The Federation appreciates this opportunity to comment on the exposure draft for Proposed Regulation 16-4953-ND. While the FNMRA supports the majority of the language in the exposure draft, there two areas we see as problematic for proper regulation of naturopathic doctors in the Commonwealth:

1.       The use of terminology that is inconsistent with naturopathic medical education, scope of practice, and regulation as outlined in HB 516.

2.       The informed consent and advertising section of the exposure draft that does not allow registered naturopathic doctors (N.Ds) to say they practice medicine or use the terms “physician, medicine or medical” in their advertising. This language is contrary to the education and competence of qualified naturopathic doctors.

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