FAQs

For information regarding the scope of practice for California Naturopathic Doctors, be sure to visit our Scope of Practice pageIf our FAQ page and Scope page doesn't answer your question, please post it in our private Facebook group for NDs

Licensure and Continuing Education Requirements in California

  1. How do I become a licensed naturopathic doctor in California?
  2. When does my ND license expire? How do I renew my license? 
  3. What are the Continuing Education requirements for naturopathic doctors in California?
  4. What happens if I move out of state or my California licenses lapses?
  5. Do I need to contact the NMC if I move my personal address?
  6. What is a Furnishing Number? How do I get a Furnishing Number?
  7. What is a DEA number? How do I get my DEA number?
  8. What is an NPI number? How do I get my NPI number?
  9. What if my question is not answered here? 

Laws Relating to Your Business and Practice
  1. Can I call myself "doctor"? Do I always need to specify "naturopathic doctor"?
  2. Can I call my office a "medical clinic"?
  3. How can I advertise my services? 
  4. How should I prepare for a house call? 
  5. Should I be charging sales tax for my services?
  6. Can I charge my patients additional fees for lab test results?
  7. Am I required to have malpractice insurance in California? Am I required to have general liability insurance? 
  8. What are my malpractice insurance options? 
  9. What do I need to do to become compliant with the new HIPAA regulations?
  10. What information do I need to include on my prescription pad? Do I need to list my supervising MD/DO's information? 
  11. Beyond registering with the CURES 2.0 program, is there anything else NDs need to know about compliance with CURES?

Laws Relating to the Scope of Practice for NDs in California
  1. What legend and controlled drugs can an ND prescribe?
  2. Do I need a DEA number to prescribe hormones?
  3. How do I find a supervising MD or DO? Can I use the CNDA’s ND Supervision Agreement as a complete legal contract? 
  4. Can NDs dispense prescription medication?
  5. Can NDs employ and give orders to an RN or LVN?
  6. What are the training requirements for Naturopathic Assistants?
  7. What are CLIA Waived tests? Do I need to become a Lab Director for tests like salivary hormone tests or finger-prick food allergy tests?
  8. Can NDs sign off on vaccine waiver forms? How has SB 277 affected this? 
  9. Can NDs request the release of medical records from other NDs, MDs, DOs and hospitals?
  10. Are NDs able to practice telehealth? 

Performing IV Therapy in California
  1. What are the requirements for naturopathic doctors to perform IV therapy in California?
  2. I have met the necessary training requirements to practice IV Therapy. Do I need to have something on file with any agency or pharmacy?
  3. Is it legal for me to do IM nutrient injections if I haven’t yet attained the twenty-five IV therapy training hours described in the 2013 IV Clarification law?

Continuing Education: Questions For CE Presenters
  1. How long is a CE course available for renewal for another live presentation once it has been approved by the CNDA?
  2. How long is a CE course available for self-study once it has been approved by the CNDA?
  3. Why is the California Naturopathic Medicine Committee more limited than other licensing boards on what they will and will not accept for CEs?
  4. Why are the recordings of ‘live’ webinars only offered as self-study hours after the webinar?

Patient Insurance
  1. Is it possible for labs I order to be covered by my patients’ insurance? Can I charge my patients additional fees for lab test results?
  2. How do my patients apply for insurance reimbursement?

For Pharmacists
  1. As a pharmacist, may I fill an ND’s prescription for Armour Thyroid if the ND doesn't have a supervising MD/DO?
  2. If a pharmacist has questions about filling a prescription from an ND, where can he/she obtain help and information? 

 


Licensure and Continuing Education Requirements in California
1) How do I become a licensed naturopathic doctor in CA?
 

In order to qualify for licensure, graduates from one of the seven accredited naturopathic medical schools must pass Parts I and II of the Naturopathic Physicians Licensing Examination (NPLEX). The NPLEX is a rigorous, standardized licensing examination that is used in all states that license NDs. It is administered by the North American Board of Naturopathic Examiners (NABNE) twice a year at six different test sites throughout the United States and Canada.

After passing the NPLEX, naturopathic medical students can apply for CA licensure through the state licensing body, called the Naturopathic Medicine Committee (NMC). The initial application fee is $400, and the initial licensing fee is between $433-800 (see question #2 below for an explanation of this). The fee schedule can be found here.

To apply:

 

2) When does my ND license expire? How do I renew my license?
 

In California, your license must be renewed every two years. You license expires at midnight on the last day of your birth month, every two years. Your first licensing period will likely be less than two years, and your licensure fees will be prorated to reflect this - hence the initial licensing fee varies from $433-800.

For example, your birthday is 09/10/80. Your apply for your ND license and receive your license on 01/01/2014. Your license will expire at midnight on 09/30/2015, meaning your initial license lasts for 20 months, rather than 24, and your licensure fee will be prorated to reflect this (in this case, they would be $667 instead of $800). Your next license renewal date will be 09/30/17, then 09/30/19, and so on. Each license renewal will cost $812. A $12 increase was added to the renewal fee for the implementation of the CURES database. For the NMC fee schedule, click here. For details on the $12 increase, click here.

If you file to renew your license more than 30 days after the expiration date, your renewal is subject to a $150 late fee.

To renew your license, visit the NMC's Forms & Publications webpage.

 


3) What are the Continuing Education requirements for naturopathic doctors in California?
 

During your first licensing period, you are exempt from CE requirements. That means for the first two years you are licensed, you do not need to take any Continuing Education courses before renewing your license. After your first renewal, you will need to take 60 hours of CE courses before your second renewal. Using the example above, you will not need any CEs from 01/01/2014 through 09/30/2015, but you will need to take 60 hours of CE courses between 09/30/2015 and 09/30/2017. Additionally, and importantly, any webinars or conferences attended from 01/01/2014 to 09/30/2015 will not count towards your 2017 renewal.

Visit our CA CE Requirements page for more information on the specific breakdown of course requirements, and what courses can be used to meet these requirements.


4) What happens if I move out of state or my California licenses lapses?
 

If you decide to move out of state and do not plan to continue practicing in CA, you may write to the NMC to indicate you would like your license to go inactive. If you would like to continue practicing in California, you must maintain an active license. Should you ever wish to reinstate an inactive license, you must pay all accrued renewal fees since your last license renewal, and demonstrate that you have satisfied all CE requirements for each license renewal period. For instance, if your license goes inactive for 8 years, you will need to pay $3200 for 4 license renewals, and demonstrate that you have completed 240 hours of CE for the 4 license renewal periods.

If your license lapses (meaning you did not write to the NMC to file for inactive license, and simply did not pay renewal fees), you have 3 years to renew your license. Again, you are responsible for all accrued renewal and late fees, as well as CE requirements. After 3 years, you must apply for a new license. In this case, you are also still responsible for all accrued renewal and late fees, as well as CE requirements. 

You can find this information in the NMC's Regulations on Licenses.


5) Do I need to contact the NMC if I move my personal address?
 

Yes, you are required to maintain a current address and current contact information with the NMC at all times. To do this, visit the NMC's Licensees page and click "Change your address online," OR fill out this form and mail it to the NMC.


6) What is a Furnishing Number? How do I get a Furnishing Number?
 

A Furnishing Number is the unique code given to licensed California naturopathic doctors to be used for prescribing. It is typically the doctor’s license number preceded by the letters “NDF”. This number can be used to independently prescribe natural and synthetic hormones (except scheduled hormones like testosterone and hCG). A DEA number is necessary to prescribe any scheduled hormones.

The application for a furnishing number is part of the application for your ND license. In order to qualify for a furnishing number, the NMC requires that an applicant must show evidence of 48 hours of instruction in pharmacology that included the pharmacokinetic and pharmacodynamic principles and properties of the drugs to be ordered or furnished. To comply with this requirement, the instruction must have been offered by one of the following (Source: NMC Regulations Section 4212):

  • An approved naturopathic medical school.
  • An institution of higher learning that offers a baccalaureate or higher degree in medicine, nursing, pharmacy, or public health.
  • An educational institution or provider with standards and course content that are equivalent to the educational standards approved by State Law and by the Bureau.

Most newer NDs will have met the above requirements through their curriculum.


7) What is a DEA number? How do I get my DEA number?
 

A DEA number is a unique identifier used to prescribe controlled substances (otherwise known as scheduled drugs). NDs can independently prescribe natural and synthetic hormones, but need a DEA number to prescribe any scheduled hormones (i.e. testosterone, hCG, GH, etc). Naturopathic doctors are legally allowed to prescribe Schedule III –V controlled substances under the supervision of a MD or DO (for more information on Supervision, see Laws Relating to the Scope of Practice). When prescribing controlled substances, an ND must use his or her own DEA number on a controlled prescription pad - not the supervising doctor's DEA number.

To apply for a DEA number, you must have a furnishing number (NDF) issued by the NMC. 

  • To begin the application process, visit the DEA New Registration Applicant page.
  • In the section for Business Activities/Schedules, apply as a "Mid-Level Practitioner" and select "Naturopathic Doctor".
  • Check schedules III Narcotic, III Non-Narcotic, IV & V, then check the boxes for these schedules under "Prescribe."

To prescribe scheduled drugs, you need to use a tamper-proof prescription pad. To order a prescription pad, visit the CA Pharmacy Board's Approved List of Security Prescription Printers.

Your DEA number must be renewed every 3 years, at a cost of $731. You will need two DEA numbers if you are practicing in two states. You may also choose to transfer a DEA number from one state to another, and there is no fee to do this. If you are dually licensed, for example as an ND and pharmacist, you will need two DEA numbers.For more information on renewing or transferring your DEA number, visit the DEA Office of Diversion Control Registration page. You can also call the Drug Enforcement Administration Registration Unit at 1-800-882-9539. 

 

8) What is an NPI number? How do I get my NPI number?
 

The National Provider Identifier (NPI) is a unique 10 digit code used to identify health care providers in standard transactions, such as health care claims. NPIs may also be used to identify health care providers on prescriptions or lab orders, in coordination of benefits between health plans, in patient medical record systems, and in other ways. It was created in response to the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which mandated the adoption of a standard unique identifier for health care providers.

To apply for you NPI online, visit the National Plan & Provider Enumeration System (NPPES) Application website. They also have a helpful Application Instructions page. You will be asked for standard identifying information and will have to select your provider taxonomy (naturopath is specified after you select “other” in the initial menu). There is no fee to apply. Numbers are usually issued in 2-7 business days. 


9) What if my question is not answered here? If you are a naturopathic doctor, you can join our private Facebook group for NDs only and ask your question there! 


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Laws Relating to Your Business and Practice 

1) Can I call myself "doctor"? Do I always need to specify "naturopathic doctor"?
 

You can refer to yourself as "Doctor" or "Dr." in written materials, as long as somewhere in the document you specify "Naturopathic Doctor" or "ND." For clarity and ease, the CNDA encourages use of the following designation: Dr. John Smith, ND.  From the Naturopathic Practice Act
 

"A naturopathic doctor who uses the term or designation "Dr." shall further identify himself or herself as "Naturopathic Doctor," "Licensed Naturopathic Doctor," "Doctor of Naturopathic Medicine," or "Doctor of Naturopathy" and shall not use any term or designation that would tend to indicate the practice of medicine, other than naturopathic medicine, unless otherwise licensed as a physician and surgeon, osteopathic doctor, or doctor of chiropractic."
 

Graduates from an accredited naturopathic school who passed the NPLEX exams may not use any designation of "ND" until they are licensed through the Naturopathic Medicine Committee. 


2) Can I call my office a "medical clinic"?
 

Legally, any healthcare corporation run by at least 50% naturopathic doctors must designate itself as a naturopathic corporation in all legal paperwork (filing status documents, business license, taxes, etc). If a naturopathic doctor owns 49% or less of a clinic, the clinic does not need to be designated a naturopathic corporation in legal documentation. Section 3674 of the CA Business and Professions Code reads: "The name of a naturopathic corporation and any name or names under which it may render professional services, shall contain the words "naturopathic" or "naturopathic doctor" and, as appropriate, wording or abbreviations denoting its status as a corporation." More information can be found here in the California Business & Professions Code.

However, your clinic’s "doing business as" (DBA) title is more flexible and can be referred to as a "medical clinic." 
 

3) How can I advertise my services? 
 
B12 Happy Hours. You cannot offer a lower price for B12 shots for those who are able to come during a set period of time. You CAN offer a B12 Happy Hour where patients can come without having an appointment, but they must pay the same fees you charge at other times of the week.

Groupon. This constitutes a fee for referral service and is against current law. 

Package Deals with an Expiration Date. You cannot require that a patient get a medical treatment or service within a specific period of time.

Monthly Discounts. Similar to B12 Happy Hours, you are not allowed to offer different patients different fees. This includes monthly specials for all patients of a certain type.


Additional details about the laws regarding how you may advertise can be found here.
 

4) How should I prepare for a house call? 
 

NDs can and do make house calls. Be sure to check with your malpractice insurance carrier to confirm your coverage for locations outside of your specified office. You do not need to see a patient prior to making a house call and no additional certification is required.

In the interest of safety for both the doctor and patient, the CNDA strongly encourages you not to start home visits until you have established rapport/ trust with the patient. It is also important to note that if you go to a home and end up referring the patient to an emergency room or other health care facility, the patient should make their own travel arrangements and/or be held financially responsible for their transportation.
 

5) Should I be charging sales tax for my services?


No, you do not need to charge sales tax for your services. However, pre-formed supplements sold in your office are taxable. This does not include tinctures and other remedies made in your office. You must register with the California Board of Equalization before you begin to sell any of these taxable supplements from your office. We also recommend familiarizing yourself with any local city taxes, as well as the current California sales tax.


6) Can I charge my patients additional fees for lab test results?


You are are allowed to include additional fees for lab results when billing patients if you disclose to the patient:

  1. The amount the lab charged you for the test on the patient's bill, and
  2. The service you are providing that necessitates the additional fee, and
  3. The name and address of the lab on any billing documents.

If you do not include this information, you could potentially be subject to sanctions. CA Business & Professions Code Section 655.5 details the regulations regarding this subject more fully.
 

7) Am I required to have malpractice insurance in California? Am I required to have general liability insurance?

If your practice is a sole proprietorship, you are not required to have malpractice insurance in CA. If you are an employee of a corporation, typically it is the corporation's responsibility to acquire malpractice insurance to cover your services.


On the other hand, naturopathic corporations are required to have malpractice insurance. The regulations regarding malpractice insurance requirements for California naturopathic corporations are as follows: (Article 11, Section 4266 of the California Code of Regulations)

"§ 4266. Security for Claims Against a Naturopathic Corporation.

(a) When a naturopathic corporation provides security by means of insurance for claims against it by its patients, the security shall consist of a policy or policies of insurance insuring either the corporation or all the employed licensed persons rendering such naturopathic services against liability imposed by law for damages arising out of the rendering of, or failure to render, naturopathic services by the corporation in an amount for each claim of at least $50,000 multiplied by the number of employed licensed persons rendering such naturopathic services and an aggregate maximum limit of liability per policy year of at least $150,000 multiplied by the number of such employees; provided that the maximum coverage shall not be required to exceed $150,000 for each claim and $450,000 for all claims during the policy year, and provided further that the deductible portion of such insurance shall not exceed $5,000 multiplied by the number of such employees.

(b) All shareholders of the corporation shall be jointly and severally liable for all claims established against the corporation by its patients arising out of the rendering of, or failure to render, naturopathic services up to the minimum amounts specified for insurance under subdivision (a) hereof except during periods of time when either the corporation or all the employed licensed persons rendering naturopathic services provide and maintain insurance for claims by its patients arising out of the rendering of, or failure to render naturopathic services. Said insurance when provided shall meet the minimum standards established in subdivision (a) above." 

What about general liability? 
If you are an employee, the clinic's policy will cover you. If you are an independent contractor OR if you rent space you need to get your own general liability coverage. 

8) What are my malpractice insurance options?
 

Malpractice coverage in California is available for naturopathic doctors through several companies, including:



9) What do I need to do to become compliant with the new HIPAA regulations?
 

Starting September 23, 2013, all businesses covered by HIPAA must comply with HIPAA's privacy rules and regulations. While the CNDA has not compiled an overview of the new regulations and requirements, the CNDA does offer a Business Basics Self-Study Webinar, HIPAA for Naturopathic Doctors in a High Tech World in our shopping cart. Several other organizations have also put together information for practitioners who are currently working on compliance. We recommend the following resources:


The Omnibus HIPAA/HITECH Final Rule Summer Webinar Series 
This is a free four part webinar series, produced by WEDI in collaboration with DHHS, that provides a great tutorial of the HIPAA/HITECH rules. The first session is a broad overview of the rules and each subsequent session drills down into specifics, such as breach notification and drafting business associate agreements

The Network for Public Health's Fact Sheet 
This fact sheet reports on the recent changes to HIPAA. The Network for Public Health Law provides insightful legal assistance, helpful resources and opportunities to build connections for local, tribal, state and federal officials; public health practitioners; attorneys; policy-makers; and advocates.

The AANP's HIPAA Compliance Page
The American Association of Naturopathic Physician's has put together a HIPAA Survival Guide and Action Steps for Compliance that is available to AANP members.

The HHS Summary of the HIPAA Privacy Rule Booklet 
Produced by the US Dept. of Health & Human Services, this document explains many provisions of the new HIPAA regulations in plain language. 
 

10) What information do I need to include on my prescription pad? Do I need to list my supervising MD/DO's information? 
 

Prescription pads are required to include:

1. The name or names and address of the patient or patients
2. The name and quantity of the drug or device prescribed and the directions for use
3. The date of issue
4. Either rubber stamped, typed, or printed by hand or typeset, the name, address, and telephone number of the prescriber, his or her license classification, his or her National Provider Identification (NPI) number, and his or her ND furnishing number/DEA number
5. A legible, clear notice of the condition or purpose for which the drug is being prescribed, if requested by the patient or patients
6. If in writing, signed by the prescriber issuing the order

Prescription pads do not need to include your supervising MD/DO's information. 
 

11) Beyond registering with the CURES 2.0 program, is there anything else NDs need to know about compliance with CURES?

You are not required to report to CURES what you prescribe and administer to patients. However, prescribers must file reports of dispensed controlled substances. California Health & Safety Code Section 11165(d) requires dispensing pharmacies, clinics, or other dispensers of Schedule II through IV controlled substances to provide specified dispensing information to the Department of Justice on a weekly basis in a format approved and accepted by the DOJ.
 
For NDs, with each prescription of a Schedule III, or Schedule IV controlled substance, the dispensing clinic or other dispenser shall report the following information to the Department of Justice as soon as reasonably possible, but not more than seven days after the date a controlled substance is dispensed:
 
(1) Full name, address, and, if available, telephone number of the ultimate user or research subject, as well as the gender, and date of birth of the ultimate user.

(2) The prescriber’s category of licensure, license number, national provider identifier (NPI) number, if applicable, the federal controlled substance registration number, and the state medical license number of any prescriber using the federal controlled substance registration number of a government-exempt facility.

(3) Pharmacy prescription number, license number, NPI number, and federal controlled substance registration number.

(4) National Drug Code (NDC) number of the controlled substance dispensed.

(5) Quantity of the controlled substance dispensed.

(6) ICD-10 Code classifying the disease.
 
(7) Number of refills ordered.

(8) Whether the drug was dispensed as a refill of a prescription or as a first-time request.

(9) Date of origin of the prescription.

(10) Date of dispensing of the prescription.
 
Additionally, all CURES 2.0 users are required to renew their accounts on an annual basis. Users receive renewal notifications on the renewal date and 30 days after the user’s one-year renewal date.

Full text of the Health and Safety Code Section 11165 can be downloaded here. More compliance, reporting, and access information from the Department of Justice can be found here.
 

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Laws Relating to the Scope of Practice for NDs in California


1) What legend and controlled drugs may an ND prescribe?

NDs are independently allowed to prescribe, furnish, order or administer all synthetic and natural hormones, as well as epinephrine. To prescribe, furnish, or order any other legend drugs (i.e. antibiotics, hypertensives, etc.) or Schedule III-V Controlled Substances, an ND must have signed a supervision agreement with an MD or DO licensed in California. The supervision agreement must include a formulary and standardized protocols or procedures which include: "which naturopathic doctors may furnish or order drugs, which drugs may be furnished or ordered under what circumstances, the extent of physician and surgeon supervision, the method of periodic review of the naturopathic doctor's competence, including peer review, and review of the provisions of the standardized procedure." The law specific to supervision of prescribing can be found here (Section 3640.5). 

For more information about how to establish a supervisory agreement and a sample template of an agreement, visit our Supervision Agreement page. You will need to be a CNDA member and logged into the website to access this page. We strongly encourage you to have a lawyer look over your individualized supervisory agreement before you and your supervising MD/DO sign the document.

Additionally, NDs may only order or furnish Schedule III controlled substances in accordance with a patient-specific protocol approved by the treating or supervising physician. NDs should document an email, call, fax, etc. to their supervising MD/DO regarding the patient-specific protocol when ordering or furnishing Schedule III substances.

A licensed pharmacist is allowed to request a copy of the section of the naturopathic doctor's standardized procedure relating to controlled substances when there is uncertainty about the naturopathic doctor furnishing the order.

For quick reference, below are lists of all scheduled drugs. NDs can not administer or prescribe Schedules I or II. 
Under MD/DO supervision, NDs can prescribe legend and Schedule IV-V controlled substances, and prescribe Schedule III drugs under a patient-specific protocol checked by a supervising MD or DO.

Schedule I Drugs - http://www.drugs.com/article/csa-schedule-1.html
Schedule II Drugs - http://www.drugs.com/schedule-2-drugs.html
Schedule III Drugs - http://www.drugs.com/schedule-3-drugs.html
Schedule IV Drugs - http://www.drugs.com/schedule-4-drugs.html
Schedule V Drugs - http://www.drugs.com/schedule-5-drugs.html
Legend Drugs include substances that require a prescription but are not listed among the scheduled drugs above. 


2) Do I need a DEA number to prescribe hormones?

Yes, hormones that are also a controlled substance (Schedule III-V) require a DEA number. Examples of scheduled hormones are: testosterone, human growth hormone, and growth hormone. A drug furnishing number is sufficient to prescribe all other hormones.
 

3) How do I find a supervising MD or DO? Can I use the CNDA’s ND Supervision Agreement as a complete legal contract?
 

Visit our Supervision Agreement page for information on how to find a supervising doctor. You will need to be a CNDA member and logged into the website to access it.

Our Supervision Agreement template will need to be adjusted according to your own specific protocol arrangements with your supervising doctor. We strongly recommend having a lawyer review it once you have customized it to your needs.

 

4) Can NDs dispense medication?


Technically, NDs can dispense medication - however, you must ensure that you are meeting all applicable state laws when dispensing medication (e.g. pharmacy laws, labelling laws, etc.).

 

5) Can NDs employ and give orders to an RN or LVN?

No. NDs who work in a naturopathic corporation can hire RNs, LVNs and other medical personnel but NDs cannot give orders to any medical practitioner beyond naturopathic medical assistants and physical therapists. For the laws regarding training and scope of Naturopathic Assistants, see the NMC's page: Naturopathic Assistants.

 

6) What are the training requirements for Naturopathic Assistants?
 

For the laws regarding training and scope of Naturopathic Assistants, see the NMC's page: New Laws Effective January 1, 2011.



7) What are CLIA "waived" tests? Do I need to become a Lab Director for tests like Salivary hormone tests or Finger-prick food allergy tests?

 

In California, NDs must become a Lab Director to perform certain specimen tests in office, called CLIA "waived" tests (examples are listed below). Applications for the Lab Director's License are available through the Laboratory Field Services division of the CA Department of Public Health. For instructions on applying for Lab Director status, refer to this page from the CA Department of Public health: https://www.cdph.ca.gov/programs/lfs/Pages/NewClinicalLaboratoryRegistration.aspx

Specimens collected in office but sent out for analysis are not considered CLIA waived tests, and therefore do not require lab director status.

The waived tests are any test that are over the counter and pose no risk to the patient, with very reliable results that are difficult to misinterpret. Basically, any test that a patient could take home and do themselves, including interpreting the results, is a CLIA waived test. More information about these tests can be found on the CDC's Waived Tests page.

A complete list of CLIA waived tests can be found here. Common CLIA waived tests include: 

1. Dipstick or Tablet reagent urinalysis (non-automated) for the following: Bilirubin, Glucose, Hemoglobin, Ketone, Leukocytes, Nitrite, pH, Protein, Specific gravity, or Urobilinogen
2. Fecal occult blood
3. Ovulation tests - visual color comparison tests for luteinizing hormone
4. Urine pregnancy tests - visual color comparison tests
5. Erythrocyte sedimentation rate-non-automated
6. Hemoglobin-copper sulfate - non-automated
7. Blood glucose by glucose monitoring devices cleared by the FDA specifically for home use
8. Spun microhematocrit
9. Hemoglobin by single analyte instruments with self contained or component features to perform specimen/reagent interaction, providing direct measurement and readout
 

8) Can NDs sign off on vaccine waiver forms? 

NDs who have a supervising agreement in place with an MD or DO can sign off on the vaccine waiver form after providing patients appropriate education materials about the risks and benefits of vaccines. The California Immunization Coalition has informational documents to distribute to patients available here. For more information about the supervisory agreement, see #3 above. 

On June 30th, 2015, Governor Jerry Brown signed SB 277 into law. SB 277 went into effect on January 1, 2016. At this time, no new personal belief or religious exemption waivers will be obtainable. Only medical exemptions will be allowed. NDs cannot write for medical exemptions. For additional details on SB 277, please see our page, SB 277 - Vaccines and Personal Belief Waivers
 

9) Can NDs request the release of medical records from other NDs, MDs, DOs and hospitals?  

Yes. NDs can request the release of medical records from other NDs, MDs, DOs and hospitals. The patient must first request the transfer of records. For a sample template of a Release of Records form, visit our Office Forms and Practice Guides page. You will need to be a CNDA member and logged into the website to access this page.  
 

10) Are NDs able to practice telehealth? 

Yes. NDs are able to diagnose, consult, treat, educate and facilitate care management over email, phone and other communications technologies. Telehealth in California was expanded to all health care providers through AB415, the Telehealth Advancement Act. The full text of AB415, establishing all licensed health care providers in California as able to practice telehealth, can be found here

 

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Performing IV Therapy in California


1) What are the requirements for naturopathic doctors to perform IV therapy in California?


To perform IV therapy in CA, you must have completed a qualifying course on IV therapy from a course provider approved by the NMC. As of 9/30/16, approved providers include Bastyr University (2007 and forward), NCNM (2009 and forward), and IV Nutritional Therapy for Professionals (all years). The most recent list of providers can be found here: NMC IV Therapy Approved Providers. Only courses offered through Approved Providers qualify NDs to perform IV therapy in California. For more information on the laws regulating IV therapy, see the NMC's New Laws Effective January 1, 2013.

IMPORTANT! If you are going to be performing IV Therapy in California, you need to be compliant with CA OSHA standards. This means your office must have standards in place for maintaining sterility, staff training, what to do in case of a medical emergency, etc. The CNDA is working on creating an OSHA resource for our members, but in the mean time you can access information directly here: Cal OSHA Injury and Illness Prevention Program e-tool.
 

2) I have met the necessary training requirements to practice IV Therapy. Do I need to have something on file with any agency or pharmacy?
 

No. You must complete the necessary training requirements to be able to legally practice IV Therapy in your practice, but it is your responsibility to confirm that you are in compliance. You do not need to have a certificate on file with any agency. However, it is recommended that you retain proof of your training for your own records, in the case it was ever called into question via a complaint or suit.
 

3) Is it legal for me to do IM nutrient injections if I haven’t yet attained the twenty-five IV therapy training hours described in the new law?


Yes. Intramuscular injections are within the California ND scope of practice, and injectable nutraceuticals are now a part of the ND independent formulary.
 

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Continuing Education: Questions For Presenters

1) How long is a CE course available for renewal for another live presentation once it has been approved by the CNDA?
 

Your approved CE course is available for renewal for a maximum of 2 years after the date the course was accredited. Renewal is defined as any reoccurence of the accredited live CE event. Cost of renewal is $25 per CE hour.

There is a time limit for renewal because medical information is continually updated. Therefore a need for periodic review of content to ensure the information being presented has not become out-dated is necessary.
 

2) How long is a CE course available for self-study once it has been approved by the CNDA?

Self-study is an additional charge. Self-study courses are likewise approved for a maximum 2 year duration. An agency pays a one time additional cost of $25 per CE credit to offer any CE as an enduring self-study option for a maximum of 2 years after CE accredidation.
 

3) Why is the California Naturopathic Medicine Committee more limited than other licensing boards on what they will and will not accept for CEs?

The Sunrise Document SB907 set forth strict licensing guidelines in the Business and Professions code for Naturopathic Doctors to gain and keep licensure in California. The bill specifically lists those agencies which can issue CEs for California Naturopathic Doctors. The Department of Consumer Affairs is involved in tracking CE courses being issued by associations such as the CNDA.
 

4) Why are the recordings of ‘live’ webinars only offered as self-study hours after the webinar?

Live webinars, once past and offered as a recording, default to self-study. It is the 'participation' aspect of a live webinar where you can ask questions and get answers through the on-line chat feature that allows credits to be considered 'live' credits. Being present on-line and having the ability to interact with the presenter is what makes it possible to receive live webinar credit during the original presentation but not through the later recorded version.

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Patient Insurance


1) Is it possible for labs I order to be covered by my patients’ insurance?

Yes, if your patients have a PPO and if the lab is contracted with the insurance provider. Basic blood orders are covered, however saliva hormone panels, nutrient panels, food Elisa sensitivity panels and other “functional medicine” labs are often deemed outside the conventional medicine standard of care or “not medically necessary" and are usually not covered by insurance.
 

2) How do my patients apply for insurance reimbursement?
 

The CNDA has recently compiled a comprehensive resource on all insurance-related issues that covers how to assist your patients in filing for reimbursement, filing appeals and submitting complaints. Visit our Insurance page (www.calnd.org/insurance) to learn more and get involved in the effort to increase insurance coverage of naturopathic medicine in California!

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For Pharmacists

1) As a pharmacist, may I fill an ND’s prescription for scheduled hormones if the ND doesn't have a supervising MD/DO?

Yes. According to the Naturopathic Practice Act, “Notwithstanding the requirements of Section 3640.5 or any other provision of this chapter, a naturopathic doctor may independently prescribe epinephrine to treat anaphylaxis and natural and synthetic hormones” (emphasis added). Source: Section 3640.7 of the California Business & Professions Code.

The Naturopathic Medicine Committee has also posted a notice on their website regarding the independent hormone prescription privileges of licensed Naturopathic Doctors. That notice can be found here.

2) If a pharmacist has questions about filling a prescription from an ND, where can he/she obtain help and information?

The regulations dealing with the prescribing authority of NDs can be found in the Business and Professions Code sections 3640-3645. To review these provisions, you may access the Laws & Regulations section of the Naturopathic Medicine Committee’s website.
 

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