The recently appointed White House Commission for Complementary and Alternative Medicine held a Town Hall Meeting in Seattle, WA on October 31, 2000. CNH president, Jeffrey Goin gave testimony there, on behalf of the Coalition's membership. The following is that testimony in its entirety:

Mr. Chairman and members of the Commission, my name is Jeff Goin. I am President of the Coalition for Natural Health, a grassroots organization that represents over 2,500 natural healers nationwide.

Over the last couple of days, I have noted a few points relating to the misuse of CAM terminology and philosophy. I'd like to use the bulk of my three minutes to clarify those points:

Throughout this town hall hearing, both speakers and members of the commission have been using the terms “naturopathic medicine” and “naturopathy” interchangeably. It's imperative for the members of the Commission to understand that traditional naturopathy involves natural, non-invasive modalities that serve to stimulate the body's own, intrinsic self-healing capacity without the use of drugs. “Naturopathic medicine” is a hybrid approach toward health that combines traditional naturopathic modalities with allopathic procedures such as the prescription of drugs and surgery. There is a material and very important difference between “naturopathy” and “naturopathic medicine.”

Similarly, throughout the two days of meeting, the titles “naturopathic physician” and “naturopath” have been treated as though they're synonymous. Furthermore, many speakers, some inadvertently, some not, have implied that “naturopathic physicians” comprise the entire universe of qualified naturopaths. This is most assuredly not the case.

I'll give you my organization's take on the naturopathic universe: there are “naturopathic physicians” and then there's everybody else. The “everybody else” in the field of naturopathy is my organization's constituency and “everybody else” is comprised of generational healers, Central and South American curanderos and curanderas; French treaters; English herbalists; Native American tribal healers; and, other traditional naturopaths, in this country, who use methods and remedies proven effective over thousands of years, which have been handed down from generation to generation, as well as naturopaths educated through distance learning. It is wrong to assume that traditional naturopaths are not properly educated and trained simply because they did not receive their training from a resident college or university. Traditional naturopathy has existed in the public domain since the 1600's without the necessity for naturopaths to attend four-year medical schools and without any evidence of harm to those who follow its principles. Training to become a naturopath may be obtained from several different sources including: distance education programs that lead to an N.D. degree, apprenticeships, institutions that specialize in teaching a particular therapy, specific courses, seminars, workshops, and in some cases, formal education of required duration in an accredited institution. And for the record, I consider distance learning to be a much more respectful term than the term “mail order diploma” which is the moniker that Daniel Labriola and the Bastyr students prefer. But, lest I digress, please let the point be clear: In the entire naturopathic universe, the “naturopathic physicians” are a tiny minority.

The distinction between titles and terms becomes very important when considered within the context of licensing and regulatory activity that this Commission may be considering.

As you may know, naturopathic medicine licensing laws exist in 11 U.S. States. Those laws, were championed by the American Association of Naturopathic Physicians and the AANP's state chapters, and exclude the vast majority of naturopaths, or traditional naturopaths, in the following way:

First, the laws use the scope of practice that comprises naturopathic medicine as being the definition of all forms of naturopathy. In other words, the prescription of drugs and surgery are included in the laws' definitions of naturopathy.

Secondly, the laws state that in order to be qualified to practice any form of naturopathy, one must be qualified to perform the types of surgery and prescribe the types of drugs encompassed in naturopathic medicine.

Furthermore, the only way, according to these laws, that one can become qualified to perform the types of surgery included in naturopathic medicine is to attend one of only three schools in the country that are accredited to teach naturopathic medicine.

Then, the laws state that prospective licensees must pass the Naturopathic Physician Licensing Exam, and that only graduates of one of the aforementioned three naturopathic medical schools are eligible to sit for the exam.

Finally, the laws state that only those qualified to practice naturopathic medicine can use titles involving the word “naturopath.” The titles co-opted by these laws include Naturopathic Physician, Naturopath, Doctor of Naturopathy, Naturopathic Practitioner, and Naturopathic Doctor — even the adjective “naturopathic.”

The upshot of the foregoing is that in order to be able to offer any form of naturopathic service, traditional naturopaths — practitioners who don't even believe that drugs and invasive procedures should be part of naturopathy — are being asked to be qualified to perform surgery and prescribe pharmaceuticals. The net affect of this licensing initiative has been to preclude traditional naturopaths — again, those who comprise the overwhelming majority of practitioners — from practicing their trade.

The question posed by the Coalition's members is clear: Why, when there are presently in existence allopathic physicians capable of delivering primary health care to patients, and naturopaths that are qualified to offer natural therapies, does a third party need to create an entirely new profession that combines the two? This action can only dilute the potency of the benefits that are provided by each distinctive model from which they're drawn, thereby reducing the effectiveness of each component. If allopathic physicians, in the interest of offering safer and more cost effective patient care, wish to include some modality of natural healing in their practice; this is perfectly acceptable — provided that their knowledge about the subject is sufficient to allow for an effective application. But, it is absolutely and unequivocally unacceptable and unethical for the AANP to attempt to co-opt all naturopathic modalities and all titles using the word “naturopath” as part of it's “naturopathic medicine” licensing efforts.

To summarize, our recommendations to the Commission are:

1. Distinguish between “Traditional Naturopathy” and “Naturopathic Medicine.”
   
   
2. Differentiate between “Naturopaths” and “Naturopathic Physicians.”
   
   
3. Should the Commission concern itself with the matter of regulation and licensing — something that I'm not at all convinced is wise or appropriate — please try to develop an approach that serves the needs of consumers and practitioners, not one that is exclusionary.

Thank you for your time.