Naturopaths are receiving a 45 day review to comment on the submission of the Naturopathy Act 2007. This process has not been transparent for most of the naturopathic doctors in Ontario. Naturopaths have until May 15, 2015 to voice their concerns and June 1, 2015, there may be the proclamation of the Naturopathic Act 2007. The transition counsel has had several years to listen and attend to naturopathic doctors concern and still fails to understand how many naturopathic doctors serve their patients every day.

As a profession, naturopaths would have never imagined that their scope of practice would have been reduced and not expanded such as naturopaths in British Columbia and more recently Saskatchewan. The assumption was based on the previous Drugless Practitioners Act, education at the college that trains naturopathic doctors (CCNM), and continuing education requirements needed to maintain a naturopathic license and also approved by the previous licensing body. As health care professionals, it is understood that naturopaths may have be required to write exams to demonstrate competence but the exams for this process are not yet available and if we do not have the exam we lose the right to prescribe previously used substances that are integral to patient care.

Examples would include the loss of prescription of DMSA and an inability to use laboratories from outside Canada and many laboratory tests consistent with naturopathic treatments such as ALCAT, environmental toxicity panel, expanded Cholesterol panel, inhalants such as yeast, candida and mold, metabolic testing (liver profiles, amino acids profile and detailed metabolic urine testing), nutrient levels, and genetic testing (SNPS). Not to mention the early loss of injectable homeopathic substances.

The lengthy consultation process the Transition Council of The College of Naturopaths of Ontario was inadequate and one sided. As naturopathic doctors have many parts of our scope of practice, it should have been a part of the consultation communicate which parts of the current scope would be eliminated and which parts the transition council was not willing or able to bring to the Ministry of Health and Long Term Care. Never was there a summary of what was being discussed with the Ministry, nor the transparency of what would be lost before this 45 day process.

Potentially the Transition Council of The College of Naturopaths of Ontario themselves do not realize the depth of loss to the scope or have the knowledge to adequately realized the limitations placed on naturopaths would result in harm to patients.

The 45 day process should be lengthened to allow all naturopathic doctors to fully understand the loss of the scope of practice and to reach out to the current members of the Regulated Health Professionals Act to allow a full scope of practice to be given to naturopathic doctors.

The possible dissolution of the current Transition Council of The College of Naturopaths of Ontario who has not fully consulted with naturopathic doctors to those who would represent and understand a comprehensive and fulsome consultation and negotiation process.