On March 1, 2018, the Member attended before a panel of the Inquiries, Complaints and Reports Committee to be cautioned.
At the outset, the Panel noted that the Member's website indicated that the Member was trained in bio-identical hormone replacement and that she was able to prescribe this form of treatment prior to having met the Standard of Practice for Prescribing. The Member was reminded that the Prescribing course and exam are required by the College in order to ensure that appropriate knowledge, skill and judgment exist with regards to therapeutic prescribing. The Panel cautioned the Member that having BHRT training did not permit her to prescribe drugs or substances and that her failure to comply with this statutory requirement might have put her patients at risk.
The Panel further outlined its concerns with respect to the Member's advertising, which included issues with testimonials, prescribing, conflict of interest as well as use of restricted titles.
The Panel acknowledged that the Member had taken steps to amend her advertising in order to comply with the professional standards. Nevertheless, as the Member's website appeared to continue to advertise brand name products to the public, she was cautioned that endorsing products is in contravention of the College’s Advertising Standard, and may also be perceived as a conflict of interest, regardless of whether or not the products were designed or formulated by the Member.
It was also concerning to the Panel that the Member appeared to advertise product kits, sell drugs or substances and recommend non-scheduled substances outside the context of the naturopathic doctor-patient relationship. The Panel reinforced with the Member that naturopaths in Ontario are only able to recommend or sell a compounded drug or substance to their patients within the context of the naturopathic doctor-patient relationship. In addition, members are expected to conduct a thorough assessment of the patient, to monitor and document the patient’s response to the therapy and any adverse reactions, and adjust dosage or discontinue the therapy as appropriate.
The Panel further outlined its concerns with regard to the Member's billing practices. The Member was reminded that block fees are not available to naturopaths in Ontario and that issuing an invoice, bill or receipt that the Member knows or ought to know is false or misleading is an act of professional misconduct under the Naturopathy Act.
In conclusion, the Panel noted that should the Member commit similar or analogous conduct, the Panel will have no choice but to take stronger action, including a referral to the discipline committee.