This is a guest post by Dr. Mary-Ellen McKenna, ND (Inactive) the College's Regulatory Education Specialist

The Standard of Practice for Record Keeping says that when a Member issues a receipt it contains the name of the treating Member. This would appear to be straightforward. The Member bills for assessments and treatments they provided and issues the receipt, to the patient, reflecting this.

There appears, at times, to be some confusion regarding whose name is on the receipt when a Member works in a multi-disciplinary clinic, hosts a naturopathic student extern, or has a naturopathic college graduate working in their clinic prior to being registered with the College.

It is common in a multi-disciplinary setting for a patient to see more than one practitioner in the clinic. The patient may initially see the naturopath for a specific condition but then is referred to a clinic colleague for additional care. In some cases the colleague may not be a regulated health care practitioner but has been trained to provide specific treatments. The Member may not bill for the care provided by any other practitioner, regardless of whether they are a regulated practitioner. If the naturopath were to refer the same patient to a colleague for the same treatment in a clinic across town, there is no consideration by the ND as to whether they can bill for the treatment. The same applies when the patient is referred to a practitioner in the same clinic.

When a Member hosts a naturopathic student extern or has a naturopathic college graduate working in their practice, they have a responsibility to ensure the care provided by the unregulated student or graduate meets the standards of practice of the profession. While they have this oversight obligation, if the Member does not personally provide the assessment or treatment, they may not issue a receipt indicating that they have done so. An exception to this rule would be if the Member is present during the entire patient visit, along with the student or graduate who is observing, and may actively contribute to the assessment and/or treatment. In such a case, the Member may bill for that time spent providing naturopathic care to the patient.

According to the College's Professional Misconduct Regulation, issuing an invoice, bill or receipt that the Member knows or ought to know is false or misleading is considered to be professional misconduct.

For more information about:
  • having a naturopathic graduate work in your clinic see the Spring 2017 edition of iNformeD, and
  • hosting a naturopathic student extern see the Winter 2017/18 edition of iNformeD.