The Osteopathic Physicians and Surgeons of California (OPSC), representing the 5000 osteopathic physicians licensed in California, urges you NOT to move forward with the proposal to integrate the Bureau of Naturopathic Medicine into the Osteopathic Medical Board of California (OMBC).
The recommendation in this regard, supported by Mondays vote of the Senate Business and Professions Committee, lacked the usual transparency that you have both called for and insisted upon. While advance Daily File notice of the hearing indicated elimination of the Naturopathic Board, we know of no such notice having been given to its integration with the OMBC. The public, whose safety depends on the effectiveness of the Osteopathic Medical Board, and the practicing osteopathic physicians of California were denied the notice that usually accompanies a policy action of such significance. As a result, Committee members did not have the opportunity to fully understand the deficiencies of this concept.
Following are the reasons why this proposal is a bad idea:
➢ No savings. Placing the responsibility for licensure of naturopaths under the board that licenses osteopathic physicians would not save funds for the state. Both boards are entirely self supported from license fees. Even if the fees collected from the 365 naturopaths licensed in the state were to be added to the general fund and all current duties and responsibilities of that board were to be assumed by the current staff of the Osteopathic Medical Board (and no additional staff were hired) the state would still only receive $100,000.
➢ Endangering the public. Moving licensure responsibility for naturopaths to the OMBC would likely threaten public safety. In a recent OMBC staff/workforce analysis, the 6.9 employees of OMBC averaged 1.85 full-time-equivalent positions each. In other words, OMBC is now working at twice its capacity already. Increasing the number of licentiates by nearly 10% would hinder the OMBC from fulfilling its core responsibility of public protection.
➢ Different structures. The Osteopathic Medical Board of California was created by voter initiative nearly 100 years ago, while the Bureau of Naturopathic Medicine was statutorily created with the last 5 years. Modifications to the OMBC structure would require a vote of the public, while the Bureau of Naturopathic Medicine could be readily changed by the legislature.
➢ Naturopaths are NOT complete physicians. Osteopathic physicians (DOs) have full rights and privileges equivalent to medical doctors (MDs). DOs can prescribe medications, perform surgery, and specialize in any area of medicine. Conversely, naturopathic doctors have limited practice rights. NDs are unable to prescribe controlled substances and they do not have the training to analyze complex medical tests. It is possible that this proposal was crafted without an understanding of these differences. The public confusion that exists about the training and abilities of DOs would only be exacerbated by adding naturopaths under the same licensing board.
OPSC reiterates its vehement opposition to moving the licensure of naturopaths under the osteopathic physicians licensing board. We are hopeful that this concept does not get placed into legislation at all. However, if the proposal is placed in legislation, we are pleased that you will likely take it up in stand-alone legislation rather than in trailer language so that the issue may be fully considered.
Please note that OPSC is neutral on the proposal to eliminate the Bureau of Naturopathic Medicine. However, for the above reasons, we strongly urge you not to include provisions that would make the Osteopathic Medical Board its new home.
