Testimony Opposing Naturopathic Licensure in Massachusetts

June 13, 2003

Presented to the Commonwealth of Massachusetts

Joint Committee on Health Care

May 28, 2003

Kimball C. Atwood, M.D.

Representing the Massachusetts Medical Society

Re: Bill Number: MA03RHB 2603 (Senate no. 661)
Filed: December 4, 2002
Author: Kathleen M.Teahan
An Act Providing for the Registration of Naturopathic Doctors


The Joint Committee on Health Care is today considering, for the sixth time in seven years, a bill that would make “naturopathic doctors” licensed health care providers in the Commonwealth. In each previous attempt the bill failed to emerge from committee. This year supporters argue that the result should be different because of a state Special Commission convened in 2000 to study the issue. The commission issued two reports in January 2002. The “majority” report, signed by six commission members, recommended licensure for naturopaths [1]. The “minority” report, signed by three, opposed such licensure [1]. Three members abstained. Today’s legislation omits some of the provisions of previous bills, particularly those covering obstetrics and surgery. The underlying belief systems of naturopathy remain unchanged, however; only the naturopaths’ belief in what they may get from the legislature has been modified.

Naturopaths Portray Themselves as “Primary Care
Physicians,” but Their Training is Substandard

The naturopaths who seek licensure here consider themselves to be “primary care physicians.” [3] Although Massachusetts law now forbids them from using the term “physician,” they will nevertheless portray themselves as being the equivalent: that is what they are told by their schools and their national organization, and that is what is stated in all of their national literature [4]. This is in spite of the fact that their training includes no experience with sick, hospitalized patients, no internship or residency training, and occurs in four obscure institutions that are unaffiliated with academic medical centers and that have been denied accreditation by the U.S. Dept. of Education.

Naturopathic Practices are Bizarre, Irrational, and Unsafe

Naturopathic practices are a large assortment of erroneous claims mixed with a sprinkling of non-controversial dietary and lifestyle advice. Examples of the first category are the claims that hydrogen peroxide dissolved in a bath can provide vital oxygen through the skin of a patient suffering from an acute asthma attack [5]; that wet compresses applied to the feet of a child with an ear infection can “draw the congestion out of the ear” [6]; that the goldenseal plant can cure a strep throat, thus making penicillin unnecessary [7]; that balloons inflated inside the nose can cure learning disorders [8]; that strokes in progress can be reversed by cold compresses applied over the carotid arteries [9]; that multiple sclerosis can be detected at a very early stage by “pulse” and “tongue” diagnosis and cured by means unknown to modern medicine [10]; that enemas and fasting are necessary to rid the body of “toxins” [11]; that vitamin C is an effective treatment for approximately 100 conditions, including glaucoma, male infertility, and AIDS [12]; that HIV-positive patients should be treated with St. John’s wort and garlic (both of which have been shown to interfere with life-saving anti-HIV medicines [13,14]), “acupuncture detoxification auricular program,” whole-body hyperthermia, “adrenal glandular,” homeopathy, “cranioelectrical stimulation,” digestive enzymes, colloidal silver, and nearly 100 other implausible and dangerous methods [15,16] that high blood pressure and coronary heart disease should be treated with unproven herbs and “chelation therapy” [17]; and much more. Naturopaths advocate these methods as “alternatives” to modern medical care, not merely as “complementary” [18]. Interested legislators can learn more in the minority reports of the Commission and from a variety of other sources that I am happy to provide. I urge you to learn some of the details of naturopathic practice and to ask whether it offers a viable alternative to your own medical care.

Superficial Appearances do not Ensure Validity

The examples I have cited are found on the websites of the national naturopathic organization, of the four schools, and in the only general textbook of the field [12]: thus they are standard naturopathic practices. Superficial appearances of legitimacy, such as the existence of schools, exams, a national organization, and licensure in 11 states cannot provide protection for the public. These trappings cannot make ineffective and dangerous treatments effective or safe.

Government’s Responsibility: Licensure Implies Validity and Self-Regulation

There are two reasons that government should deny licensure to any group that professes irrational health claims. The first is that licensure is interpreted by the public as an endorsement of the field. Unsuspecting parents who lack sophistication in science or medicine couldn’t be faulted for having their sick children treated by a practitioner who thinks that a hydrogen peroxide bath is effective for asthma, if that practitioner is licensed by the state.

The second reason is that a licensed, self-regulating profession determines its own standards of practice [19]. The bill before you today provides for a nine-member board, of which four would be naturopaths. All that would be necessary for these four to control the majority would be to convince one of the others that they know what they are talking about. Since naturopathic practices are esoteric and baffling to most people, this wouldn’t be difficult. Such a board would find that all the practices described above are within the appropriate “standards of care” for naturopaths. Paradoxically, if medical doctors were to engage in the same practices they would be subject to discipline and malpractice suits — and rightly so.

A Double Standard for Health Care is Wrong

There simply cannot be one standard for one type of “primary health provider” and a different one for another. There must be a single standard, and it must be based on rational decision-making informed by science and clinical research.

The Public Demand for Naturopathy is Miniscule

The contention that naturopathy is in public demand is also false. Every recent survey of the public’s use of non-standard health practices has found that naturopathy was used by too few people to mention, or at most that it was used by fewer than 0.4% of the population [20]. In Massachusetts there are only 30 naturopaths of the sort that are seeking licensure, and nationwide there are only about 1500. The demand for naturopathy is tiny and marginal. It will likely stay that way unless inappropriate governmental endorsement occurs. The Commonwealth should not expend scarce resources to create a board that confers licensure status on these 30 people.

Previous Government Studies have found
Naturopathy Unsuited to the Practice of Medicine

This is not the first time that government has studied naturopathy. In 1968 naturopaths asked the U.S. Department of Health, Education and Welfare (now the Department of Health and Human Services) to give Medicare reimbursement for their practices. The department conducted a thorough investigation and returned an unfavorable decision. The HEW report concluded:

Naturopathic theory and practice are not based on the body of basic knowledge related to health, disease, and health care that has been widely accepted by the scientific community. Moreover, irrespective of its theory, the scope and quality of naturopathic education do not prepare the practitioner to make an adequate diagnosis and provide appropriate treatment [21].

That conclusion remains entirely justified 35 years later. This is from a recent treatise on naturopathy:

In our research for this chapter, we provided naturopaths and their professional associations ample opportunity to refute the conclusions of several major commissions of inquiry over the years that deemed their therapeutic rationale lacking in scientific credibility. None of our informants was able to convince us that the field had taken these earlier critiques to heart; in fact, precious few seemed to recognize that a problem still exists. [O]ur own bibliographic searches failed to discover any properly controlled clinical trials that supported claims of the profession, except in a few limited areas where naturopaths’ advice concurs with that of orthodox medical science. Where naturopathy and biomedicine disagree, the evidence is uniformly to the detriment of the former.

We therefore conclude that clients drawn to naturopaths are either unaware of the well-established scientific deficiencies of naturopathic practice or choose willfully to disregard them on ideological grounds [22].

A Threat to Health Insurers, an Insult to Non-MD Practitioners,
and a Headache for the Department of Public Health

Licensure of naturopaths would pose problems for health insurers, who would be pressured to pay for ineffective and dangerous services. It would be a slap in the faces of nurse practitioners and physician’s assistants, who are far more qualified than naturopaths but who would enjoy less autonomy and the appearance of lower status in the eyes of a public that places its trust in government. It would be a giant headache for the Department of Public Health, which would be inundated by bogus claims of “heavy metal poisoning,” “fluoride toxicity,” widespread “food allergies,” “yeast infections” and “toxins,” exaggerated dangers of childhood vaccinations, and other claims common to naturopathic practice (4).

“Collaboration” with Medical Doctors Violates Medical Ethics

Language in the bill that calls for collaboration between naturopaths and medical doctors is in direct conflict with formal codes of medical ethics, which require physicians to eschew unscientific practices themselves and to refrain from referring patients to, or collaborating with, unscientific practitioners [23,24].


Massachusetts legislators should use this opportunity not only to refuse licensure to naturopaths, but to inform them that there is no point in pursuing this goal in the future until and unless the field changes radically. Anything less than this would be contrary to current efforts to make health care safer and more accountable. It would be a huge setback for the public health of a state that enjoys a reputation for having the best medical care in the world.

  1. Majority report of the Massachusetts Special Commission on Complementary and Alternative Medical Practitioners: A report to the legislature. Jan 2002.
  2. Atwood KC, WJ Ryder, Minority report of the Massachusetts Special Commission on Complementary and Alternative Medical Practitioners: A report to the legislature. Jan 2002.
  3. Modalities. National College of Naturopathic Medicine website, archived, Feb 20, 2002.
  4. Atwood KC. Naturopathy: A monograph. Presented April 2001 to the Massachusetts Special Commission on Complementary and Alternative Medical Practitioners.
  5. Kane E. Asthma. AANP Web site, archived April 2001. The author is listed as senior editor of the Journal of Naturopathic Medicine, the official publication of the American Association of Naturopathic Physicians.
  6. Rothenberg A. Testimony at the Massachusetts Special Commission on Complementary and Alternative Medical Practitioners, 2001. The author is a naturopath who edits the New England Journal of Homeopathy.
  7. AANP Position paper on treatment of strep pharyngitis. AANP Web site, acessed, June 3, 2003.:
  8. Barrett S. Be Wary of NeuroCranial Restructuring (NCR).
  9. Kane, E. Stroke. AANP Web site, archived April 2001.
  10. Kruzel T.. Multiple sclerosis. The author is chief medical officer of the Southwest College of Naturopathic Medicine.
  11. Barrett S. A close look at naturopathy.
  12. Pizzorno JE. Murray MT, eds. Textbook of Natural Medicine, 2nd Edition, London: Churchill Livingstone, 1999
  13. Piscitelli SC and others. Indinavir concentrations and St John’s wort. Lancet 355:547, 2000.
  14. Piscitelli SC and others. The effect of garlic supplements on the pharmacokinetics of saquinavir. Clinical Infectious Diseases 34:234-238, 2002.
  15. Standish LJ and others. HIV/AIDS: Naturopathic medical principles and practice. In Pizzorno JE, Murray MT, eds. Textbook of Natural Medicine. London: Churchill Livingstone, 1999, pp. 1277-1302
  16. Bastyr University AIDS Research Center. Current scientific activities.
  17. Textbook of Natural Medicine, 2nd Edition. pp. 1078-1082
  18. AANP website. Definition of naturopathic medicine.
  19. Studdert DM and others. Medical malpractice implications of alternative medicine. JAMA 280:1610-1615, 1998.
  20. Druss BG, Rosenheck RA. Association between use of unconventional therapies and conventional medical services. JAMA 282:651-656, 1999.
  21. HEW Report on Naturopathy (1968). Available on Quackwatch at:
  22. Beyerstein BL Downey S. Naturopathy. In: Sampson W, Vaughn L, eds. Science Meets Alternative Medicine: What the Evidence Says about Unconventional Treatments. Amherst, NY: Prometheus Books; 2000, pp141-163
  23. AMA Code of Medical Ethics. E-8.20: Invalid medical treatment.
  24. AMA Code of Medical Ethics. E-3.01: Nonscientific practitioners.

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This article was posted on June 13, 2003