Note:  The CNDA does not, and cannot, provide legal advice to our membership.  Those seeking legal advice are advised to consult with a licensed attorney with appropriate experience. 

Periodically, the Naturopathic Medicine Committee will send out urgent information about changes to the law or other regulatory changes that may affect your license.  It is strongly suggested that you sign up for our email communications by registering at 



  • Licensure Concerns? - Contact the NMC 
  • CE Questions? Visit the CE section of our website 
  • Scope of Practice Questions? Check out this FAQ, the Naturopathic Doctors Act, or contact the NMC
  • If you're having trouble downloading a certificate from a webinar or conference, please try using a different browser or re-starting your computer and trying again. If the link to your self - study certificate is not working, please copy the link into your browser
  • If your membership payment failed, you must pay the outstanding invoice and update your credit card on file in order to bring membership up to date.  Please log in to do so.
  • If you are unable to renew your membership, first check for unpaid invoices from previously failed or missed member payments. Once all invoices are up to date, you will be able to renew online. Please log in to your account using the log in form on the left hand side of this page to do so. 



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





E-Prescribing Mandate

Beginning January 1, 2022, all prescriptions issued by a licensed healthcare practitioner to a California pharmacy must be submitted electronically. Healthcare practitioners who fail to meet the requirements of AB 2789 may be subject to disciplinary action. The law provides certain exemptions, including if transmission of the prescription is temporarily unavailable because of technological or electrical failure; if the prescription is dispensed by a pharmacy located outside California; or if the prescription is issued to a patient who has a terminal illness pursuant to Section 11159.2 of the Health and Safety Code. The complete list of exemptions is included within Business and Professions Code section 688.  The full text of the bill may be reviewed here.

Under this law, a healthcare practitioner who does not issue a controlled substance prescription as an electronic data transmission prescription due to technological or electrical failure shall document the reason in the patient’s medical record as soon as practicable, and within 72 hours of the end of the technological or electrical failure.

Although prescriptions will be issued electronically, the Naturopathic Medicine Committee recommends that all licensed prescribers have paper prescription forms available that meet the requirements of AB 149 should a technological or electrical failure prevent a prescription from being issued electronically. A list of the approved security prescription printers is available on the State Attorney General’s website as well as the Prescribing section of this FAQ. 

The CNDA has created this summary and FAQ page for members to better understand the law and how to comply; you must be logged in as a member to view this content.  Additionally, the California Pharmacy Board has put together a list of FAQs here.  
        CURES Compliance
CURES stands for Controlled Substance Utilization Review and Evaluation System and is California's way of monitoring controlled substance use and prescribing.  Under California law (Health and Safety Code Section 11165.1) all California-licensed healthcare providers authorized to prescribe Schedule II, II, and IV controlled substances are to register for access to CURES upon issuance of a DEA certification.  

Beginning January 1, 2021, California requires that all paper prescriptions for controlled substances have 15 security elements, including a 12-digit serial number and corresponding barcode for tracking.  Authorized printers for these prescription pads can be found at the DOJ's California Security Prescription Printers ProgramThis new law does not apply to electronic prescribing or prescribing of non-controlled substances.  General CURES information can be found here.

What if I don't prescribe controlled substances or have a DEA number?  Then any CURES criteria does not apply to you.
What if I prescribe testosterone?  Then you must comply with the new CURES criteria if you write paper prescriptions for testosterone. 


NDs are not permitted to write medical exemptions from mask mandates for adults or children. If you have a patient who you believe meets the criteria for exemption, please refer them to an MD or DO.


Administering Vaccines
  • With the exception of COVID-19 vaccines (see the following bullet point), licensees may procure and administer vaccines if they have MD/DO prescription oversight
  • As of March 30, 2021, Naturopathic doctors may independently order and administer COVID-19 vaccines that are approved or authorized by the federal Food and Drug Administration (FDA) to persons 16 years of age or older and, in cases involving a severe allergic reaction, epinephrine or diphenhydramine by injection, subject to the following conditions:
    • The naturopathic doctor successfully completes the required COVID-19 training programs prescribed by the California Department of Public Health at the following website:https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Immunization/COVID-19VaccineTraining.aspx
    • The naturopathic doctor complies with all applicable federal and state recordkeeping and reporting requirements, including providing documentation to the patient’s primary care provider, as applicable, and enters information in the appropriate immunization registry designated by the immunization branch of the State Department of Public Health.
    • The subject vaccine is administered in accordance with any applicable FDA emergency use authorization.
Procuring COVID-19 Vaccines and Vaccine Cards for In-office Administration
  • If you wish to procure COVID-19 vaccines for administration in your office, there is a registration, training, and on-site visit process to go through that can be started here.  It has been reported that it is a fairly lengthy process from registration to procuring the vaccines, and the website currently notes that the State is focusing enrollment on independent practices that already routinely vaccinate their patients.
  • COVID-19 vaccine cards come with the actual vaccination vials; everything is tracked and any outliers or anomalies are flagged.
  • The Naturopathic Medicine Committee has reported receiving a concerning number of requests from licensees asking how to procure Covid-19 vaccine cards but not the vaccine itself.  Please note that any licensee involved in a discrepancy will be under review. 
Vaccine Exemptions
From the Naturopathic Medicine Committee regarding writing exemption letters for the COVID-19 Vaccine:
" The only time that a licensee should provide a waiver is if they are providing the vaccine. If an ND is not providing the vaccine, they should refrain from providing a waiver. Further, if the Committee or Dept of Public health gets reports that waivers are being provided from a single licensee, there is a high probability that they will be reviewed to ensure that they are providing waiver for medical reasons only. We do not want another high-profile case to read about. That is a very touchy situation, especially when NDs are trying to gain independent Rx rights. We hope there are no glaring reasons for the legislature to shut down any future legislative efforts surrounding ND abilities to prescribe. Additionally, we have sunset review in less than 6 months. "
General Vaccine Exemptions:
Since NDs do not hold a physician title, we are unable to sign provide vaccine exemptions. Please refer to information regarding SB277 for greater context.


The Naturopathic Medicine Committee is working on an update for the regulatory language for IV therapies to include injection specialties encompassing PRP, micro-needling, and other aesthetic procedures.  As of November 2020, the proposed text language is currently under legal review. While the routes of administration fall within our ND scope, most of the therapies offered need to include some additional training to ensure proper use of the modalities, especially since most of the treatments include facial and scalp areas.
Until then, anyone wishing to perform these procedures should make sure that they have the additional training for the treatments that they are interested in providing, such as PRP facials.  If a licensee wants to treat the scalp area in addition to the PRP facials, then they would need to ensure that they had training in the scalp application in addition to the facial application. There will be a grandfathering period for the IV therapy, however other advanced injection therapies will require proof of the additional training.  The use of Botox/Juviderm or other filler product requiring pharmaceutical prescription would fall under the physician oversight agreement. 


NDs in CA can utilize hemp-derived CBD (with no trace amounts of THC) within their practice and may furnish and provide it to their patients as it has been removed from the Schedule I list.  Dr. Stephanie Berg conducted a Facebook Live on December 23rd, 2020 answering questions on this topic, which can be found within the CNDA Facebook group for members.


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 1/17/19, approved providers include Bastyr University (2007 and forward), NUNM (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 and you should also be compliant with USP 797 clean room standards, otherwise you are liable for extensive fines and risk to your license. Dr. Paul Anderson offers a great FREE overview of USP 797 compliance here.

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?
Once you receive your certificate of completion, forward this to the NMC so they may update the database with this information.  Your IV certifcation will be displayed on your license as well as in the online license search so that pharmacies and other agencies may check your IV certification status. If a pharmacy asks for your certificate, you can direct them to this online database or forward them your license indicating your IV certification. 

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 part of the ND independent formulary.

4) Are NDs able to practice telehealth in California
Yes, as long as the patient is located IN California. NDs are able to diagnose, consult, treat, educate and facilitate care management over email, phone and other communications technologies, including first office visits. Proper judgement should be exercised in the event of making diagnoses or prescribing medications that are best assessed through physical examination. 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

5) 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.  NDs may not use the term "physician" at this time.

6) 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." 

7) 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.

8) 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.

9) Should I be charging sales tax on the supplements in my office?
Yes, supplements sold in your office are taxable. 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.

10) 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.

11) 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. 

12) What are my malpractice insurance options?
Malpractice coverage in California is available for naturopathic doctors through several companies, including:
·       NCMIC: 1-800-769-2000(x8198) 
·       Sprague Israel Giles Insurance (SIG): 1-800-526-0635 
·       Aegis: 1-855-234-4729

13) 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 statusrefer to this page from the Centers for Medicare & Medicaid Services

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
14) Can I order labs for a Medicare Patient? For a Medicaid Patient?
For Medicare patients, only doctors that are registered with PECOS may order labs run through Medicare and, at this time, NDs are not able to register for this status.  Even if they retain a secondary private insurance you still cannot order labs, as they must go through Medicare first.  For Medicaid patients, you can register as a MediCal provider to received coverage for medically necessary labs only, but office visits are not covered and will not be reimbursed. For both types of patients, the best course of action is to run the labs through a cash-pay provider, or have their Medicare/Medicaid provider order the tests on your behalf. 

15) 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.  Labs will not be covered with patients that have HMO insurance. 


1) What pharmaceutical can I 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 (with the addition of a DEA license), an ND must have signed a supervision agreement with an MD or DO licensed in California.  This agreement is kept by the ND and does not need to be filed with any governing body. As the prescribing doctor you do not need to include your supervising doctor's name or information when placing a prescription, however, a licensed pharmacist may request a copy of the document to verify your ability to prescribe the medication you are prescribing.  They may also request the section pertaining to the naturopathic doctor's standardized procedure relating to controlled substances when there is uncertainty about the naturopathic doctor furnishing the order. The law specific to supervision of prescribing can be found here (Section 3640.5). A pharmacy should not be requesting a supervisory agreement for those substances that an ND is able to independently prescribe (e.g. hormones) and if a pharmacy is requesting this, please refer them to the appropriate BPC codes or reach out to the CNDA or NMC. 

The supervision agreement must include a formulary and standardized protocols or procedures, and 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.

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.

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 with a DEA license 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. 

In summary, California-licensed naturopathic doctors are not required to file their supervisory agreements or protocols with any governing body, and they are only required to provide the specific protocol relating to controlled substances to a pharmacist if the ND prescribes a controlled substance and the pharmacist asks to see it. 

2) 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.

3) 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.).

4) 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.

5) 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. 

6) 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 barcoded prescription pad compliant with CURES criteria. 

Your DEA number must be renewed every 3 years, at a current a cost of $888 (as of 2021). You will need a separate DEA number for each state you practice in, and for each location you will be prescribing controlled substances from. You may 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. 
7) 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/NPI is sufficient to prescribe all other hormones.

8) Beyond registering with the CURES 2.0 program, is there anything else NDs need to know about compliance with CURES?
The Controlled Substance Utilization Review and Evaluation System (CURES) was certified for statewide use by the Department of Justice (DOJ) on April 2, 2018. The mandate to consult CURES prior to prescribing, ordering, administering, or furnishing a Schedule II–IV controlled substance became effective on October 2, 2018. The statement of mandatory use from the California Medical Board can be found here.

You are not required to report to CURES what you prescribe and administer to patients. More information on what "mandatory use of" and "consultation of" CURES means, how to successfully meet consultation requirements, and how to document CURES consultation in a patient's file can be found here

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.

9) 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
7. For controlled substances, prescription pads must meet CURES criteria.

Prescription pads do not need to include your supervising MD/DO's information.  10) What substances may a licensed naturopathic doctor prescribe?
NDs are independently allowed to prescribe, furnish, order or administer all synthetic and natural hormones, as well as epinephrine. The state board, the Naturopathic Medicine Committee, has a notice about this on their website 

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 as per Business and Professions Code Section 3640.5 within the Naturopathic Doctors Act. The supervision agreement includes 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 only requirement for providing the protocol developed between the ND and his/her supervising physician to a pharmacist is with respect to the ND's specific standardized protocol/procedure relating to controlled substances. Section 3640.5(f) states:
"Drugs furnished or ordered by a naturopathic doctor may include Schedule III through Schedule V controlled substances under the California Uniform Controlled Substances Act (Division 10 (commencing with Section 11000) of the Health and Safety Code) and shall be further limited to those drugs agreed upon by the naturopathic doctor and physician and surgeon as specified in the standardized procedure. When Schedule III controlled substances, as defined in Section 11056 of the Health and Safety Code, are furnished or ordered by a naturopathic doctor, the controlled substances shall be furnished or ordered in accordance with a patient-specific protocol approved by the treating or supervising physician. A copy of the section of the naturopathic doctor’s standardized procedure relating to controlled substances shall be provided upon request, to a licensed pharmacist who dispenses drugs, when there is uncertainty about the naturopathic doctor furnishing the order."
The CNDA does not have the prescribing protocols for California-licensed naturopathic doctors, and the Naturopathic Medicine (Committee of California, the state body that governs California licensed naturopathic doctors, does not have these either. These are developed and maintained between each naturopathic doctor (ND) and his/her supervising physician if the naturopathic doctor wants to prescribe any legend or Schedule III - V drugs other than natural and synthetic hormones, including testosterone; epinephrine for anaphylaxis; and vitamins, minerals, amino acids, glutathione, botanicals, and their extracts, homeopathic medicines, electrolytes, sugars, and diluents, all of which a California-licensed naturopathic doctor may prescribe independently without a supervising physician. (See California Business and Professions Code section 3640.7 for the list of what California-licensed naturopathic doctors can prescribe and administer independently). 
11) 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.

12) 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.


1) How do I become a licensed naturopathic doctor in CA?
The Naturopathic Medicine Committee (NMC) is the state licensing organization for California.  The initial application fee is $400, with a licensing fee of $1,000 for two years (see question #2 below for an explanation of this). 

To apply: 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). .
2) When does my ND license expire? How do I renew my license?
In California, your license must be renewed every two years. Your 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 $633-1,000.

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 $867 instead of $1,000). Your next license renewal date will be 09/30/17, then 09/30/19, and so on. Each license renewal will cost $1,000.

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 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.

4) 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 timesTo 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.

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1) 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.

2) 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.

3) 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.

4) 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.

5) 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.

6) Accepted Credits
The continuing education requirements must be met through courses pre-approved by one of the following accrediting agencies or organizations:

  1. California Naturopathic Doctors Association (CNDA)
  2. American Association of Naturopathic Physicians (AANP)
  3. State Board of Chiropractic Examiners
  4. CA State Board of Pharmacy (BOP)
  5. Accreditation Council for Pharmacy Education (ACPE)
  6. Pharmacy Foundation of California (PFC)
  7. American Academy of Family Physicians (AAFP)
  9. other courses that meet the standards for continuing education for licensed physicians and surgeons in California (such as AMA PRA Category 1™ accredited classes)
Visit the CA CE Requirements page for more details

7)  During the State of Emergency (SOE) due to the pandemic, licensees are permitted to do the following:
  • Take online, recorded CE in lieu of live hours and renew, or
  • Renew and waive CE hours for up to 6 months after the SOE.
If the licensee chooses option 2, where they waive their CE requirement until after the SOE, they will be required to complete the actual live hours and will not be allowed to use pre-recorded hours in lieu of live CE hours.

Naturopathic Advocates

The CNDA is working to educate state legislative and insurance agencies as well as the public on the benefits of naturopathic medicine. We will continue to build relationships in the naturopathic community in an effort to optimize the impact of the naturopathic doctors in our state.