D.), which to date is not regulated by the state.  As stated in the accompanying documents, “The U.S. education system recognizes both public (state) and private education and makes no distinctions between them as to restrictions or limitations.” Also “Accreditation in the United States involves non-governmental entities as well as governmental agencies.”  Therefore the state lacks jurisdiction to license the branch of naturopathy designated by the title Doctor of Naturopathy, (N.D.) because its accreditation is independent of state affiliation.

Respectfully,

Beverly Betancur, N.D.

Chief Executive Officer

Cc:  Governors, Attorney Generals and Licensing Boards.