Bringing Naturopathic Medicine to Massachusetts: Testimony Before the Joint Committee on Public Health

By Craig Mehrmann, NMSA President


Last Tuesday, I testified before the Joint Committee on Public Health at the Massachusetts State House to support the implementation of licensing for NDs in Massachusetts: House Bill #1992 & Senate Bill #1205, An Act Establishing a Board of Registration in Naturopathy. The bill defines a standard for educational and clinical training requirements and includes the rights for naturopathic doctors to order labs and diagnostic testing – essentially a “foot in the door” bill. The Massachusetts Society of Naturopathic Doctors (MSND) invited me to testify just weeks before. As a Massachusetts native, with experience as both a healthcare provider and patient within the MA healthcare system, I saw an important opportunity to educate the state legislature about the benefits of licensing NDs in Massachusetts, as well as about the naturopathic medical student experience and the forces that compel us to pursue this form of medical training.

This bill has been vetted from many angles over the past two decades, and has passed both the Massachusetts House & the Senate a number of times. An early 2000s commission, appointed by then governor, studied the scope of practice, education and training, and public support of this legislation, and recommended licensure in its majority report. In the session before last, both houses of the Massachusetts legislature passed our bill, but Governor Patrick did not sign it. After consultation with the state Department of Public Health leaders, MSND made small administrative changes recommended. As one of our supporters stated to the committee, “At this point, there is no reason NOT to license NDs in the state.” A positive outcome this session would allow MA to join the majority of New England states that currently license NDs: Vermont, New Hampshire, Maine and Connecticut.

Licensure would require that naturopathic physicians practicing in MA have completed undergraduate pre-medical training, followed by at least four years of post-graduate medical education at an accredited naturopathic medical school recognized by the U.S. Department of Education, and have passed two national licensing exams. This provides a necessary protection for Massachusetts citizens seeking medical care, especially those who wish to utilize holistic or integrative healthcare. Licensing NDs would provide confirmation that individuals using the title Naturopathic Doctor have completed rigorous licensing requirements, thereby increasing the safety of their patients.

I had the pleasure of reading through letters of support provided to the committee by MSND, which included a letter of support on behalf of NMSA. MDs, DOs, DCs, NPs, PhDs, presidents and CEOs, bearing the seals of their respective institutions and affiliations, all voiced their appreciation for naturopathic medicine and their complete support of licensing NDs in Massachusetts. Harvard, Mass General, Boston University, Tufts, UMass, Baystate, lab companies, major non-profits, and grateful patients have all spoken loud and clear: Massachusetts is ready to license naturopathic doctors.


The AAMC anticipates a shortage of 90,000 physicians in the United States by 2025. Currently, over half of PCPs across Massachusetts are unable to accept new patients. According to the 2014 Merrit-Hawkins survey, patients scheduling a visit with their family physician in Boston can expect to wait an average of 66 days before the earliest available appointment. Massachusetts health policy leaders are well aware of the increasing scarcity of primary care providers, but little progress has been made in working to remedy the situation. The scope of the issue is overwhelming, and immediate changes are needed. Removing barriers for nurse practitioners may help, but a more complete solution may be found in designating naturopathic doctors as PCPs in Massachusetts. Several states have already done so, and with good results.

In response to the already existing PCP shortage and the projected increased demand following the Affordable Care Act, the Oregon Healthcare Workforce Committee proposed immediate removal of coverage and credentialing barriers as a means to incorporate NDs into the Oregon healthcare system by 2014. Lisa Dodson, MD, chair of the committee, is quoted as saying, “The reason we singled (NDs) out is that they are the closest equivalent to the medical doctor that we have.” She added that NDs are prepared to step in immediately to fill the gap in primary care, “without any new programs being created.”

NDs have made significant strides in establishing themselves as PCPs in Oregon. State health officials are beginning to credential ND clinics in Oregon as Patient Centered Primary Care Homes (PCPCH), certifying them as top-tier primary care medical facilities. The National College of Natural Medicine (NCNM) main teaching clinic in Portland, serving 5,600+ patients annually, was certified as a PCPCH earlier this year.

Perhaps this speaks to why the average wait time in scheduling an appointment with a family physician in Oregon is 13 days, while in Boston, the scheduling to appointment time-lag averages a whopping 66 days, which is nothing short of a primary care crisis. The good news is that NDs are ready, willing and qualified to help, and will gladly do so, if ever the MA legislature is able to look beyond decades of turf battles, and focus on the facts:

Currently, 17 states, five Canadian provinces, the District of Columbia, and the US territories of Puerto Rico and the US Virgin Islands all have laws regulating naturopathic doctors (NDs). The understanding, slowly gaining awareness throughout North America, is that licensed NDs are trained as primary care physicians in accredited, four-year, residential graduate medical colleges and pass two extensive postdoctoral licensing examinations (NPLEX I and II). Licensed naturopathic physicians must fulfill state- or province-mandated continuing education requirements annually, and have a specific scope of practice defined by the law in their state or province.

In Oregon, NDs can get DEA numbers, have the authority to prescribe any pharmaceutical needed in a primary care setting, and use pharmaceuticals alongside botanical medications. They can also order, dispense and administer topical and intravenous preparations, medical equipment and mechanical devices, all labs and diagnostic procedures, antibiotics and vaccines, and homeopathic preparations.

An increasing body of evidence shows that patients who see NDs use fewer prescriptions, require fewer referrals to medical specialists, and experience fewer emergency room visits. While NDs can treat chronic and acute illness, they emphasize disease prevention by helping patients learn about and become accountable for their psychoemotional health and lifestyle choices like nutrition and exercise.

Massachusetts policy leaders have a responsibility to solve the primary care shortage and to provide MA citizens with access to safe and effective natural medicine. Regulation of naturopathic doctors in MA will help achieve the Triple Aim of healthcare: increased patient satisfaction, improved patient outcomes, and reduced cost. NDs can increase access to primary care providers in a climate of shortage, and can play a strong role as part of policy aimed to improve the short and long-term health of MA citizens.

I, for one, would like to return to my home state of Massachusetts to practice medicine at the full scope of my training. I worked as an Emergency Medical Technician for three years during my undergrad at UMass Amherst, and after graduating magna cum laude with a bachelor’s in neuroscience/premed, with a minor in philosophy, I spent 2.5 years working as an acute care psychiatric counselor at Baystate Medical Center in Greenfield. During that time, I also worked as a research affiliate of Mass General Hospital, focusing on the neurobiology of stress and disease, and published a review in the Harvard Journal of Psychiatry on the neurobiology of insight meditation and its applications in the psychiatric setting. I chose not to enroll after being accepted to the Complimentary and Alternative Medicine program at Georgetown University to pursue degrees in naturopathic medicine and classical Chinese medicine. I shared all of this with the MA Joint Committee on Public Health to elucidate the fact that I am but one of thousands of naturopathic medical students who are well qualified to pursue a terminal medical degree, and that after completing our training, we would be honored to be able to bring our services to Massachusetts.

Thank you Amy Rothenberg, ND, for inviting me to testify and for your career-long dedicated service, and thank you Massachusetts Society of Naturopathic Doctors for your dedication to bringing naturopathic medicine to Massachusetts. If you would like to be kept abreast about the progress of this bill, please send an email to Dr. Rothenberg at and she will keep you in the loop. If you would like to support the MA effort financially, you can donate online here:

Craig Mehrmann is a third year ND, MSOM student at the National College of Natural Medicine, and serves as 2015-2016 president of the Naturopathic Medical Student Association (NMSA).



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