Transforming and Supporting Patient Care - Health Professions ...

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262Chapter 11 – Profession of NaturopathyProponents’ RationaleNDs require the controlled act of selling to enable them to provide certainnatural substances to their patients. These might otherwise be difficult toobtain because they are not stocked in community pharmacies or areotherwise unavailable.5. What HPRAC FoundReadiness for ChangeMore than 95 percent of OAND members who responded to a recent surveyindicated that they are in favour of being authorized the controlled acts ofprescribing, compounding and dispensing drugs. Respondents said thatcontinued access to substances integral to naturopathic care depends onbeing authorized to perform these controlled acts, and that the authority toperform these controlled acts would allow them to increase their role asprimary care providers.HPRAC’s review of the ND education and training programs in drugtherapies found educational content is similar to the content taught innursing, pharmacy and medical schools.The BDDT-N Continuing Education (CE) Policy sets out the minimum CErequirements for NDs to maintain high professional standards innaturopathic practice and to assure the public of the continuingprofessional competency of NDs in Ontario. CE activities include:• A total of 30 CE credits for a two-year period that must include tenmandatory credits (two credits in Pharmacology, six credits “in thenaturopathic modalities such as Clinical Nutrition and BotanicalMedicine, which include prescribing and administration of somesubstances that are now classified as drugs”, and two credits inOntario jurisprudence).• CPR must also be updated in the two-year period. 31On balance, HPRAC is satisfied that there is sufficient evidence in thecurrent drug education of naturopathic doctors to recommend prescribingauthority for traditional naturopathic remedies that have been rescheduled.However, there may be additional re-education requirements forpractitioners who graduated before 1994, when the NPLEX examinationscommenced.HPRAC heard that NDs are well trained in compounding natural substancesand are sought out by patients for their ability to provide access to thesetherapeutic substances. NDs have unique expertise in the therapeutic useof natural substances and are skilled primary care providers.31Ibid: 94.HPRAC Critical Links January 2009
263Chapter 11 – Profession of NaturopathyNDs are already safely and effectively using natural substances whenadministered parenterally (e.g., by injection, through intravenous,subcutaneous and intramuscular routes). They recognize that high dosesof nutrients and herbs should be administered only by an experiencedpractitioner, due to the possibility of toxicities and drug-herb interactions.The training that NDs receive, through their foundational clinical anddidactic education and continuing education programs, indicates that NDshave the knowledge, skill and judgment to ensure they are competent tosafely administer these substances.There is also adequate foundational education to consider the requests fornew prescribing authority for a limited number of Schedule I drugs. Many ofthe drugs and conditions are similar to those proposed by pharmacists forminor ailments treatment protocols.The joint submission reiterates requests made in submissions to HPRAC inits 2005 review of the profession of naturopathy. Based on its initial work,including consultation and research, in its New Directions report to theMinister in April 2006, HPRAC recommended that NDs be authorized to“prescribe, dispense, sell and/or compound drugs that are consistent withnaturopathic practice, as prescribed in regulations”. 32At the time, HPRAC was advised that the federal Natural Health ProductsDirectorate (NPHD) and the Natural Health Product (NHP) regulations,which came into force in January 2004, excluded from the “natural healthproducts” regulation a number of products or substances that havetraditionally been safely prescribed, compounded or dispensed by NDsbut are considered to have additional risks of harm in over-the-counterdistribution. As a result, NHPD has created a separate schedule forbotanical medicines and natural health products that are of higher risk,and that should only be used under the advice and supervision of a healthprofessional who is trained and educated in their use. The profession iscontinuing to evolve and is showing that it is ready to receive thisprescribing authority.HPRAC also notes the proponents’ statements that the legislative evolutionof NDs scope of practice has not kept pace with advancing clinicalknowledge, increases in training and competencies, evolutions in otherjurisdictions and trends in consumer demands.What Leading Jurisdictions DoInformation from other jurisdictions provides evidence that NDs areequipped to prescribe within their scope of practice. Evidence fromjurisdictions such as Oregon and Arizona that currently authorizeprescribing for NDs indicates a high safety record. While prescribing rightsfor NDs are still limited to natural substances in many jurisdictions, someleading jurisdictions are moving to include Schedule I drugs in anaturopathic formulary. In British Columbia, for example, NDs are subject to32HPRAC. New Directions:183.HPRAC Critical Links January 2009
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Table of ContentsCritical Links:Tra
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20Chapter 2 - Excellence in Health
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56Chapter 3 - A New Drug Approvals
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164Chapter 7 - Professions of Chiro
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186Chapter 8 - Profession of Dental
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340Chapter 14 - Profession of Pharm
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366Chapter 15 - Profession of Physi
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378Chapter 16 - Profession of Respi
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394Chapter 17 - Conclusionscontinui
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396Chapter 17 - Conclusionsincluded
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398Chapter 18 - Summary of Proposal
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