Licensure is the process by which a naturopathic physician (naturopath) proves that it has achieved minimum competency to practice naturopathic medicine (naturopathy).  Licensure is not specific to a specialty area of naturopathic medical practice.

 

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Below are answers to frequently asked questions about the licensure of naturopathic physicians (naturopaths) in the USA.

A Note Regarding Patient Safety

A naturopathic physician (naturopath) who only has a license, but states it is board-certified, is making a false claim about its credentials.  There is no such credential as a “board-certified naturopathic physician,” just as there are no such credentials of “board-certified allopathic physician” and “board-certified osteopathic physician.”  A board certification is granted when a naturopathic physician (naturopath) has proved that it has achieved expertise in a specialty area of naturopathic medical practice.  The only board certifications currently available to naturopathic physicians (naturopaths) are in naturopathic oncology and naturopathic homeopathy.  A board-certified naturopathic oncologist is recognized by the credential “FABNO” (“Fellow of the American Board of Naturopathic Oncology”) and a board-certified naturopathic homeopath is recognized by the credential “DHANP” (“Diplomate of the Homeopathic Academy of Naturopathic Physicians”).

 

What licensing examination do naturopathic physicians (naturopaths) take?¹

Naturopathic physicians (naturopaths, NMDs/NDs) take the Naturopathic Physicians Licensing Examinations (NPLEX), which consists of two parts – Part I and Part II.  NPLEX Part I is the Biomedical Science Examination (BSE) and is administered after the second year of naturopathic medical school.  NPLEX Part II is the Core Clinical Science Examination (CCSE) and is administered after the fourth year of naturopathic medical school.

Allopathic physicians (allopaths, MDs) take the United States Medical Licensing Examination (USMLE), which consists of three steps – Step 1, Step 2 (CK & CS), and Step 3.  USMLE Step 1 is administered at the end of the second year of allopathic medical school.  USMLE Step 2 CK (Clinical Knowledge) and USMLE Step 2 CS (Clinical Skills) are administered during either the third or fourth year of allopathic medical school.  USMLE Step 3 is administered during residency.

Osteopathic physicians (osteopaths, DOs) take the Comprehensive Osteopathic Medical Licensing Examination (COMLEX-USA), which consists of three levels – Level 1, Level 2, and Level 3.  COMLEX Level 1 is administered at the end of the second year of osteopathic medical school.  COMLEX Level 2-CE (Cognitive Evaluation) and COMLEX Level 2-PE (Performance Evaluation) are administered during either the third or fourth year of osteopathic medical school.  COMLEX Level 3 is administered during residency.  Osteopathic physicians are eligible to take the USMLE.

 

Who administers the licensing examination?²

The North American Board of Naturopathic Examiners (NABNE) administers the Naturopathic Physicians Licensing Examinations (NPLEX) to each naturopathic medical student (NMS) and naturopathic physician (NMD/ND).

The National Board of Medical Examiners (NBME) and the Federation of State Medical Boards (FSMB) co-sponsor administration of the United States Medical Licensing Examination (USMLE) to each allopathic medical student (MS) and allopathic physician (MD).

The National Board of Osteopathic Medical Examiners (NBOME) administers the Comprehensive Osteopathic Medical Licensing Examination (COMLEX-USA) to each osteopathic medical student (OMS) and osteopathic physician (DO).

 

Who is eligible to take the licensing examination?³

Naturopathic medical students who successfully complete their biomedical science coursework during their first two years are eligible to take the NPLEX Part I BSE.  Naturopathic medical students who successfully complete their clinical science coursework and clinical rotations during their second two years and who passed the NPLEX Part I BSE are eligible to take the NPLEX Part II CCSE.

 

In every state and territory of the USA, is there licensure of naturopathic physicians (naturopaths)?⁴

No, in every state and territory of the USA, there is not currently licensure of naturopathic physicians (naturopaths). Currently, naturopathic physicians (naturopaths) are licensed in 17 USA states; Washington, DC; and the USA territories of Puerto Rico and the Virgin Islands.  In 3 USA states, naturopathic physicians (naturopaths) are registered, instead of licensed.

States & Territories with Licensure of Naturopathic Physicians (Naturopaths)

• Alaska
• Arizona
• California
• Connecticut
• Florida
• Hawaii
• Kansas
• Maine
• Maryland
• Massachusetts
• Montana
• New Hampshire
• North Dakota
• Oregon
• Utah
• Vermont
• Washington
• District of Columbia
• Puerto Rico
• US Virgin Islands

States & Territories with Registration of Naturopathic Physicians (Naturopaths)

• Colorado
• Minnesota
• Pennsylvania

 

Are licensure requirements currently standardized in all USA states and territories?⁵

No, licensure requirements are not currently standardized in all USA states and territories.  In addition to the NPLEX, some states and territories have jurisprudence examinations that must be passed in order for licensure to be granted.  Utah is currently the only state that requires completion of at least 1 year of a naturopathic residency program in order to be eligible for licensure.

 

Is completion of a residency program required for licensure?⁶

At this time, completion of a naturopathic residency program is not required for naturopathic licensure, except in the state of Utah, where completion of at least 1 year of a residency program is required.

Completion of a residency program is generally required for allopathic licensure and osteopathic licensure, except in the state of Missouri, where an allopathic medical doctor (allopath) or osteopathic medical doctor (osteopath) can work as an assistant physician.

 

Why is completion of a residency program not required for licensure?⁷

Completion of a residency program is not currently required for licensure, other than in Utah, because of how the legislation has been written and passed in states that license or register naturopathic physicians.  A current barrier to requirement of completion of a residency program, other than in Utah, is that naturopathic residencies are privately funded and there are more graduating naturopathic physicians each year than there are available naturopathic residencies.

Allopathic and osteopathic residency programs are currently federally- and state-funded, mostly through Medicare, Medicaid, and the Veterans Administration (VA), which is why there are more programs and completion of a residency is able to be required for licensure.

 

What is the importance of licensure of naturopathic physicians (naturopaths) and regulation of naturopathic medicine (naturopathy) in every state?⁸

Public safety is the most important aspect of licensure of naturopathic physicians (naturopaths) and regulation of naturopathic medicine (naturopathy) in every state.  Not understanding the difference between naturopathic physicians (naturopaths, NMDs/NDs), who have attended CNME-accredited or provisionally-accredited four-year naturopathic medical schools to specialize in naturopathic medicine (naturopathy) and earned a Doctor of Naturopathic Medicine (NMD) or Doctor of Naturopathy (ND) doctoral-level professional degree to become licensed naturopathic physicians, as compared to laypersons, who have earned a diploma, distance-learning diploma, or distance-learning degree in “naturopathy” from a non-accredited institution, can be very confusing to the public.  It is critical to the safety of the public that the public is educated on the difference between a naturopathic physician (naturopath) versus a layperson claiming to practice naturopathic medicine (naturopathy).

Lay naturopaths are not licensed in any USA state or territory to practice naturopathic medicine, as it is not a part of their in-person or online diploma, distance-learning diploma, or distance-learning degree in naturopathy from a non-accredited institution program, however, they have founded their own organizations of which the titles imply that they are trained to do so, which is misleading and dangerous to the public.  The American Naturopathic Medical Association (ANMA), the American Naturopathic Medical Accreditation Board (ANMAB), the American Naturopathic Medical Certification Board (ANMCB), American Naturopathic Certification Board (ANCB), and the National Registry of Naturopathic Practitioners (NRNP) are all organizations for lay naturopaths who do not have training in naturopathic medicine.  This is very important for the public to understand, as it can be confusing to patients who do not have the education and resources available to them to distinguish between a naturopathic physician and a lay naturopath, but want to see a naturopathic physician (within permissible capacity of state laws) in a state that does not yet have licensure for naturopathic physicians and regulation of naturopathic medicine.

In states without licensure of naturopathic physicians and regulation of naturopathic medicine, there is no educational degree title protection nor are there protected professional titles of naturopathic physicians.  This means that, in those states, a naturopathic physician who earned a “Doctor of Naturopathy” (“ND”) doctoral degree from a CNME-accredited naturopathic medical school and a lay naturopath who earned a “Doctor of Naturopathy” online diploma from a non-accredited institution, which includes no medical training, can both use “ND” as initials after their name to signify their education, since there is no regulation of those initials in those states.  In many states with licensure of naturopathic physicians and regulation of naturopathic medicine, using “NMD” or “ND” after a person’s name to signify their education is restricted to naturopathic physicians who have earned an NMD or ND degree from a CNME-accredited naturopathic medical school, as those states only recognize the degree from CNME-accredited naturopathic medical schools.

Due to lack of available information, education, and resources, many people do not understand the difference between an educational degree title and a protected professional title.  Without licensure of naturopathic physicians and without regulation of naturopathic medicine, a person may see a lay naturopath using the initials “ND”, instead of a naturopathic physician, and not understand the difference in level of education and training.

Additionally, the ANMCB issues certification titles to lay naturopaths, who have taken and passed a “national exam” that has no name, including, “Board Certified Naturopathic Physician” (“BCNP”) and “Board Certified Naturopathic Doctor (“BCND”), which are used by lay naturopaths without training in naturopathic medicine in states without licensure for naturopathic physicians and regulation of naturopathic medicine.  This is confusing, misleading, and dangerous to patients, as they may think they are seeing a naturopathic physician, but may be actually seeing a lay naturopath.  It is important to know that, currently, the only two board certifications available to naturopathic physicians who have graduated from a CNME-accredited naturopathic medical school are in naturopathic oncology (FABNO) and homeopathy (DHANP).  If a person is using the title “Board Certified Naturopathic Physician” or “Board Certified Naturopathic Doctor,” that person is a lay naturopath without any medical training, not a naturopathic physician with training in naturopathic medicine.

It is crucial that education and resources are made available to the public to help patients understand the educational background and difference between naturopathic physicians, with training in naturopathic medicine, and lay naturopaths.

 

What is the importance of consistent scope of practice in each state and territory that accurately reflects the scope of training of naturopathic physicians (naturopaths)?⁹

Public safety and health are the most important aspects of consistent scope of practice in each state that accurately reflects the scope of training of naturopathic physicians (naturopaths).  Like all health care providers, having proper scope of practice that accurately reflects scope of training allows for safe and effective medical care to be delivered.  If proper scope of practice is not in place, for example, if in a state naturopathic physicians (naturopaths) do not have pharmaceutical prescribing rights that accurately reflect their scope of training, since patients may choose to see a naturopathic physician (naturopath) for any symptom or complaint, naturopathic physicians (naturopaths) may be unable to prescribe antibiotics for conditions such as strep throat, vaccines for vaccine-preventable diseases, epinephrine injectors for patients with risk of anaphylaxis due to allergic reaction, hormonal contraception, or emergency oxygen for life-threatening hypoxic (low oxygen) situations.  In emergency situations, deliverance of epinephrine or oxygen may be crucial to saving the life of a patient while emergency medical services (EMS) are on their way.  It is important that the scope of training of naturopathic physicians (naturopaths) is understood so that the scope of practice of naturopathic physicians (naturopaths) in each state is consistent and accurately reflects the scope of training.

 

Do naturopathic physicians (naturopaths) have the same public health duties as allopathic physicians (allopaths) and osteopathic physicians (osteopaths)?¹⁰

Yes, like allopathic and osteopathic physicians, naturopathic physicians are held liable for reporting diseases and conditions to a state department of health that are considered to be mandatory reportable diseases.

 

Can naturopathic physicians (naturopaths) lose their licenses to practice naturopathic medicine (naturopathy)?¹¹

Yes, naturopathic physicians can lose their licenses to practice naturopathic medicine, just like allopathic and osteopathic physicians can lose their licenses to practice medicine.

 

 

REFERENCES

1. What licensing examination do naturopathic physicians (naturopaths) take?

   • North American Board of Naturopathic Examiners.  NPLEX Examination Overview.  Accessed on 2016 Mar 25.
   • United States Medical Licensing Examination.  United States Medical Licensing Examination.  Accessed on 2016 Mar 25.
   • National Board of Osteopathic Medical Examiners.  COMLEX-USA:  Comprehensive Osteopathic Medical Licensing Examination.  Accessed on 2016 Mar 25.

2. Who administers the licensing examination?

   • North American Board of Naturopathic Examiners.  About NABNE.  Accessed on 2016 Mar 25.
   • National Board of Medical Examiners.  About the NBME.  Accessed on 2016 Mar 25.
   • Federation of State Medical Boards.  USMLE Step 3 Medical Licensing Examination.  Accessed on 2016 Mar 25.
   • National Board of Osteopathic Medical Examiners.  COMLEX-USA:  Comprehensive Osteopathic Medical Licensing Examination.  Accessed on 2016 Mar 25.

3. Who is eligible to take the licensing examination?

   • North American Board of Naturopathic Examiners.  Eligibility Requirements.  Accessed on 2016 Mar 25.

4. In every state and territory of the USA, is there licensure of naturopathic physicians (naturopaths)?

   • American Association of Naturopathic Physicians.  Licensed States & Licensing Authorities.  Accessed on 2016 Mar 25.
   • Legislature of the Virgin Islands – Office of the Code Revisor.  V.I.C. Title 27 Chapter 4 Section 192.  Accessed on 2016 Oct 05.

5. Are licensure requirements currently standardized in all USA states and territories?

   • American Association of Naturopathic Physicians.  Licensed States & Licensing Authorities.  Accessed on 2016 Mar 25.
   • Utah State Legislature.  Utah Code Title 58 Chapter 71 Part 3 Section 302 – Qualifications for licensure.  Accessed on 2016 Apr 03.
   • Legislature of the Virgin Islands – Office of the Code Revisor.  V.I.C. Title 27 Chapter 4 Section 192.  Accessed on 2016 Oct 05.

6. Is completion of a residency program required for licensure?

   • Utah State Legislature.  Utah Code Title 58 Chapter 71 Part 3 Section 302 – Qualifications for licensure.  Accessed on 2016 Apr 03.
   • Missouri General Assembly.  Missouri Revised Statutes, Chapter 334, Section 334.036.1 Assistant physicians–definitions–limitation on practice–licensure, rulemaking authority–collaborative practice arrangements.  Accessed on 2017 Mar 17.
   • Missouri Division of Professional Registration – Missouri Board of Registration for the Healing Arts.  Assistant Physicians.  Accessed on 2017 Mar 17.

7. Why is completion of a residency program not required for licensure?

   • Naturopathic Post-Graduate Association.  Current Residencies:  CNME-Approved Residency Training Sites.  Accessed on 2016 Mar 25.
   • American Medical Association.  Graduate Medical Education (GME) Financing Resource Page.  Accessed on 2016 Mar 25.
   • Association of Accredited Naturopathic Medical Colleges.  Post-Graduate Naturopathic Residencies.  Accessed on 2017 Mar 17.

8. What is the importance of licensure of naturopathic physicians (naturopaths) and regulation of naturopathic medicine (naturopathy) in every state?

   • Montana Legislative Services.  Montana Code Annotated 2015 Title 37 Chapter 26 Section 102 – Legislative finding — purpose.  Accessed on 2016 Apr 12.
   • Washington State Legislature.  Revised Code of Washington (RCW) Title 18 Chapter 18.36A.010 Intent.  Accessed on 2016 Apr 12.
   • American Naturopathic Medical Association.  American Naturopathic Medical Association.  Accessed on 2016 Mar 25.
   • American Naturopathic Medical Accreditation Board.  American Naturopathic Medical Accreditation Board.  Accessed on 2016 Mar 25.
   • American Naturopathic Medical Certification Board.  American Naturopathic Medical Certification Board.  Accessed on 2016 Mar 25.
   • National Registry of Naturopathic Practitioners.  National Registry of Naturopathic Practitioners.  Accessed on 2016 Mar 25.
   • Association of Accredited Naturopathic Medical Colleges.  Comparing ND & MD Curricula.  Accessed on 2016 Apr 03.
   • American Naturopathic Certification Board.  American Naturopathic Certification Board.  Accessed on 2016 Sep 21.

9. What is the importance of consistent scope of practice in each state and territory that accurately reflects the scope of training of naturopathic physicians (naturopaths)?

   • Washington State Legislature.  WACs Title 246 Chapter 836 Section 210 – Authority to use, prescribe, dispense and order.  Accessed on 2016 Sep 28.
   • Arizona State Legislature.  Arizona Revised Statutes Title 32 Chapter 14 Article 1 Section 32-1501 – Definitions.  Accessed on 2016 Sep 28.
   • Washington State Department of Health.  Medical Marijuana.  Accessed on 2016 Sep 28.
   • Arizona Department of Health Services.  Medical Marijuana – Physicians.  Accessed on 2016 Sep 28.
   • Arizona Department of Health Services.  Medical Marijuana Physician Certification Physician Information for All Qualifying Patients.  Accessed on 2016 Sep 28.
   • World Health Organization.  Health Topics – Pharmaceutical Products.  Accessed on 2016 Sep 28.

10. Do naturopathic physicians (naturopaths) have the same public health duties as allopathic physicians (allopaths) and osteopathic physicians (osteopaths)?

    • Association of Accredited Naturopathic Medical Colleges.  AANMC Core Competencies of the Graduating Naturopathic Student.  Accessed on 2016 Apr 12.
    • Vermont General Assembly.  The Vermont Statutes Online Title 26 Chapter 81 Section 4124 – Reporting Contagious and infectious diseases; death certificates.  Accessed on 2016 Apr 12.
    • Montana Legislative Services.  Montana Code Annotated 2015 Title 37 Chapter 26 Section 303 – Public health duties of naturopathic physicians.  Accessed on 2016 Apr 12.
    • Colorado Revised Statutes.  Title 12 Article 37.3 Section 105(3)(a).  Accessed 2016 Apr 12.
    • Arizona State Legislature.  Arizona Revised Statutes Title 32 Chapter 14 Article 3 Section 32-1554 – Observance of public health laws and regulations.  Accessed on 2016 Sep 18.
    • Oregon State Legislature.  Oregon Revised Statutes (ORS) 2015 Edition Volume 15 Chapter 685 Section 685.040 – Application of health laws.  Accessed on 2016 Sep 18.
    • Legislature of the Virgin Islands – Office of the Code Revisor.  V.I.C. Title 27 Chapter 4 Section 192.  Accessed on 2016 Oct 05.

11. Can naturopathic physicians (naturopaths) lose their licenses to practice naturopathic medicine (naturopathy)?

    • The Office of the Revisor of Statutes, State of Minnesota.  2015 Minnesota Statutes Chapter 174E.30 – Discipline; Reporting.  Accessed on 2016 Apr 12.
    • Connecticut’s Official State Website.  General Statutes of Connecticut – Volume 7 Title 20 Chapter 373 Section 20-42.  Accessed on 2016 Apr 12.