Regulatory Guidance

 New Graduates Working for a College Member

During the period between graduation from a naturopathic college and the day when the graduate becomes a Member of the College of Naturopaths of Ontario, many graduates look for opportunities to work with a registered Naturopathic Doctor (ND). 

This article discusses important aspects of the relationship between the Member and new graduate, including business and patient care components of practice.

The phrase that is sometime used when referring to this kind of opportunity is that the graduate is looking to "work under an ND's licence". The idea that a graduate can work under a member's "licence" is incorrect because NDs do not have a "licence". They receive a certificate of registration. Second, an ND does not have the unilateral ability to simply allow a graduate to work "under" them. There are regulatory and legal requirements that must be met before an ND can work with another person.

At the outset, the ND will want to consider the role of the graduate within the clinic. Will certain controlled acts be delegated to them or will the graduate simply observe? Will the graduate be expected to perform non-controlled acts? By clearly contemplating and planning for the graduate's role in the clinic, the ND can ensure that all regulatory and legal requirements will be addressed.

The ND is also encouraged to speak with an employment lawyer to ensure they are complying with all legal requirements. For instance, a written employment contract is recommended for all employment relationships that an ND enters into. The ND should check with their professional liability insurance provider to ensure the proper coverage is in place.

The graduate may provide certain aspects of care for the Member's patients, however keep in mind that the graduate does not have their own patients. Depending on the assessment or treatment, the graduate may provide care to the Member's patients either through an assignment of care or a delegation from the Member.

Assignment of care refers to the process of a Member assigning the performance of a procedure that is not a controlled act to another person, in this case the graduate. Please refer to the Assignment of Care Guideline for more information.

Some examples of assessments and treatments that can be done through an assignment of care include:
  • taking a patient's history,
  • performing a physical examination that excludes controlled acts, and
  • recommending treatments that are in the public domain such as botanical and homeopathic remedies, nutritional supplements, or dietary changes.
The graduate may only perform a controlled act by accepting a delegation made by a Member provided all the criteria stated in Part III of the General Regulation and the Standard of Practice for Delegation are met. A graduate has no authority to perform a controlled act without receiving a delegation.

Delegation is a process whereby a Member who is authorized to perform a controlled act confers that authority to someone - regulated or unregulated - who is not so authorized and is not a Member of the College. See the College's Standard of Practice for Delegation, as well as the article Delegation in the Practice of Naturopathy in the Regulatory Guidance section of our website for more information.

It is left to the judgment of the Member to determine when it is appropriate to make a delegation to the graduate however, the Member is not allowed to delegate:
  • communicating a naturopathic diagnosis, or
  • acupuncture.
The reasons for these restrictions are:
  • the General Regulation prohibits a Member of the College to delegate communicating a naturopathic diagnosis, and
  • acupuncture is authorized to the profession through an exemption rather than in the Naturopathy Act, 2007 and therefore cannot be delegated.
It is required that the Member and the graduate, being a possible future Member of the College, abide by all the requirements and expectations set by the College. Below, we clarify requirements around a number of inquiries we have received from Members and graduates about working together.
  • The receipt provided to the patient includes the name of the treating Member - a Member is not to bill for assessments or treatments they did not personally provide. The receipt is to reflect who provided the different aspects of a patient's visit.
  • Informed consent includes providing information to the patient prior to treatment as to who will be providing the patient's care and that the receipt will reflect who provided which service. This may affect whether or not the patient will be able to claim the naturopathic fees on their insurance.
  • While the graduate may gather the subjective and objective information leading to the diagnosis, only the Member can communicate the diagnosis to the patient.
  • The appropriate level of supervision will vary with the risks associated with the assessment or treatment and it is the responsibility of the Member to make that determination.
The College is aware that there are graduates who are looking to maintain their skills prior to becoming a Member, and that it can be done within the College's rules and regulations, however, it must always be done in a way that is in the best interest and needs of the patient.