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. 14 (www.ed.gov U. S. Dept. of Education. Competent 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